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I have included Louie in the distribution and am sure he will have some input.
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My comments are as follows: 1.
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I dont know how relevant it is to know about the customers facilities at this time.
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As you know, we have more than one customer (PG&E and SoCal), and I think that we should maintain a low profile especially with respect ot SoCal.
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Both parties in the past, have been helpful and very cooperative in matters pertaining to PCB's.
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Because the modeling study will be conducted between C/S 3 and C/S 2, the customers facilities should have no impact on this.
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2.
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Also, I would like to see if we can deal with PCB's and arsenic at the same time?
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Is it possible to simultanously model both contaminants?
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3.
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Because the modeling efforts are conducted on a very small portion of the pipeline, can this section be used for all of the Transwestern system?
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In leau of the fact that we have pipe under rivers, over rivers, major elevation chages in short distances etc which are not covered in the section to be modeled, will the pipeline characteristics be covered to the extent that it will yeild information applicable to the entire pipeline system?
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4.
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I am also concerned about stirring up the PCB's and moving additional PCB's into the SoCal system.
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Its been pretty quiet in discussions with the SoCal PCB person.
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I wonder if we should notify Ralph Komai to be on the alert when we start the cleaning?
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Louie, thoughts?
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5.
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Injection of terpenol into the station yard piping.
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How will we do this and how do we get it out?
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6.
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Impact of terpenol on gaskets, engine parts, etc.
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Bill, we had an air inspection at the facility a couple of weeks ago and all went well.
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Prior to the state visit, we went through a "trouble shooting" scenario and found out that Solar provided us with innacurate permitting information for that altitude and temperature.
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Solar was very helpful and provided us with updated information to reflect conditions at the facility.
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I submitted a permit revision and it was submitted to the state of Colorado prior to their inspection, requesting more fuel but no more emissions.
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Recent testing has shown that even under extreme low temperatures, the emissions are under the original permitted levels.
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Because we did not request additional emissions, I expect the permit to be issued within the next couple of months.....
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bottom line is that no NOV will be issued for the fuel use issue.
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William Kendrick
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This is just a short update on the conference call just completed with Michael Adewumi of Penn State, concerning the PCB pipeline modeling project proposed for the Transwestern mainline system.
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David Roensch, Dr. Adewumi and myself discussed the latest proposal submitted by Adewumi and based upon his answers to the technical and operational questions, it appears that the model will yeild some useful information.
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Adewumi was asked about the simultaneous modeling of PCB's and arsenic and feels that the model can address this situation.
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He felt that by initiating the model to the pipeline segement selected for the study (between C/S 4 and C/S3) this information could be projected to the other pipeline segments with physical and elevational conditions not represented in the segment selected.
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As is the case with most projects of this nature, answers to some questions cannot be addressed until we begin the process.
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It appears that the next step in this process is to have Mike Terraso contact Michael Adewumi.
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David Roensch and I will be available to feed technical and operational information to Adewumi for his modeling input.
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It may also be in the best interest of this project to see a team of technical and operational experts from Enron and Transwestern begin a brain stroming of this project during the data input stage to address issues related to the field cleaning trials, both of the pipeline system and the C/S piping.
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By working through the process, we may be able to alleviate some potential concerns and increase the cleaning success.
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Although Transwestern has been involved in this type of cleaning for a number of years, based upon the liquids data results, the system has met with variable success.
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The more technical and operational information we can incorporate into the model, the better will be the modeling conclusions and results of the cleaning activity.
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A meeting was held at C/S 6, Laguna on Tuesday November 16th, to reintroduce the pueblo of Laguna to Transwestern's environmental activities at the facility.
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The Laguna's have hired an environmental person to oversee environmental issues on pueblo lands.
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The meeting centered around three issues: a UST site which had been removed, but not formally closed, a historic removal of asbestos which had been buried at the facility in the late 1980's, and the ongoing groundwater remediation at the site.
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Transwestern provided a history of the above mentioned activiites and why these issues were unresolved in the "eyes" of the Laguna.
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Transwestern committed to submitting closure requests for the UST and asbestos issues.
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With repsect to the groundwater issue, a presentation was given enlighting the Laguna representative of the difficult nature of the subsurface geology and groundwater characteristics to rapidly clean the contaminants (chlorinated solvents and PCB's) and Transwestern's intent to continue its remediation efforts.
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Transwestern assured the Laguna environmental representative that all correspondance and data pertaining to environmental issues would be submitted to the pueblo agency.
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At the conclusion of the meeting, the Laguna's understood Transwestern's commitment to maintaining the policies and practices consistent with the pueblo of Laguna.
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The meeting provided Transwestern and the Laguna's with the opportunity to meet and share ideas and opinions and initiate working relationships.
