RE: Staions 3 and 4 air permit comments to EPA

John, we are working out some issues with the station 1 permit and the EPA=
=20
permits for 3 and 4. Briefly here they are.

First issue, that we did not anticipate from the ADEQ. It applies to hours=
=20
of operation for the generator. The ADEQ has restricted hours of operation=
=20
because we are close to the PSD levels at the facility. In talking to=20
Shdeish, the ADEQ protects itself and applies a 10% safety factor on all=20
applications that approach PSD to ensure that the PSD levels are not=20
triggered. This is there policy not regulation. What is ironic is that=
=20
they accepted our calculations for the netting, but did not indicate that=
=20
they would apply any safety factor for their comfort. Im concerned about t=
he=20
time frame to iron out this issue and the construction start date. I need=
=20
some guidance. Do we want to spend time fighting this, not knowing how lon=
g=20
it will take to resolve or do we bite the bullet and put on a catlytic=20
converter for the generator and have unlimited operating hours? In speakin=
g=20
with Shudeish, I got the impressions that when an application approaches th=
e=20
PSD limit, they want to see the applicant apply CEMS or some kind of contro=
l=20
technology just to be sure that they stay under the 250 ton limit. I know=
=20
time is of the essence.

Second issue. The EPA has given us a pretty good permit for stations 3 and=
=20
4, but have restircted us to ppmvd values for NOx and CO, instead of lb./hr=
=20
or ton/yr. The values that they have given us in the permit are OK (25 ppm=
vd=20
for NOx and CO) at base load operation. GE will guarantee this. However, =
at=20
lower tempertures and at reduced loads of 60%, the manufactures numbers are=
=20
40 ppmvd for NOx and CO. We cant live with this. In our application, we=
=20
stated that we would be operating at low loads for 20% of the time and we=
=20
applied a 15% safety factor for the higher NOx and CO levels and presented=
=20
this in lb.hr and tons/yr. This would have covered us, but because the=20
permits limits are in ppmvd, we would exceed these limits during low loads=
=20
and low temps. I have requested from Roger that we would accept permit=20
conditions that would allow us 40 ppmvd during low temps and low loads with=
=20
with requiring us to do associated recordkeeping and Roger said that he wou=
ld=20
bring this before his management. Ill keep you apprised of this issue.

=20
---------------------- Forwarded by Larry Campbell/ET&S/Enron on 10/10/2001=
=20
08:17 AM ---------------------------
From: John Shafer/ENRON@enronXgate on 10/09/2001 10:43 PM CDT
To: Larry Campbell/ET&S/Enron@ENRON, Ruth Jensen/ENRON@enronXgate
cc: William Kendrick/ENRON@enronXgate=20

Subject: RE: Staions 3 and 4 air permit comments to EPA

Larry,
Please also keep Jerry D. Martin in the loop on progress with the permits.=
=01;=20
Thanks, John

-----Original Message-----=20
From: Campbell, Larry=20
Sent: Tue 10/9/2001 4:48 PM=20
To: Jensen, Ruth=20
Cc: Kendrick, William; Shafer, John=20
Subject: RE: Staions 3 and 4 air permit comments to EPA

this is what Im trying for.=01; The permits dont hold us to a mass rate of=
=20
emissions, just ppmvd.=01; We covered ourselves when we presented emisisons=
=20
rates of t/yr in the application, but the EPA came back with NSPS limits,=
=20
which of course hurt us when we operate at loads of less than 64%.=01; We c=
an=20
either cave in to their NSPS limits and when we get under low load condtion=
s,=20
just do a bunch of recycling which wastes gas, or we can spend some valuabl=
e=20
time trying to get the EPA to give us emission limitations=01; in lb/hr or=
=20
t/yr.=01; Im discussing this with the EPA permit engineer.=01;=01; He is ch=
ecking with=20
his management on this issue.=01; Ill keep you apprised.=01;=01;=20

From:=01;=01; Ruth Jensen/ENRON@enronXgate on 10/09/2001 04:36 PM CDT

To:=01;=01;=01;=01; Larry Campbell/ET&S/Enron@ENRON

cc:=01;=01;=01;=01; William Kendrick/ENRON@enronXgate=20

Subject:=01;=01;=01;=01;=01;=01;=01; RE: Staions 3 and 4 air permit commen=
ts to EPA

I agree with your comments.=01; Can't we get a lb/hr limit (based on the=
=20
netting calculations) that we can live with?=01; We're only required to hav=
e a=20
ppm limit that matches NSPS requirements, and that value would be a lot=20
greater than 25 ppmv.

