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market_relations@nyiso.com writes to the NYISO_TECH_EXCHANGE Discussion List: Dear Market Participants: Due to forecasted high loads, the NYISO Back-Up Dispatch test scheduled for Tuesday, August 7, 2001, will be cancelled.
A future date will be determined at a later date.
If you have any questions, please call Customer Relations at 518-356-6060.
| NYISO Back-Up Dispatch Testing CANCELLED |
The Executive Committee of the New York State Reliability Council ("NYSRC") is posting this message to inform all interested parties of the ability to attend in person or participate, on a "listen-only" basis, in the NYSRC Executive Committee's Meeting No.
29 scheduled for September 14, 2001, starting at 10:00A.M.
at the Albany Country Club in Guilderland, NY.
Attached in Word format is the Agenda for this meeting.
Also attached please find directions to the Albany Country Club.
The NYSRC has opened its Committee, Subcommittee, and Working Group meetings in accordance with NYSRC Policy No.
2, which is available of the NYSRC web site at "www.nysrc.org", on the "Policies" web page.
Those who plan on attending the meeting in person are requested to contact me at least four (4) days in advance of the meeting (by at least September 10th) by sending me an email at "jcfleury@nyseg.com", with the names of the individuals & organizations attending.
Meeting space will be available on a first-come, first-served basis due to the space limitations of the conference rooms.
Those wishing to participate on a "listen-only" basis can call (304) 345-7506, and enter Participant Code 903712, starting at 10:00 A.M.
Participants will be required to place their telephones on mute so as not to prevent other parties from participating.
Those who plan on listening to the meeting shall send an email to my attention at "jcfleury@nyseg.com" with the names of the individuals & organizations participating.
Attendees who are not NYSRC Executive Committee Members or Alternate Members will be given an opportunity to comment at the end of each meeting, or earlier at the Chairman's invitation.
| NYS Reliability Council Executive Committee |
scheije@selectenergy.com writes to the NYISO_TECH_EXCHANGE Discussion List: I apologize for the larger circulation of this email than to just the S&P WG.
The MC last week urged a rapid consideration of the interactions between BME and SCD and their related prices from the hot, high load days of July 24 and 25.
To pursue this there is additional information needed from the ISO.
Below is a preliminary list I compiled that would be useful in assessing the situation.
Data should be provided for relevant hours i.e.
those with high BME or RT prices or both.
Particularly for those hours with binding reserve constraints in HA or RT.
1 RT reserve levels in each hour (it is recognized that the value fluctuates but the the point is to get an idea of apporximately how short the ISO was of reserves, if at all) 2 Similar information should be obtained for our neighbors; PJM, NE and IMO.
Also, could the ISO describe what the others do hour ahead to prepare for the next operating hour under circumstances such as we encountered those two days?
NY has the unfortunate position of producing prices related to decisions for which it pays otherwise - what were our neighbors doing?
3 An accounting, by hour, of reserves carried on exports out of NY 4 Identification of any non-ICAP based exports that may have been counted for reserve; this shouldn't happen as it puts non-ICAP providers in the position of being recalled... 5 BME reserve deficiencies by hour; were the reserve levels always met, albeit at extreme prices, or was the ISO unable to cover the requirements in advance?
6 Based on Mike Calimano's report, there were "a couple hundred Mws" of operating units not seen by BME; this situation needs to be (1) confirmed and (2) explained and corrected The following are sort of 2nd tier questions: 1 If the ISO was short of reserves in RT why weren't the EDRP resources, who were notified, not called into play to aid in curing the deficiency?
There should have been no economic judgement call by operators (if the first two hours were at $500 that was likely cheaper than what BME was taking in if the BME prices applied to settlement under ECA B).
BME made no judgement call when its prices spiked due to the 30 M NSR scarcity and took available imports.
2 What would have been the System State(s) if the reserve margins had been held in RT (assuming ISO was short in RT)?
Would this have forced a Major Emergency and subsequent voltage reductions, public appeals etc?
Had this been done would have the EDRP Mws been activated?
I would also like to offer the following as potential changes to be considered.
They are based on the limited discussions that have taken place so far.
1 Include exports that are being counted as reserve in BME as it evaluates its reserve position.
Since BME is deciding which transactions will be scheduled, operators would need to indicate which transactions and how many Mws could be counted in RT as reserves.
The implications for the solution algorithm are unclear - can BME recognize the additional reserves thus carried?
Would it result in fewer imports and lower BME prices?
What if the reserve requirements used as input to BME were manipulated downward for reserves on exports?
What happens if BME did not schedule the export(s)?
2 Subject to the ISO providing detailed RT reserve info, it seems that the reserves should be carried in RT and that SCD should not be allowed to dispatch with units that were not available to BME (thus resulting in the large price disparities).
If the ISO had adequate reserves in RT, SCD should not be allowed to produce RT price reductions relative to what BME is doing.
However, having said this, if there are no energy resources to maintain reserve levels AND the ISO needs to maintain its regulation room, the next thing to go is load.
To my long understanding, we do not shed load to avoid shedding load (at least not to maintain reserves...) Perhaps if BME has some adjustments and the missing Mws are accounted for, little needs to be done in RT.
(This does not mean that SCD handles GTs correctly - that is still a commit problem it is incapable of resolving...) 3 At one point, we had approved use of BME prices to settle all HA transactions.
This approach was scuttled by the ISO when they discovered that there were persistent, unidirectional price differences between the proxy busses and their connected in-NY zones.
We then retreated to automating what is done under ECA B; substituting BME prices only under constrained ramp or ATC conditions.
The ISO should review this again.
Does the price difference remain, inviting gaming?
If so, is there a way for the MMU to watch for or prevent inappropriate opportunistic behavior?
A full, partial 3rd settlement would lessen the sting of HA prices that are out of synch with RT.
4 The ISO should review the multipliers in the LP solution that insure that energy, then regulation and then the 3 types of reserve are maintained.
They should be no more than required for a proper solution outcome.
Prices at $65000 are not necessary and misleading (while mathematically correct...).
Also, if we are to consider settling transactions at BME prices, such an outcome would result in considerable opposition... 5 Another non-controversial change would be to extend the DADRP participants to hour ahead evaluation.
In the instant circumstance, it is likely that BME would have chosen some of those loads opposed to imports (there was no congestion so some of those western loads might have looked pretty good...).
Since there is the issue that the DADRP is subsidized, I would propose that, if extended to BME, that the DA bids be used for BME evaluation.
If nothing else look at it as sending money to companies in NYS.
Jim
| S&P Mtg re: BME/RT Issues |
DDechiaro@nyiso.com writes to the NYISO_TECH_EXCHANGE Discussion List: THIS IS TO CONFIRM THAT IS MEETING WILL TAKE PLACE ON MONDAY, AUGUST 13, 2001.
Marty Amati is requesting a Special BSP Subcommittee Meeting on Monday, August 13, 2001.
The meeting will be to consider and hopefully approve an Interim Credit Policy to support the Virtual Bidding Program.
In order to support implementation of the Virtual Bidding Program on November 1, 2001, it is Critical that the related Credit Policy in Support of Virtual Bidding be filed with FERC by August 31, 2001.
Following are the details for the meeting:
| NYISO - Budget, Standards and Performance Subcommittee SPECIAL Meeting - 8/13/2001 - CONFIRMATION OF DATE |
DCongel@nyiso.com writes to the NYISO_TECH_EXCHANGE Discussion List: Market Participants: New advisory statements for April 2000 have been posted to your secure web sites as of 8/4/2001.
The reason for the update is due to a printing error in the previous version for LRR Uplift charges.
Some of you may have had problems getting the LRR dollars in line with what you were invoiced due to this printing error.
It is important to note that the bills were NOT re-run, just re-printed.
| April 2000 Advisory Statements |
PSC Staff has asked us to poll our active Marketers to determine who might be EDI compliant and has been utilizing EDI transactions such as enrollment, drop, historical information and current usage.
The goal here is to find suitable partners for testing EDI transactions that are scheduled to become effective at the end of this year.
If your company is currently actively using EDI and is interested in testing with KeySpan in the next several months, please forward me the proper contact person in your organization along with their telephone number.
Thank you.
Mike
| EDI Testing |
RBowers@nyiso.com writes to the NYISO_TECH_EXCHANGE Discussion List: The NYISO will be posting invoices later today for the initial settlements of July 2001 and the 1st settlement adjustments of July 2000, August 2000, & March 2001.
Transmission Customers will observe the following adjustments to their settlements.
Adjustments have been made to Transmission Customers' invoices to recover the costs related adjustments made to customer settlements outside of the billing process and to adjust the NYISO clearing account balance to zero for each month invoiced.
Prior to October 2000, the NYISO recovered or refunded differences in the revenue received from Schedule 1 charges, which were comprised of forecasted uplift & residual adjustments, and the costs actually incurred by adjusting subsequent month's Schedule 1 rates accordingly.
In October 2000, the NYISO implemented a change in the tariffed Schedule 1 provisions that allowed the recovery and refund of these costs as they were incurred.
In order to allow any changes in uplift and residual adjustments to be settled through the settlement adjustment process, the code implemented in October 2000 was used to report these costs to the market.
This results in an over-collection which is being returned to Customers through an adjustment to their monthly balances.
This billing treatment for July 2000 and August 2000 settlement adjustments resulted in credits to the market totaling $7,700,605.23 and $32,146,310.55, respectively.
Customers where paid their share of these adjustments based upon their respective ratio shares of NYISO load for each month.
