RE: Clarification on plant capacity factor - revised Units 1&2 BART update. 

Parker, James M to: Aaron Worstell 10/19/2011 01 :56 PM 

Cc: Vanessa Hinkle 

From: "Parker, James M" <jmparker@pplweb.com> 

To: Aaron Worstell/R8/USEPAlUS@EPA 

Cc: Vanessa Hinkle/R8/USEPAlUS@EPA 

Aaron. In looking back on the data, I found I may have told you the wrong 

years that we based our CF on. I have an inquiry to the person who actually 

put this information together and gave it to our consultant in 2007. He 

recently retired but is available for questions. I'll let you know what 

find out - on your most recent question and on the timeframe. 

Thanks. 

Jim 

-----Original Message----­

From: Worstell.Aaron@epamail.epa.gov [mailto:Worstell.Aaron@epamail.epa.gov] 

Sent: Tuesday, October 18, 2011 2:28 PM 

To: Parker, James M 

Cc: Hinkle.Vanessa@epamail.epa.gov 

Subject: RE: Clarification on plant capacity factor - revised units 1&2 BART 

update. 

Jim- Thanks for your quick response. Can you describe how the capacity 

factor for each of the five years was calculated? For example, is it based on 

the annual gross load (MWh) as reported to CAMD? 

Aaron J. Worstell 

Environmental Engineer 

u.S. Environmental Protection Agency - Region 8 Air Program - Mail Code 8P-AR 

1595 Wynkoop Street 

Denver, CO 80202 

Phone: 303-312-6073 

Fax: 303-312-6064 

From: "Parker, James M" <jmparker@pplweb.com> 

To: Aaron Worstell/R8/USEPA/US@EPA 

Cc: Vanessa Hinkle/R8/USEPA/US@EPA 

Date: 10/18/2011 01:15 PM 

Subject: RE: Clarification on plant capacity factor - revised Units 

1&2 BART update. 

Aaron - The capacity factor was developed in 2007, the date of our original 

BART submittal. The CF was derived by taking the average capacity factor of 

the five years 2003-2007, with the 2007 CF values used in the average being a 

projection to year's end (since the year wasn't complete at the time of the 

analysis) . 

Also, pursuant to our correspondence last week, attached please find revisions 

for our Units 1&2 September 23, 2011 submittal. I've attached the revised 

I 
pages and also a complete revised report. 

Please let me know if you have any questions. 

Thanks. 

Jim 

406-237-6932 

-----Original Message----­

From: Worstell.Aaron@epamail.epa.gov [ 

mailto:Worstell.Aaron@epamail.epa.gov] 

Sent: Tuesday, October lS, 2011 S:12 AM 

To: Parker, James M 

Subject: Clarification on plant capacity factor 

Hi JimIn your NOx update for Colstrip 1 and 2 (September 2011), you use a plant 

capacity of 92%. Can you tell me how this was derived? 

Thanks in advance. 

Aaron J. Worstell 

Environmental Engineer 

u.S. Environmental Protection Agency - Region S Air Program - Mail Code SP-AR 

1595 Wynkoop Street 

Denver, CO S0202 

Phone: 303-312-6073 

Fax: 303-312-6064 

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[attachment "NOX Control Update to PPL Montana's Colstrip Generatiing Station 

- Revised pages (Oct2011) .pdf" deleted by Aaron Worstell/RS/USEPA/US] 

[attachment "NOx Control Update to PPL Montana's Colstrip Generating Station 

BART Report (Revised) .pdf" deleted by Aaron Worstell/RS/USEPA/US] 

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RE: Clarification on plant capacity factor - revised Units 1&2 BART update. 

Parker, James M to: Aaron Worstell 10/18/201101:15 PM 

Cc: Vanessa Hinkle 

From: "Parker, James M" <jmparker@pplweb.com> 

To: Aaron Worstell/R8/USEPAlUS@EPA 

Cc: Vanessa Hinkle/R8/USEPAlUS@EPA 

2 attachments 

!I:;n.-.·.···. 

NOX Control Update to PPl Montana's COISThmi ... Generatiing Station - Revised pages(Oct2011).pdf 

!~!

