Subject: Nitrogen and Sulfur reporting and Recordkeeping for Turbines
From: [email-masked]
To: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Cc: [email-masked], [email-masked], [email-masked]
Date: Wed, 2 Feb 2000 02:20:00 -0800 (PST)

For those teams that have turbines installed after 1990 and/or for those 
turbines which have undergone power  unit changouts, the following 
recordkeeping and monitoring conditions apply:

1) DAILY recordkeeping of nitrogen and sulfur must be taken of the fuel gas 
which supplies the applicable turbine(s). 

2) This recordkeeping consists of electronic recording (gas chromtograph for 
nitrogen and  delmar or equivelant for sulfur) or stain tubes may also be 
used  for sulfur. These DAILY records include measurements on Saturdays and 
Sundays.

3) The measurement must be taken at the location.  An exception to this is 
that the nitrogen and sulfur measurements may be taken upstream or 
downstream  of the applicable turbine facility provided that there are no 
natural gas deliveries into the pipe which would interfere or dilute/increase 
the measurements  for the applicable turbine fuel gas. 

4) Fuel gas records in hard copy form or equivalent  for  the nitrogen and 
sulfur must be maintained at the facility or at a central location for easy 
retrival.  

5) A turbine facility may waiver out of this nitorgen and sulfur daily 
recordkeeping requirement by obtaining a custom fuel monitoring schedule 
(CFMS) from  the EPA.  Approval of a  CFMS allows a greatly reduced 
recordkeeping and reporting for nitrogen and sulfur.  CFMS requests have been 
submitted for the  following facilities:

   P-1 C/S
   Plains Turbine C/S
   Atoka No 2 C/S
   Monument C/S
   Crawford C/S
   Bloomfield C/S
 
Approvals have not as yet been obtained.  Until issuance of a CFMS, an 
applicable facility is required to continue daily sampling for nitrogen and 
sulfur.   
 
Facilities which have received CFMS from the EPA include:

   La Plata C/S
   P-2 C/S

Please be advised that there may be certain reporting requirements that might 
be required for each CFMS.  I would strongly advise that the La Plata and 
Panhandle  teams review their CFMS and include reporting dates into MCS, so 
that the deadlines and reportings are not missed. 

If you have a turbine facility which is subject to the nitrogen and sulfur 
reporting requirements and would like to reduce the reporting burden, contact 
Butch or myself.