FW: FW: Determination to update Entergy White Bluff baseline rates

Pettyjohn, Mary to: Dayana Medina 08/29/2012 02:30 PM

From: "Pettyjohn, Mary" <PETTYJOHN@adeq.state.ar.us>

To: Dayana Medina/R6/USEPA/US@EPA

History: This message has been forwarded.

3 attachments

Hi Dayana,

Here is what will be discussed.

Mary

From: Jeremy Jewell [

mailto:JJewell@trinityconsultants.com]

Sent: Tuesday, August 28, 2012 7:31 PM

To: Pettyjohn, Mary; Brown, Derrick; Rheaume, Thomas

Cc: kmcque1@entergy.com; Tracy Johnson; Chad Wood; 

Molly Goldstein; Kasi Dubbs; Kara Gerlach

Subject: Re: FW: Determination to update Entergy 

White Bluff baseline rates

Mary et. al.,

I don't suppose there is any guarantee that the lower 

sulfur mines will always be used. That is what is 

being used now, and therefore that is the basis from 

which any visibility improvement will occur in 

actuality.

Tom's comment, "Is this going to make any difference 

in the final (BART) analysis?" is certainly 

appropriate. From what we can tell, the selection of 

the baseline period is not going to change the 

ultimate BART determinations. Having said that, we 

have already completed much of the modeling based on 

the new ('09-'11) baseline period. Right or wrong, 

we assumed this would be preferred. So changing back 

to '01-'03 would cause a substantial amount of 

re-modeling.

Your idea of a call with EPA next week is probably 

best. We certainly want everyone to agree before we 

go too much further.

In the meantime we offer the following additional 

information, including your request for a comparison 

of max. daily emissions between the two baseline 

period possibilities, for your consideration.

The below table summarizes the main differences 
between the two baseline periods:

[cid:_1_086EDC80086ED8800002D39886257A69]

Ultimately the boilers simply do not operate like 

they did in 2001-2003 because the boiler efficiency 

has been improved (affecting both NOX and SO2) and 

the fuel has changed (really just an SO2 issue). 

Thus, the 2001-2003 period is not reflective of what 

now is to be controlled. To us, this type of 

situation is addressed in the BART guidance - 40 CFR 

Part 51, Appendix Y, Section IV.D.4.c.

_____________________________________________________

___

Jeremy W. Jewell | Manager of Consulting Services, 

Oklahoma

OKC: 120 E. Sheridan, Suite 205, Oklahoma City, OK 

73104 | 405-228-3292

Tulsa: 1831 E. 71st Street, Suite 118, Tulsa, OK 

74136 | 918-877-2742

e-mail: jjewell@trinityconsultants.com<

mailto:jjewell@trinityconsultants.com> | e-fax: 

918-512-7084

From:

"Pettyjohn, Mary" <PETTYJOHN@adeq.state.ar.us<

mailto:PETTYJOHN@adeq.state.ar.us>>

To:

"Jeremy Jewell (jjewell@trinityconsultants.com<

mailto:jjewell@trinityconsultants.com>)" 

<jjewell@trinityconsultants.com<

mailto:jjewell@trinityconsultants.com>>

Cc:

"Rheaume, Thomas" <RHEAUME@adeq.state.ar.us<

mailto:RHEAUME@adeq.state.ar.us>>, "Brown, Derrick" 

<brownd@adeq.state.ar.us<

mailto:brownd@adeq.state.ar.us>>

Date:

08/28/2012 12:26 PM

Subject:

FW: Determination to update Entergy White Bluff 

baseline rates

________________________________

Hi Jeremy,
I apologize for not sending this to you earlier. The 

questions are the same EPA has.

Tom and I believe it is okay to change the parameters 

and baseline emissions for Domtar but still have 

reservations about Entergy White Bluff.

Before you run the model, please reply to the 

concerns below and we will get back to you right 

away.

Thanks,

Mary

From: Rheaume, Thomas

Sent: Monday, August 27, 2012 2:30 PM

To: Pettyjohn, Mary

Cc: Brown, Derrick

Subject: RE: Determination to update Entergy White 

Bluff baseline rates

Since there are multiple mines involved, what 

guarantee is there that these lower sulfur containing 

mines will always be used? Also this is going to 

raise a lot of questions about differences from the 

first analysis.

Is this going to make any difference in the final 

(BART) analysis?

Thomas Rheaume

Permit Branch Manager

Arkansas Department of Environmental Quality

Air Division

5301 Northshore Drive

North Little Rock, AR 72118-5317

501 682 0762 Phone

501 682 0880 Fax

From: Jeremy Jewell [

mailto:JJewell@trinityconsultants.com]<mailto:[

mailto:JJewell@trinityconsultants.com]>

Sent: Monday, August 27, 2012 12:08 PM

To: Pettyjohn, Mary

Cc: Rheaume, Thomas

Subject: Fw: Determination to update Entergy White 

Bluff baseline rates

See below.

