Message-ID: <33177535.1075851903336.JavaMail.evans@thyme> Date: Tue, 19 Jun 2001 10:45:00 -0700 (PDT) From: larry.campbell@enron.com To: john.shafer@enron.com, william.kendrick@enron.com Subject: Compliance Order, P-1 C/S Cc: ruth.jensen@enron.com, marc.phillips@enron.com, david.nutt@enron.com, louis.soldano@enron.com, rich.jolly@enron.com Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit Bcc: ruth.jensen@enron.com, marc.phillips@enron.com, david.nutt@enron.com, louis.soldano@enron.com, rich.jolly@enron.com X-From: Larry Campbell X-To: John Shafer, William Kendrick X-cc: Ruth Jensen, Marc Phillips, David Nutt, Louis Soldano, Rich Jolly X-bcc: X-Folder: \Larry_Campbell_Nov2001_1\Notes Folders\Discussion threads X-Origin: CAMPBELL-L X-FileName: lcampbe.nsf Transwestern received a Compliance Order from the State of New Mexico, Air Quality Bureau, for an outstanding turbine replacement activity at the P-1 C/S which occurred in 1996. Transwestern had met with the AQB over this issue in 1996 and assumed that the issue had been resolved, as no further actions were received from the agency until this Compliance Order was received. The issue in question was Transwestern's replacement of interchangeable internal components from a 4700 turbine into the existing smaller turbine (3505). The larger internal components (inlet guide vanes/nozzles) which were placed into the 3505 were mechanically derated to simulate conditions of the smaller turbine. When Transwestern received permit approval from the AQB to operate at the larger turbine capacity, Transwestern made the upgrade adjustments and then operated at the higher turbine value 4700. The AQB did not understand that Transwestern could not make the adjustments to the inlet guide vanes as any such activity by Transwestern would void the warranty with Soalr Mfg. Only Solar is authorized to make adjustments to the turbine. This prevents Transwestern from randomly and arbitrarily manipulating and adjusting horsepowers of this turbine at their descretion. In the 1996 meeting with the AQB, Transwestern committed to conducting a emissions test of the 4700 to determine if emissions were more or less than the permitted values for the 3505. It was shown that emissions from the 4700 were less than that permitted by the AQB for the 3505. It should also be mentioned that the 3505 was a regerative turbine and the 4700 is a simple cycle. Apparently, EPA has mandated that the AQB act on all issues considered to be outstanding as determined by the EPA. Dave Nutt has been sent the Compliance Order to review. Under the conditions of the Order, Transwestern has 30 days to request another hearing. Id like to have a group discussion to decide how Transwestern will manage and handle this issue. Would someone contact Anabelle and have her set up a conference call for sometime next week?