Staions 3 and 4 air permit comments to EPA

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

1. The responsible official name change to Danny Pribble.

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. The potential to emit calculations presented the emissions in
the application in units of lb.hr and ton/yr. These values were accepted by
the EPA for the netting analysis, and took 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%, the emissions of
NOx and CO would be 40 ppmvd. Transwestern is requesting that a provision
be made in the permit conditions that 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%.

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.