),"~tar Energy. 

January 16, 2013 

Mr. Russ Brichacek 

Bureau of Air 

Kansas Department of Health 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 of the Monitoring, Recordkeeping and Reporting section of the Permit 

specifies that in accordance with 40 CFR 52.21 (r)(6)(iii), Westar shall monitor, calculate and maintain a 

record of the a1mual emissions ofNOx, VOC, PM10, PM and S02, in tons per year on a calendar year 

basis, for a period of 10 years following resumption of regular operations after the change. Additionally, 

Item #6 of the Monitoring, Recordkeeping and Reporting section of the 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 of each calendar year setting out the emissions during the previous calendar year. · 

Kansas Administrative Regulation (K.A.R.) 28-19-350 (Prevention of Significant Deterioration (PSD) of 

Air Quality) was published in the December 13, 2012 edition of the Kansas Register. This regulation, 

·which became effective December 28, 2012, adopts by reference the definition of"reasonable possibility" 

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 of a 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 of our understanding of this requirement. Unless we hear to the 

cont.rary, \\iesi<~r wiil oniy be providing rt:ccrds oi our \ iOC: enussiOft!) m the r.;port wtucn IS due 60 days 

a Her the ca!endar year going forward. 

If you have any questions, please contact me at (785) 575-1614 or by e-mail at 

d:-m. w ilkus@wcstareneq,'Y.com. 

Sincerely, 

0)7?:~ Daniel R. Wilkus, P.E. 

Director; Air Proh'l'ams 

818 S KarutU A4le I PO Box 889 I Topeka, KarutU 6660 1.()889 
Bureau of Air 

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 of a 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 of January 16, 2013 requesting modifying item #5 of the Monitoring, Recordkeeping and 

Reporting section of the permit issued by KDHE, BOA on 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 of the Monitoring, 

Recordkeeping and Reporting section of the permit now reads "In accordance with 40CFR52.21(r)(6)(iii): 

Monitor, calculate, and maintain a record of the 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 of regular operations after the 

change." Since there is only a reasonable possibility of an increase in emission ofVOC (the other pollutants 

will decrease their emission due to control improvements done as conditions of the permit), item #5 shall 

require only VOC to be monitored, calculate and maintain annual emissions and to report as required by item #6 

of that section. 

If you have any questions regarding this letter, please contact me at (785) 296-1576 or by email at 

rbolfing(a).kdheks. gov. 

RJB:csm 

c: NEDO 

Rick Bolfin , P .E. 

Environmental Engineer 

Air Compliance Section