February 26, 2016 

Louisiana Department of Environmental Quality 

Office of Environmental Services 

602 North Fifth Street 

Baton Rouge, Louisiana 70802 

Attn: Ms. Tegan Treadaway 

Administrator 

Re: CLECO Power, LLC 

Dolet Hills Power Station (Al No. 585) 

S02 Ambient Monitoring Quarterly Report 

Period: October 23, 2015 -January 31, 2016 

Dear Ms. Treadaway, 

4171 Essen Lane 

Baton Rouge, LA 70809 

Tel: +1 225 932 2500 

Fax: +1 225 987 7300 

www.CBl.com 

On behalf of CLECO Power, LLC (CLECO), CB&I Environmental & Infrastructure (CB&I) is 

submitting this S02 Ambient Monitoring Quarterly Report for the Reporting Period October 23, 

2015 - January 31, 2016 for the ambient monitoring station near the Do let Hills Power Station 

(DHPS). The Report provides data for the Reporting Period of October 23, 2015 through January 

31, 2016. 

Should you have any questions regarding this report, please feel free to contact me at (225) 987-

7719 or chris.howard@cbi.com. 

Sincerely, 

CB&I Environmental & Infrastructure, Inc. 

Chris Howard, PE 

Project Manager 
802 Ambient Monitoring for Quarterly Report 

Period: October 23, 2015 - January 31, 2016 

Do let Hills Power Station 

Agency Interest Number 585 

CLECO Power LLC 

Pineville, Louisiana 

........_\// --CLECO 

Submitted to: 

Louisiana Department of Environmental Quality 

Baton Rouge, Louisiana 

Prepared by: 

CB&I 

2500 City West Boulevard, Suite 1700 

Houston, Texas 77042 

CB&I Project No. 154165 

February 22, 2016 
CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

Table of Contents 

List of Tables ................................................................... ~ .................................................................... ii 

List of Figures .. .-.................................................................................................................................... ii 

List of Appendices ................................................................................................................................ ii 

List of Acronyms and Abbreviations .................................................................................................. iii 

1.0 Background· ............................................................................................................................ 1-1 

2.0 Reported Data ......................................................................................................................... 2-1 

3.0 Results .................................................................................................................................... 3-1 

3.1 Missing Data Summary .. ........ .... .................................... ... .... .. ....................... . : ........ .. ..... 3-1 

3.2 Meteorological Data Summary .... ............................... ................................................. .... 3-2 

3.3 Ambient Hourly S02 Concentration Data Summary ...... .. .. ........... .................. ............. ..... 3-2 

CLECO Dolet Hills S02 Monitoring - Quarterly Report 01 Table of Contents 
List of Tables 

Table 3-1 

Table 3-2 

Table 3-3 

Missing Data Summary 

Statistical Summary of Hourly Meteorological Parameters 

Statistical Summary of Hourly Ambient S02 Concentration 

List of Figures 

Figure 1-1 

Figure 1-2 

Figure 1-3 

Figure 1-4 

Figure 3-1 

Figure 3-2 

Figure 3-3 

Location of S02 Monitoring Station 

Photographs of S02 Monitoring Station 

Location of Meteorological Monitoring Station 

Photograph of Meteorological Monitoring Station 

Wind Rose - October 23, 2015 to January 31, 2016 

Pollution Rose - October 23, 2015 to January 31 , 2016 

Daily Maximum 1-hour S02 Concentrations 

List of Appendices 

Appendix 1 

Appendix 2 

Appendix 3 

Appendix 4 

Appendix 5 

Hourly Meteorological Data 

Hourly Ambient S02 Concentration Data 

Data Recovery Reports 

Weekly Inspection Reports 

System Audit and Calibration Reports 

CLE CO Dolet Hills S02 ~onitoring - Quarterly Report 01 

CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

Table of Contents 
List of Acronyms and Abbreviations 

CLE CO 

CFR 

Deg 

Deg F 

DHPS 

in Hg 

LDEQ 

m 

mph 

NAAQS 

ppb 

S02 

USE PA 

CLECO Power LLC 

Code of Federal Regulations 

Degrees 

Degree Fahrenheit 

Dolet Hills Power Station 

inches of Mercury 

Louisiana Department of Environmental Quality 

meters 

miles per hour 

National Ambient Air Quality Standard 

parts per billion 

sulfur dioxide 

U.S. Environmental Protection Agency 

CLE CO Dolet Hills S02 Monitoring - Quarterly Report 01 iii 

CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

List of Acronyms and Abbreviations 
CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

