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Enron Mail |
Cc: william.kendrick@enron.com, ruth.jensen@enron.com
Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit Bcc: william.kendrick@enron.com, ruth.jensen@enron.com X-From: Larry Campbell X-To: Kohn.Roger@epamail.epa.gov X-cc: William Kendrick, Ruth Jensen X-bcc: X-Folder: \Larry_Campbell_Nov2001_1\Notes Folders\All documents X-Origin: CAMPBELL-L X-FileName: lcampbe.nsf Roger, presented below are the comments which Transwetern has on the permits which were issued to the Klagetoh and Luepp compressor station. The most critical and sensitive issue for us is item 2 below. The permits really restrict us and cause us some major operational concerns if we are held to 25 ppmvd for NOx and CO throughout the entire operating range of the turbines. We would really appreciate your help and assistance in this issue. Let me know what additional information you may need. 1.The responsible official name change to Danny Pribble, VP Southwest Operations. 2.The draft permit limits NOx and CO emissions to 25 ppmv at 15% O2, based on a 3-hour average, except during periods of startup and shutdown. At 60F and above the GE data indicates that these rates are achievable under all operating conditions. However, GE data indicates that NOx and CO may be as high as 40 ppmv during low-load conditions of 60% and lower. The permit application represented turbine operations at base load 80% of the time with reduced load operations (64% load)occurring no more than 20% of the time. TWP also included a 15% safety factor to cover periods of reduced operating loads and fluctuating ambient temperatures. The potential to emit calculations presented the emissions in the application in units of lb/hr and ton/yr. These potential to emit values were accepted by the EPA for the netting analysis, and were taken into account by the EPA (See EPA Statement of Basis document). Because the permit conditions hold us to ppmvd values and not lb/yr or ton/year values, Transwestern is concerned that under low load conditions of less than 60% and low ambient temperatures, the emissions of NOx and CO could go as high as 40 ppmvd. Transwestern is requesting that a provision be made in the permit conditions that allows emissions of NOx and CO be held to 40 ppmvd during the 20 % of the time that the turbines operating conditions is less than or equal to 60% load. 3. The word "Catepillar" is mispelled throughout the permit. 4. Permit conditions for sulfur testing in the fuel gas requires Transwestern to use methodologies (wet chemistry technology) that are not normally used to monitor and measure sulfur in the natural gas. Transwestern has received approval from the EPA for other custom fuel monitoring schedules to use "GPA Standard 2377" (length of stain tube) or gas chromatography as the proposed methodology to monitor sulfur in the natural gas.
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