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all your trades.
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Bill, Just a short note to let you know whats going on at Bakersfield.
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I have spoken to the agency inspector about one of the NOV issues and have been told that EOTT will definately receive a an NOV and fine for failure to conduct the emissions testing on a heater that apparently should have been tested approx.
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6 months ago.
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With repsect to the other NOV issue, Rick Suderman had a testing company in to perform emissions testing on another heater which was required to be tested by today.
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As the testing contractor began his testing, an 02 issue developed with the equipment the testing company was using and a miscommunication on the part of the testing contractor was directed to Rick.
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As a result, the the inspector observed elevated CO readings from the heater that Rick had made adjustments in the heater set points (based upon recommendations from the contractor) causing the elevated CO readings to result.
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The inspector stated that the facility would receive another NOV for this exceedance.
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In any event this isssue was NOT Rick's fault and was due to some bad communication on the part of the contractor.
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We have sent the testing company home and will be bringing in another testing company (AEROS) on thursday.
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This is the contractor who has done the majority of the previous emissions testing for the facility to complete the heater testing and substantiate the innaccuracy of the first testing company's data.
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With this new data, we shold be able to demonstrate inaccuracy in the first testing company's QA/QC.
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It should also be mentioned that we have identified other environmental issues which we should discuss at your convenience.
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Butch and I will have completed the permit compliance investigataion and be available for discussions on friday.
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William Kendrick
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I wanted to present this summary of the meeting Transwestern had with representatives of the Laguna Pueblo concerning the status of the PCB remediation activities by TW.
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On the Laguna side were members of the Laguna pueblo, the PEOP a technical oversight group that provides expertise and assistance on technical issues for all of the 19 pueblos in New Mexico (ranging from UST to superfund), and members of ETS ( 5 members of the Laguna team, Butch Russell, Rick Smith (advisor for the Laguna team), myself) and George Robinson.
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This is the third meeting we had in the last year and a half with this group since the Lagunas have started showing renewed interest in environmental activities on their pueblo.
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The meeting centered around two issues at the site: the closure of the UST and the PCB remediation activity.
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With respect to the first, concensus was reached that we would continue monitoring and collecting groundwater samples at the two downstream well locations from the UST site on a quarterly basis, and send the results to POEP for review.
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With repsect to the PCB remediation issue, things were a little different.
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The POEP representatives expressed concern on behalf of the Laguna tribal Coucil that the progress of the remediation activities Transwestern is presently using to bring closure to the site is not showing positive goals toward achieving cleanup at the site and that the data submittals to the Lagunas have verified this.
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They indicated that that have been patient with Transwstern's attempts to allow natural attenuation to reduce the PCB contamination, but based upon the historic sampling results, that this technology is not proving to be very successful, in fact the results have shown stagnant results (Im using their words).
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They would like to see Transwestern implement other more proactive technologies to arrive at cleanup and closure of this site.
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Members of the Laguna pueblo, who work for the POEP, expressed concern that the PCB contamination could negatively impact future generations of Lagunas members and that it was the responsibility of Transwestern to clean up the contamination which they brought onto their lands.
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One member of the Laguna pueblo called the contamination a "cancer" with potential to spread.
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A comment was made by the POEP that there was a major potential of increasing the magnitude and spread of the contamination if we continue to just maintain our present approach of just monitoring the site and installing additional wells..
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A member of the POEP has been in contact with a consortum of individuals from North Dakota State University, (Energy and Environmental Research Center) who claim to be experts in reclamation of contaminated sites which are considered difficult to remediate (this site would certainly fall into this category due to the presence of the sandstone bedrock which has numerous cracks and channels present which direct the PCB containing liquids present at the site).
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Although the POEP was not recommending Transwestern utilize their service, they did strongly suggest that we should at least discuss this site with them.
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It shold also be mentioned that Syed Risvi, the POEP Superfund representative was at this meeting.
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He had mentioned that the POEP has been in discussions with EPA Region VI concerning potential classification of the site on the CERCLIS list of sites for inclusion on the NPL..
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He had indicated that he did not want to see this site included on the list, but stated that Transwetern needed to update and show postive results in our remediation efforts and that it was the tribal councils opinion that this was not being done.
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At the conclusion of the meeting, I informed the POEP that Transwestern's internal remediation group would contact the NDSU group and discuss the site characteristics with them and we would reprot back to them the results of our discussions.
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This seemed to satisify the POEP and they were content with this.
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John, I would like to schedule a conference call with the above list of people and discuss this issue.
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A couple of things I want to bring out.
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First, we will be undergoing ROW and Compressor Station renewals with the Lagunas in the near future.
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Second, on the Laguna tribal lands, they have experienced other releases of contimation and are currently very sensitive to this whole contamination problem.
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Although we are considered by the POEP as proactive up to this point and very easy to work with (direct quote from the POEP) they are wanting a more proactive and measurable effort from Transwestern to clean up the PCBs.
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Please get back with me on this.
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This is a short note to apprise those that the before and after emissions testing for the fuel valves and carbuerator at the Spraberry C/S has been submitted to t he TNRCC.
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The data showed fuel savings, as we had hoped it would and we also received an emissions reduction benefit.
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According to the agency, this replacement activity will not require an amendment to the permit, which will be a plus for the company.
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My compliments to all involved for the retesting and efforts it took to make this happen.
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I will forward the response from the TNRCC as it is received.
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The PCB Annual Document Logs for the facilities that generated PCB waste and stored it at TW's long term storage facility were completed and distributed to locations and entered into Envisions.
