10
G
Street,
N.
E.
Suite
700
Washington,
D.
C.
20002
September
28,
2005
Robert
Wayland
U.
S.
Environmental
Protection
Agency
Mail
Code:
C439­
01
Research
Triangle
Park,
NC
27711
Dear
Dr.
Wayland:

In
an
August
2,
2005
conference
call
between
the
Interstate
Natural
Gas
Association
of
America
(
INGAA)
and
EPA,
the
status
of
the
Subpart
KKKK
Turbine
NSPS
proposal
was
discussed.
One
topic
discussed
was
the
inherently
low
sulfur
levels
in
natural
gas,
and
the
INGAA
position
that
the
Subpart
KKKK
proposal
should
be
revised
or
clarified
to
avoid
unnecessary
sulfur
monitoring.
INGAA
noted
that
the
2004
revisions
to
the
existing
Turbine
NSPS,
Subpart
GG,
included
positive
changes
that
eliminated
unnecessary
sulfur
monitoring.
As
detailed
in
our
April
2005
comments
on
the
proposed
standard,
INGAA
is
concerned
that
Subpart
KKKK
would
reinstate
unnecessary
sampling
requirements
for
affected
units.
INGAA
has
provided
a
summary
of
analysis
results
from
previous
Subpart
GG
sampling
that
indicates
natural
gas
sulfur
levels
far
below
the
proposed
limit
in
Subpart
KKKK
 
even
when
the
sulfur
requirement
in
the
natural
gas
tariff
sheet
(
e.
g.,
20
grains
total
sulfur
per
100
SCF)
is
marginally
higher
than
the
proposed
sulfur
limit
in
Subpart
KKKK.

As
an
action
item
from
the
conference
call,
INGAA
was
asked
to
provide
example
rule
language
to
address
sulfur
monitoring.
As
discussed
in
the
call,
a
concept
of
interest
for
low
sulfur
natural
gas
is
an
approach
with
decreasing
frequency
and
cessation
of
sampling
requirements
when
the
natural
gas
is
shown
to
contain
total
sulfur
well
below
the
500
ppmw
proposed
limit
(
e.
g.,
less
than
10%
of
the
limit).

INGAA
offers
two
options
below
for
revised
rule
language
that
would
minimize
unnecessary
sulfur
monitoring
for
natural
gas­
fired
turbines
under
Subpart
KKKK.
The
first
option
includes
reduced
frequency
and
eventual
elimination
of
monitoring
when
sulfur
analysis
for
gas
is
shown
to
be
much
less
than
tariff
levels
and
the
500
ppmw
proposed
limit.
In
addition,
this
option
includes
text
to
allow
representative
analysis
that
has
been
completed
under
an
existing
custom
monitoring
schedule
to
serve
as
the
basis
to
validate
low
sulfur
levels
and
eliminate
the
need
for
additional
testing
for
a
Subpart
KKKK
unit.
The
second
option
considers
another
approach
discussed
in
the
August
2
call,
and
is
based
on
providing
an
alternative
sulfur
limit
for
natural
gas
commensurate
with
the
common
tariff
level
for
interstate
pipelines.
INGAA
still
believes
that
this
is
a
viable
option
and
provides
proposed
language
following
such
an
approach
as
a
second
option.
Further
discussion
and
the
INGAA
proposed
text
for
the
two
options
follow.
Proposed
revisions
to
the
relevant
Subpart
KKKK
text
is
shown
with
additions
underlined
and
strikethrough
used
for
deletions.

