1
Summary
of
Teleconference
with
the
Gas
Transmission
Industry
Representatives
Regarding
the
Combustion
Turbine
New
Source
Performance
Standards
March
22,
2005
Attendees
Jaime
Pagán,
EPA
ESD
Combustion
Group
Sims
Roy,
EPA
ESD
Combustion
Group
Christian
Fellner,
EPA
ESD
Combustion
Group
Sam
Clowney,
Clean
Air
Strategy
Jim
McCarthy,
Innovative
Environmental
Solutions,
Inc.
Mark
Philips,
Panhandle
Energy
Charles
Wait,
Williams
Vincent
Brindley,
El
Paso
Corporation
Fiji
George,
El
Paso
Corporation
Lisa
Beal,
INGAA
Kelly
Carmichael,
NiSource
David
Felcman,
Duke
Energy
Jennifer
Snyder,
AGTI
Purpose
of
Meeting
The
purpose
of
this
teleconference
was
to
discuss
the
key
issues
identified
by
the
Interstate
National
Gas
Association
of
America
(
INGAA)
regarding
the
proposed
Combustion
Turbine
New
Source
Performance
Standards
(
NSPS).
This
list
of
key
issues
was
provided
in
the
agenda,
and
includes
the
following:
potential
dates
for
INGAA/
EPA
meeting;
form
and
level
of
the
standard;
achievability
for
"
very
small"
turbines;
partial
load
efficiencies;
sulfur
limits
in
regards
to
tariff
sheets;
effective
dates
for
refurbished,
reconstructed
and
modified
turbines;
and
applicability
for
units
less
than
1
MW
installed
after
the
Subpart
KKKK
effective
date.

Issues
Discussed
Potential
Dates
for
Face­
to­
Face
Meeting
Gas
transmission
industry
representatives
had
requested
setting
a
date
for
a
face­
to­
face
meeting
with
EPA
regarding
the
issues
to
be
broached
at
this
teleconference.
Jaime
suggested
several
dates.

Form
and
Level
of
the
Standard
Jim
McCarthy
led
the
discussion,
stating
that
their
industry
has
issues
with
the
outputbasis
for
the
standards.
In
particular,
he
brought
up
mechanical
drive
units,
stating
that
there
is
no
easy
way
to
determine
the
output,
and
in
the
rule
there
is
not
enough
detail
on
how
output
should
be
determined
for
mechanical
drive
operations.
The
calculations/
equations
given
in
the
rule
are
specific
to
reporting
for
systems
that
incorporate
CEMS,
and
the
majority
of
the
turbines
in
the
natural
gas
transmission
industry
do
not
utilize
CEMS.
In
addition,
Jim
noted
that
the
term
"
baseload"
given
in
the
rule
is
a
term
that
does
not
have
a
practical
meaning
in
their
industry.
Neither
output
nor
efficiency
can
be
measured
directly
with
their
turbine
setups.
For
these
reasons,
INGAA
recommends
developing
a
concentration
(
ppm)
or
input
based
standard
2
(
lb/
MMBTU)
for
these
units,
and
perhaps
keeping
the
output
based
standards
for
larger
units.

Jaime
replied
that
EPA's
intention
was
to
have
consistent
output­
based
limits
across
the
board.
He
stated
that
EPA
is
willing
to
work
with
INGAA
to
identify
ways
to
arrive
at
outputbased
emissions
through
development
of
calculations,
and
asked
for
INGAA's
input.
Jim
suggested
that
one
way
to
perform
this
calculation
is
to
use
the
minimum
efficiency
on
which
the
output
based
standard
was
based,
in
this
case,
30
percent,
as
the
default
in
the
calculation,
rather
than
determining
this
on
a
case­
by­
case
basis.

Sims
interjected
that
he
didn't
believe
that
determining
thermal
efficiency
was
a
problem
for
natural
gas
transmission
units.
He
stated
that
these
calculations
are
based
on
the
compressor
efficiency,
and
load
is
determined
by
the
compressor
itself.
Sam
stated
that
flow
is
needed
for
this
equation,
and
load
is
then
inferred
from
a
manufacturer
lookup
chart
developed
from
the
test
cell.

