FW: AEP/Flint Creek FFA

Pettyjohn, Mary to: Guy Donaldson, Dayana Medina, Erik 

Snyder, Michael Feldman, Joe Kordzi 01/24/2013 08:37 AM

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

To: Guy Donaldson/R6/USEPA/US@EPA, Dayana Medina/R6/USEPA/US@EPA, Erik 

Snyder/R6/USEPA/US@EPA, Michael Feldman/R6/USEPA/US@EPA, Joe 

Kordzi/R6/USEPA/US@EPA

9 attachments

Here is the updates AEP Flint Creek update BART 

analysis and supporting documents. Please note there 

are three separate correspondences in this email. 

The one from Kris Gaus explains the attachments and 

justification for not looking at a 99% removal 

efficiency with the wet scrubber.

If you have any questions, please feel free to 

contact me.

Best regards,

Mary

From: bwmoore@aep.com [mailto:bwmoore@aep.com]

Sent: Wednesday, January 23, 2013 2:09 PM

To: Pettyjohn, Mary

Cc: jjhenry@aep.com; kpgaus@aep.com; Jeremy Jewell 

(jjewell@trinityconsultants.com); 

jchendricks@aep.com; jmmcmanus@aep.com; 

kdubbs@trinityconsultants.com; kjmunson@aep.com; 

scarney@aep.com; Brian Bond (tbbond@aep.com); 

wemast@aep.com; Spencer, Stuart

Subject: Re: AEP/Flint Creek FFA

Mary,

In the email Kris sent to you on 1/16/13 that had the 

Flint Creek FFA information (attached below), there 

were three documents (NIDS OandM Costs.pdf; SCR 

CapCosts and OandM Costs.pdf; and Wet Scrubber OandM 

Costs.pdf) that contained the statement "PRIVILEDGED 

AND CONFIDENTIAL - AT THE REQUEST OF LEGAL COUNSEL". 

We have reviewed the information in those files and 

have determined that it does not need to be protected 

as confidential and are resubmitting the same files 
without the confidential designation. Please replace

the referenced files previously sent with those 

attached below. Let Kris or me know if you need any 

additional information or have any other questions. 

Thanks.

========================

Bruce Moore

Manager - Air Quality West

AEP Environmental Services

1201 Elm Street, Suite 800

Dallas, TX 75270

Ph: 214-777-1116

Cell: 214-536-7386

bwmoore@aep.com<mailto:bwmoore@aep.com>

=====================================================

=====================================================

=====================================================

===

Kristen P Gaus/AEPIN

01/16/2013 04:40 PM

To

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

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

cc

"Jeremy Jewell (jjewell@trinityconsultants.com<

mailto:jjewell@trinityconsultants.com>)" 

<jjewell@trinityconsultants.com<

mailto:jjewell@trinityconsultants.com>>, "Brian Bond 

(tbbond@aep.com<mailto:tbbond@aep.com>)" 

<tbbond@aep.com<mailto:tbbond@aep.com>>, Bruce W 

Moore/AEPIN@AEPIN, John C Hendricks/OR4/AEPIN@AEPIN, 

kdubbs@trinityconsultants.com<

mailto:kdubbs@trinityconsultants.com>, Janet J Henry 

'Legal Dept'/OR4/AEPIN@AEPIN, John M 

McManus/OR4/AEPIN@AEPIN, William E 

Mast/OR4/AEPIN@AEPIN, Kevin J Munson/AEPIN@AEPIN, 

Scott Carney/AEPIN@AEPIN

Subject

Re: AEP/Flint Creek FFALink<

Notes:///862568EA006C8FB4/959C5F3240601BFA852568B0007

05D47/C86373ACFDE78FFE05257ACC0051575F>
Mary,

Here are responses to the three issues you brought up 

in your 12/6 email. Each one is addressed below.

#1 - SO2 Control

I'm attaching a revised FFA report, 

"Flint_Creek_BART_Analysis_2013-01-16_compiled.pdf", 

that shows WFGD at 95% and NID at 92% removal 

efficiencies. Please see Tables 5-2, 5-3 and page 

5-4 for the scrubber comparisons. According to B&W 

representatives, the 99% removal efficiency claimed 

in its marketing literature represents a conditional 

one time performance test on a new piece of equipment 

and does not represent the scrubber's expected 

lifetime SO2 removal performance. B & W also 

indicated that this removal efficiency was applicable 

to higher sulfur fuels and that the guaranteed 

efficiency would be subject to a practical limit on 

the emission rate of about 0.04-0.05 lb/MMBtu. 

Using the maximum removal efficiency for a given 

technology is only a small "snapshot" in time and is 

not appropriate to use for the regional haze modeling 

over the lifetime of the unit. EPA provided a 

discussion related to scrubbing removal efficiencies 

and proposed BART SO2 emission limits appropriate for 

BART modeling purposes in their December 28, 2011 

Oklahoma FIP for regional haze requirements. In that 

discussion (page 81742) EPA notes that, although a 

dry FGD can reasonably achieve 95% SO2 removal 

efficiency resulting in an emission rate of 0.045 

lb/MMBtu SO2, an emission rate of 0.06 lb/MMBtu was 

the appropriate value to use for visibility modeling. 

The 0.06 lb/MMBtu value equates to a 93% removal 

efficiency and is obviously less than the documented 

capability of a dry FGD. EPA based their decision not 

to use the 95% removal efficiency on "a thorough 

review of achievable emission rates of current Dry 

Flue Gas Desulfurization (DFGD) scrubbers." 

Therefore, the removal efficiency appropriate for 

regional haze modeling is not necessarily the same 

value as the maximum design capability of a given 

technology.