Option
1:
This
approach
retains
the
fuel
sulfur
limits
in
the
proposal.
Proposed
new
text
addresses
natural
gas
with
a
tariff
sheet/
transportation
contract
specification
of
20
grains
per
100
SCF
or
less,
and
defines
fuel
sulfur
testing
with
a
sample
frequency
that
decreases
if
the
measured
value
is
shown
to
be
significantly
less
than
the
tariff
specification
and
Subpart
KKKK
sulfur
limit.
Testing
discontinues
if
multiple
measurements
indicate
a
sulfur
level
less
than
10%
of
the
sulfur
limit.
Note
that
INGAA
believes
that
the
tariff
provides
an
assurance
of
continuity
in
fuel
sulfur
content
over
time.
However,
as
an
alternative,
this
provision
could
be
"
fuel
neutral"
and
the
proposed
fuel
analysis
schedule
proposed
below
for
natural
gas
could
be
allowed
for
any
fuel
under
Subpart
KKKK
that
is
measured
at
less
than
10%
of
the
standard,
with
some
assurance
that
fuel
sulfur
content
remains
consistent
over
time.
The
proposed
language
follows:

§
60.4365
How
can
I
be
exempted
from
monitoring
the
total
sulfur
content
of
the
fuel?
You
may
elect
not
to
monitor
the
total
sulfur
content
of
the
fuel
combusted
in
the
turbine,
if
the
fuel
is
demonstrated
not
to
exceed
300
ppmw
total
sulfur.
You
must
use
one
of
the
following
sources
of
information
to
make
the
required
demonstration:
(
a)
The
fuel
quality
characteristics
in
a
current,
valid
purchase
contract,
tariff
sheet
or
transportation
contract
for
the
fuel,
specifying
that
the
maximum
total
sulfur
content
of
the
fuel
is
300
ppmw
or
less;
or
(
b)
Representative
fuel
sampling
data
which
show
that
the
sulfur
content
of
the
fuel
does
not
exceed
300
ppmw.
At
a
minimum,
the
amount
of
fuel
sampling
data
specified
in
section
2.3.1.4
or
2.3.2.4
of
appendix
D
to
part
75
of
this
chapter
is
required.;
or
(
c)
For
natural
gas
as
defined
in
§
60.4420
with
a
total
sulfur
requirement
in
a
tariff
sheet
or
contract
specification
not
to
exceed
20
grains
per
100
standard
cubic
feet,
sampling
following
the
criteria
identified
in
§
60.4370(
c).

§
60.4370
How
often
must
I
determine
the
sulfur
content
of
the
fuel?
The
frequency
of
determining
the
sulfur
content
of
the
fuel
must
be
as
follows:
(
a)
Fuel
oil.
For
fuel
oil,
use
one
of
the
total
sulfur
sampling
options
and
the
associated
sampling
frequency
described
in
sections
2.2.3,
2.2.4.1,
2.2.4.2,
and
2.2.4.3
of
appendix
D
to
part
75
of
this
chapter
(
i.
e.,
flow
proportional
sampling,
daily
sampling,
sampling
from
the
unit's
storage
tank
after
each
addition
of
fuel
to
the
tank,
or
sampling
each
delivery
prior
to
combining
it
with
fuel
oil
already
in
the
intended
storage
tank).
(
b)
Gaseous
fuel.
If
you
elect
not
to
demonstrate
sulfur
content
using
options
in
§
60.4365,
and
the
fuel
is
supplied
without
intermediate
bulk
storage,
the
sulfur
content
value
of
the
gaseous
fuel
must
be
determined
and
recorded
once
per
unit
operating
day.
(
c)
Natural
gas.
Conduct
quarterly
testing
to
determine
the
sulfur
content
of
the
fuel.
If
any
quarterly
test
indicates
total
sulfur
content
less
than
50
ppmw
(
10%
of
the
500
ppmw
sulfur
limit),
then
the
test
frequency
can
be
reduced
to
annually.
If
two
consecutive
annual
tests
indicate
total
sulfur
content
less
than
50
ppmw,
no
subsequent
fuel
sampling
and
analysis
is
required.
The
quarterly
test
that
triggers
an
annual
frequency
serves
as
the
first
of
two
annual
tests
to
fulfill
this
requirement.
(
i)
If
within
the
previous
five
years,
representative
fuel
sampling
has
been
conducted
on
the
natural
gas
pipeline
under
a
custom
monitoring
schedule,
records
of
that
analysis
can
be
used
to
fulfill
the
requirements
of
§
60.4370(
c).
If
these
results
indicate
total
sulfur
less
than
50
ppmw,
then
no
additional
fuel
sulfur
analysis
is
required.