1.0 Background 

The U.S. Environmental Protection Agency (USEPA) issued the final primary National Ambient Air Quality 

Standard (NAAQS) for 1-hour sulfur dioxide (S02) on June 2, 2010 (2010 S02 standard). On August 5, 2013, the 

USEPA published a notice announcing designation of nonattainment for the 2010 S02 standards, based on 

certified ambient air quality monitoring data for the years 2009-2011 that showed these areas exceeding the 

standard. For all other areas, the USE PA developed and proposed a Data Requirement Rule that would require 

states to gather and submit additional information characterizing S02 in areas with larger S02 emissions. The 

information will be used by the USEPA for future area designations. 

Separately, in a consent decree signed with the Sierra Club in the District Court in Northern California on March 2, 

2015, the USEPA is required to complete area designations with available monitoring data within 16 months of 

date of the consent decree. Also, for areas without adequate monitoring data, the area designations are to be 

completed in two phases by December 31 , 2020. 

The Dolet Hills Power Station (DHPS) in Desoto Parish, Louisiana, owned by CLECO Power LLC (CLECO) has 

been identified as one of the large sources of S02 emissions affected by the consent decree. In addition, the 

DHPS is the largest S02 emissions source in Desoto Parish, and consequently, its impact in the vicinity may 

decide the area designation under the 2010 S02 standard. 

CLECO has installed one (1) S02 ambient monitoring station near the facility to gather ambient monitoring data in 

the vicinity of the DHPS to provide supporting information to both the Louisiana Department of Environmental 

Quality (LDEQ) and the USEPA Region 6 (USEPA R6) in the area designation process for 1-hour S02 NAAQS. 

Justification of the siting location and details of the monitoring station was submitted to LDEQ in August 2015. 

Figure 1-1 shows the location and Figure 1-2 shows a photograph of the S02 monitoring station as installed. 

CLECO has also installed one (1) meteorological station at the facility to support analysis of the monitored data 

from the S02 monitoring station. Figure 1-3 shows the location and Figure 1-4 shows a photograph of the 

meteorological monitoring station. 

The design, implementation, operation, quality assurance, and data reporting for the ambient monitoring station 

and the meteorological station meet the applicable requirements included in the following regulations and 

guidance documents: 

• USEPA, "Quality Assurance Handbook for Air Pollution Measurement Systems, Volume I - Principles," 

EPA-600/9-76-005, Office of Research and Development, Research Triangle Park, North Carolina, 

January 1976. 

• USEPA, "Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II -Ambient 

Air Specific Methods," EPA-600/4-77-027a, Office of Research and Development, Research Triangle 

Park, North Carolina, May 1977. 

• USEPA, "Quality Assurance Handbook for Air Pollution Measurement Systems, Volume IV -

Meteorological Measurements," EPA-600/4-82-060, Office of Research and Development, Research 

Triangle Park, North Carolina, August 1989. 

• USEPA, "Meteorological Monitoring Guidance for Regulatory Modeling Applications," EPA-454/R-99-

005, Office of Air Quality Planning and Standards, Research Triangle Park, NC, February 2000. 

CLECO Doiel Hills S02 Monitoring - Quarterly Report 1-1 Background 
CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

• USEPA, "Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans," EPA600/4-83-004, Office of Research and Development, Research Triangle Park, North Carolina, 

February 1983. 

• USEPA "S02 NAAQS Designations Source-Oriented Monitoring Technical Assistance Document 

(TAD)," EPA-450/4-87-007, Office of Air Quality Planning and Standards, Research Triangle Park, 

North Carolina, December 2013, Draft. 

• USEPA 40 CFR part 58 - "Ambient Air Quality Surveillance," Appendices A, C, and E. 

• USE PA 40 CFR part 51 - "Data Requirements Rule for the 1-Hour S02 Primary National Ambient Air 

Quality Standards (NAAQS)," May 2014, Proposed Rule. 

• USE PA Automated Equivalent Method: EQSA-0495-100 UV Fluorescence Detection of 802. 

• . LDEQ "Ambient Air Quality Standards," Chapter 7 of LAC 33:111 

The monitoring started on October 23, 2015. This report covers the first quarter of the monitoring data during the 

period October 23, 2015 through January 31, 2016. 