This adjustment provides for the settlement of all accounts in the market in the month(s) the costs or over-collections were realized and adjusts the NYISO clearing account balance impact to zero for each month.
Adjustments have also been made to Transmission Customers' invoices to recover the costs related adjustments made to customer settlements outside of the billing process.
These adjustments totalled $964,548.42 for March 2001, $375,110.49 for July 2000 and $48,973.41 for August 2000.
Customers where allocated their share in these costs based upon their respective ratio shares of NYISO load for each month.
Regards,
| Adjustments to 7/2000, 8/2000, & 3/2001 Settlement Adjustment Invoices |
Please note the attached letter from Nancy Cianflone.
The intent here is to let you know that KeySpan Energy Delivery has hedged 27% of our flowing winter supply.
This was done in order to mitigate any spikes in this winters market.
You may want to take this into account when pricing your winter contracts.
Mike - Hedge1.doc
| KeySpan Hedging |
DCongel@nyiso.com writes to the NYISO_TECH_EXCHANGE Discussion List: Market Participants: In the early evening hours on 8/8/2001 the NYISO inadvertently ran a billing job for 7/16/2001.
This created a version 5 of the bills for this billing date.
Version 5 is not valid, all customers should use version 4 when reconciling their advisory statements to their invoice.
| July 16 2001 Advisory Statements |
8/7 - DEAL 722269, TRANS ID 5079112 DELETED HE 23 FOR 100 MW.
NY OR PJM SHOWED MW FLOWING FOR THIS HOUR.
8/7 - DEAL 722272, TRANS ID 5062820 DELETED HE 23 FOR 100 MW.
NY OR PJM SHOWED MW FLOWING FOR THIS HOUR.
| 8/7/2001 HE 23 |
Dear Enron Employees: I'm sorry to report that a third Enron employee has died in the hospital as a result of injuries from yesterday's explosion and fire at Teesside Power Station.
To lose another employee is a devastating blow to all of us.
A fourth employee remains in the hospital and is in stable condition.
Please keep these employees and their families in your thoughts and prayers.
We will release their names as soon as all family members and relatives have been notified.
I'm in the U.K. now and will be visiting with the employees and families who've been affected by this tragic accident.
I will also visit the site and will meet with authorities in order to determine the cause of the explosion.
I will keep you posted on any new developments.
| Teesside Update |
Dear Market Participant, Technical Bulletin # 73 - Payment for uninstructed over-generation from off-dispatch generating units - is being distributed for Market Participant comment.
The Technical Bulletin will be posted to the NYISO web site following the comment period.
The purpose of our Technical Bulletins is to facilitate participation in the NYISO by communicating various NYISO concepts, techniques, and processes to Market Participants before they can be formally documented in a NYISO manual.
Please forward comments on this Technical Bulletin, via email, by 5PM on Thursday, August 16, 2001 to: Peter Lemme NYISO Customer Technical Services plemme@nyiso.com (See attached file: TB73.pdf) - TB73.pdf
| NYISO - Technical Bulletin # 73 - Payment for uninstructed over-generation from off-dispatch generating units. |
Dear Larry, Off Season Savings!
What's the best way to save money on your vacation?
Book through Travelocity.
What's the second-best way to save?
Book off-season.
Airlines, hotels, and even cruise lines often lower their rates when their peak seasons are over.
This means bigger savings and smaller crowds for you.
Read more about how to plan your trip to take advantage of seasonal savings, from Europe to Australia and Hawaii--and more.
Destination Guides Make Reservations
| The Insider from Travelocity.com |
eSource Presents Free CountryWatch Training This class will provide an introduction and overview of the CountryWatch product offerings and services including Country Reviews, Country Wire, CountryWatch Data and Business Services components.
Identify how Enron employees can use the CountryWatch products in order to satisfy country-specific research and business needs.
Attend one of our CountryWatch Sessions: August 13 1:30 - 2:30 PM EB5C2 August 13 2:45 - 3:45 PM EB5C2
| CountryWatch Training |
The cancer journey is sometimes lonely and frustrating for both those suffering with the disease and those providing care.
But it can also be a time of friendship, personal growth, humor, and fulfillment.
Please join Marlene Lockey, Sr. Social Work Counselor at MD Anderson Cancer Center on Wednesday, August 15, 2001 at 11:30 a.m. in the Forum in 2AC (12th floor) for a Brown Bag session on "Caring for the Caregiver."
Marlene has many stories to share, as well as many ways to cope with the challenges of living with cancer.
The presentation will be followed by an audience discussion, so please bring your questions and experiences.
Contact Laura Herrera -laura.herrera@enron.com - if you would like to attend.
| "Caring for the Caregiver" - MD Anderson Brown Bag" |
Interested in learning more about the fun and convenience of on-line stock trading?
Join EFCU for our On-Line Stock Trading Brown Bag.
WHO: Joel Spry of Star Financial Network will discuss the basics of on-line trading and EFCU's trading program.
WHEN: Friday, September 14, 2001 11:30 - 12:30 WHERE: EB 5C2 RSVP: joy.wagman@enron.com Refreshments will be provided.
| On-Line Stock Trading Brown Bag |
barkerde@nmenergy.com writes to the NYISO_TECH_EXCHANGE Discussion List: It appears that the NYISO , who has obviously been allotted two HAM mulligans for each reliability period, used them yesterday for the HB 16,17 Zonal HAM results.
Cool!
I particularly admire the part where they just quietly left them out figuring that you wouldn't notice 1300,1400.1500, 1800,1900 .
resent after 1/2 hr delay if you get this twice
| 8/9/01 mulligans |
barkerde@nmenergy.com writes to the NYISO_TECH_EXCHANGE Discussion List: It appears that the NYISO , who has obviously been allotted two HAM mulligans for each reliability period, used them yesterday for the HB 16,17 Zonal HAM results.
Cool!
I particularly admire the part where they just quietly left them out figuring that you wouldn't notice 1300,1400.1500, 1800,1900 .
| Mulligans for Aug 9 |
DCongel@nyiso.com writes to the NYISO_TECH_EXCHANGE Discussion List: Market Participants: In a billing inquiry sent to us concerning the June 2000 adjustments made per the email below, which was sent on 7/10/2000, we noticed an incorrect value was stated for the NYISO clearing account balance prior to adjustment.
That value was $7,831,072.52.
The value should have been $7,262,238.10, and this has caused problems for reconciling your invoices.
| May & June 2000 1st settlement adjustment invoice banking instructions |
Please be advised that the KeySpan Energy Delivery deadline for September enrollments is Tuesday, August 21, 2001 at 1:30PM (NY time) and the deadline for drops is Thursday, August 16, 2001 at 1:30PM (NY time).
We strongly recommend that you process your transactions as well in advance of these deadlines as possible.
Key Span will not accept any transaction beyond these dates.
Transactions that are rejected and resubmitted subsequent to the deadline dates will not be accepted.
Your cooperation in complying with this request is greatly appreciated.
Thank You,
| September 2001 Enroll/Drop Deadline |
Please make note of the following: 1:30pm CT - Staff Meeting - CANCELLED 2:30pm CT - Safety Meeting - CANCELLED.
If you have any questions, please give me a call.
Thank you,
| Staff meetings cancelled today |
Enron Energy Services has one single entry point for all customer leads and service issues - The EES Business Center.
Your assistance is requested in routing all retail customer calls to this center.
The Business Center can manage general customer service requests or provide information on EES product offerings.
The number for the EES Business Center is 800-337-7837 (800-EES-SVCS) or internally, calls can be transferred to x59390.
E-Mail address is: EESBusinessCenter@enron.com Thank you for taking the time to route these calls appropriately.
Your assistance is critical to Enron's customer acquisition success and to ensure our customers' satisfaction.
| Routing of Calls to EES Business Center |
jcfleury@nyseg.com writes to the NYISO_TECH_EXCHANGE Discussion List: The Executive Committee of the New York State Reliability Council ("NYSRC") is posting this message to inform all interested parties of the change in starting time for the Open Session of the NYSRC Executive Committee's Meeting No.
28 on Friday, August 17, 2001, to 10:30A.M.
at the Albany Country Club.
Those planning to participate on a "listen-only" basis can call (304) 345-7506, and enter Participant Code 903712, starting at 10:30 A.M.
Participants will be required to place their telephones on mute so as not to prevent other parties from participating.
| NYS Reliability Council Executive Committee |
It is with regret that I have to announce that Jeff Skilling is leaving Enron.
Today, the Board of Directors accepted his resignation as President and CEO of Enron.
Jeff is resigning for personal reasons and his decision is voluntary.
I regret his decision, but I accept and understand it.
I have worked closely with Jeff for more than 15 years, including 11 here at Enron, and have had few, if any, professional relationships that I value more.
I am pleased to say that he has agreed to enter into a consulting arrangement with the company to advise me and the Board of Directors.
Now it's time to look forward.
With Jeff leaving, the Board has asked me to resume the responsibilities of President and CEO in addition to my role as Chairman of the Board.
I have agreed.
I want to assure you that I have never felt better about the prospects for the company.
All of you know that our stock price has suffered substantially over the last few months.
One of my top priorities will be to restore a significant amount of the stock value we have lost as soon as possible.
Our performance has never been stronger; our business model has never been more robust; our growth has never been more certain; and most importantly, we have never had a better nor deeper pool of talent throughout the company.
We have the finest organization in American business today.
Together, we will make Enron the world's leading company.
On Thursday at 10:00 a.m. Houston time, we will hold an all employee meeting at the Hyatt.
We will broadcast the meeting to our employees around the world where technically available, and I look forward to seeing many of you there.
| Organizational Announcement |
Larry........Deal 729346, NY trans id 5079112, NY is showing that HE 14 was 78 mw not 100.
