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After that meeting, I will decide who should do the applications.
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I have calls in to the person I deal with in the EPA in San Francisco for the two locations on the Navajo lands.
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Pending the outcome of each meeting, I will decide who to use.
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Ive used Argent in the past for both Arizona permits and Indian lands permits, and they would probably be my first choice.
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I am keeping Mr. Ayers involved in the permitting process and all changes or activities that impact the permits for Arizona.
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One thing that I shold mention is that I spoke with Phil Lowery about his desires for this project.
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He has requested that the existing units at each station maintain operations for six months after the turbines have been installed to act as a backup in the event that the turbines temporary fail or to iron out any potential kinks.
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Based upon the reduction in emissions from the existing mainline units, which will be permitted for a six month period, there will still be an overall major emissions decrease.
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After the six month period, the existing units will be abandoned in place and not be operated again.
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Also, my intent is to permit these turbines at 45 ppm NOx as opposed to the lower 25 ppm NOx number to eleminate the problems that were originally encountered on the Northern Border system.
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If this was a new station, I probably wouldnt be allowed to use the 45 number, but seeing as how there will be a major decrease in emissions from shutting off the recips and using the turbine, this should be easy to do.
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The differrence in emission between 45 and 25 is not that great and it will allow the facilities in Az a larger range of operation comfort as opposed to the 25 ppm number that Rolls says they can do, but has had trouble reaching.
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One thing that has complicated the permitting is the elevation and temperature extremes at the locations.
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By permitting at 45 ppm, this will greatly help this.
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Ill share the emissions numbers with you, when I receive them from Rolls and the emissions info I have from the existing units.
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I have spoken to Terry Hacket about doing the F-1 document for the FERC submittal, and have been feeding him data and supporting information for the report.
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Based upon the scope of work for the turbine installation, the F-1 report will be completed by March 1.
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Is there something Ive missed?
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With respect to the September 13, 1999 letter from Richard and Oreane Garcia concerning pipeline integrity and noise issues, Transwestern Pipeline Company offers the following response: Pipeline Integrity.
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With the construction of the evaporation ponds over Transwestern's right of way and pipline, Transwestern has closely monitored the potential for impacts for the pipeline.
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This includes a more frequent inspection of the pipeline conditions underlying the ponds by taking potentiometric readings to verify that corrosion is not present.
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Transwestern has also installed rectifiers to assist in eleminating the potential of pipeline corrosion.
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As a DOT requirement, Transwestern has cathodically protected the entire pipeline system with an external pipeline coating to further ensure the integrity of the pipeline underlying the evaporation ponds.
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The pipline safety measures implemented by Transwestern are designed to not only identify corrosion iimpacts to the pipeline system at the inception of detrimental impacts as a result of corrosion, but also allow for long term stability and integrity by conducting state of the art monitoring and detection.
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Noise Issue.
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In the initial environmental assessment and study, Transwestern conducted baseline surveys of the area to determine existing noise levels.
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This study was completed to assist Transwestern in the mitigation measures which will be implemented after construction of the Gallup Compresso Station.
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Pending completion of the facility, Transwestern will conduct post noise studys to determine whether facility noise levels have increased above those levels mandated by FERC.
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In the event of operational noise levels exceeding the FERC regulatory level of 55 ldn, Transwestern is committed to performing any and all mitigation measures necessary to ensure that the post noise level of the facility will not be above the level mandated by FERC.
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Decrepancy of trailer park residents.
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In the letter by Mr. Garcia, it was stated that Transwestern's assessment of the number of residences in the adjacent trailer park was not 18 as had been stated in our original study, but "more like 35 trailers".
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The number of mobile home residences currrently in the trailer park may in fact be closer to 35.
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Transwestern's trailer park residence count was taken in the winter of the year when the fluctuating job market is normally down and the number of residences in the park was low.
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The transient nature of mobile home residences and the fluctuating job economy of the area is probably a direct reflection of the up and down nature of the residences.
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It should also be noted that during the time that the trailer park count was made, the owner of the trailer park who is also the operator of the evaporation ponds was experiencing major difficulties in the operation of the ponds and raw sewage had overflowed the pond embankments and had resulted in the raw sewage ponding in the yards of many of the trailer park residents.
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It was actually noted that many of the spaces normally occupied by mobile homes had been vacated.
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This unsanitary condition was also identified by the New Mexico Environment Department.
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The NMED had implemented enforcement actions against the trailer park owner.
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This is a gentle reminder, and Im sure that most are aware, but under no circumstances is there to be any construction activiy initiated for the turbine installation at the four mainline compressor stations, until the air construction permits are issued by the applicable air agency.
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Construction activity is defined, but is not limited to roads, trenching activity, buildings, electrical poles etc. The state and federal agencies take a very dim view on initiating any attempts to initiate construction prior to approval.
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This approval is considered to be the air permit authorizing construction of the proposed activity.
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Your assistance in this compliance issue will be greatly apprecaited.
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Data generation and agency consultations are now in progress to expidite the permit submittals.
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Should you need further clarification, give me a call (505) 625-8022 or via e-mail.
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Thanx, George.
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Please let us know what their initial reaction and evaluation is of the conditions at Sta.
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6.