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The 2rd quarter Transwestern/SoCal PCB mgt.
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committee conference call was completed.
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This committee meets to discusss PCB management on the SoCal system and review invoices generated by SoCal during each quarter.
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This quarters invoice amount was $280,633.48 of which Transwestern is 86% responsible or $241,344.79.
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Final activities are in progress at the Topock Lateral where cleanup of the 1850' pipeline and appurtenances has been completed.
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Analytical results of the wipe samples and liquid samples taken showed the cleanup to be successful.
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All wipes after the cleaning showed to be less than 1 microgram/100 cm.
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sq. Analytical results of the liquids showed to be less than 20 ppb.
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The next phase of the cleanup activities will be in November when the remaining 11 miles of pipe will be cleaned and have launcher facilities installed at the mainline interconnect.
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Rick, Terry had informed me that Solar had trouble with this unit in making its emissions guarantees, prior to shipping it to La Plata.
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I was not aware of this when I permitted the unit.a couple of years ago.
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In an attempt to solve the problem, in November, I had submitted a modification to the permit to the state of Colorado requesting additional emissions as it appears the unit exceeds its permitted levels during the colder months.
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I received a call form the state of Colorado and they said they are hesitant to approve of more emissions for us.
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We reached an agreement with the state that they would remove the pound per hour limit and keep the ton per year requirement in an attempt to give us more operating room (the higher emissions months would be balanced by the warmer months which produce less emissions. However, after Terry went through the calculations we were still exceeding the permitted emission limits when we calculated yearly limits. I dont know if Solar might have sold us a bill of goods but based upon emisisons calculations, the unit cant stay under the emissions guarantees that Solar promised. We have notified the state of Colorado, as the permit requires and Im sure they will be following up on this. Let me know what Solar says.......
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see attached save for thursday
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password: megan1
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Ed the 6" project you are talking about is a small project independant of Rogas where a 6"line will be constructed from North Coles and run above ground, if possible, to a tie in approx.
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1 mile away.
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We will need a waiver for this.
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There wont be any by pass crossing concerns and only ocal notifications due to the efforts to run the pipe above ground.
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The reason for constructing above ground is to minimize surface disturbance.
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Im sure that one of the conditions of the approval for this construction actiivty is that EOTT wil be required to maintain integrity of the pipeline to ensure no releases.....inspections, reporting etc....
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Ill keep you in the loop on this.....
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John, I had asked Randi to complete an annual report for the F&G 2081 permit, as I did not want to have this hang over our head when EOTT's 2081 application was reviewed.
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This may be the annual report that were talking about.
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As you remember, the 2081 requires an annual report for activities conducted for the prior year and it is due by Jan 10th of every year.
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It was not been submitted for 1999 or 2000.
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Because Randi has been personally involved in all construction activities at the North Coles Levee facility, I thought she would be the prime person to complie the reports for us and then we would submit.
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If this is the annual report everyone is talking about, then, yes, I instructed her to do these, primarily, because she has been involved since the get go and she has the information.
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She has also promised the reports to me by 2/15 for sumibttal to the F&G.
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John Shafer
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nope.
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what's the occasion?
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John, this is a short note to let you know where we stand on the 7 mile pipeline construction Rogas Project with respect to environmental permitting and approvals.
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The following documents and applications have been submitted to the agencies: California fish and game 1603 application Kern County Floodplain Management Agency-encroachment application US COE 404 Nationwide permit- preconstruction notification Reclamation Board- encroachment application Califonia State Fire Marshall-waiver to install aboveground pipeline Office of Pipeline Safety-waiver to Install aboveground pipeline I am checking to see what state requirements there are for SHPO clearances for this project.
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I would suspect that they would want us to do a field survey prior to construction.
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It seems that every Califonia state and county agency is a candidate for notification or approval.
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Ill keep you apprised......
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John, I have attached the site characteristics for the 4 locations in Az.
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where Transwestern plans to install the four RB211's.
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With this information please provide emissions quarantees for each location (sta. 1-4).
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We will use the same gas quality for each location.
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I have a meeting with the agency on the 26th of Feb. and would greaatly appreciate the guarantees prior to this date.
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If possible, I am going to try and permit each site for 45 ppm NOx as opposed to the 25 ppm NOx number, so I would appreciate your assistance in this also.
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Stream: 1 Mainline Mode: ANLY Cycle Start Time: 11:05 Company: Enron Transportation & Storage Component Mole BTU Relative Name Percent Gross Density '*' indicates user-defined components Base Pressures 14.73000 Real Relative Density Gas = 0.5895
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John, Lou, Cutty, Bill, I want to bring this issue back up for your attention, as I know that everyone is very busy.
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During the EPA Title V inspection at the Laguna C/S this past week, Barbara Bernacek, the Laguna environmental person was present.
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She had been asked to be there by the EPA.
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During our tour of the facility, she casually asked if any progress or decision had been made by Enron management towards remediation assistance in the groundwater issue at the Laguna C/S.
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I had informed her that we were still actively discussing this issue and would contact her in the near future concerning management's decision.
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I would appreciate it very much if each of you would revisit my memo below and then lets discuss what should be done and the approach we should take in addressing the Laguna's concern about a proactive approach to reaching cleanup and closure.
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Bill, the baseline noise surveys, which have been completed, were performed by Hoover and Keith out of Houston, Tx.
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I have a meeting scheduled with the permit engineers from state of Arizona on Monday to discuss the permitting for the two C/S on state lands.
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Ive dealt with these individuals before, but the ADEQ has gone through some reg changes and I want to visit with them on that.
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