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Data gathering and correspondance continues with the third party lawyer for the NOV issue at the P-1 C/S.
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This involved a like for like replacement of a turbine in New Mexico.
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Annual blanket renewal requests were submitted to the Texas SHPO and the Arizona F&W.
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A permit be rule has been submitted to the TNRCC for the like for like I/C engine replacement at the NNG Reagan Co 2 C/S.
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The EOTT tank database is 90% complete.
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Field verification with each team will begin to determine compliance with recordkeeping, fees, NSPS and air permit status.
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Air permits for the EOTT facilities in New Mexico were copied from the agencies records.
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Compliance status will be determined for these facilities also.
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John some quick thoughts on agenda items for the meeting with PG&E: 1.
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Status of the mini filter separator installations at PG&E interconnect/delivery/receipt points?
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Future thoughts/plans for additional separator installations.
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2.
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PG&E customer attitudes about potential PCB introduced into their equipment.
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Any new customers with positive hits of PCBs?
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3.
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Internal sampling activities.
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How far have PCB's spread into the PG&E system.
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(wipe tests results versus liquids collections).
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A map would be nice depicting this.
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4.
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Transwestern continues to be pretty much dry on mainline and extremely dry on the Topock lateral.
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Maybe we should have a little presentation showing liquids collected in the last year on the mainline and Topock lateral.
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Our commitment to keeping the PCBs as immobile as possible.
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5.
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We might consider sharing what we've learned from our PCB modeling study with Penn State and what our future plans are.
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Another Tranwestern effort to show our commitment.
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John, if we plan on opening up our separator, has a decision been made to decon it or just clean out the hydrocarbon buildup and replace the filters.
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If we do decide to decon our separator and or theirs, we will need to line out a contractor to be onsite when we blow down the systems.
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Id like to discuss possibly not using Vector for this type of routene activity any longer.
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There is a company in Farmington, NM (Riley) that can probably do the job.
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As you know, this decon work is not rocket science and Vector is $$$$$$$, although they do a good job.
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Chew on these and if I think of any other additional topics, Ill send them your way.....By the way, Earl Chanley is now in Roswell.
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FYI in case you plan on asking him to attend the meeting........
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In the final phase of developing and determining environmental compliance for the EOTT crude oil tanks in the Midland Region, I have planned a one day site visit on the following days to visit each team location to finalize the spreadsheet for EOTT crude oil tank environmental compliance: Hobbs team August 6 8:00 am Lovington team August 7 8:00 am Jal team August 8 8:00 am Eunice team August 9 8:00 am I would appreciate one member from each team be available at the team office on the assigned day and time to discuss tank history and possibly visit each tank farm within the teams area of responsibility.
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Your patience and assistance in finalizing this information will be greatly appreciated.
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If a conflict arises, give me a call at (505) 625-8022.
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Travis, Count me in on Cozumel.
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I received from the TNRCC an NOV letter for the above facility for failure to submit an emissions inventory for 2000.
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This notification from the agency originally came to Rick Loveless by way of Wayne Brunette.
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I called the TNRCC and spoke to Kevin Cauble concerning the NOV and he pulled the emissions inventory submitted in 1999 for the facility.
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Because VOC's are the issue, I asked him what the emissions were for VOC's on the 1999 inventory.
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Kevin stated that the inventory showed VOC emissions of 19.50 tons/yr actuals and 33.56 tons/yr potentials.
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We discussed why EOTT would submit an inventory as it is not a major source and not required to.
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The only thing we could come up with is that EOTT may have anticipated an increase in throughput at this site and therefore, wanted to ensure that this facility was shown as a title V source.
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According to the phone records from the TNRCC for this facility, Craig Willoughby of Entrix had requested that the faciltiy be kept on the list of facilities required to do inventories.
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I have a call into EOTT to determine whether increased throughput is proposed for this facility in the near future.
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In speaking with Kevin, he suggested that if a determination is made that if there is to be an increased throughput that wont exceed the 100 ton/yr limit on VOC's, or that throughput conditions remain approximately consistent with previous years, EOTT should provide written notification to the agency that this facility does not meet the applicability requirements of 101.10 (emissions inventory requirements) and request that this facility be removed from the TNRCC mailings.
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Should EOTT confirm the status of operating throughput to be below the 100 ton/yr VOC emissions limit, I will make make written notification to the TNRCC requesting removal from the list.