I made changes to enpower for deal 729346.
Marci........For PJM the deal is 729345 and enpower is showing 100 mw as well for you.
Could you please check to see what amount PJM is showing for this hour.
| 8/13 |
IMPORTANT MESSAGE!
PLEASE READ THIS MESSAGE!
FILENET SYSTEM OUTAGE AUGUST 17 - 19, 2001 All users will NOT be able to access the System after close of business on Friday the 17th and we anticipate users having full access on Monday morning August 20th.
The FileNET System is scheduled to be down for maintenance to start upgrade process to IMS 3.5.
This upgrade will be done in several stages, the first stage being the Oracle database.
For this upgrade all batches scanned or imported into queues must be cleared from the FileNET System by Friday, August 17th at noon.
If you have any questions or concerns about this outage, please feel free to call the Help Desk @ 713-853-1555 Option #1
| Scheduled Envision System Outage |
DCongel@nyiso.com writes to the NYISO_TECH_EXCHANGE Discussion List: Market Participants: On 8/12/2001 at ~1700, the billing date of 7/05/2001 was incorrectly re-run and printed to the web creating a version 6.
This version has been removed from the web, and version 5 has been restored.
We apologize for any confusion this may have caused.
| July 5, 2001 advisory statement |
Dear Larry, When was the last time you got a weekly car rental for $110?
Or spent a night in luxury for $100--in the Bahamas?
Have you ever gotten money
| Real Deals From Travelocity.com |
To: All Enron Houston Users Subject: New Dialing Instructions Ref: Tie Line Access Code Changes - Enron Building Phone System Effective Saturday, August 18, the access code for remote locations will be modified within the Enron Building phone system to reflect a standard utilized by all Enron phone systems.
The modification will change the first digit dialed when accessing the tie lines by using the Alternative Routing feature from 7 to 8.
As all other Enron phone systems currently access the tie lines with the digit 8, the change from 7 to 8 will only affect users who reside in the Enron Building.
All other Enron phone system users should note that several digits of the tie lines to London, Calgary, and Portland have changed.
What This Change Means To You Effective Saturday, August 18, you must replace the first digit 7 with an 8 when accessing the tie lines.
Additionally, several of the digits to the London, Calgary, and Portland tie lines have changed.
All other digits of existing access codes will remain the same.
For your reference, a list of the new dial strings for remote locations is identified at the bottom of this message.
Please Note: This change also means that any Auto-Dial buttons you use to call associates at remote locations will now have to be re-programmed.
Such buttons may be programmed on conference room phones and FAX machines in your area.
To re-program an Auto-Dial button: ?
Press the Menu button on your soft keys ?
Press the Program button on your soft keys ?
Press the Auto-Dial button you wish to program ?
Dial the new Dial String (as identified below) ?
Press the # key REVISED DIAL STRINGS FOR ENRON TIE LINE NETWORK Users must dial 8 digits to call via Tie Lines
| New Dialing Instructions |
Larry: HE 13 EDT - Original deal made for 50 MW @ $82.20 - Hourly P&L notes deal was cut at 12:15 and therefore only 13 MW flowed as confirmed by PJM data - Tag review indicates flow started at 12:15 and ended at HE 13 (38 MW flow) - Settlements is requesting this be revised back to 50MW @ $60/MW - I need input from you regarding this deal to determine the action required.
Please provide any helpful info you have as soon as possible.
HE 10 EDT - Just an FYI that the purchase price was changed to $41/MW from $42 at the request of Exelon to our Settlements group.
I went ahead and changed it due to the low value and because it is in our favor.
If you disagree with this or have any questions, please let me know.
Thanks,
| 705512.1 - 07/24/01 |
"Robb, Kathy" <KRobb@hunton.com> writes to the NYISO_TECH_EXCHANGE Discussion List: Howard Fromer, chair of the ICAP Working Group, has asked that we cancel the ICAP Working Group meeting scheduled for next Tuesday, August 21, because it conflicts with the RTO mediation, which he and others involved in the ICAP Working Group are attending.
In addition, the Tuesday, September 11 meeting is cancelled and will be rescheduled for some time in September that does not conflict with the RTO effort.
If you have any questions, please contact John Charlton at the NYISO, Howard Fromer, or me.
Many thanks.
| ICAPWG Aug 21 MTG CANCELLED |
Dear Larry Campbell: Datek is now offering call writing1 to qualified and approved option-trading customers.
Materials developed by the Chicago Board Options Exchange discuss the risks associated with call writing .2 In addition to call writing, Datek plans to offer writing puts, spreads and straddles to qualified, approved customers in the months ahead.2 Click here for more information on option trading at Datek.
Please remember that trading options is not appropriate for all investors.
Click here to access Characteristics and Risks of Standardized Options.
Sincerely,
| Account Service Notice: Call Writing Available at Datek |
Hello everyone, Not as many upsets this past weekend in the college and pro games.
Among the games that were commonly missed were, in the college games, Auburn/Georgia and Iowa/Northwestern; in the pros, Green Bay/Chicago, Miami/Indianapolis, and Oakland/Seattle.
Going into tonight's game, we have 4 people still alive for the money.
Larry Campbell, Dave Ryan, Kayne Coulter and Joe Quenet, all who missed 4 games.
Dave, Kayne and Joe picked Baltimore and Larry picked Tennessee.
Therefore, if Tennessee wins, then Larry will win outright.
If Baltimore wins tonight, then it will come down to total points scored.
Dave picked 24 points, Kayne has 29 and Joe had 56.
Dave will win with Baltimore and 26 or less points, Kayne will win with Baltimore and between 27 and 42 points, and Joe will win with Baltimore and 43 or more points.
We only had 22 entries this weekend, therefore the prize will be $66.
This coming week's games will be handed out tomorrow and due Thursday afternoon, since I will be off this Friday.
Here are the results from the games with the amount of games each person missed.
Andy Larry Campbell 4 Dave Ryan 4 Kayne Coulter 4 Joe Quenet 4 Paul Broderick 5 Joe Brewer 5 Joe Step 6 Robert Vargas 6 Andy Pace 6 Jacob Shupe 6 Rick Broussard 7 Clayton Vernon 7 Bryce Schneider 7 Gerald Gilbert 7 Dean Laurent 7 Carter Ellis 7 Daniel Jenkins 7 Diana Allen 7 Mauricio Trujo 8 Michele Wilks 8 Rudy Acevedo 9 Ashish Mahajan 12
| results of the football pool |
Byron as per the Red Rock expansion conference call today presented below are the emissions estimates for the auxillary engines at sta.
1-4.
Understand these are not actual emissions, but are emissions based upon potential to emit.
When these units were permitted actual testing data was not required, so each unit was permitted based upon an accpeted emissions limit from an EPA approved document.
This has worked out in our favor as the emisisons numbers presented in the EPA document were high, therefore, this will allow us to net more emissions, if needed.
Emissions are presented for a single engine only in tons per year, even though there are two auxillary units at each facility except Sta.
1 where they only have one auxillary unit.
Sta.
1 1- Waukesha 350 Hp LRZ NOx 30.48 CO 121.94 VOC 1.31 Sta.
2 2- Waukeshas 350 Hp LRZ NOx 30.48 CO 121.94 VOC 1.31 Sta.
3 2-366 Hp PSVG Ingersol Rands NOx 35.35 CO 30.40 VOC .04 Sta.
4 2-450 Hp Waukeshas F3520 GU NOx 43.46 CO 37.38 VOC .05
| emissions levels for the auxillary units 1-4 |
I spoke to John Nystedt, the contact person for the Navajo Nation F&W service concerning the need to do endangered plants and animal surveys at the two C/S on reservation lands.
I had sent to him the USGS quad sheets of the C/S sites for review.
Today he stated that he didnt think surveys would be needed at either location due to the fact that there had been historic disturbance at each location and that there was no sensitive habitiats in or near the C/S sites which would warrant surveys.
However, because of the issue of tribal lands, he was going to discuss this issue with the Navajo Nation director and verify his opinion and he would let Transwestern know on Monday of next week as to what the Tribes final decision would be, but he was almost sure that the Trib would recommend no surveys.
John has faxed to me the list of approved botonists and boilogists which are approved to do work on the reservation.
I have contacted a number of individuals on the list and they are prepared to do the boilogical surveys next week in the unlikely event a survey is required.
| F&W Issue on the Navajo Lands |
I spoke with Ralph Komai, PCB person with SoCal, concerning the SWG meeting about PBCs on the SWG system.
As mentioned in the last note, SWG has discovered PCBs and has been sampling to determine extent and movement into their system.
SWG receives gas from SoCal and PGE at two separate and independent interconnects.
Liquids have been collected at the two interconnects from SoCal at concentrations of <500 and <100 ppm, respectively.
They have taken approx.
100 wipe samples and have had "hits" but nothing over 100 ug per wipe.
In the meeting, SWG has expressed aggressive interest to SoCal about the installation of filter separators at the SoCal/SWG interconnects.
They felt that the installation of separators would greatly benefit the reduction of PCBs into their system.
Becasue of this, Ralph stated that SWG would be sending him a proposal for the installation of separators at the two interconnect locations.
I gave Ralph Earl Chanleys phone number as he was involved in the separator construction project last summer with PG&E.
| Additional Noters on SoCals Meeting with Southwest Gas over PCBs |
John, Bill this is the latest on the environmental issues for the turbines in Arizona.
The arch surveys at stations 3 and 4 on the Navajo reservation have been completed and nothing reportable was found or identified.