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Im interested in what their thoughts are with respect to the remediation of the sandstone fractures and movement of condensate with PCB's..
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George Robinson
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Rich, thanx for the sampling update.
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Ill pass it along to the apropriate parties.
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A cursory look at the data shows it to be inconsistently up and down, as expected, with no glaring increases.
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Anything urgent we need to discuss?
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I wanted to let everyone know that the meeting between Southwest Gas and SoCal concerning presence of PCBs on the Southwest Gas system will be this tuesday.
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I had an opportunity to speak with Ralph Komai today during the PCB quarterly management conference call that Transwestern has with SoCal to discuss PCB related invoices.
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As a brief summary, Southwest has had isolated hits of PCB in liquids (232 and 132 ppm) and in wipe tests (10-100 ug/wipe) in regulators on their system and they have asked Ralph if he would assist them in the management and disposal of PCBs on their system.
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He wil also be providing thoughts on how and why PCBs move in a gas pipeline.
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I had asked Ralph not to mention about Transwestern's agreement with SoCal for which Transwestern pays SoCal for 86% of their PCB costs.
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I had asked him to only focus on the Southwest system.
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Apparently Southwest is not up to speed with the PCB regualtions, however, enough so that they do realize that the mega rule will impact their operations and Ralph will probably provide input for that as well from an LDC standpoint.
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I asked Ralph whether Southwest seemed excited or worried about the PCB discovery on their system and he indicated that they were more concerned about compliance with the PCB regulations.
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Ralph said he will let me know the results of the meeting.
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go to page D-6 for the capital loss carryover worksheet.
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Mr. Stewart, as per you voice mail request to me on Feb. 20, 2001, attached is the correspondance concerning the reqeust to replace the mixing valves with carbuerators at the Northern Natural Gas, Spraberry Plant.
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The players in this activity included Jon Fields of Argent Consulting.
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Due to the fact that the pre testing data for the emissions from the mixing valves and the post testing data for emissions from the carbuerators were received in hard copy only, I am not able to provide this as an attachment.
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This data was, however, sent to you via fed-x on January 24, 2001.
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If needed, I can resubmit the results of the data for your review.
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As expected, the emissions levels did decrease when the carbs were installed.
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Please reveiw the attached correspondance concerning the request to replace the mixing valves at the Spraberry Plant (TNRCC account No. ML-0022-W) with carbuerators without requiring involvement of a permitting activity.
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Thank you for your consideration in this issue.
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Mr. Stewart, as per your voice mail request on Feb. 20, 2001, attached find the correspondance relating to the request of replacing the existing mixing valves with carburetors at the Northern Natural Gas, Spraberry Plant.
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In this discussion, Jon Fields of Argent Consulting was involved.
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I have attached for your review the letter requests from Northern to you and the e-mails which were traded back and forth from yourself and Argent.
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The results of the pre testing emissions with the mixing valves on and the post testing of the emissions with the carburetors on were mailed to you on Jan. 20, 2001.
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The testing results were compiled in hard copy form and are not included with this submittal, but can be resubmitted if requested.
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Your favorable request in this replacement activity is requested.
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Arnold, I think I will pass on the meeting.
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Please apprise me of anything I may need to know from the meeting.
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To bring you up to date on the environmental events of the turbine approvals in Arizona, I received the rough draft of the baseline noise survey and you were copied.
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As discussed, we should address changes to the documents as the contractor has made some obvious conclusions and asumptions which are not valid or representative of what we would like to do or not do.
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I was contacted by the Navajo Nation and they have requested that we do onsite surveys at the C/S on the reservation (C/S 3 and 4) for T&E plants and animals and archeology.
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I have contacted a contractor and they will be on site to do the surveys at both stations.
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I am planning on having the entire C/S facility surveyed at both locations as there has not been a pin point location established as yet for all the construction and ground disturbance which will take place.
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In the event there might be changes after the survey is completed, surveying the entire facility will keep us from having the new distrubance areas surveyed after the original survey was completed.
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The F-1 environmental document for the FERC application will be submitted to Donna by this friday.
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The air permit applications for C/S 1 and 2 have been started.
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I have a meeting with EPA in San Francisco to discuss permitting the C/S facilities on the reservation on 3/20.
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Im going to try and move this meeting up if possible.
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After the meeting, I should be able to have an application in front of the Navajo air permitting agency and the EPA within a week.
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Based upon experience with the state of Arizona, EPA and the Navajo Nation, expect permit approval within 5-7 months after submittal of the application.
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I was just informed by the Navajo Nation that prior to receiving approval from the agency fo rthe installation of the turbines, an archeology survey is to be performed at each compressor station site.
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Be advised that an archeologist will be present at sta.
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3 on 3/ 9 this friday in the am and at sta.
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4 on 3/12 monday also in the am to conduct the required surveys.
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Please have someone from each team present at each location during the surveys and allow access to the facility by the archeologist.
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The survey should only last 3-4 hours.
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Donna, I spoke to the Navajo Nation about expiditing the report submittal once the archeological surveys have been completed and the Nation said that under their current regulations, assuming that there are no cultural resources identified at either location, they are allowed 30 days to review the findings before they are required to issue the final report.
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She didnt think it would take this long, but said that due to existing surveys back logs, and personnel, it might.
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Ill keep the pressure on.
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