### 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 fileswithout the confidential designation

. P lease 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>

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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 name d "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 CostsPlease 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]