Each contractor is now preparing their reports and hopefully, will have them submitted to their mgt.
for review in a couple of days and then issued to TW.
The Forest Service has given us permission to do the arch survey for station 2 on Monday.
The arch survey for station 1 is scheduled for Tuesday.
Preliminary quotes for the surveys are $4-5000.00 for both sites.
The original word from them was 7-10 prior to giving approval.
This was definatley a plus.
Still no word on where the turbine buildings are to be located and what turbine equipment is to be installed at each facility.
GE or Rolls Royce.
Additionally, confirmed decisions have not been made as to what auxillary power will be installed at each location (wind, natural gas, diesel).
| latest on the Az Mainline Expansion |
I received a call from the consultant who performed the archeology survey at stations 1 and 2.
Based upon the plot plan provided by construction, the archeology discovery at station 1 does not occur within the area of proposed impact, even though part of the discovery is within the facility fence.
The report recommendation to the SHPO by the archeologist will be that during construction activities in this area, an archeologist be onsite to monitor and ensure that the site is not impacted.
They will also recommend that we fence the discovery area within our facility to ensure that future pipeline activities will not disrupt the site.
I have asked that two reports be prepared for each site.
One report for each station covering the construction areas and the other reports to include the entire 40 acres at each compressor station.
All four reports will be submitted to Bret Fritch in Omaha on Monday, the 26th of March.
| Station 1 Archeology Discovery |
Presented Title V training to the Flagstaff Team.
The training included responsibilities, recordkeeping and semi annual reporting requirements.
A meeting was held with representatives of Transwestern and PG&E to discuss activities related to removing PCB's from the Topock Lateral.
Sampling data was reviewed and discussions were held addressing past cleaning efforts.
PG&E has stated by letter and verbally that natural gas volumes will be decreased weekly until PCB concentrations fall below 5 ppm.
Transwestern will be implementing a pipeline cleaning of the remaining 1850 of pipe between our M/S and the PG&E C/S.
Included in this cleaning will be decontamination of the additional filter separators and meter runs.
Assisted in the compilation and data gathering of the Title V compliance monitoring and annual certification reports for C/S No.
5, Thoreau.
The annual blanket request for the Arizona SHPO was submtted for renewal.
Notification letters were submitted to the state of New Mexico notifiying the agency of like for like replacements of recipricating engines at the AToka No.
1 C/S.
Additional notifications were submitted to the agency apprising them of engine removal activities at C/S's No.
5 and 9 which would impact emissions fees.
| Weekly Activity Report |
Guys, look at the attached draft of a letter I plan on sending to the Laguna pueblo regarding Transwestern efforts to date of finding new technologies to address and remove PCB contamination from the groundwater at the facility.
You may remember, we had a meeting in January to hear the Laguna's concerns that Transwestern was not moving fast enough to clean up the site.
This letter addresses our attempts to find a solution to the PCB problem, and that remediation technologies are not presently available to operate effectively at the site given the sites unique characterisstics.
Id like to send this out on Friday or Monday.
| status letter, PCB contamination, Laguna C/S |
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".
The letter was addressed to a Mr. Paul Newman of EOTT.
The letter stated that we may owe emissions fees for the facility.
My question is, do you have such a facility in your team area, and what does it comprise?
ie..number and size of tanks, throughput in 2000.
The TNRCC letter was dated March 28, 2001 and we are required to provide information to them within 30 days.
I just received the letter today.
HELP!!
I need something from you by this afternoon or tomorrow at the latest.
| Hendrick/Wink Tank Farm |
Alison, have you found out anything about the above referenced?
The deadline for submitting the FY 2001 emissions fee is April 30.
The TNRCC can levee a fine on the facility if we dont provide them with some informaiton pretty fast.
Your assistance in this will be appreciated.
| Hendrick Wink Tank Farm |
I am sending this notification to your department to seek a solution of halting and stopping inappropriate e mail materials which I am receiving.
I have been requested by Louis Soldano, Enron attorney for the Gas Pipeline Group, to apprise you of this situation.
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.
Please be advised, that many times it is difficult to screen this material based upon the headings and titles that accompany the contents.
Consequently, innappropriate materials such as this are opened.
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.
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.
I would appreciate your immediate attention in this matter.
Thank you very much.
| Innappropriate E Mail Materials Received |
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.
All environmental records which were available in the file data room at the Koch office were reviewed.
Assumptions were made that the environmental records were complete for all assets included in the sale.
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.
In particular, pipeline and tank farms were the most critical assets which were reviewed.
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.
This statement is again based upon the assumption that all environmental information was present in the data room for the assets in question.
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.
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.
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.
| Environmental findings, Koch South Texas Records Review |
On behalf of EOTT, an environmental records review was completed for a block of Koch crude oil pipeline assets located in south Texas.
There were no issues or environmental deficiencies identified during the review.
A due diligence was recommended to verify confirmation of the housekeeping activities presented in the records review.
The air permit modification for the La Plata C/S was received from the state of Colorado.
This modification allows for additional emissions and fuel use as a result of a change in gas quality supplies in the San Juan basin.
| Weekly Report, Roswell Area |
Randy, based upon the records review, this is the only issue that may be a= =20 problem.
If a tank has been moved to another location, it would trigger=20 requirements which were enacted on the date of the relocation.
For instanc= e,=20 if a tank constructed prior to 1973 was moved in 1978, there would be=20 emissions control requirements placed on the tank as required by the 1978= =20 tank regulations.
If the tank had remained at its original location, it=20 would be grandfathered with respect to emissions.
However, because the tan= k=20 was relocated, it is looked upon as being a tank constructed in 1978 and=20 subject to the 1978 regulations and is no longer grandfathered.
I was not given this information during the records review, so I dont know = if=20 any of the tanks apply.
If any of the tanks fit into the above scenerio,= =20 EOTT or Koch will be looking at some major $$$$$ to bring any subject tank= =20 into compliance.
Generally speaking, the regualtions and costs to comply= =20 increase as a function of date.
=20 1.
Q.
Of the tanks listed on the spreadsheet, have any of the tanks been=20 relocated from its original construction locations?
List the tank, date=20 moved and location moved to.
A. Benevides Station Tank 6125 and Mirando Station Tank 28591 were relocat= ed=20 to those stations.
Three Rivers Tanks 28508 and 28100 were relocated and= =20 re-erected at that station.
Duval Station Tank 28052 and Mirando Station= =20 28045 were relocated and re-erected at those stations prior to Koch=01,s= =20 acquisition of those assets.
| Koch South Texas pipeline data room questions and answers |
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.
So far, only the Midland, Lovington, Kermit, Andrews, Hobbs and Jal teams have responded.
I would appreciate your assistance in motivating the remaining seven teams to get this information to me at their earliest convenience.
I have attached the most recent update of the tank spreadsheet for you to pass on to the teams.
Thanks for the help.
| EOTT tank database request |
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.
The scheduled completion date for six of the items is 6/30.
I understand the there is an issue concerning Koch's individual and shared responsibility for some of the issues identified during the audit.
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.
Whatever you can do to assist us in either initiating the investigations or placing a hold on the drilling would be greatly appreciated.
| Bakersfield Environmental Action Items |
Bill you may want to sit in on this if you have time.
It seems we have items of concern that were identified during the consolidated audit at Bakersfield which were tied into a previous agreement with Koch for which the action team did not know when the action items were prepared.
The action dates are approaching and Scott and I are having a hard time getting clearification on how to initiate getting the the action items started due to the responsibility of Koch for some of the items.
Ed, the attorney for EOTT, will be requested by Lou, to notify Koch concerning their responsiblity.
If this sounds convoluted, then you know as much as I.....
| Conference Call |
After reveiwing the documents entitled, "Baseline Environmental Investigation of Arco North Coles Levee Plant 8, Rogas Loading Facility and Associated Natural Gas Pipeline Systems Kern County, California" and "Report of Preliminary Asessment Sampling North Coles Levee Gas Plant Loading Rack Area Tupman, California", it appears that the following areas should be investigated further to detemine horizontal and vertical extent of identified contamination from the above referenced reports: Tank 15 area- total petroleum hydrocarbons Glycol reboiler area- total petroleum hydrocarbons Hot oil heater area- total petroleum hydrocarbons Wash rack area- lead Propane comp.
area lead total petroleum hydrocarbons chromates Cooling tower area- chromates Compressor area- BTEX chromates lead In the "Baseline Environmental Investigation" report, sampling was only conducted to an approximate depth of 2.5'.
I am not comfortable with basing decisions for further investigations on such a shallow depth, in leau of the fact that many times water soluble constituents may horizonatlly move vertically from surface shallow depths into the lower subsurface areas.
This is indeed the case for chromates.
I based my recommendations for metal concentrations on the federal RCRA Subtitle C hazardous waste target levels for metals and evaluated the TPH and BTEX levels with the underground storage tank guidlines for California.
There were references to a 1989 document in the "Baseline" report for specific parameters, but there may have been an update to target contamination level requirements since that date and therefore, I used 10,000 ppm which is a general action level for most states for total petroleum hydrocarbons.
Again, I did not evaluate the mercury or the loading rack issues.
One last issue.
As you know, identification of contamination is usually accomplished by sight observations of visible contamination, knowledge of processes and or history.
Report results of the surface contamination do not show there to be an immediate environmental concern.
Due to the age of the facility, there may be concerns which were not identified in the reports.
