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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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Based upon submitted discussions it was decided to dispose of the turbine, compressor and auxillary box as a PCB contaminated waste and move the contaminated articles to a PCB landfill.
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The quarterly Transwestern/SoCal PCB management committee mtg was held via conference call.
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Invoices and charges were discussed which So cal had charged to their management and handling of PCB's on their system.
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At 86%, Transwestern's responsibility was $71,208.61.
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Clearances were received from the F&W and SHPO for the additional areas for the powerline transmission corridor of the Gallup C/S which is in progress.
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A custom fuel monitoring request wqas submitted to Region VI EPA for the Installation and testing has been initiated on the precombustion chambers for the Superiors at the Atoka No. 3 C/S.
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While fabrication is in progress for the correct chamber, temporary Waukesha chambers were installed.
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Even though the chambers were not of the correct size and configuration, a 12.5% fuel savings was achieved and emissions were reduced by over 56%.
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The correct chambers will be available and installed sometime next week.
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Mike I wanted to give a short update on the latest events related to the PCB issue with PG&E.
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Transwestern met with PG&E this last Wednesday with an agenda that included some sharing of sampling results collected downstream of their first C/S (Topock) and on out west toward their main distribution areas.
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With respect to the most recent sampling data, Low PCB concentrations (N.D. to 38 ppm) have been detected in drips and interconnects between Topock and Hinckley C/S.
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The good news is that PCB's have not been detected downstream of Hinckley which is approx.
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160 miles from the Topock C/S.
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PG&E has also initiated construction and installation of some drips and small separators at locations where their gas feeds into other lines or directly into customers.
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the proposed installation date for the large mainline filter separators is still on target for 6/1/00.
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Now for the bad news.
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At the conclusion of the meeting, PG&E has stated that they want their Topock C/S decontaminated.
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This includes all piping and equipment.
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I stated to them the impractabibility and zero success rate of removing all the PCB's from their system and that there would be no quarantees that the deconning would be successful.
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The contract PCB deconning companies only have permits which would guarantee cleanup to 10 ug.
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They were told that it would be impossible to clean everything and that in all probability the PCB concentrations would be showing up as the gas continues to move through the system.
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Additionally, the better remediation approach would be to continue to remove PCB containing liquids at strategic locations.
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Even with this, they were pretty insistent that their management wanted the facility cleaned.
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Preliminary $$ estimates range to approx.
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3-5 million.
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I think that this is only the "tip of the iceberg".
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If they are successful with this action, the pipeline system will be next.
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Their pipeline is not piggable and to make it such would require replacement of pipe, valves etc. Ill keep you informed on this,,,,,,,
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Michael, our liquids data collections have been pretty lean.
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Its only been in the last couple of months where we have actually collected any arsenic data.
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I will send to you what data have have with respect to arsenic, including some historic reserch in the Abo field of southeast New Mexico where the arsenic is generated from down hole.
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The source is not so much from what is coming out of the wells (catalyst towers were installed in the late 80's to trap the arsenic) as the residual which has collected in the pipeline prior to the installation of the catalyst towers.......
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As a reminder, the state of Texas requires releases of natural gas greater than 119 mscf to the atmosphere (in a 24 hour period), to be reported to the Regional Offices of the TNRCC.
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These releases include but may not be limited to the following: ESD's, startups, shutdowns, pipeline ruptures and maintenance activities.
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Should any of the above activities release natural gas in excess of 119 mscf, a written notification should be faxed to the Regional Office of the TNRCC within the following timeframes: Unanticipated Upsets- within 24 hours after the discovery of the upset.
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Maintenance, Startup or Shutdowns- 10 day prior to the expected exceedance.
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This reminder is being sent to all ET&S teams within Texas because in the last two Northern Natural Gas compressor station inspections conducted by the TNRCC, they specifically requested backup data and reporting documentation of the natural gas releases to the atmosphere which were greater than 119 mscf.
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The agency's inquiry specifically addressed knowledge of compressor station venting for ESD, start ups and shutdowns.
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It should also be mentioned that there has been inconsistencies in the TNRCC's position regarding this issue.
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However, until a position has been adopted by Enron's GPG, I am recommending that each facility comply and report as appropriate.
