Message-ID: <25639732.1075851923324.JavaMail.evans@thyme> Date: Thu, 11 Oct 2001 05:19:00 -0700 (PDT) From: larry.campbell@enron.com To: rick.loveless@enron.com, mike.riedel@enron.com, scott.jones@enron.com Subject: Weekly Envoironmental Activity Report Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: Larry Campbell X-To: Rick Loveless, Mike Riedel, Scott Jones X-cc: X-bcc: X-Folder: \Larry_Campbell_Nov2001_1\Notes Folders\'sent mail X-Origin: CAMPBELL-L X-FileName: lcampbe.nsf Transwestern Pipeline Company Transwestern has run into some problems with the air permit conditions for the Redrock Expansion. For the state permits, the ADEQ wants to abitrarily set a 10% safety factor to the emissions levels which approach PSD. This means that they have written into the draft permit a reduction in the allowable hours of operation for the generator from 8760 to 7800. This generator is the facility's prime source of power and therefore, needs to be operated for 8760 hours. Transwestern will challenge the agency's authority to apply a 10%safety factor. For the Indain lands permits, the EPA has written a permit condition of 25 ppmvd for NOx and CO under all operating conditions. Manufacturerers guarantees only apply at 25 ppmvd at loads above 65% and at 0F. It appears that Transwestern may have convenienced the EPA to back away from permit limits in ppmvd and include as permit conditons lb/hr and ton/yr emissions limits that Transwestern originally placed into its applications. Northern Natural Gas Company A standard exemption for the NNG Martin Co. No. 1 facility was submitted to the TNRCC. Preliminary maintenance activities and newly published AP-42 emissions factors have shown that the Martin Co. 1 facility may be a Title V facility. Under the old AP-42 factors, the units at the facility were not greater than 100 ton/year sources. Continued investigation is being conducted to determine emissions levels from the units at the facility. EOTT A request and supporting documentation was submitted to the TNRCC to remove the EOTT Crane facility from the Title V operating permit program. New data on the crude oil received into the facility shows the emissions limits for VOCs to be less than the Title V regulated limit. General Preparations are being finalized for the environmental roundtable to be held next week in Albuquerque.