With this information, do you feel it is reasonable - 

or even preferred - to use updated baseline emission 

rates in the BART analysis?

_____________________________________________________

___
Jeremy W. Jewell | Manager of Consulting Services,

Oklahoma

OKC: 120 E. Sheridan, Suite 205, Oklahoma City, OK 

73104 | 405-228-3292

Tulsa: 1831 E. 71st Street, Suite 118, Tulsa, OK 

74136 | 918-877-2742

e-mail: jjewell@trinityconsultants.com<

mailto:jjewell@trinityconsultants.com> | e-fax: 

918-512-7084

----- Forwarded by Jeremy Jewell/Trinity Consultants 

on 08/27/2012 12:05 PM -----

From:

"JOHNSON, GEORGE" <GJOHNS6@entergy.com<

mailto:GJOHNS6@entergy.com>>

To:

Jeremy Jewell <JJewell@trinityconsultants.com<

mailto:JJewell@trinityconsultants.com>>

Cc:

Molly Goldstein <MGoldstein@trinityconsultants.com<

mailto:MGoldstein@trinityconsultants.com>>, "McQueen, 

Kelly" <kmcque1@entergy.com<

mailto:kmcque1@entergy.com>>

Date:

08/27/2012 11:01 AM

Subject:

RE: Determination to update Entergy White Bluff 

baseline rates

________________________________

Yes, we did start getting coal from different mines. 

White Bluff had a long term (20 year) contract in 

place with one mine which had expired. This allowed 

us to expanded our portfolio of suppliers and some of 

these mines have lower sulfur coal than the original 

mine.

From: Jeremy Jewell [

mailto:JJewell@trinityconsultants.com]

Sent: Friday, August 24, 2012 9:53 AM

To: JOHNSON, GEORGE

Cc: Molly Goldstein; McQueen, Kelly

Subject: Fw: Determination to update Entergy White 

Bluff baseline rates
See question from ADEQ.

_____________________________________________________

___

Jeremy W. Jewell | Manager of Consulting Services, 

Oklahoma

OKC: 120 E. Sheridan, Suite 205, Oklahoma City, OK 

73104 | 405-228-3292

Tulsa: 1831 E. 71st Street, Suite 118, Tulsa, OK 

74136 | 918-877-2742

e-mail: jjewell@trinityconsultants.com<

mailto:jjewell@trinityconsultants.com> | e-fax: 

918-512-7084

----- Forwarded by Jeremy Jewell/Trinity Consultants 

on 08/24/2012 09:51 AM -----

From:

"Pettyjohn, Mary" <PETTYJOHN@adeq.state.ar.us<

mailto:PETTYJOHN@adeq.state.ar.us>>

To:

"Jeremy Jewell (jjewell@trinityconsultants.com<

mailto:jjewell@trinityconsultants.com>)" 

<jjewell@trinityconsultants.com<

mailto:jjewell@trinityconsultants.com>>

Date:

08/24/2012 09:50 AM

Subject:

FW: Determination to update Entergy White Bluff 

baseline rates

________________________________

H Jeremy,

Tom has some questions concerning Trinity's rationale 

for changing the baseline emissions. They are shown 

below.

Thank you,

Mary

From: Rheaume, Thomas

Sent: Friday, August 24, 2012 9:11 AM
To: Pettyjohn, Mary; Brown, Derrick

Subject: RE: Determination to update Entergy White 

Bluff baseline rates

I would like to know why it changed. Did they start 

getting coal from a different mine? Do they even 

know why?

Thomas Rheaume

Permit Branch Manager

Arkansas Department of Environmental Quality

Air Division

5301 Northshore Drive

North Little Rock, AR 72118-5317

501 682 0762 Phone

501 682 0880 Fax

From: Pettyjohn, Mary

Sent: Friday, August 24, 2012 6:47 AM

To: Rheaume, Thomas; Brown, Derrick

Subject: FW: Determination to update Entergy White 

Bluff baseline rates

Tom and Derrick,

I would like your opinion on the below rationale to 

use different baseline emissions before I present it 

to the group and evidentially EPA.

Thanks,

Mary

From: Jeremy Jewell [

mailto:JJewell@trinityconsultants.com]<mailto:[

mailto:JJewell@trinityconsultants.com]>

Sent: Thursday, August 23, 2012 7:25 PM

To: Pettyjohn, Mary

Cc: JOHNSON, GEORGE; kmcque1@entergy.com<

mailto:kmcque1@entergy.com>; Chad Wood; Molly 

Goldstein

Subject: Re: Determination to update Entergy White 

Bluff baseline rates

Mary,

Molly's email below inadvertently left out a third 

change that resulted in substantially less emissions 

in recent years compared to the original baseline. 

