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Let me know and we can do this at one of their safety meetings.......
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David Roensch
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Kermit Team, I received a letter from the TNRCC concerning emissions fees that have not been paid for a facility called the "Hendrick/Wink Tank Farm".
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The letter was addressed to a Mr. Paul Newman of EOTT.
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The letter stated that we may owe emissions fees for the facility.
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My question is, do you have such a facility in your team area, and what does it comprise?
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ie..number and size of tanks, throughput in 2000.
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The TNRCC letter was dated March 28, 2001 and we are required to provide information to them within 30 days.
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I just received the letter today.
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HELP!!
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I need something from you by this afternoon or tomorrow at the latest.
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Kermit Team, I really need your assistance on this.
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I received a notice from the TNRCC about the above facility.
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Apparently, the emissions fees for the facility have not been paid for 2000.
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In light of this, does this facility exist in your area of responsibility?
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Please let me know.
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If so, I need the follwoing information ASAP to aviod an NOV for the facility.
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Size of each tank height and capacity Number of tanks Color of tank(s) and roof(s) fixed or floating roof if floating, internal or external primary or secondary seals how is tank loaded and or unloaded ie trucks, pipeline etc...
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Relative vapor pressure if known monthly throughput maximum fill rate of tank how long does it take to fill tank
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Alison, have you found out anything about the above referenced?
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The deadline for submitting the FY 2001 emissions fee is April 30.
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The TNRCC can levee a fine on the facility if we dont provide them with some informaiton pretty fast.
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Your assistance in this will be appreciated.
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Alison, better send me what you have via fed-x or fax (505) 627-8172.
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I have spoken to Bill about this.
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We need to send a check to the agency to cover ourselves prior to the April 30 deadline.
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I beleive that EOTT is responsible for paying the fee.
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I have left a message with Larry Fensted and his associate Ruth Ann and expressed the need for the $416.00 check by 4/1.
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I am sending this notification to your department to seek a solution of halting and stopping inappropriate e mail materials which I am receiving.
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I have been requested by Louis Soldano, Enron attorney for the Gas Pipeline Group, to apprise you of this situation.
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The content of materials received, I consider offensive, and am sure it would also be considered objectionable and innappropriate by the standards of Enron Corporation.
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Please be advised, that many times it is difficult to screen this material based upon the headings and titles that accompany the contents.
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Consequently, innappropriate materials such as this are opened.
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I have accidently opened two such e mails by mistake and have received the "Enron warning" that my name and mailbox will be or may be audited in the future and that my name has been placed in a file.
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Because of this, I am extremely uncomfortable about future accidents occuring and more importantly, about the increased frequency and accessability of my e mail box to trash and questionable materials.
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I would appreciate your immediate attention in this matter.
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Thank you very much.
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Randy, this is a short summary of the environmental findings that were identified during the records review conducted at the Corpus Christi Koch facility offices on May 1st and 2nd of this year.
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All environmental records which were available in the file data room at the Koch office were reviewed.
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Assumptions were made that the environmental records were complete for all assets included in the sale.
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Primary emphasis was placed on those environmental issues which are normally associated with a sale or purchase of assets dealing with distribution and transmission of crude oil.
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In particular, pipeline and tank farms were the most critical assets which were reviewed.
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Based upon the data review, the Koch assets were in compliance with the following: Air permitting, permit by rule, standard expemtions, recordkeeping and fee payments were documented NSPS recordkeeping and inspections for VOC control on large crude oil tanks were documented Oil Pollution Act-OPA 90 plans had been prepared and were up to date SARA compliance and reporting had been completed SPCC plans had been prepared for each site which qualified under 40 CFR 112 Spill reporting history and notifications to the state agency were available for review There are ongoing groundwater and soil remediation activities at one site included in the asset for sale (permits for the remediation activity is in place) Hazardous waste notifications, annual reportings and fee payments were documented Based upon the above review, there were no issues which could be identified which would be condsidered a major environmental limitation or would be a considered a major environmental liability.
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This statement is again based upon the assumption that all environmental information was present in the data room for the assets in question.
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It should also be stated that this analysis of Koch's environmental compliance is based upon the fact that Koch has not held back or provided false or misleading information or knowledge during their presentation or informaiton contained in the facility files.
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Pending further development and interest of this potential purchase, a recommendation is made to conduct a phase I due diligence and site visit to each location to verify findings from the records review.
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Also, due to the past history of Koch's operating practices, it is recommended that contract conditions be implicitly stated that EOTT will not be held liable for discoveries of past deficiencies or releases of contamination which have occurred on any of the Koch assets purchased.
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On behalf of EOTT, an environmental records review was completed for a block of Koch crude oil pipeline assets located in south Texas.
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There were no issues or environmental deficiencies identified during the review.
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A due diligence was recommended to verify confirmation of the housekeeping activities presented in the records review.