However, based upon the locations of the preliminary samplings which were conducted throughout the facility, it appears that the information presented in the reports would be adequate to address suspected contamination at the facility.
| Additional Soil Investigations, North Coles Levee |
I spoke with Ken Jacobs, with the Forest Service in Flagstaff, concerning his agencies approval for the turbine construction at Station 2.
As a condition of the approval from his agency, he has requested that all the ponderosa pine trees to be removed for the turbine construction activities be flagged for identification.
After the trees have been marked, we are to then contact him so that he can visit the site and make an evaluation as to whether the Forest Service will charge us for the tree removal or whether no additional charges will be incurred as a result of the construction activity.
The charges will depend upon the calculation of how many board feet of lumber there are in the trees which are flagged.
As this activity is included in the time line for completion of all permits and approvals, please contact me when the trees have been tagged and flagged and I will contact Ken Jacobs so that he can make a site visit.
| Tree Removal, Sta. 2 |
Bob, James, Roger, Im having a hard time getting a response from the teams in the Midland Region in completing the attached EOTT tank spreadsheet.
Ive heard from some of the teams but nothing from others.
Im under the gun as to finding out where the MIdland Region is in term of permits and and environmental compliance and the only way I can begin to make the evaluation is to have the field data inputed onto the spreadsheet.
This is where the teams assistance is required.
I have attached the latest version of the spreadsheet in the hope that you will deliver it to the following teams for their valued input: Monahans Team Hamlin/Haskel Team Lamesa Team Big Lake Team Midland Team Eunice Team Your assistance in this will be greatly appreciated.
| EOTT tank database spreadsheet |
In light of the recent PCB issue with PG&E on the Topock Lateral, I have asked Mr. John Woodyard of Roy F. Westin to c ome to Houston and make a presentation on PCB's in natural gas pipelines.
Mr. Woodyard has considerable experience in the management of PCB's and works closely in industry associations (INGAA and GRI), Mr. Woodyard also works as a consultant in this capacity.
The date of this meeting will be on Friday, September 3rd, beginning at 9:00 am.
Lou Soldano will be setting up a meeting room and will notifiy all attendees via lotus notes prior to the September 3rd meeting date.
I think this meeting will be very interesting and informative and and encourage all to attend, if possible.
| PG&E PCB Meeting with John Woodyard |
Eunice team, The NNG Eunice C/S is required to prepare and submit the semi annual and annual reports required by the facilities Title V Operating Permit which was issued by the State of New Mexico.
The reports are required to be submitted to the state of New Mexico and the EPA by July 19, 2001.
These reports are required even though the facility is not in operation.
If you would like assistance in the preparation and submittal of each document, give me a call and we can set up a time to meet at the C/S to do each report.
This should take about half a day.
| Title V annual certification and compliance monitoring report due date |
John, I just spoke with Dan Walker, Vice President of Development for the Rocky Mountain Elk Foundation about Enron's initiative for a corporation partnership.
After we had discussed our interest and desire and what opportunities are available with the Foundation for Enron, Dan stated that will be visiting with the Foundation's CEO next week and one of the issues to be discussed will be development of an MOU or Agreement between Enron and the RMEF.
Looks like things are beginning to progress.
Im having quite a bit of interest from some of the Houston based Enron employees about how they can get involved.
Any suggestions on how I can "advertise" opportunities within the Corporation for employee involvement with the RMEF?
| Rocky Mountain Elk Foundation Status |
Had a conversation with Dan Walker, V.P.
of Development for the Rocky Mountain Elk Foundation concerning Enron's future as a partner.
Dan will be meeting with the CEO of the Foundation to pursue actions towards an Agreement or MOU between Enron and the RMEF.
Interest has been surprisingly high for employees within and without GPG expressing a desire to be involved with the Foundation.
Assisted C/S No.
8, Corona with the development and submittal of the facility's Title V semi annual report and annual compliance certification report submittals.
Presented annual pollution prevention training for the Kingman and Flagstaff teams as required by the State of Arizona for large quantity generators of hazardous waste.
Received a Compliance Order from the State of New Mexico, Air Quality Bureau, for an outstanding turbine replacement activity at the P-1 C/S which occurred in 1996.
Transwestern had met with the AQB over this issue in 1996 and assumed that the issue had been resolved.
The issue in question was Transwestern's replacement of internal components from a smaller turbine to a larger turbine, with the internal components of the larger turbine components (inlet guide vane adjustment and removal of the regenerator) mechanically adjusted to simulate conditions of the smaller turbine.
When Transwestern received permit approval from the AQB to operate at the larger turbine capacity, Transwestern made the upgrade adjustments operable.
Apparently, EPA has mandated that the AQB act on all issues considered to be outstanding as determined by the EPA.
Dave Nutt has been sent the Compliance Order to review.
Under the conditions of the Order, Transwestern has 30 days to request another hearing.
| Weekly Environmental Activity Report-Roswell Area |
I dont know if you guys are doing this, but a requirement to your air permit states that the facility is to report the number of hours of operation each year to the Air Quality Bureau for the Catepillar generator.
The report is to be submitted by January 31st of each year.
If we need to discuss this, give me a call.
| FYI, Engine Hour Reporting, P-1 C/S |
The annual pollution prevention plans were completed and submitted to the State of Arizona.
These plans are requried for the three large quantity generators of hazardous waste in Arizona.
Annual hazardous waste fees were paid and submitted to the State of New Mexico for four facilities in New Mexico.
A conference call was held with Houston Legal and Environmetnal Affairs to discuss the alleged NOV issued for the P-1 C/S which involved a turbine like for like replacement activity.
Data has begun to be collected to substantiate Transwestern's position concerning the proposed action by the State of New Mexico.
A field trip was made to the Air Quality Bureau to copy all files relevant to the P-1 C/S and will be delivered to the contract attorney who will be assisting Transwestern with this issue.
Copies of the New Mexico EOTT air permits were received.
Comparisons will be made with the nearly completed EOTT tank database spreadsheet to determine status of permit compliance with each air permit.
| Weekly Environmental Acitivity Report Roswell ARea |
Be advised that there will be a meeting on Thursday 11:00 am August 23 at the NNG Turbine station, south of Kermit Tx.
to complete and submit annual certification reports which are required by the following Title V permitted facilities: Seminole Brownfield Plainview Spraberry Irion Co. No.
1 Reagan Co. 2 Eldorado Wt-2 Walton Keystone Kermit Turbine Should a team decide not to attend this meeting, be advised that the required submittal date for the annual certifications for the state of Texas is September 8, 2001.
It will be your teams responsibility to ensure that the certifications are submitted prior to the 9/8/01 deadline should you decide not to attend the August 23 meeting.
| Annual Certifications Reports Required by Title V |
Participated in the compliation and submittal of the Title V semi annual monitoring and annual certification reports for the NNG Eunice C/S.
Data gathering and correspondance continues with the third party lawyer for the NOV issue at the P-1 C/S.
This involved a like for like replacement of a turbine in New Mexico.
Annual blanket renewal requests were submitted to the Texas SHPO and the Arizona F&W.
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.
The EOTT tank database is 90% complete.
Field verification with each team will begin to determine compliance with recordkeeping, fees, NSPS and air permit status.
Air permits for the EOTT facilities in New Mexico were copied from the agencies records.
Compliance status will be determined for these facilities also.
| Weekly Activity Report, Roswell Area |
I received from the TNRCC an NOV letter for the above facility for failure to submit an emissions inventory for 2000.
This notification from the agency originally came to Rick Loveless by way of Wayne Brunette.
I called the TNRCC and spoke to Kevin Cauble concerning the NOV and he pulled the emissions inventory submitted in 1999 for the facility.
Because VOC's are the issue, I asked him what the emissions were for VOC's on the 1999 inventory.
Kevin stated that the inventory showed VOC emissions of 19.50 tons/yr actuals and 33.56 tons/yr potentials.
We discussed why EOTT would submit an inventory as it is not a major source and not required to.
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.
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.
I have a call into EOTT to determine whether increased throughput is proposed for this facility in the near future.
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.
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.
| Potential NOV letter from TNRCC to EOTT for Ozona Crude Station |
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.
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.
The calendar year 2000 PCB annual document logs were prepared and submitted to each generator of PCBs on the Transwestern system.
Training was given to the Midland Region over the correct completion and submittal of forms used to report natural gas releases to the TNRCC.
The agency has updated and has become more stringent with respect to Regional requirements for the reportable releases which are submitted to them.
An incomplete form submittal by a compressor station facility near MIdland led to this emergency training being given.
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".
| Weekly Activity Report Roswell Area |
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.
per day.
If there is any tank within your teams area of responsiblity which equals or exceeds the 500 bbls.
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....
| EOTT Crude Oil Tanks |
Bill, presented below is a summary of the Midland EOTT tank compliance=20 status verified by fax and telephone with the teams.
This information is 9= 8%=20 complete until actual onsite verification occurs, which is set up for the= =20 month of August.
I plan on visiting each team and tank in the Midland=20 Region.
However, until the site visits are completed, this should give you= a=20 good idea of the status of the EOTT pipeline tanks stand with respect to ai= r=20 compliance.
=20 1.
Tank compliance database, general.
The database, which included 366 tan= ks=20 at the onset, has been reduced to 106 EOTT P/L tanks.
Tanks operated by EO= TT=20 Trucking; non-EOTT tanks; tanks sold, removed, duplicated, or otherwise=20 listed in error, were removed (and saved in another file).
Of the 106 tank= s=20 listed, 80 are active, 12 are inactive, 10 are permanently out-of-service,= =20 and 4 are abandoned in place.
=20 2.
Permit issues.=20 Federal a.
Title V permit concerns do not appear to be a problem.