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John, I was just thinking that if this deconning becomes a routene activity for us and PG&E, we might want to consider breaking in a company that is less expensive, can more quickly mobilize and get the same quality work product.
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Vector, has to travel from Ohio.
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Deconning the separators becomes an internal washing job of the vessel.
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I will discuss this with Tiny about possibly using someone else.
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Tiny, do you think Riley would be interested in tackling this issue for us and PG&E?
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As you know, they do not have a deconning permit from the EPA, but with the new PCB rules in place, a permit is not necessary anymore to do deconning activities.
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How do you think PG&E will respond to us possibly using another contractor other than Vector for the work.
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I suppose we can bring this issue up in Flagstaff.
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Mums the word on the PCB modeling issue, John.
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Thanks for your guidance and thoughts.
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A meeting was held with the third party attorney who is providing assistance with the recently issued NOV for the P-1 C/S over a like for like turbine exchange which occurred in 1996.
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A history was given of the incidents which led up to the NOV being issued and results of the meeting which Transwestern had with the AQB in 1996 which lead Transwestern to believe that issue had been resolved.
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The calendar year 2000 PCB annual document logs were prepared and submitted to each generator of PCBs on the Transwestern system.
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Training was given to the Midland Region over the correct completion and submittal of forms used to report natural gas releases to the TNRCC.
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The agency has updated and has become more stringent with respect to Regional requirements for the reportable releases which are submitted to them.
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An incomplete form submittal by a compressor station facility near MIdland led to this emergency training being given.
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Based upon a phone call with Region 7 of the TNRCC, the agency stated that they will be issuing NOV's to facilities that submit incomplete "Upset/Maintenance NOtification Forms for Reportable Events".
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A newly revised rule (Subpart HH) has just been implemented by the EPA concerning curde oil tanks with a daily throughput of equal to or greater than 500 bbls.
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per day.
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If there is any tank within your teams area of responsiblity which equals or exceeds the 500 bbls.
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per day throughput criteria, please provide to me the following: tank name/serial number tank size average daily throughput Thanks for your help in this matter....
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I just spoke to the state of Arizona concerning the tree removal at Station 2.
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Their response to our request to remove the trees has been APPROVED, provided that this is the only pre activity we do prior to receiving the air permit.
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This means that no other construction or preparation activities can be performed or conducted untill the air permit has been issued.
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This approval also includes stump removal if need be......
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As you may know, we are at the end of our grace period for not being required to do monthly sampling for the public water systems at sta.
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3,4 and 5.
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Jeff Lobstein has been requested to do the monthly drinking water sample collections at each of the three compressor station and has three months completed.
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This memo is a reminder that each location is again required to send their drinking water analytical reports to the following agencies on a monthly basis as the analytical results are received at each compressor station.
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Stations 3 and 4: each months reports are to be sent to the following 2 agencies: Navajo Nation EPA Window Rock, AZ 86515 Atten: Yolanda Barney Program Manager US EPA Region IX 75 Hawthorne Street San Francisco, CA 94105 Atten: Danny Collier (WTR-6) Station 5: your water sample reports are to be sent to the Navajo Nation EPA in Window Rock, AZ, only.
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In speaking with Charlie, he has indicated that he will be handling the reporting for Station 4 also.
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I have contacted Nortest in Flagstaff (520) 774-2312, which is the lab selected to do the testing to send station 3 reports to station 3 and station 4 and 5 reports to station 5.
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The Navajo Nation has been given primacy and will be taking over the drinking water program for the Navajo Nation in November of this year.
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Expect some changes in reporting.
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Youmay want to use MCS as a monthly reminder for the submittal of the reports.
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Questions, give me a call 505 625-8022..
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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.
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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.
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Adewumi was asked about the simultaneous modeling of PCB's and arsenic and feels that the model can address this situation.
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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.
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As is the case with most projects of this nature, answers to some questions cannot be addressed until we begin the process.
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It appears that the next step in this process is to have Mike Terraso contact Michael Adewumi.
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David Roensch and I will be available to feed technical and operational information to Adewumi for his modeling input.
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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.
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By working through the process, we may be able to alleviate some potential concerns and increase the cleaning success.
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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.
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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.
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please remove from list.
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thank you.
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The Air Quality Bureau conducted an agency inspection of C/S's 7 Mountainair and 8 Corona.
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There were no deficiencies or items of concern identified by the inspector.
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Facility records were copied from the Air Quality Bureas files in Santa Fe for the P-1 C/S.
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