Nitrogen and Sulfur reporting and Recordkeeping for Turbines

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.