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It encompasses alot of the variablity present on the Transwestern system (elevation, temperature, consistent activities with respect to the rest of the PCB contaminated system). | dev45 |
Let me know before the Penn State visit, so I can start rounding up the analytical data for the pipeline and stations..... | dev45 |
Butch, you may want to attend this | dev45 |
Bret, what do you think about this? | dev45 |
We have pretty much proven that we are not the culprits is this activity. | dev45 |
I have a problem conducting an ongoing sampling for an issue that were not responsible for, even though we initiated the sampling activity. | dev45 |
I plan on visiting the OCD about this issue and either forcing them to justify why we should continue the sampling when the data points to our neighbors. | dev45 |
Additionally, because of the turnover and inability to get the guilty party to get moving on this, spending additional money and not receiving any return seems like a waste of time. | dev45 |
Thoughts.... | dev45 |
George Robinson | dev45 |
George, after Bret's memo, go ahead and conduct the sampling. | dev45 |
the soonest I can discuss the issue with the OCD is in the middle of November. | dev45 |
I have reviewed the reports and results of the studies conducted by us and them and the evidence weighs in our favor. | dev45 |
At your leisure and prior to the November OCD meeting, prepare a memo to file of the resaons and justification based upon the report results and data why Eunice is not the bad guy in this and why Texaco is. | dev45 |
Gradients, plume elevations and characteristics of the contaminants show that this is not our problem. | dev45 |
Id like to have sufficient evidence, both mine and yours, to force OCD to go afterTexaco and get us out of this issue. | dev45 |
I think this would also help Bret's case for having Texaco (or whoever is responsible) reimburse Northern for the costs we have incurred for what is Texaco's problem. | dev45 |
George Robinson | dev45 |
George, I will attend this meeting with you on the 16th. | dev45 |
George Robinson | dev45 |
Mike, I reveiwed the proposal by Adewumi and it is correct and fairly accurate, for the purposes of a historic account and and in as far as what was provided to him in the way of data and history. | dev45 |
His proposed scope seems to be conclusive and appears to be what we need. | dev45 |
I have included Louie in the distribution and am sure he will have some input. | dev45 |
My comments are as follows: 1. | dev45 |
I dont know how relevant it is to know about the customers facilities at this time. | dev45 |
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. | dev45 |
Both parties in the past, have been helpful and very cooperative in matters pertaining to PCB's. | dev45 |
Because the modeling study will be conducted between C/S 3 and C/S 2, the customers facilities should have no impact on this. | dev45 |
2. | dev45 |
Also, I would like to see if we can deal with PCB's and arsenic at the same time? | dev45 |
Is it possible to simultanously model both contaminants? | dev45 |
3. | dev45 |
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? | dev45 |
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? | dev45 |
4. | dev45 |
I am also concerned about stirring up the PCB's and moving additional PCB's into the SoCal system. | dev45 |
Its been pretty quiet in discussions with the SoCal PCB person. | dev45 |
I wonder if we should notify Ralph Komai to be on the alert when we start the cleaning? | dev45 |
Louie, thoughts? | dev45 |
5. | dev45 |
Injection of terpenol into the station yard piping. | dev45 |
How will we do this and how do we get it out? | dev45 |
6. | dev45 |
Impact of terpenol on gaskets, engine parts, etc. | dev45 |
Bill, we had an air inspection at the facility a couple of weeks ago and all went well. | dev45 |
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. | dev45 |
Solar was very helpful and provided us with updated information to reflect conditions at the facility. | dev45 |
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. | dev45 |
Recent testing has shown that even under extreme low temperatures, the emissions are under the original permitted levels. | dev45 |
Because we did not request additional emissions, I expect the permit to be issued within the next couple of months..... | dev45 |
bottom line is that no NOV will be issued for the fuel use issue. | dev45 |
William Kendrick | dev45 |
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. | dev45 |
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. | dev45 |
Adewumi was asked about the simultaneous modeling of PCB's and arsenic and feels that the model can address this situation. | dev45 |
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. | dev45 |
As is the case with most projects of this nature, answers to some questions cannot be addressed until we begin the process. | dev45 |
It appears that the next step in this process is to have Mike Terraso contact Michael Adewumi. | dev45 |
David Roensch and I will be available to feed technical and operational information to Adewumi for his modeling input. | dev45 |
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. | dev45 |
By working through the process, we may be able to alleviate some potential concerns and increase the cleaning success. | dev45 |
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. | dev45 |
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. | dev45 |
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. | dev45 |
The Laguna's have hired an environmental person to oversee environmental issues on pueblo lands. | dev45 |
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. | dev45 |
Transwestern provided a history of the above mentioned activiites and why these issues were unresolved in the "eyes" of the Laguna. | dev45 |
Transwestern committed to submitting closure requests for the UST and asbestos issues. | dev45 |
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. | dev45 |
Transwestern assured the Laguna environmental representative that all correspondance and data pertaining to environmental issues would be submitted to the pueblo agency. | dev45 |
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. | dev45 |
The meeting provided Transwestern and the Laguna's with the opportunity to meet and share ideas and opinions and initiate working relationships. | dev45 |
The Laguna's now have an understanding of the environmental activities at the site and what Transwestern's approach is to removing the contaminants. | dev45 |
The Laguna's appreciated Transwestern's efforts and commitment to environmental compliance on the Laguna pueblo. | dev45 |
Jim, yes you will need a USGS | dev45 |
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. | dev45 |
It would probably be a good idea to check on the emissions status of the Whites at the same time. | dev45 |
The state of Texas conducted an air quality inspection of the NNG Seminole C/S. | dev45 |
There were no deficiencies or violations identified at the facilit during the inspection. | dev45 |
The State of New Mexico Air Quality Bureau conducted an inspection of the Transwestern Atoka No. 3 C/S. | dev45 |
The Agency conducted a record review and did portable emissions testing of 3 of the 5 emissions units at the facility. | dev45 |
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. | dev45 |
The State of New Mexico Air Quality Buureau conducted an inspection of the Transwestern Atoka No. 2 C/S. | dev45 |
The agency conducted a portable emissions testing of the two turbines and one recip at the facility. | dev45 |
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. | dev45 |
The agency requested sulfur readings from the fuel gas as required under Subpart GG NSPS for the last twelve months. | dev45 |
The Artesia team has contacted Gas Control in Houston for the for the monthly sulfur values at the facility. | dev45 |
Leo, my computer has fouled up and I wasnt sure you got this so Im sending it again..... | dev45 |
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..... | dev45 |
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). | dev45 |
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. | dev45 |
These DAILY records include measurements on Saturdays and Sundays. | dev45 |
3) The measurement must be taken at the location. | dev45 |
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. | dev45 |
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. | dev45 |
Approval of a CFMS allows a greatly reduced recordkeeping and reporting for nitrogen and sulfur. | dev45 |
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. | dev45 |
Until issuance of a CFMS, an applicable facility is required to continue daily sampling for nitrogen and sulfur. | dev45 |
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. | dev45 |
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. | dev45 |
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