Document 0JqVR02DNDb861K8OO4kBzDxM
c The standard for filterable particulate matter, applicable on or after July 6, 2027, for existing coal-fired
generating units, not low-rank virgin coal, listed in -fable 2 to 40 CFR Part 63 Subpart CUCCU. This
standard is 1E-02 lb/MMBtu or 1E-01 lb/MWh.
c In lieu of meeting this revised fPM emission standard, we propose that this unit instead continue to
comply with current emission standard of 3E-02 lb'MMBtu or 3E-01 lb!MWh, which has been
determined by EPA to be protective of public health with an adequate margin of safety.
Facilities and effected source:
c
Entergy Louisiana, I.I.C R S Nelson Plant located in Westlake, Louisiana
o Effected Source: Unit 6
Length of compliance period being requested:
c A 2-year exemption is requested, from July 6, 2027 through July 5. 2029
Technology:
R. S Nelson Unit 6 is equipped with an Electrostatic Precipitator (ESP) to control emissions of fPM, and
the unit has continuously achieved compliance with the current MATS fPM limit of 3E-02 lb!MMBtu.
However, examination of Continuous Emission Monitoring System data for Unit 6 reveals a consistent
pattern of fPM emission rates in excess of the revised fPM standard of 0.01 lb!MMBtu. ELL does not
anticipate that R. S Nelson Unit 6 will be able to consistently achieve compliance with this revised fPNI
limit.
Based on current resource planning, the relevant technology under consideration is either to replace the
generating capacity of Unit 6 or to repower Unit 6 to utilize natural gas as a fuel source. ELL does not
anticipate that either of these technologies can be implemented prior to July 6. 2027, thus the relevant
technology to meet the capacity and generation needs of ELL and its customers is not available prior to
this date.
National Security:
c In Executive Order 14156, Deciciring u Ncuioncil Energy Finergencv, President Trump emphasized that
aln affordable and reliable domestic supply of energy is a fundamental requirement for the national and
economic security of any nation" and that "the United States' insufficient energy production,
transportation, refining, and generation constitutes an unusual and extraordinary threat to our Nation's
economy, national security, and foreign policy.". The ability for R. S Nelson Unit 6 to continue to
provide safe, reliable, and affordable power is aligned with the national security interests noted in these
statements.
Should you have any questions regarding this recommendation, please let us know.
Thank you, Laura Beauchamp Vice President, Business Operations and Strategy Entergy Louisiana, LLC
entergy
Laura Beauchamp Vice President Business Operations and Strategy Entergy Louisiana, LLC 11...2auclii`cD,entergy.com O 504-840-2582 M 504-606-6983 4809 Jefferson Hwy, Jefferson, LA
70121
From: Beauchamp, Laura Sent: Monday, March 31, 2025 6:17 PM
Sierra Club FOIA 2025-EPA-04883
ED_018388_00005586-00002
SC_EVERSPLIT0006409