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Enron Mail |
---------------------- Forwarded by Rick Loveless/ET&S/Enron on 02/07/2000
09:23 AM --------------------------- Kenneth Young 02/04/2000 04:06 PM To: Rick Loveless/ET&S/Enron@Enron cc: Subject: Re: NSPS Calculation for Saturn 1200 -Reply Rick, Attached is communications I have had with Solar on the Saturn turbine fuel consumption. The fuel rate Ms Leslie Whitherspoon cites in her example below is the lowest I have seen from Solar for a Saturn turbine. I do not know for a fact whether her example is applicable to our operation. I am making you aware that any of the calculations using Solar's data has exceeded the 10.7 gigajoule/hr limit as specified in 40 CFR 60.330 clause of the BNA's Subpart GG - Standards of Performance for Stationary Gas Turbines. I was incorrect to say exceeding this fuel consumption would trigger PSD; per our conversation it only triggers a NSPS permit which occordingly is triggered anyway with the replacement of a Saturn turbine. Attached is the spreadsheet I forwarded to Ms Whitherspoon. Ken Young ---------------------- Forwarded by Kenneth Young/ET&S/Enron on 02/04/2000 03:45 PM --------------------------- Leslie H Witherspoon <Witherspoon_Leslie_H@solarturbines.com< on 02/01/2000 09:49:00 AM To: Kenneth Young/ET&S/Enron@Enron cc: Subject: Re: NSPS Calculation for Saturn 1200 -Reply In the NSPS formula the "STD" value is % by volume.... Therefore, you take your result, 0.015 % ppmv, and move the decimal two places to the left to represent ppmv. Result 0.00015 or 150 ppm. Yes, the Saturn has a heat input high enough to trigger the NSPS regulation. This regulation however, has nothing to do with triggering PSD. I don't understand the connection you are making between NSPS, Subpart GG and PSD. Most states, including Kansas, have the delegated authority for NSPS. All that is required by the standard is a performance test within 180 days of start-up and a record of the sulfur and nitrogen content of the fuel. In some cases, less testing is required. Please let me know if this doesn't answer your questions. I feel that there may be some disconnect on what your strategy and how I'm assisting. Leslie 619.544.2434 On Wednesday, I can be reached at 619.590.0552 all day. <<< Kenneth_Young@enron.com 02/01/00 04:21pm <<< Leslie, Please review your calculations. I do not think (14.4 / 14.4 x 0.015) equals 150ppm. This issue is not the tolerable limits of emission of the Solar Saturn. I feel this issue relates to a fuel flow limit which governs whether a Saturn falls under the 10.7 gigajoule limit prescibe by 40 CFR 60.330 clause of the BNA's Subpart GG - Standards of Performance for Stationary Gas Turbines. I have included a spreadsheet to illustrate my point. From your data a Solar Saturn consumes fuel at the rate of 10,864 BTU/HP.hr; my calculations show that this rate consumes fuel a rate about .5 gigajoule above BNAs limit, which may force us to apply for a PSD permit. Please take time to review the spreadsheet and my comments, and if you see anything that needs correction, please advise. (See attached file: Solar Saturn limits.xls) Thanks Ken Young Leslie H Witherspoon <Witherspoon_Leslie_H@solarturbines.com< on 01/26/2000 02:28:00 AM To: Kenneth Young/ET&S/Enron@Enron cc: Leslie H Witherspoon <Witherspoon_Leslie_H@solarturbines.com< (IPM Return requested) (Receipt notification requested) Subject: NSPS Calculation for Saturn 1200 Heat Rate at ISO conditions: 10,864 Btu/Hp-hr 10,864 Btu/Hp-hr x 1055 J/Btu / 745.7 w/Hp / 1000 J/KJ = 15.37 KJ/w-hr Max denominator is 14.4 per the regulation 14.4 / 14.4 x 0.015 = 150 ppm The regulatory limit is 150 ppm. We warranty the Saturn 1500 at 110 ppm. I would suppose that the 1200 had a similar warranty. Please let me know if you need anything else. Leslie Witherspoon Solar Turbines 619.544.2434
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