Electric pumps a= re=20 the norm at EOTT tank farms, so site emissions are exclusively from the=20 tanks and do not exceed 100 TPY.
(Only Crane Station has a Title V permit)= .
=20 This statement is based on =01&worst case=018 calculations using EPA TANKS = 4.0=20 which indicated that in a: 5,000 bbl fixed roof tank: 3.6 MM bbls of RVP 5 crude throughput (i.e., 7= 20=20 turnovers) produced annual emissions of 48 tons (2 tpy breathing loss, 46 t= py=20 working loss).=20 55,000 bbl EFR tank: 14.0 MM bbls of RVP 5 crude throughput (i.e., 255=20 turnovers) produced annual emissions of 9 tons (6 tpy breathing loss, 3 tpy= =20 working loss).=20 55,000 bbl fixed roof tank: 14.0 MM bbls of RVP 5 crude throughput (i.e.,= =20 255 turnovers) produced annual emissions of 4 tons (1 tpy breathing loss, 3= =20 tpy working loss).=20 State=20 b.
State permit concerns do not appear to be a problem.
Sixty-three (63) o= f=20 the 106 tanks were constructed before 1971 (and not modified or=20 reconstructed).
These tanks are grandfathered and require no permit as long= =20 as throughputs do not significantly change.
=20 All of the EOTT Texas tanks of any size constructed/modified/reconstructed= =20 after 1971 and equipped with a floating roof are exempt under Standard=20 Exemption 86, currently known as Permit-by-Rule 106.478.
None of the tank= s=20 store material with a true vapor pressure above 11.0 psia, and total actual= =20 VOC emissions authorized under exemption from any site does not exceed the = 30=20 TAC 106.4 limit of 25 tpy.
No registration for the exemption is necessary= ,=20 since the tanks are not located in a nonattainment county for ozone.
New Mexico=01,s permitting program for petroleum storage tanks is being=20 developed but, currently, there are no requirements.
Therefore, all EOTT= =20 tanks in New Mexico meet state permit requirements.
However, when finalize= d,=20 the control requirements for tanks in New Mexico will not be more stringent= =20 than the federal NSPS Subpart Kb.
Therefore, a tank equipped with a floati= ng=20 roof would be authorized to store petroleum product with a true vapor=20 pressure up to 11.0 psia.
Only the four fixed roof tanks at Maljamar and= =20 the one at Loco Hills could be affected.=20 4.
Recordkeeping and inspection issues.
The grandfathered tanks have no=20 requirements.
For tanks subject to NSPS Subpart K, only capacity data is=20 required.
Tanks subject to Ka and Kb require inspection, repairs if=20 warranted, and recordkeeping.
=20 Note: Especially for some of the older tanks, neither a manufacturer=01,s= =20 identification plate or=20 strapping table is available.
I would suggest that we pursue a records=20 search of old EOTT files to verify construction dates.
I dont know where t= o=20 start on this.
5.
Specific compliance/requirements summary.
The tabled information=20 identifies the following: Federal - 2 tanks (McElroy 58005, Loco Hills 4602) may not be meeting NSPS control= =20 requirements - 4 tanks (Maljamar 1519-1522) may not be meeting NSPS control requirement= s (All are cone tanks, subject to Ka/Kb.
Based on a capacity > 472 bbls and= =20 product true vapor pressure > 2.18 psia, the tanks require a floating roof = or=20 closed vent system); - 28 tanks at 18 sites are subject to NSPS K/Ka/Kb inspection and/or=20 recordkeeping requirements: K (recordkeeping of tank capacity, dimensions only): Foster 787, 790=20 Quito-Hendrick 58044 Sands 15089A Lynch 1511; Ka/Kb (inspection & recordkeeping): Burger 58018 (if returned to active status) China Grove 56007-56010 Garden City 56003 Haskell, N. 58509 (if returned to active status) Haskell, S. 58023 (and 58022, if returned to active status) McAfee 1523 McElroy 58005 Midland 1516 Scurry 1517 Wildfire 1524 Livingston-Ridge 68414 Loco Hills 4602, 68417, 68418 Maljamar 1519-1522 Sonora 1515 (if returned to active status) Thomas 68413 State - Crane Station has an emissions potential > 100 tpy and is therefore=20 required to remit a TNRCC emissions fee, due by 11/1 each year:=20 =20 10 sites are subject to an NSPS Subpart (i.e., K, Ka, Kb) and are therefor= e=20 required to remit a TNRCC emissions fee, due by 11/1 each year:=20 China Grove, Foster, Garden City, Haskell S., McAfee, McElroy, Midland,=20 Quito-Hendrick, Scurry, Wildfire; - 8 sites need a TNRCC account number from the Regional office: China Grove= , =20 Haskell S., McAfee, McElroy, Midland, Quito-Hendrick,=20 Scurry, Wildfire;=20 I have initiated the request to the TNRCC for account number for the above= =20 sites =20 - 4 additional sites which, if returned to active status, need a TNRCC=20 account number and are subject to a TNRCC emissions fee, due by 11/1: Burger, Haskell N., Sands, Sonora; - 3 sites that are not subject to a TNRCC emissions fee, but paid one last= =20 year: Adair, Hendrick, Ozona.
6.
Specific inspection requirements: Primary and secondary seal inspections= .=20 See Attachment A for list of tanks affected.=20 API Standard 653-based =01&In-service=018 inspection checklist.
Internal/External Floating Roof Inspection Report checklists.
Sketch and Calculation for Perimeter Seal Gap Measurement.
Comprehensive =01&Out-of-service=018 inspections are performed after the ta= nk is=20 cleaned and should=20 be budgeted at approximately $5000.
each.
This will include a thorough flo= or=20 scan but will not include required repairs.
=20 =20 ATTACHMENT A IFR/EFR Storage Tanks Seal Inspections For the tanks equipped with a floating roof and subject to Ka or Kb, the=20 following requirements apply: - Tanks with an IFR (internal floating roof) require an internal inspection= =20 every 5 years (however, the interval can be extended to every 10 years if an annual visua= l=20 inspection is performed): Burger 58018 (if returned to service) China Grove 56007-56010 Garden City 56003 Haskell S. 58023 (and 58022, if returned to service) McAfee 1523 Midland 1516 Scurry 1517 Wildfire 1524 Livingston Ridge 68414=20 Loco Hills 66417, 66418 Thomas 68413 - Tanks with an EFR (external float.
roof) require measurement of the gap= =20 between the shell wall and the primary seal every 5 years, and between the= =20 shell wall and the secondary seal annually: Foster 787, 790 Quito-Hendrick 58044 Lynch 1511 Sonora 1515 (if returned to service) =20
| Status Air Compliance, EOTT Tanks, Midland Region |
NNG Gomez Plant, Site Cleanup has been completed.
All activities associated with the items identified during the sale of the facility have been corrected.
Becuse ET&S owns and WGR operates, there is a concern that WGR may not adhear to compliance and housekeeping at the facility.
This has been the case in the past.
Discussions will be held with Enron Legal to address these concerns.
TW Bell Lake Gas Plant, Ground Water Remediation.
A revised Water Development Easement from the State Land Office was received.
This will allow TW access to install one additional downgradient groundwater monitor well.
The tentative schedule to install the well will be the week of September 13th.
A construction permit application for installation of an SVE remediation system for the North Crawar C/S was mailed to the TNRCC.
The State of New Mexico conducted an air quality inspection of the Atoka No.
2 C/S.
No items or deficiencies were identified by the agency.
The Title V air permit application for the Atoka No.
3 C/S was mailed to the State of New Mexico, Air Qualtiy Bureau.
The Notice of Intent air permit application for the Crawford C/S was mailed to the State of New Mexico, Air Quality Bureau.
Annual blanket request letters were submitted to the USFWS in New Mexico and Texas for renewal.
A meeting was held in Houston with John Woodyard of Roy F. Weston and ET&S mgt.
addressing PCB activity in natural gas pipelines as related to the PG&E PCB Topock Lateral issue.
| Weekly Activity Report, Roswell Area |
Sta.3, 4 and 5 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.
3,4 and 5.
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.
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.
Stations 3 and 4: each months reports are to be sent to the following 2 agencies: Navajo Nation EPA P.O.
Box 339 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.
In speaking with Charlie, he has indicated that he will be handling the reporting for Station 4 also.
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.
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.
Expect some changes in reporting.
Youmay want to use MCS as a monthly reminder for the submittal of the reports.
Questions, give me a call 505 625-8022..
| Public Water System Sampling Time Again |
Advisors, presented below is a memo from GPG Houston requesting that we provide to them the number of ETS employees in each team who have taken advantage of the one year free membership with The Nature Conservancy.
Apparently there is some concern that employees are not taking advantage of the opportunity which has been provided for them to get involved with an organization that has some benefit towards wildlife and habitat preservation and enhancement.
Should an employee desire to sign up for the one year free memebership, the Conservancy the web address is www.tnc.org.
You can click the button that says "Become a member" and sign up for the annual membership at that time.
At the request of Mr. John Shafer, please provide to me a total by team of the number of individuals which have signed up with the Nature Conservancy by the end of the month.
Your assistance in this is greatly appreciated
| TNC Membership |
George, Dave Cobrain of the NMED has verbally approved of the soil characterization work plan which you submitted to him for review and has said that we can begin work as soon as the plan is approved by the OCD.
I have not heard from Bill Olson of the OCD yet.
Dave was going to inform the OCD that their office has given approval of the plan and that this might expidite Bill's review process.