NOx Control Update to PPL Montana's Colstrip Generating Station BART Report (Revised).pdf 

Aaron - The capacity factor was developed in 2007, the date of our original 

BART submittal. The CF was derived by taking the average capacity factor of 

the five years 2003-2007, with the 2007 CF values used in the average being a 

projection to year's end (since the year wasn't complete at the time of the 

analysis) . 

Also, pursuant to our correspondence last week, attached please find revisions 

for our units 1&2 September 23, 2011 submittal. I've attached the revised 

pages and also a complete revised report. 

Please let me know if you have any questions. 

Thanks. 

Jim 

406-237-6932 

-----Original Message----­

From: Worstell.Aaron@epamail.epa.gov [mailto:Worstell.Aaron@epamail.epa.gov] 

Sent: Tuesday, October 18, 2011 8:12 AM 

To: Parker, James M 

Subject: Clarification on plant capacity factor 

Hi JimIn your NOx update for Colstrip 1 and 2 (September 2011), you use a plant 

capacity of 92%. Can you tell me how this was derived? 

Thanks in advance. 

Aaron J. Worstell 

Environmental Engineer 

u.S. Environmental Protection Agency - Region 8 Air Program - Mail Code 8P-AR 

1595 Wynkoop Street 

Denver, CO 80202 

Phone: 303-312-6073 
Fax: 303-312-6064 

The information contained in this message is intended only for the personal 

and confidential use of the recipient(s) named above. If the reader of this 

message is not the intended recipient or an agent responsible for delivering 

it to the intended recipient, you are hereby notified that you have received 

this document in error and that any review, dissemination, distribution, or 

copying of this message is strictly prohibited. If you have received this 

communication in error, please notify us immediately, and delete the original 

message. 
RE: Uncontrolled NOx Rate for SCR - Colstrip 1and 2 

Parker, James M to: Aaron Worstell 10/13/2011 03:05 PM 

Cc: Vanessa Hinkle 

From: "Parker, James M" <jmparker@pplweb.com> 

To: Aaron Worstell/R8/USEPNUS@EPA 

Cc: Vanessa Hinkle/R8/USEPNUS@EPA 

Aaron - Your observation is correct. The "uncontrolled" Nox value in table 

2-3a should be 0.20 #/MMBtu. This change flows through to Table 2-3b, such 

that the cost of application is slightly lower because of lower reagent 

preparation equipment, urea, and other minor costs. The $/ton goes down from 

$7,405 to $7,300. We will revise the report accordingly and submit revised 

pages to you. Thank you for catching that inadvertent error, and my apologize 

for any confusion this may have caused. 

Jim 

406-237-6932 

-----Original Message----­

From: Worstell.Aaron@epamail.epa.gov [mailto:Worstell.Aaron@epamail.epa.gov] 

Sent: Thursday, October 13, 2011 9:44 AM 

To: Parker, James M 

Cc: Hinkle.Vanessa@epamail.epa.gov 

Subject: Uncontrolled NOx Rate for SCR - Colstrip land 2 

Hi JimI'm reviewing the IPM calculations for SCR in your September 2011 NOx control 

update for Colstrip Units 1 and 2. The "NOx Emiss Rate" in Table 2-3a is 

shown as 0.26 lb/MMBtu. In the following table, Table 2-3b, "Uncontrolled 

Emissions" are shown as 0.20 lb/MMbtu. Both tables address SCR reductions on 

a 30-day average emissions basis. Did you intend for the NOx emission rate in 

Table 2-3a to be 0.20 lb/MMBtu, reflecting installation of SOFA system? 

Aaron J. Worstell 

Environmental Engineer 

U.S. Environmental Protection Agency - Region 8 Air Program - Mail Code 8P-AR 

1595 Wynkoop Street 

Denver, CO 80202 

Phone: 303-312-6073 

Fax: 303-312-6064 

The information contained in this message is intended only for the personal 

and confidential use of the recipient(s) named above. If the reader of this 

message is not the intended recipient or an agent responsible for delivering 

it to the intended recipient, you are hereby notified that you have received 

this document in error and that any review, dissemination, distribution, or 

copying of this message is strictly prohibited. If you have received this 

communication in error, please notify us immediately, and delete the original 

message.