#2 Documentation

I'm attaching a spreadsheet named "AEP_BART_Followup 

for Mary_2013-01-15.xlsx" that contains two 

worksheets (tabs). The green tab is the requested 

"NPS 'speciation spreadsheet'". This, of course, is 

based on the spreadsheet tool available at 

http://www.nature.nps.gov/air/permits/ect/ectCoalFire

dBoiler.cfm?CFID=8865509&CFTOKEN=82435042.

The requested "CEMS report" is the red tab. This 

data is from CAMD.
I am also attached a spreadsheet named

"AEP_BART_Costing_2013-01-16_for Mary.xlsx." This 

should satisfy the requests to provide "spreadsheets" 

and "example calculations." They are 

unlocked/unprotected such that you can follow our 

work from cell to cell if desired.

The requested "March 2006 stack test" and "2006 

emission inventory report" are also attached.

#3 Costs

The attached file, "AEP_BART_Costing_2013-01-16_for 

Mary.xlsx" includes these calculation details. As 

seen in this spreadsheet, the methods/equations from 

the Control Cost Manual were used, and any particular 

numbers that were taken from vendor quotes are 

footnoted. The attached FFA report was also revised 

to be more clear in this area.

Lastly, several .pdf files containing referenced 

vendor/engineering information are attached. Plese 

call me if you have questions.

[attachment "AEP_BART_Followup for 

Mary_2013-01-15.xlsx" deleted by Bruce W Moore/AEPIN] 

[attachment 

"Flint_Creek_BART_Analysis_2013-01-16_compiled.pdf" 

deleted by Bruce W Moore/AEPIN] [attachment 

"AEP_BART_Costing_2013-01-16_for Mary.xlsx" deleted 

by Bruce W Moore/AEPIN] [attachment "NIDS CapCosts 

(FC NID FGD Cost Estimate Summary - BART Rev 0 

11-8-12).pdf" deleted by Bruce W Moore/AEPIN] 

[attachment "NIDS OandM Costs.pdf" deleted by Bruce W 

Moore/AEPIN] [attachment "SCR CapCosts and OandM 

Costs.pdf" deleted by Bruce W Moore/AEPIN] 

[attachment "Wet Scrubber CapCosts (FC WFGD Cost 

Estimate Summary BART Rev 1 11-20-12).pdf" deleted by 

Bruce W Moore/AEPIN] [attachment "Wet Scrubber OandM 

Costs.pdf" deleted by Bruce W Moore/AEPIN]

[attachment "FLC 2006 Emissions Inventory.pdf" 

deleted by Bruce W Moore/AEPIN] [attachment "FLC 

Compliance Test_2006_PM_CO.pdf" deleted by Bruce W 

Moore/AEPIN]

Kris Gaus, QEP

American Electric Power

Air Quality Services

office: 214/777-1113

fax: 214/777-1138

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

mailto:PETTYJOHN@adeq.state.ar.us>>
12/06/2012 08:49 AM

To

"Kris Gaus (kpgaus@aep.com<mailto:kpgaus@aep.com>)" 

<kpgaus@aep.com<mailto:kpgaus@aep.com>>

cc

"Brian Bond (tbbond@aep.com<mailto:tbbond@aep.com>)" 

<tbbond@aep.com<mailto:tbbond@aep.com>>, "Jeremy 

Jewell (jjewell@trinityconsultants.com<

mailto:jjewell@trinityconsultants.com>)" 

<jjewell@trinityconsultants.com<

mailto:jjewell@trinityconsultants.com>>

Subject

AEP/Flint Creek

Hi Kris,

As per your request I am sending you my comments on 

the five-factor analysis. Some of them mirror EPA's 

comments.

SO2 control:

I am sending you Babcock and Wilcox sales material on 

a wet scrubber that has greater than 99% SO2 removal 

efficiency. According to BART Guidelines and ADEQ's 

BART Engineering Analysis Format (attachments), the 

most stringent option must be included in the 

five-factor analysis. Please include this control in 

your five-factor analysis.

Documentation:

As stated in the attached BART Engineering Analysis 

Format, documentation is to be included in each step 

of the analysis. Documentations not only refer to 

vendor quotes, journal articles, regulations, etc., 

it also refers to work products such as spreadsheets 

and example calculations. In other words show your 

work. Besides the documentations requested by EPA, I 

am requesting the following documentations: the March 

2006 stack test; the 2006 emission inventory report; 

the CEMS report used to determine the 24-hour highest 

emission rate for 2001-2003; the NPS "speciation 

spreadsheet"; the actual calculations used in 

determining the annual tons reduced and cost 

effectiveness.

Cost of Compliance:

Control Costs
Please provide a detailed breakdown of what was

followed in the EPA Air Pollution Control Cost Manual 

and justify what wasn't followed. Also provide the 

supplemented vendor information that was used in the 

cost of compliance.

If you would like to discuss this with me, my 

calendar is open today, Monday, Wednesday, and 

Thursday of next week.

Thank you,

Mary

Mary Pettyjohn

Epidemiologist

Arkansas Department of Environmental Quality

Air Division

5301 Northshore Drive

North Little Rock, AR 72118-5317

Phone: 501-682-0070

Email: pettyjohn@adeq.state.ar.us<

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

[attachment "99%SO2Removal.pdf" deleted by Kristen P 

Gaus/AEPIN]

[attachment "BART Engineering Analysis 

Format_Final.doc" deleted by Kristen P Gaus/AEPIN]

[attachment "Final_guidelines_2005_6_15.pdf" deleted 

by Kristen P Gaus/AEPIN]