Option
2:
This
approach
provides
alternative
sulfur
criteria
for
units
that
fire
natural
gas,
with
a
separate
sulfur
limit
based
on
fuel
that
meets
the
Subpart
KKKK
definition
of
natural
gas
and
includes
a
tariff
limit
of
20
grains
per
100
SCF
or
less.
Revisions
are
required
to
§
60.4330(
b)
along
with
addition
of
a
new
section
(
c).
Proposed
text
for
the
tariff­
based
exemption
in
§
60.4365
is
also
provided.
The
proposed
language
follows:

§
60.4330
What
emission
limits
must
I
meet
for
sulfur
dioxide
(
SO2)?
You
must
comply
with
one
or
the
other
of
the
following
conditions:
(
a)
You
must
not
cause
to
be
discharged
into
the
atmosphere
from
the
subject
stationary
combustion
turbine
any
gases
which
contain
SO2
in
excess
of
73
nanograms
per
Joule
(
ng/
J)
(
0.58
pounds
per
megawatt­
hour
(
lb/
MW 
hr)),
or
(
b)
You
must
not
burn
in
the
subject
stationary
combustion
turbine
any
liquid
fuel
or
gaseous
fuel
other
than
natural
gas
which
contains
total
sulfur
in
excess
of
0.05
percent
by
weight
(
500
parts
per
million
by
weight
(
ppmw)).,
or
(
c)
For
a
subject
stationary
combustion
turbine
burning
natural
gas
as
defined
in
§
60.4420,
you
must
not
burn
natural
gas
with
total
sulfur
content
in
excess
of
20
grains
per
100
standard
cubic
feet
based
on
a
valid
tariff
sheet
or
transportation
contract.

§
60.4365
How
can
I
be
exempted
from
monitoring
the
total
sulfur
content
of
the
fuel?
You
may
elect
not
to
monitor
the
total
sulfur
content
of
the
fuel
combusted
in
the
turbine,
if
the
fuel
is
natural
gas
with
a
total
sulfur
level
not
to
exceed
20
grains
per
100
standard
cubic
feet
or
other
fuel
demonstrated
not
to
exceed
300
ppmw
total
sulfur.
You
must
use
one
of
the
following
sources
of
information
to
make
the
required
demonstration:
(
a)
The
fuel
quality
characteristics
in
a
current,
valid
purchase
contract,
tariff
sheet
or
transportation
contract
for
the
fuel,
specifying
that
the
maximum
total
sulfur
content
of
natural
gas
does
not
exceed
20
grains
per
100
standard
cubic
feet
or
the
total
sulfur
content
of
other
fuels
is
300
ppmw
or
less;
or
(
b)
Representative
fuel
sampling
data
which
show
that
the
sulfur
content
of
the
fuel
does
not
exceed
300
ppmw.
At
a
minimum,
the
amount
of
fuel
sampling
data
specified
in
section
2.3.1.4
or
2.3.2.4
of
appendix
D
to
part
75
of
this
chapter
is
required.

INGAA
appreciates
your
consideration
of
this
issue.
If
you
have
any
questions
or
require
clarification
or
additional
input
on
the
sulfur
monitoring
language
proposed,
please
contact
me
at
202­
216­
5935.

Sincerely,

Lisa
S.
Beal
Director,
Environment
and
Construction
Policy
Interstate
Natural
Gas
Association
of
America
cc
(
by
email):
Jaime
Pagan,
U.
S.
EPA
Sims
Roy,
U.
S.
EPA