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The Laguna's now have an understanding of the environmental activities at the site and what Transwestern's approach is to removing the contaminants.
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The Laguna's appreciated Transwestern's efforts and commitment to environmental compliance on the Laguna pueblo.
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Jim, yes you will need a USGS
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I think its time that we did a maintenace spot check on the White units at the above referenced facility, to stay in line with the operating conditions of the facility permit.
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It would probably be a good idea to check on the emissions status of the Whites at the same time.
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The state of Texas conducted an air quality inspection of the NNG Seminole C/S.
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There were no deficiencies or violations identified at the facilit during the inspection.
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The State of New Mexico Air Quality Bureau conducted an inspection of the Transwestern Atoka No. 3 C/S.
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The Agency conducted a record review and did portable emissions testing of 3 of the 5 emissions units at the facility.
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Although fuel use and a natural gas analysis were not available for the units tested, emissions exceedances for NOx are expected for the 2 White Superiors at the facility.
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The State of New Mexico Air Quality Buureau conducted an inspection of the Transwestern Atoka No. 2 C/S.
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The agency conducted a portable emissions testing of the two turbines and one recip at the facility.
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Although fuel use and a natural gas analysis was not available at the facility, all units tested appeared to be in compliance with the permit limits.
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The agency requested sulfur readings from the fuel gas as required under Subpart GG NSPS for the last twelve months.
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The Artesia team has contacted Gas Control in Houston for the for the monthly sulfur values at the facility.
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Leo, my computer has fouled up and I wasnt sure you got this so Im sending it again.....
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Rick, its that time of year again, do your magic and approve the attached expense report And thanx again for the Topock consideration, I do appreciate it.....
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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).
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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.
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These DAILY records include measurements on Saturdays and Sundays.
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3) The measurement must be taken at the location.
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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.
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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 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.
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Approval of a CFMS allows a greatly reduced recordkeeping and reporting for nitrogen and sulfur.
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CFMS requests have been submitted for the following facilities: Plains Turbine C/S Monument C/S Crawford C/S Bloomfield C/S Approvals have not as yet been obtained.
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Until issuance of a CFMS, an applicable facility is required to continue daily sampling for nitrogen and sulfur.
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Facilities which have received CFMS from the EPA include: Please be advised that there may be certain reporting requirements that might be required for each CFMS.
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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.
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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.
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The biennial hazardous waste reporting for 1999 for Transwestern Pipeline Company was submitted to the states of Texas, and New Mexico.
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A meeting was held in Roswell to discuss air permitting activites and the recent agency inspection of the TW Atoka No. 3 C/S.
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Due to the agenciy's portable testing of units at the AToka No. 2 and 3 C/S, A plan was developed to address potential actions which may result from the agency testing.
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Also discussed was NSPS fuel gas monitoring for nitrogen and sulfur and other miscellaneous air issues.
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Texaco has initiated soil excavation of an abondoned pit which may be the source of groundwater contamination at the NNG Eunice C/S.
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An Enron contractor is onsite to oversee the activities by Texaco and to assist in the results of the investigation.
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The 3rd request to Region VI EPA was completed requesting approval of 5 Transwestern and 1 NNG facilities for custom fuel monitoring schedules.
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Initial requests dating back to 10/8/98 were included with the packet.
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A phone call to the Regional Administer of Region VI was also completed.
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Pending additional lack of response, a meeting will be requested to the agency requesting action and approval of the requests.
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Data requests from Argent Consulting have been distributed to the field for the 1999 emissions inventories.
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Results of the additional archeological and biological survey's for the Gallup C/S power transmission line 7C application have been submitted to regualtory affairs in Omaha.
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There were no positive concerns or impacts identified which would require additoinal actions.
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Bret, per ;you request, presented below is a list of Priority 1 and 2 sites in Arizona, New Mexico, Colorado and Texas for which we have running horsepower and emit emissions to the atmosphere.
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Priority 1 Priority 2 NEW MEXICO C/S No. 9 Monument Turbine Bloomfield C/S La Plata Keystone Lone Star Valero C/S
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Louie, I dont have any plans for a trip to HOuston, except for the Mage tech mtg during the last week in Feb. 28, 29, March 1 ,2 Louis Soldano
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A presentation was given to the Transwestern Marketing Group in Houston over the PCB issues affecting sales of natural gas into western markets.
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The history and future potential impacts of market stratgies were also discussed.
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A training session on the Dehy MACT was attended in Santa Fe which was sponsored by the state of New Mexico, apprising companies of forth coming requirements under Title III.
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A request will be sent out ot the field for each location which has dehydration to complete a extended gas analysis and rich lean glycol samples.
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Notification to the staes and EPA is due by June A conference call was attended to discuss the C/S 8 turbine project and its fate.
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