CLE CO Doiel Hills 502 Monitoring - Quarterly Report 1-2 Background 
CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

2.0 Reported Data 

The following data gathered from the S02 monitoring station and the meteorological monitoring station are 

included in this report. 

• Appendix 1: Hourly meteorological data including the following parameters: 

o Ambient temperature at 10 meters (m) height in degrees Fahrenheit (Deg F); 

0 Ambient temperature at 2m in Deg F; 

0 Barometric pressure in inch Hg; 

0 Delta Temperature in Deg F; 

0 Rainfall in inches; 

0 Sigma Theta in Degrees (Deg); 

0 Solar radiation in Langleys; 

0 Wind direction in Deg; and 

0 Wind speed in miles per hour (MPH) 

• Appendix 2: Hourly ambient S02 concentration at the monitoring station with corresponding wind speed 

and wind direction. 

• Appendix 3: Monthly and quarterly data recovery report showing percent of data capture for each 

monitored parameter 

• Appendix 4: Weekly inspection reports for both monitoring station and meteorological station 

• Appendix 5: System Audit and Calibration reports 

CLECO Doiel Hills S02 Monitoring - Quarterly Report 2-1 Reported Data 
CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

3.0 Results 

3.1 Missing Data Summary 

Table 3-1 shows the missing data summary for this quarter. 

Table 3-1: Missing Data Summary 

Monitoring 

Parameters Missing Data Period Reason for Missing data 

Hour 23 of each day Daily calibration 

10/23/15 hours 08 and 1 O Power outage 

S02 Concentration 11 /18/15 hours 12 and 13 Audits performed by CB&I 

12/08/15 hours 10 and 11 Cylinder gas change out and calibration check 

12/15/15 hour 15 Replacement of analyzer filter and analyzer 

span check 

10/25/15 hour 22 Rainfall, data acquisition failure 

11 /18/15 hour 10 

(All but rainfall) Calibration of the 10-meter temperature sensor 

12/13/15 hour 12 through 12/15/15 Logger lockup probably caused by hour13 thunderstorm induced power surge 

12/21/15 hours 07-17; 12/22/15 

hours 07-16; 12/23/15 hours 07-17; 

12/24/15 hours 07-12; 01/11 hours 

Meteorological 07 -14; 01/12 hours 07 -14; 01/13 

hours 10-17; 01/14hours11-17; Power outage Data 01/16hour 10- 01/18 hour 19 

(precipitation also missing for 01 /16 

hour 09); and 01/19 hours 09 - 20 

01 /18 hour 20 - 01 /19 hour 08 

Malfunction of the 8872 data logger voltage 

(except precipitation) module 

01/19 hour 21 - 01/22hour14 

Malfunction of the 8872 data logger voltage 

(except precipitation) module 

01/22hour15 Replacement of the 8872 data logger voltage 

module 

CLECO Doiel Hills S02 Monitoring - Quarterly Report 3-1 Results 
CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

3.2 Meteorological Data Summary 

Figure 3-1 shows the wind rose for the 3 months of monitoring in this quarter. The wind from southwest to 

southeast and from northwest to northeast were both approximately 42.8% of the time. The highest wind speed 

was <23 miles mph, predominantly from the south. 

Table 3-2 shows the statistical summary of the meteorological parameters during this quarter. 

Table 3-2: Statistical Summary of Hourly Meteorological Parameters 

Meteorological 

Parameters Unit Maximum Minimum Average Data Recovery(%) 

Wind Speed Mph 22.3 Calm 5.2 88.86 

Ambient Temperature (1 Om) Deg F 82.4 25.8 55.8 88.86 

Ambient Temperature (2m) Deg F 82.8 24.9 55.2 88.86 

Barometric Pressure Inch Hg 30.27 29.22 29.80 88.86 

Rainfall Inch 1.1 9 0 0.01 92.08 

Solar Radiation Langleys 1.08 0 0.14 88.86 

3.3 Ambient Hourly S02 Concentration Data Summary 

Figure 3-2 shows the pollution rose for this quarter. Figure 3-3 shows the distribution of the daily maximum 1-

hour concentration for the quarter. 

The 1-hour 802 NAAQS is based on ggth percentile of daily maximum 1-hour 802 concentration. Table 3-3 

shows the statistical summary of the daily maximum 1-hour ambient 802 concentration during this quarter. 

