Larry,

This looks like all of the comments.

Jon

-----Original Message-----
From: Larry.Campbell@enron.com [mailto:Larry.Campbell@enron.com]
Sent: Tuesday, October 09, 2001 3:57 PM
To: Ruth.Jensen@enron.com; William.Kendrick@enron.com;
jfields@argentinc.com
Subject: TW Comments to air permits for Stat3 and 4


Jon and Ruth, presented below are the comments to the air perimts at 3 and
4.  Please review for clairty and content.  I have spoken to Roger Kohn
about all of these issues and the only one which may be a problem is with
No. 2.  He is checking on what the EPA can do about this.  I have spoken to
Arnold Eisenstein about what we can do with the strict 25 ppmvd requriement
for NOx and CO and he has said that we can hold to the 25 ppm value by
doing some major gas recycling.  This is a fuel waste and costly.  Anyway,
depending upon how long this issue delays the issuance of the permit will
undoubtably determine whether we give in to the 25 ppmvd or hold out for 40
ppmvd.  Id like your comments asap.


              1.     The responsible official name change to  Danny
Pribble.

                         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.  The potential to emit
        calculations presented the emissions in the application in units of
        lb.hr and ton/yr.      These values were accepted by the EPA for
        the netting analysis, and  took 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%, the emissions of NOx and CO would be
        40 ppmvd.  Transwestern is       requesting that  a provision be
        made in the permit conditions that  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%.

        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.



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