Beginning in 2007 the sulfur content of the coal 

utilized at the facility decreased compared to 

previous years. All of this points to a real 

difference in operations/emissions between now and 

then, and our conclusion is that the 2001-2003 time 

period is not representative of current (and thus 

future, post-BART) operations.

Thanks,

_____________________________________________________

___
Jeremy W. Jewell | Manager of Consulting Services,

Oklahoma

OKC: 120 E. Sheridan, Suite 205, Oklahoma City, OK 

73104 | 405-228-3292

Tulsa: 1831 E. 71st Street, Suite 118, Tulsa, OK 

74136 | 918-877-2742

e-mail: jjewell@trinityconsultants.com<

mailto:jjewell@trinityconsultants.com> | e-fax: 

918-512-7084

From:

Molly Goldstein/Trinity Consultants

To:

"Pettyjohn, Mary" <PETTYJOHN@adeq.state.ar.us<

mailto:PETTYJOHN@adeq.state.ar.us>>

Cc:

kmcque1@entergy.com<mailto:kmcque1@entergy.com>, 

"JOHNSON, GEORGE" <GJOHNS6@entergy.com<

mailto:GJOHNS6@entergy.com>>, Chad Wood 

(wood@gill-law.com<mailto:wood@gill-law.com>) 

<wood@gill-law.com<mailto:wood@gill-law.com>>, Jeremy 

Jewell/Trinity Consultants@TCI_Dallas

Date:

08/23/2012 05:47 PM

Subject:

Determination to update Entergy White Bluff baseline 

rates

________________________________

Entergy White Bluff and Trinity Consultants have 

reviewed the baseline rates from 2001-2003 that were 

used in the original visibility modeling analysis. 

While we agree with the methodology of SO2 and NOx 

emission rates representing the highest actual 

24-hour emission rates, the current operation of the 

boilers warrants that the baseline emission rates be 

updated so that they reflect a more realistic 

estimate of emissions. See BART guidance, Per 40 CFR 

Part 51, Appendix Y, Section IV.D.4.c. In 2006 

Entergy completed the addition of a neural net 

system. In that same year extensive boiler tuning 

occurred and these two projects combined lowered 
pollutant emission rates, especially for SO2.

Table 1-1 summarizes the emission rates for SO2 for 

the years before the boiler updates, 2001-2006, as 

well as the most recent years, 2007-2011. As you can 

see from the table, the average emission rates from 

the years before the boiler updates were 2,000-3,000 

tpy greater per boiler than the most recent years.

Table 1-1: Summary of Annual SO2 Emission Rates from 

Unit 1 and Unit 2 at Entergy White Bluff, 2001-2006 

and 2007-2011

[cid:_1_086FC7C0086FBE180002D39886257A69]

BART guidance, Per 40 CFR Part 51, Appendix Y, 

Section IV.D.4.c states,

"The baseline emissions rate should represent a 

realistic depiction of anticipated annual emissions 

for the source. In general, for the existing sources 

subject to BART, you will estimate the anticipated 

annual emissions based upon actual emissions from a 

baseline period. When you project that future 

operating parameters (e.g., limited hours of 

operation or capacity utilization, type of fuel, raw 

materials or product mix or type) will differ from 

past practice, and if this projection has a deciding 

effect in the BART determination, then you must make 

these parameters or assumptions into enforceable 

limitations. In the absence of enforceable 

limitations, you calculate baseline emissions based 

upon continuation of past practice."

In order to represent realistic anticipated annual 

emissions, Entergy is proposing to use the 2009-2011 

emission rates based on 2009-2011 continuous 

emissions monitoring system (CEMS) data. Using the 

higher emission rates from 2001-2003 would not show 

the true emissions reductions from the proposed BART 

control technology. Moreover, using the higher 

2001-2003 emission rates would show greater 

improvement than would occur in actuality. Thus, 

updating the emissions to be based on recent years 

that more accurately represent current, normal 

operation is an approach which better reflects 

compliance with the regulations as compared to the 

alternative.

Molly Hathaway Goldstein │ Senior Consultant 

│mgoldstein@trinityconsultants.com │(913) 894-4500

Trinity Consultants, Inc. - Kansas City │ 9777 Ridge 

Drive, Suite 380│Lenexa, KS 66219 │Phone: (913) 

894-4500

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http://www.trinityconsultants.com/Subscribe/> today 

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The information transmitted is intended only for the 
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