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The fax numbers for the following Regional offices are as follows: Midland (915) 570-4795 Included facilities- Wt-2, Walton, Keystone, Lone Star Valero, Spraberry, Seminole Lubbock (806) 796-7107 Included facilities- P-2, Plainview, Brownfield San Angelo (915) 658-5431 Included facilities- Reagan Co. 2, Irion Co. 1, Reporting forms for the release can be faxed to your location by request by contacting me at (505) 625-8022.
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Just a short note to let you know that I received a call from Rod Bosche of PG&E apprising me of a meeting PG&E will be having with SW Gas this tuesday.
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They will be discussing PCB issues and the sampling results from the PG&E system.
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From discussions with Louie, a media statement is being prepared by them which Louie has a copy of.
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The statement is a little harsh and makes some statements which are incorrect.
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Louie and I are planning to attend this meeting in Las Vegas to possibly assist in making some suggestions about rewording their statement and provide some additional insight and history on the Transwestern system with respect to PCB's.
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The results of this meeting will be forwarded at a later date.....
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Steve, you have been given all the written permit history and portable analyzer correspondance from myself to and from the State of New Mexico.
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All of my air permit files were copied and sent to you previously.
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If there is confusion, I apologize but everything that has been agreed to by the State of New Mexico has been made available for review and use.
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If I need to sit down with you and or others to go over this, let me know.
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Steve SanMiguel
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No. thank you
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Mike, I spoke to Ralph and he gave me an open week of April 17th in San Francisco.
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He thought that one day would be more that adequate.
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I need to have somebody contact the PG&E side for their availablity during that week.
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Should I or someone else contact Rod Bosche or let Louie do this from his end with our legal contacting their legal?
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Some of the highlights that I had requested to Ralph for his presentation was the following: PCB's are a contaminant, just as benzene is, which occurs naturally in the gas.
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Health issues of PCBs in pipeline are not a concern especially from a customer and employee standpoint (the name PCB lends itself to public outcry of the unknown) Removal of PCB's is best accomplished by managing liquids, not deconing Fiilter separators are a proven method of PCB removal Transwestern's proactive assistance with SoCal on their system to manage their PCBs Most pipelines on the east coast have PCB's and no adverse environmental impacts have occurred Michel Nelson
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A meeting was held with the Roswell Team at C/S No 8 discuss roles and responsibilities of the Title V Operating Permit for the Corona C/S.
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The sale of the TW Crawford C/S has been cancelled.
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A permit revision was requested to the Air Quality Bureau to transfer the new permit to the existing facility to keep intact the ability to conduct turbine power unit replacements without agency notification.
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Preparations are in place for the forthcoming meeting between PG&E and Transwestern over PCB issues on their mainline.
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Analytical shows that the PCB's are continuing to move further downstream into their system.
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Ralph Komai, with SoCal, will make a presentation concerning SoCal's experience with PCBs on mainline and LDC systems and present it during the 4/20 meeting in San Francisco.
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The annual certification for the Atoka No. 3 C/S was reveiwed for completion and submitted to M. Nelson for signature.
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Michael, we may have to petition the teams for theri analytical
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Rich, this is the public notice for the groundwater remediation at the TW North Crawar facility.
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Because we are emitting emissions to the air from the contamination in the groundwater, we had to have a permit.....
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Larry, as per our conversation, presented below are the emissions factors provided by the state of Colorado for the T-7000 Centaur under permit TSP 14.000/MMSCF NOx 0.100/MMBTU CO 0.121/MMBTU VOC 0.0348/MMBTU Formaldehyde 0.00438/MMBTU As you already know, the emissions factors for the Centaur 50H turbine under permit 97LP0885 can be found on page 5 of this permit which was issued on Remember, the state has given us until May 19 to have the rolling emissions calculations completed for both turbines at the facility.
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George/Norm because there is no immediate concern or liability with the partially filled excavation, I want us wait for the official letter from the tribe before taking it upon ourselves to fill the excavation.
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I dont want to send a message to the Lagunas about us taking environmental matters into our own hands without involvement from the tribe.
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If there is a reason to expidite the covering of this open area, then lets send another letter requesting to do so.
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Given the other issues yet to be resolved at the station, lets keep the tribe involved and a part of our environmental activities.
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I want to maintain a good working relationship with these people.
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As you may remember, they were a little irritated by Transwestern's neglect of not keeping them in the loop previously.
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Lets not open that type of issue again......
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