Achievability
for
"
Very
Small"
Turbines
Jim
stated
that
there
is
a
need
for
a
"
very
small"
subcategory
with
an
emission
limit
based
on
150
ppmv,
or
alternatively,
a
need
to
make
the
smallest
effective
unit
greater
than
3
MW.
This
addresses
units
that
don't
have
lean
premixed
combustors
as
a
technology
option.
In
addition,
retrofit
applications,
which
may
fall
under
the
definitions
of
modification
and
or
reconstruction,
often
cannot
meet
25
ppmv.
Jim
feels
that
42
ppmv
is
a
more
appropriate
level,
which
is
the
guarantee
for
Solar
Saturns,
new
or
refurbished,
but
he
wanted
to
point
out
that
there
may
be
other
units
which
may
not
be
able
to
achieve
42
ppmv.
EPA
responded
that
they
would
look
further
into
the
issues
of
modified
and
reconstructed
turbines,
in
particular,
if
more
data
were
supplied
by
INGAA
on
these
sources.
Sims
pointed
out,
however,
that
the
common
industry
practice
of
replacing
or
refurbishing
turbines,
as
part
of
a
maintenance
program,
does
not
generally
trigger
NSPS.
Sims
specifically
asked
for
more
data
regarding
the
frequency
of
practices
that
industry
felt
might
trigger
NSPS
for
turbines
that
are
not
"
new."

Partial
Load
Efficiencies
Jim
stated
that
many
smaller
turbines
cannot
achieve
30
percent
efficiency
at
peak
load,
and
partial
load
efficiency
can
decrease
substantially,
which
hasn't
been
taken
into
consideration
in
the
development
of
the
proposed
standard.
Furthermore,
he
added
that
in
the
Gas
Turbine
World
specifications
in
the
docket,
there
were
several
turbines
in
the
1
to
5
MW
power
range
with
efficiencies
ranging
from
24
to
28%.
Jim
added
that
the
NOx
standard
should
only
apply
at
operating
conditions
covered
by
the
NOx
emissions
guarantee
supplied
by
the
manufacturer.
For
an
output
based
standard,
lacking
availability
of
data
supporting
partial
load
performance,
the
standard
should
only
apply
at
full
load.
The
performance
test
should
only
be
required
at
the
applicable
load.

Jaime
replied
that
there
are
indeed
data
gaps
for
small
turbines,
especially
those
that
are
oil
fired,
and
EPA
is
requesting
assistance
in
gathering
more
data
in
these
areas.
He
specified
the
3
need
for
data
supporting
the
comment
that
25
ppm
is
not
achievable,
since
most
of
the
data
that
EPA
has
to
date
supports
the
25
ppmv
basis
for
the
output
based
standard.

Sulfur
Limits
in
Regards
to
Tariff
Sheets
Jim
stated
that
INGAA
has
a
problem
with
the
sulfur
limit.
He
claims
that
the
sulfur
limit
is
less
than
typical
contract/
tariff
sheet
limits
for
"
natural
gas."
He
stated
that
unnecessary
sulfur
monitoring
that
was
remedied
in
the
July
2004
revisions
to
Subpart
GG
will
be
reinstituted
unless
the
sulfur
limit
and
monitoring
exemption
criteria
is
increased
to
20
grains/
100
scf.

Jaime
replied
that
the
sulfur
limit
that
is
proposed
is
500
ppm,
which
is
much
higher
than
the
average
sulfur
content
of
natural
gas.
Jim
agreed,
but
stated
that
most
contracts
and
tariff
sheets
specify
levels
of
20
grains
per
hundred
standard
cubic
feet,
and
that
this
is
the
equivalent
of
680
ppmw.
Though
actual
levels
are
lower,
contracts
do
not
reflect
the
lower
level.
He
claims
that
no
environmental
benefit
will
be
made
by
insisting
on
a
500
ppmw
sulfur
limit,
since
natural
gas
will
be
lower
than
that
anyway,
and
that
it
will
only
cause
additional
sampling
burden
on
their
industry.
EPA
suggested
changing
the
contract
and
tariff
sheets
to
be
more
consistent
with
what
is
supplied.
Jim
stated
that
this
would
be
out
of
their
control.

Effective
Dates
for
Refurbished,
Reconstructed
and
Modified
Turbines
INGAA
stated
that
it
was
confused
about
the
effective
dates
for
reconstructed
and
modified
turbines.
In
one
place
in
the
rule
it
states
that
the
rule
is
applicable
to
turbines
which
commence
modification
or
reconstruction
after
February
18th,
2005,
yet
the
title
refers
to
applicability
"
for
turbines
which
modification
or
reconstruction
is
commenced
on
or
after
[
date
6
months
after
date
final
rule
is
published
in
the
Federal
Register]."
Whether
or
not
subpart
GG
is
applicable
between
dates
of
proposal
and
final
rule
is
also
a
question
that
Jim
raised.

Applicability
for
Units
less
than
1
MW
Installed
after
the
Subpart
KKKK
Effective
Date
Jim
also
brought
up
that
the
low
end
threshold
of
applicability
differs
between
subparts
GG
and
KKKK.
He
noted
that
there
are
a
few
turbines
which
may
fall
into
this
gap
(
between
about
0.8
MW
and
1
MW),
and
wanted
to
clarify
applicability
in
those
cases.