Ill let you know when I hear from the OCD.
| Approval of Sta. 9 Soil Characterization Plan |
Today I spoke with Jean Calhoun of the Arizona Chapter of The Nature Conservancy about the proposed Sundevil Pipeline Construction Project.
She was very cordial and appreciative concerning Transwestern's proactive efforts to contact not only her office but all federal and state agencies which may have jurisdictional lands impacted by the project.
Although the proposed route of the pipeline corridor has not been firmly established, she did offer some general, yet valuable information concerning the geographic area which exists south of Flagstaff into roughly northern Phoenix.
The area south of Flagstaff into Phoenix crosses of three major ecological regions identified by the TNC with major biological diversity of plants and animals.
The TNC has completed published studies on two of the regions.
The TNC has requested that should this project be apporved, these publications be used to assist in the environmental studies which will need to be completed prior to construction and approval by FERC.
To the south and east of Flagstaff is a sensitive portfolio consisting of the Verde River which is of ecologic interest due to the abundance of endangered fish and bird species which live in and around the area of the River.
This river could be impacted by the pipeline due to its meandering in a southwesterly direction across Arizona.
I have contacted other state and federal governmental agencies, in addition to the TNC, and all parties have expressed difficulity in assessing the environmental impact of a project of this magnitude without knowing the pipeline corridor route.
Part of this concern is due to the extensive and unique biological diversity of Arizona.
I think we will have a better handle on how we address the environmental concerns and opportunities when this piece of the puzzle is completed and also how much more specific and helpful the agencies assistance will be when identified areas are known.
| Phone Conversation with TNC |
The State of New Mexico has issued the settlement penalty for the turbine replacement issue at the P-1 C/S.
You may remember that the original amount levied against Transwestern in 1997 was $14,700.
After the Air Quality Bureau sat on this issue for more than 4 years, they reassessed the penalty to be $162,770.
I would like to get together and discus what our options are on this.
| P-1 NOV Issue |
The Southwest Region will be hosting its 2001 environmental roundtable in Albuquerque, NM on October 16-17 at the Holiday Inn Crowne Plaza (505) 821-3333.
Room rates are $89.00 per night.
Each attendee will be responsible for his/her room reservations for the two day event.
The agenda for this roundtable will be sent out in the near future.
If you would like to be a speaker and give a presentation on a topic or product please send to my attention for possible incorporation into the program.
| Southwest Region Environmental Roundtable Oct. 16-18 |
The State of New Mexico conducted a surprise air inspection of the TW Atoka No.3 C/S.
The agency found no non compliance issues or violoations during the inspection.
The second quarter Transwestern/SoCal PCB management committee meeting was held this week.
Transwestern's share of the PCB management and disposal activities on the SoCal system for the quarter was $125,950.00.
The State of New Mexico has issued the settlement penalty for the turbine replacement issue at the P-1 C/S.
The original amount levied against Transwestern in 1997 was $14,700.
After the Air Quality Bureau sat on this issue for more than 4 years without resolution, they reassessed the penalty to be $162,770.
A conference call will be set up to discuss Transwestern's next course of action.
The summary report for due diligence conducted in Portland Ore. was completed and submitted to Environmental Affairs in Houston.
| Weekly Environmental Activity Report Roswell Area |
Began initial field confirmation of EOTT crude oil tanks and equipment in the MIdland Region.
Five of the thirteen teams which have EOTT facilites have been inpsected and appropriate changes made to the database and spreadsheet.
A meeting was held with the Midland field teams which have Title V facilities, to complete and submit the required annual certifications.
All Title V locations in the MIdland region were in compliance for this year.
Region IX EPA has made a determination that prior to issuance of the air permits for the Redrock turbine installation, Transwestern is to conduct an endangered species survey of C/S's 3 and 4.
A contractor has been contacted and the surveys will be completed prior to September 15th.
This is not a new issue, as EPA Region VI, Dallas required consideration of the Endangered Species Act to be completed at the Luguna C/S, which is on Laguna Indian Lands.
The Title V permit will not be issued for the Laguna C/S until the EPA is satisified that endangered species are not a concern.
Preliminary environmental and right of way field data are being provided to an environmental contractor to initiate a fatal flaw analysis of a proposed project for Transwestern Pipeline Company.
Continued EOTT crude oil release data collections for forthcoming Sept. 27th NFL meeting in MIdland.
| Weekly Activity Report, Roswell Area |
Yesterday evening I phoned both the state of Arizona ( agency for stations 1 and 2) and Region 9 EPA ( agency for stations 3 and 4) concerning the status of when the air permits would be issued by both agencies for the Redrock expansion.
I was surprised to find out that both agencies stated a 2-4 month delay prior to issuance.
They cited back log of other permits, public comment periods, and workload as being the main reasons.
I am particularily disappointed because there were pre meetings with both agencies identifying what was to be included in each application package, and even after the applications were submitted in March of this year, each agency came back and asked for different information that from what was discussed at each meeting.
I have a call into the state of Arizona ( construction is to begin at Station 2 and they have jurisdiction for this station) to see if we can initiate some construction activities such as laying pipe and building foundations prior to receiving the permit.
I have been given these types of approvals from other agencies in the past, but these types of approvals are extremely narrow and restrictive.
If this flys I am sure that they will require us to make sure the turbine is not brought on site until the permit has been issued.
I know this will require written approval from the agency, but this may allow us to proceed on schedule and avoid any delays.
Ill keep you apprised of this issue.
| Air Permit Delay, Red Rock Expansion |
The 2001 environmental roundtable has been confirmed for the above location and dates.
Make your reservations at the Holiday Inn Crowne Plaza (505) 821-3333.
The hotel is located on the frontage road off I-25 north at the Paso del Norte exit.
Room rates are $89.00 per night.
A block of rooms is being held under "Enron Transportations Services-Environmental Roundtable".
The agenda for the roundtable is presented below: Tuesday October 16th 7:00-8:00 am Contintental Breakfast.
8:00-8:15 am Welcome and Opening Remarks.
8:15-8:45 am Bill Kendrick, Director Environmental Affairs, ETS.
8:45-9:15 am Chad Ingalls, The Nature Conservancy (Station 2 Project).
9:15-10:00 am Ruth Jensen, Air Issues and Compliance.
10:00-10:15 am BREAK 10:15-11:15 am Denise Celani Safety Kleen.
"What happens to your waste after we get it" 11:15-12:00 pm Joe Lueras.
Envisions training and demonstration.
12:00-1:30 pm LUNCH 1:30-2:30 pm Mike Riedel.
Emissions Inventories.
2:30-2:45 pm BREAK 2:45-3:45 pm Ruth Jensen.
Star Program 3:45-4:30 pm Larry Campbell.
Rocky Mountain Elk Foundation.
4:30-4:45 pm Closing Remarks and Adjourn.
Wednesday October 17th 8:30-12:00 pm Surprise Exercise.
12:00-1:30 pm LUNCH 1:30-3:00 pm Larry Campbell.
Discussion of Surprise Exercise.
3:00-3:15 pm BREAK 3:15-4:30 pm Larry Campbell.
Mock Environmental Situations.
4:30-4:45 pm Questions and comments concerning roundtable.
4:45 pm Adjourn.
Looking forward to seeing you all and having a productive and interesting session.
| Albuquerque Environmental Roundtable, Oct. 16-17 |
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.
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.
This includes a more frequent inspection of the pipeline conditions underlying the ponds by taking potentiometric readings to verify that corrosion is not present.
Transwestern has also installed rectifiers to assist in eleminating the potential of pipeline corrosion.
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.
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.
Noise Issue.
In the initial environmental assessment and study, Transwestern conducted baseline surveys of the area to determine existing noise levels.
This study was completed to assist Transwestern in the mitigation measures which will be implemented after construction of the Gallup Compresso Station.
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.
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.
Decrepancy of trailer park residents.
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".
The number of mobile home residences currrently in the trailer park may in fact be closer to 35.
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.
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.
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.
It was actually noted that many of the spaces normally occupied by mobile homes had been vacated.
This unsanitary condition was also identified by the New Mexico Environment Department.
The NMED had implemented enforcement actions against the trailer park owner.
| Garcia Response of the Proposed Gallup C/S |
Joe, presented below is the first memo I sent out concering the air permit issue: [Yesterday evening I phoned both the state of Arizona ( agency for stations 1 and 2) and Region 9 EPA ( agency for stations 3 and 4) concerning the status of when the air permits would be issued by both agencies for the Redrock expansion.
I was surprised to find out that both agencies stated a 2-4 month delay prior to issuance.
They cited back log of other permits, public comment periods, and workload as being the main reasons.
I am particularily disappointed because there were pre meetings with both agencies identifying what was to be included in each application package, and even after the applications were submitted in March of this year, each agency came back and asked for different information that from what was discussed at each meeting.
I have a call into the state of Arizona ( construction is to begin at Station 2 and they have jurisdiction for this station) to see if we can initiate some construction activities such as laying pipe and building foundations prior to receiving the permit.
I have been given these types of approvals from other agencies in the past, but these types of approvals are extremely narrow and restrictive.
If this flys I am sure that they will require us to make sure the turbine is not brought on site until the permit has been issued.
I know this will require written approval from the agency, but this may allow us to proceed on schedule and avoid any delays.
Ill keep you apprised of this issue.]
I spoke with the ADEQ after our conference call and they directed me to another group (compliance) in the air permit section.
They strongly suggested that I contact the compliance group before contacting Nancy Wrona, Director of the ADEQ.
I left a message with the supervisor of the ADEQ compliance section, Kathy McConnell (?)
602-207-2328, but have not heard back from her.
Either Bill Kendrick or I will be touching base with her again, tomorrow.
