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.

Transwestern's comments to rough drafts of permit for Klagetoh and  Leupp

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 <NUMBER> below.
The permits really restrict us and cause us some major operational concerns if we are held to <NUMBER> 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.
<NUMBER>.The responsible official name change to Danny Pribble, VP Southwest Operations.
<NUMBER>.The draft permit limits NOx and CO emissions to <NUMBER> ppmv at <NUMBER>% O0, based on a <NUMBER>-hour average, except during periods of startup and shutdown.
At 00F 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 <NUMBER> ppmv during low-load conditions of <NUMBER>% and lower.
The permit application represented turbine operations at base load <NUMBER>% of the time with reduced load operations (<NUMBER>% load)occurring no more than <NUMBER>% of the time.
TWP also included a <NUMBER>% 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 <NUMBER>% and low ambient temperatures, the emissions of NOx and CO could go as high as <NUMBER> ppmvd.
Transwestern is requesting that a provision be made in the permit conditions that allows emissions of NOx and CO be held to <NUMBER> ppmvd during the <NUMBER> % of the time that the turbines operating conditions is less than or equal to <NUMBER>% load.
<NUMBER>.
The word "Catepillar" is mispelled throughout the permit.
<NUMBER>.
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 <NUMBER>" (length of stain tube) or gas chromatography as the proposed methodology to monitor sulfur in the natural gas.
values transwestern concerned ppmv low nox entire operating hour average periods presented comments danny pribble luepp compressor station potential emit calculations permits issued klagetoh use methodologies wet