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The air permit modification for the La Plata C/S was received from the state of Colorado.
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This modification allows for additional emissions and fuel use as a result of a change in gas quality supplies in the San Juan basin.
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Butch, you may want to attend this
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Shudeish, the buildings and stack heights for each of the Flagstaff And Kingman Compressor Stations are presented below.
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Building and stack demensions (in feet), are as follows: FLAGSTAFF length width height Port a Camp 40 10 10 Let me know if you need anything else.....
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Randy, based upon the records review, this is the only issue that may be aproblem.
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If a tank has been moved to another location, it would trigger requirements which were enacted on the date of the relocation.
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For instancif a tank constructed prior to 1973 was moved in 1978, there would be emissions control requirements placed on the tank as required by the 1978tank regulations.
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If the tank had remained at its original location, it would be grandfathered with respect to emissions.
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However, because the tanwas relocated, it is looked upon as being a tank constructed in 1978 and subject to the 1978 regulations and is no longer grandfathered.
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I was not given this information during the records review, so I dont know if any of the tanks apply.
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If any of the tanks fit into the above scenerio,EOTT or Koch will be looking at some major $$$$$ to bring any subject tankinto compliance.
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Generally speaking, the regualtions and costs to complyincrease as a function of date.
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1.
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Q. Of the tanks listed on the spreadsheet, have any of the tanks been relocated from its original construction locations?
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List the tank, date moved and location moved to.
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A. Benevides Station Tank 6125 and Mirando Station Tank 28591 were relocatto those stations.
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Three Rivers Tanks 28508 and 28100 were relocated andre-erected at that station.
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Duval Station Tank 28052 and Mirando Station28045 were relocated and re-erected at those stations prior to Koch,sacquisition of those assets.
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Arnold, I have attached a spreadsheet showing what information I need to complete the air permit applications.
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I have set the Flagstaff site as the model, due to its elevation and temperature which is the worst case site.
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Let me know if there are any problems with the attached data request.
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Scott, I have sent out twice a request to each of the field teams in the Midland Region to provide some desperately needed tank information to determine compliance for all the EOTT crude oil tanks in the Midland area.
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So far, only the Midland, Lovington, Kermit, Andrews, Hobbs and Jal teams have responded.
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I would appreciate your assistance in motivating the remaining seven teams to get this information to me at their earliest convenience.
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I have attached the most recent update of the tank spreadsheet for you to pass on to the teams.
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Thanks for the help.
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Hazardous waste fees were submitted to the state of Arizona.
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Emissions fees were submitted to the state of New Mexico For C/S's 7,8,9, Atoka No. 3 and Bloomfield.
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Submitted to the state of Texas an admisistraitve revision for the "like for like" replacement of an IC engine at Irion Co. No. 1 C/S.
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To meet the requirements of 2 gms for NOx, a catalytic converter has been installed on the replacement unit.
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Submitted to the state of New Mexico notification of a "like for like" replacement of an I/C engine at Atoka No. 2 C/S.
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A revised Title V application was submitted to Region VI, EPA for C/S No. 6, Laguna.
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The emissions inventory for the TW Keystone C/S was submitted to the state of Texas.
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The spreadsheet development for the EOTT tanks in the Midland Region has slowed down.
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Six of 13 teams have responded with tank information.
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A request was made to Scott Clark, Regional Director, to assist in notifying the teams of the importance of submitting this data.
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Louie/Ed I know you guys are busy, but because of the emphasis Enron places on ensuring that action items from consolidated audits are completed prior to the action item completion date, I really need to know how Scott and I are to proceed on the subsurface drilling activities for potential contamination at the Bakersfield Fractionator.
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The scheduled completion date for six of the items is 6/30.
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I understand the there is an issue concerning Koch's individual and shared responsibility for some of the issues identified during the audit.
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Rich Jolly has contacted me asking me when the drilling will begin, as he does not want to see us exceed the 6/30 date and have the items show up as deliquent in his region.
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Whatever you can do to assist us in either initiating the investigations or placing a hold on the drilling would be greatly appreciated.
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Ed, I would appreciate it very much if you would review the action item list from Scott Jones and choose which items are Koch's responsibility and which items belong to EOTT, and let Scott and I know.
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Ill contact Scott and have him send you the action item list for your review.
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As I had previously mentioned, Scott and I have until 6/30 to complete the subsurface investigations and knowing which items are EOTT's and which are Koch's would greatly help us.
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As Scott's server is down, Ill phone him and have him send you the action item list.
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Again Thanks very much.
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Under the regulations of the state of Arizona, facilities which have a pollution prevention plan (sta.1, sta. 2 and Needles) are required to have an annual training to evaluate pollution prevention activiies.
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I have scheduled with the above three facilities to have pollution training on the following dates: Kingman team June 21 Flagstaff team June 22 This training is to be completed by July 1 of every year.
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This training will last for approximately 2-3 hours.
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