Table 3-3: Statistical Summary of Daily Maximum 1-hour Ambient S02 Concentration 

Highest Lowest Average 99tn Percentile 

Daily Daily Daily Daily 

Maximum Maximum Maximum Maximum Data 

1-Hour 1-Hour 1-Hour 1 Hour Recovery (

2

l 

Monitoring Parameter Unit Concentration Concentration Concentration Concentration (

1

l (%) 

Hourly S02 Concentration ppb 32.6 0.3 3.5 25.6 99.83 

(1) ggth percentile for the quarter is the Z'd highest daily maximum 1-hour value based on 105 data points. NAAQS for 1-hour S02 is 75 

ppb and represented as 991

h percentile of daily maximum 1-hour concentration 

(2) Counting calibration checks as valid data 

CLECO Doiel Hills S02 Monitoring - Quarterly Report 3-2 Results 
Figures 

CLE CO Doiel Hills S02 Monitoring - Quarterly Report 

CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

Figures 
CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

Figure 1-1: Location of S02 Monitoring Station 

Lat/Long of S02 Monitoring Station: 32°01'06.3000", -093°33'43.8000 

CLE CO Dolet Hills S02 Monitoring - Quarterly Report Figures 

Copyrighted map removed
Figure 1-2: Photographs of 502 Monitoring Station 

Photograph #1 

CLECO Doiel Hills S02 Monitoring - Quarterly Report 

CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

Figures 
Figure 1-2: Photographs of 502 Monitoring Station 

Photograph #2 

CLE CO Daiei Hills S02 Monitoring - Quarterly Report 

CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

Figures 
' CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

Figure 1-3: Location of Meteorological Monitoring Station 

Lat/Long of Meteorological Station: 32°02'13.7400", -093°34'16.9799 

CLECO Doiel Hills S02 Monitoring - Quarterly Report Figures 

Copyrighted map removed
CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

Figure 1-4: Photograph of Meteorological Monitoring Station 

CLE CO Doiel Hills S02 Monitoring - Quarterly Report Figures 
CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

Figure 3-1: Wind Rose - October 23, 2015 to January 31, 2016 

Site: CDH 

Parameter: SWSP 

Units: MPH 

SWSP 

• <3 

• <5 

• <1 

Period: 10/2312015-1/31/2016 

CLECO Doiel Hills S02 Monitoring - Quarterly Report Figures 
CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

Figure 3-2: Pollution Rose - October 23, 2015 to January 31, 2016 

Site:CDH 

Parameter. 802 

Units: PPB 

502 

• <5 

• <10 

• <15 

• <20 

• <25 

• <30 

• <35 

>40 

Period: 10/23/2015-1/31/2016 

CLECO Dolet Hills S02 Monitoring - Quarterly Report Figures 
CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

Figure 3-3 Daily Maximum 1-hour 502 Concentrations 

35 -,-~~~-.-~,--,--rT'1'TII~s~D....-a~d~y~lVI.-..--a x~1Ill Ill ~~1~-:H.....-r~S~u~~c~o-n e_nt~ra~t1-o ~~~~~~ 

10/23/15 to 0113112016 

~ 20 +-~~~~~~1--~~~~~~~~~~-1-~~~~~~~~~~-1-11--~~~ 

Q.. 

Q.. 

N 

0 

1J1 15 

CLECO Doiel Hills S02 Monitoring - Quarterly Report Figures 
CLECO POWER LLC 

DOLET HILLS POWER STATION 

PINEVILLE, LOUISIANA 

Appendices 

Appendix 1 Hourly Meteorological Data 

Appendix 2 Hourly Ambient 502 Concentration Data 

Appendix 3 Data Recovery Reports 

Appendix 4 Weekly Inspection Reports 

Appendix 5 System Audit and Calibration Reports 

(All On USB Drive) 

CLECO Doiel Hills S02 Monitoring- Quarterly Report Appendices 
CLECO EQUIPMENT TESTING EVALUATION 

Service Period - 01/2013 thru 12/2013 

Testing protocol entails evaluating oil-filled equipment that does not have nameplate 

data indicating non-PCB. Salvage and disposal operations facilities will accept only 

nameplate equipment at designated value. Equipment with only the regulatory blue tag 

requires confirmatory testing. The data below reflects that requirement: 