Ruth

=01;-----Original Message-----

From: =01; Campbell, Larry=01;=20

Sent:=01;=01; Tuesday, October 09, 2001 3:55 PM

To:=01;=01;=01;=01; Jensen, Ruth; Kendrick, William; jfields@argentinc.com

Subject:=01;=01;=01;=01;=01;=01;=01; Staions 3 and 4 air permit comments t=
o EPA

Jon and Ruth, presented below are the comments to the air perimts at 3 and=
=20
4.=01; Please review for clairty and content.=01; I have spoken to Roger Ko=
hn about=20
all of these issues and the only one which may be a problem is with No. 2.=
=01;=20
He is checking on what the EPA can do about this.=01; I have spoken to Arno=
ld=20
Eisenstein about what we can do with the strict 25 ppmvd requriement for NO=
x=20
and CO and he has said that we can hold to the 25 ppm value by doing some=
=20
major gas recycling.=01; This is a fuel waste and costly.=01; Anyway, depen=
ding=20
upon how long this issue delays the issuance of the permit will undoubtably=
=20
determine whether we give in to the 25 ppmvd or hold out for 40 ppmvd.=01; =
Id=20
like your comments asap.

=01;=01;=01;=01;=01;=01;=01; =01;=01;=01;=01;=01;=01;=01;=01; 1.=01;=01;=
=01;=01;=01; The responsible official name change to=01; Danny=20
Pribble.

=01;=01;=01;=01;=01;=01;=01;=01;=01;=01;=01;=01;=01;=01;=01;=01;=01;=01;=
=01;=01;=01;=01;=01;=01; 2..=01;=01;=01; The draft permit limits NOx and CO=
emissions=20
to 25 ppmv at 15% O2, based on a 3-hour average, except during periods of=
=20
startup=01; =01;=01;=01;=01;=01;=01;=01; and shutdown.=01; At 60F and above=
the GE data indicates that=20
these rates are achievable under all operating conditions.=01; However, GE=
=20
=01;=01;=01;=01; =01;=01;=01;=01;=01;=01;=01; data indicates that NOx and C=
O may be as high as 40 ppmv during=20
low-load conditions of 60%and lower.

=01;=01;=01;=01;=01;=01;=01; The permit application represented turbine op=
erations at base load=20
80% of the time with reduced load operations (64% load) occurring =01;=01; =
no more=20
than 20% of the time.=01; The potential to emit calculations presented the=
=20
emissions in the application in units of lb.hr and ton/yr. =01;=01;=01;=01;=
These values=20
were accepted by the EPA for the netting analysis, and=01; took were taken =
into=20
account by the EPA (See EPA Statement =01;=01;=01;=01;=01;=01;=01; of Basis=
document).=01; Because=20
the permit conditions hold us to ppmvd values and not lb/yr or ton/year=20
values, Transwestern is =01;=01; =01;=01;=01;=01;=01;=01;=01; concerned tha=
t under low load conditions=20
of less than 60%, the emissions of NOx and CO would be 40 ppmvd.=01;=20
Transwestern is =01;=01;=01;=01; requesting that=01; a provision be made in=
the permit=20
conditions that=01; emissions of NOx and CO be held to 40 ppmvd during the =
20 %=20
of =01;=01;=01;=01; the time that the turbines operating conditions is less=
than or equal=20
to 60%.

3.=01;=01;=01;=01;=01; The word "Catepillar" is mispelled throughout the p=
ermit.

4.=01;=01;=01;=01;=01; Permit conditions for sulfur testing in the fuel ga=
s requires=20
Transwestern to use methodologies (wet chemistry technology) that are=20
not=01;=01;=01; =01;=01;=01;=01; normally used to monitor and measure sulfu=
r in the natural gas.=01;=20
Transwestern has received approval from the EPA for other custom =01;=01;=
=01;=01;=01; fuel=20
monitoring schedules to use=01; "GPA Standard 2377" (length of stain tube) =
or=20
gas chromatography as the proposed methodology=01; to =01;=01;=01;=01; moni=
tor sulfur in the=20
natural gas.

=01;=01;=01;=01;=01;=01;=01;=01;=20