# ),"~tarEnergy. January 16, 2013 Mr. Russ Brichacek Bureau ofAir Kansas Department ofHealth and Envirorunent 1000 SW Jackson Street, Suite 310 Topeka, KS 66612-1366 RE: Jeffrey Energy Center Kansas Source ID 1490001 Dear Mr. Brichacek: The Air Emission Source Construction Permit (Permit) for the emission reduction project at Westar Energy, Inc. (Westar)- Jeffrey Energy Center (JEC) was issued by KDHE on February 29, 2008 and amended May 7, 2008. Item #5 ofthe Monitoring, Recordkeeping and Reporting section ofthe Permit specifies that in accordance with 40 CFR 52.21(r)(6)(iii), Westar shall monitor, calculate and maintain a record ofthe a1mual emissions ofNOx, VOC, PM 10, PM and S02, in tons per year on a calendar year basis, for a period of 10 years following resumption ofregular operations after the change. Additionally, Item #6 ofthe Monitoring, Recordkeeping and Reporting section ofthe Permit specifies that in accordance with 40 CFR 52.2l(r)(6)(iv), an annual report is to be submitted to KDHE within 60 days after the end ofeach calendar year setting out the emissions during the previous calendar year. · Kansas Administrative Regulation (K.A.R.) 28-19-350 (Prevention ofSignificant Deterioration (PSD) of Air Quality) was published in the December 13, 2012 edition oftheKansas Register. This regulation,

·which became effective December 28, 2012, adopts by reference the definition of"reasonablepossibility" contained within the federal PSD regulations at 40 CFR 52.21(r)(6). Therefore, in accordance with 40 CFR 52.21(r)(6), the only regulated New Source Review pollutant for which there existed a reasonable possibility ofa significant emissions increase was volatile organic compounds (VOC). Consequently, in accordance with 40 CFR 52.21(r)(6)(iii) and (iv), VOC is the only pollutant for which monitoring, recordkeeping and reporting is now required. We are seeking KDHE concurrence ofour understanding ofthis requirement. Unless we hear to the cont.rary,

**\\iesi<~r** wiil oniy be providing rt:ccrds oiour\iOC: enussiOft!) m the r.;port wtucn IS due 60 days aHer the ca!endar year going forward. Ifyou have any questions, please contact me at (785) 575-1614 orby e-mail at d:-m.wilkus@wcstareneq,'Y
.com. Sincerely,



# 0)7?:~ Daniel R. Wilkus, P.E. Director; Air Proh'l'ams



### 818 SKarutU

### A4le

## I PO Box

### 889

## I Topeka, KarutU 

### 66601.()889Bureau ofAir Curtis State Office Building 1000 SW Jackson. Suite 310 Topeka, KS 66612-1366 Robert M0ser, l'viD, Sccrcwry



### Source ID No. 1490001 Mr. Dan Wilkus Director, Air Programs Westar Energy, Inc. PO Box 889 Topeka, Kansas 66601-0889 Department ofl-lealrh & Environment


### March 12,2013

RE: Jeffrey Energy Center- Modification ofa Construction Permit (C-7839) Dear Mr. Wilkus: Phone: 785-296-1576 Fax. 785-296-7455 rbolfing@kdheks gov www.kdheks.gov/bar Sam Brownback, Governor



### Your letter ofJanuary 16, 2013 requesting modifying item #5 ofthe Monitoring, Recordkeeping and Reporting section ofthe permit issued by KDHE, BOAon February 29, 2008 and amended May 7, 2008 (C7839). Since the permit was issued, the EPA added a section under 40CFR52.21(r)(6) of"reasonable possibility" and KDHE incorporated that update on December 13, 2012. Item #5 ofthe Monitoring, Recordkeeping and Reporting section ofthe permit now reads "In accordance with 40CFR52.21(r)(6)(iii): Monitor, calculate, and maintain a record ofthe annual emissions ofNOx, VOC, PM10, PM and S02, in tons per year on a calendar year basis, for a period of 10 years following resumption ofregular operations after the change." Since there is only a reasonable possibility ofan increase in emission ofVOC (the other pollutants will decrease their emission due to control improvements done as conditions ofthe permit), item #5 shall require only VOC to be monitored, calculate and maintain annual emissions and to report as required by item #6 ofthat section. Ifyou have any questions regarding this letter, please contact me at (785) 296-1576 orby email at rbolfing(a).kdheks.gov.

RJB:csm 

### c: NEDO Rick Bolfin , P.E. Environmental Engineer Air Compliance Section