Subject: Transwestern's comments to rough drafts of permit for Klagetoh and Leupp
From: [email-masked]
To: [email-masked]
Cc: [email-masked], [email-masked]
Date: Tue, 9 Oct 2001 09:56:00 -0700 (PDT)

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.