Message-ID: <14135973.1075851917328.JavaMail.evans@thyme> Date: Wed, 10 Oct 2001 03:41:00 -0700 (PDT) From: larry.campbell@enron.com To: john.shafer@enron.com, ruth.jensen@enron.com, william.kendrick@enron.com, jerry.martin@enron.com Subject: RE: Staions 3 and 4 air permit comments to EPA Cc: louis.soldano@enron.com, richard.melton@enron.com Mime-Version: 1.0 Content-Type: text/plain; charset=ANSI_X3.4-1968 Content-Transfer-Encoding: quoted-printable Bcc: louis.soldano@enron.com, richard.melton@enron.com X-From: Larry Campbell X-To: John Shafer, Ruth Jensen, William Kendrick, Jerry D Martin X-cc: Louis Soldano, Richard Melton X-bcc: X-Folder: \Larry_Campbell_Nov2001_1\Notes Folders\Redrock mainline expansion X-Origin: CAMPBELL-L X-FileName: lcampbe.nsf 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