• Total Issued into service thru Stores 

• Total Tested during this period 

• · Total managed as per PCB Regulations 

Units >499 ppm 

Units 50 ppm to 499 ppm 

Units 45 ppm to 49 ppm (5% rule) 

General analysis 

48 

154 

10 

In-service equipment not labeled (Total Tested/Total Issued) 

PCB equipment tested (Total Disposed/Total Tested) 

PCB equipment in service (Total Disposed/Total Issued) 

5,176 

2,238 

43.24% 

10.56% 

4.10% 

212 

This is not a true statistical evaluation. The only know values are the total units tested 

and the results of that testing. General analysis is based on the following assumptions: 

1. There is no particular set of standards or assumptions; 

2. The selected period cannot be confirmed as 'typical' as no data evaluation of this 

type has been done by Cleco; 

3. Equipment issued is not verified as one-to-one replacement (probably includes 

swaps, upgrades, new construction, etc.); 

4. Testing includes ancillary articles (bushings, capacitors, tankage, etc.); 

5. No actual account was made for tagged equipment that tested as PCB. 
CLECO EQUIPMENT TESTING EVALUATION 

Service Period - 01/2013 thru 12/2013 

Breakout by Equipment Type 

• Transformers tested during this period 

(pole-top, pad mount) 

1,625 

• Total managed as per PCB Regulations 

Units >499 ppm 

Units 50 ppm to 499 ppm 

Units 45 ppm to 49 ppm (5% rule) 

General analysis 

7 

79 

7 

Equipment managed as PCB (Total Managed!Total Tested) 

• Other equipment tested during this period 

(regulators, capacitors, bushings, etc) 

• Total managed as per PCB Regulations 

Units >499 ppm 

Units 50 ppm to 499 ppm · 

Units 45 ppm to 49 ppm (5% rule) 

General analysis 

48 

154 

10 

Equipment managed as PCB (Total Managed!Total Tested) 

93 

5.72% 

608 

212 

34.87% 
CLECO EQUIPMENT TESTING EVALUATION 

Service Period - 01/2014 thru 12/2014 

Testing protocol entails evaluating oil-filled equipment that does not have nameplate 

data indicating non-PCB. Salvage and disposal operations facilities will accept only 

nameplate equipment at designated value. Equipment with only the regulatory blue tag 

requires confirmatory testing. The data below reflects that requirement: 

• Total Issued into service thru Stores 

• Total Tested (articles not properly marked) 

• Total Managed as per PCB Regulations 

· Units >499 ppm 

Units 50 ppm to 499 ppm 

Units 45 ppm to 49 ppm (5% rule) 

General analysis 

29 

94 

5 

In-service equipment not labeled (Total Tested/Total Issued) 

PCB equipment tested (Total Managed/Total Tested) 

PCB equipment in service (Total Managed/Total Issued) 

4,424 

1,730 

39.10% 

7.40% 

2.89% 

128 

This is not a true statistical evaluation. The only know values are the total units tested 

and the results of that testing. General analysis is based on the following assumptions: 

1. There is no particular set of standards or assumptions; Total Issued is a best 

query of typical oil-filled equipment issued through Stores around the State; 

2. Equipment issued is not verified as one-to-one replacement (probably includes 

swaps, upgrades, new construction, etc.); 

3. The selected period cannot be confirmed as 'typical' as no data evaluation of this 

type has been done by Cleco; 

4. Testing includes ancillary articles (bushings, capacitors, tankage, etc.); 

5. No actual account was made for equipment tagged Non-PCB that tested as PCB. 
CLECO EQUIPMENT TESTING EVALUATION 

Service Period - 01/2014 thru 12/2014 

Breakout by Equipment Type 

• Transformers tested during this period 

(pole-top, pad mount) 

1,625 

• Total managed as per PCB Regulations 

Units >499 ppm 

Units 50 ppm to 499 ppm 

Units 45 ppm to 49 ppm (5% rule) 

General analysis 

7 

79 

7 

Equipment managed as PCB (Total Managed!Total Tested) 

• Other equipment tested during this period 

(regulators, capacitors, bushings, etc) 

• Total managed as per PCB Regulations 

Units >499 ppm 

Units 50 ppm to 499 ppm 

Units 45 ppm to 49 ppm (5% rule) 

General analysis 

48 

154 

10 

Equipment managed as PCB (Total Managed!Total Tested) 

93 

5.72% 

608 

212 

34.87%