Arnold has given me the following list of construction items he would like to have the ADEQ grant us permission/waiver to do in leau of receiving the air permits: all earthwork trench construction and piping tie ins all foundation and building construction installation of ancillary equipment This list is probably too aggressive and falls out of what the agency may allow us to do.
| Redrock Permit Issue, Requested Information |
Dan, sorry about taking so long it getting back to you about this, but I had a couple of crises I had to address, Im still realing from the impact.
I have attached for your review the agreement which we are in the process of finalizing with the Wild Turkey Federation.
Take a look at the document and let me know what you think.
After your review we can make the necessary changes and modifications.
I have been advised by our legal department that each of the three major pipelines owned and operated by Enron will need a separate contract, with the RMEF, so what we decide for Transwestern, will undoubtably work for the others.
Thanks for your patience in this.
| See what you think |
Jon and Ruth, presented below are the comments to the air perimts at 3 and 4.
Please review for clairty and content.
I have spoken to Roger Kohn about all of these issues and the only one which may be a problem is with No.
2.
He is checking on what the EPA can do about this.
I have spoken to Arnold Eisenstein about what we can do with the strict 25 ppmvd requriement for NOx and CO and he has said that we can hold to the 25 ppm value by doing some major gas recycling.
This is a fuel waste and costly.
Anyway, depending upon how long this issue delays the issuance of the permit will undoubtably determine whether we give in to the 25 ppmvd or hold out for 40 ppmvd.
Id like your comments asap.
1.
The responsible official name change to Danny Pribble.
2..
The draft permit limits NOx and CO emissions to 25 ppmv at 15% O2, based on a 3-hour average, except during periods of startup and shutdown.
At 60F and above the GE data indicates that these rates are achievable under all operating conditions.
However, GE data indicates that NOx and CO may be as high as 40 ppmv during low-load conditions of 60%and lower.
The permit application represented turbine operations at base load 80% of the time with reduced load operations (64% load) occurring no more than 20% of the time.
The potential to emit calculations presented the emissions in the application in units of lb.hr and ton/yr.
These values were accepted by the EPA for the netting analysis, and took were taken into account by the EPA (See EPA Statement of Basis document).
Because the permit conditions hold us to ppmvd values and not lb/yr or ton/year values, Transwestern is concerned that under low load conditions of less than 60%, the emissions of NOx and CO would be 40 ppmvd.
Transwestern is requesting that a provision be made in the permit conditions that emissions of NOx and CO be held to 40 ppmvd during the 20 % of the time that the turbines operating conditions is less than or equal to 60%.
3.
The word "Catepillar" is mispelled throughout the permit.
4.
Permit conditions for sulfur testing in the fuel gas requires Transwestern to use methodologies (wet chemistry technology) that are not normally used to monitor and measure sulfur in the natural gas.
Transwestern has received approval from the EPA for other custom fuel monitoring schedules to use "GPA Standard 2377" (length of stain tube) or gas chromatography as the proposed methodology to monitor sulfur in the natural gas.
| Staions 3 and 4 air permit comments to EPA |
Transwestern Pipeline Company Transwestern has run into some problems with the air permit conditions for the Redrock Expansion.
For the state permits, the ADEQ wants to abitrarily set a 10% safety factor to the emissions levels which approach PSD.
This means that they have written into the draft permit a reduction in the allowable hours of operation for the generator from 8760 to 7800.
This generator is the facility's prime source of power and therefore, needs to be operated for 8760 hours.
Transwestern will challenge the agency's authority to apply a 10%safety factor.
For the Indain lands permits, the EPA has written a permit condition of 25 ppmvd for NOx and CO under all operating conditions.
Manufacturerers guarantees only apply at 25 ppmvd at loads above 65% and at 0F.
It appears that Transwestern may have convenienced the EPA to back away from permit limits in ppmvd and include as permit conditons lb/hr and ton/yr emissions limits that Transwestern originally placed into its applications.
Northern Natural Gas Company A standard exemption for the NNG Martin Co. No.
1 facility was submitted to the TNRCC.
Preliminary maintenance activities and newly published AP-42 emissions factors have shown that the Martin Co. 1 facility may be a Title V facility.
Under the old AP-42 factors, the units at the facility were not greater than 100 ton/year sources.
Continued investigation is being conducted to determine emissions levels from the units at the facility.
EOTT A request and supporting documentation was submitted to the TNRCC to remove the EOTT Crane facility from the Title V operating permit program.
New data on the crude oil received into the facility shows the emissions limits for VOCs to be less than the Title V regulated limit.
General Preparations are being finalized for the environmental roundtable to be held next week in Albuquerque.
| Weekly Envoironmental Activity Report |
Shudeish, I spoke with Roger Kohn, Region IX EPA permit engineer, about the time his agency will take to do the air permit reveiw for Kingman and Flagstaff.
He stated that EPA normally gets the allowed 45 days to do the permit review, however, at the request of the state agency, his office will do an expidited review.
Because of the urgency of Transwetern desiring to initiate construction, by this email, I am asking the ADEQ to request an expidited review of the Kingman and Flagstaff air permits from the EPA.
Again, thanks for your work and effort that you have put in on this project.
| Expidited Request to EPA for Review |
Just a short message to apprise everyone of the cleaning results performed on the filter separator from the Transwestern M/S.
Wipe tests taken of the interrior portions of the separator prior to cleaning revealed PCB results of: 360, 500 and 520 microgram.
This was not a standard wipe taken of a specific area.
These wipes were taken over large areas to determine presence/absence of PCB's within the separator.
After the cleaning operation was completed, three wipe samples were taken of the interrior portions of the separator.
All results showed non detect at less than 1.0 microgram.
I feel we can be fairly certain that the separator is free of residual PCBs.
Jeff, would you pass this information on to your counterpart for PG&E?
| Results of the PG&E Filter Separator Cleaning |
Bill as per your request, presented below is a status of the air permitting activity by the agencies as of today 11/01/01.
Stations 1 and 2.
The EPA has completed is review of these state permits and has sent them back to the ADEQ for comment.
I have spoken to Shudeish, the permit engineer for the ADEQ, and he is reviewing EPA's comments as this e mail is being written.
He will give me a call when his review is complete, but he does not anticipate any major issues which cant be resolved prior to the public hearing.
These permits went out for public notice on October 15 and 16, which means that the comment period ends on Nov. 15 and 16.
The ADEQ plans on holding the public hearing for both permits on monday Nov. 19 in Williams AZ.
at 7:00 pm.
I plan on being there.
Williams is located approx.
30 miles west of Flagstaff, AZ.
The address for the hearing is the Council Chambers located at 113 south 1st street.
So far, there have been no responses submitted to the ADEQ by the public.
In EPA's review process, they had a problem with methodology proposed by Transwestern for measuring sulfur in the fuel gas.
We had proposed stain tubes in the custom fuel monitoring schedule, they wanted us to do wet chemistry.
We convinced them otherwise (Byron, because of this, you wont need to order a sulfur analyzer for the Needles facility.
This should save you about $40K).
There was also an issue with manufacturers quarantees regarding particulate matter emissions from the turbine and catepillar.
This has been resolved also.
Stations 3 and 4.
I received a call from Roger Kohn, the permit engineer for the EPA.
He is satisified with the permit application contents and has also approved stain tubes for the sulfur measurement at these locations.
There are no outstanding issues on these permits from the EPA.
The public comment period for the Station 3 and 4 permits ends Nov. 3.
After this date, it will take 1-2 weeks for the Regional Administrator of the EPA to sign off on the permits and then he will have them issued to Transwestern.
As of this date, there have been no comments submitted to the EPA for the permits for station 3 and or 4.
Ill keep everyone apprised of future events.
| Status, Redrock Air Permits |
The third quarter PCB meeting with Southern California Gas Company was held this morning.
SoCal presented a third quarter invoce of their PCB management and disposal activities for which Transwestern is responsible for $120,602.19 (86%).
All charges were appropriate and considered normal operating expenses for PCB activities in California.
On a similar note, while speaking to Ralph
| FYI, PCB mtg with SoCal |
The third quarter PCB meeting with Southern California Gas Company was held this morning.
SoCal presented a third quarter invoce of their PCB management and disposal activities for which Transwestern is responsible for $120,602.19.
All charges were appropriate and considered normal operating expenses for PCB activities in California.
The public hearing was held in Williams, AZ for the Kingman and Flagstaff air permits under the Redrok Expansion.
There were no comments or concerns brought up at the meeting as no individuals came to the meeting.
An email was received from the ADEQ presenting the minor additions which will be added to each permit.
Each comment and addition will not impact or change the draft permits which were received earlier this month.
The permits for Klagetoh and Luepp were received from the EPA last week.
The permits from the ADEQ for the Kingman and Flagstaff C/S will be issued the later part of this week.
Attended the incident investigation and technical writing workshop in Omaha.
Assisted the Mountainair team with the semiannual Title V compliance monitoring report for C/S No.7.
A meeting was held in Phoenix, Az with PG&E to review charges and invoices by PG&E for PCB management and disposal activities on their system for the last several months.
Also discussed was recent liquids sampling results and proposed PCB activities on the PG&E system for 2002.
| Weekly Environemtnal Activity Report |
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.
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.
Adewumi was asked about the simultaneous modeling of PCB's and arsenic and feels that the model can address this situation.
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.
As is the case with most projects of this nature, answers to some questions cannot be addressed until we begin the process.
It appears that the next step in this process is to have Mike Terraso contact Michael Adewumi.
David Roensch and I will be available to feed technical and operational information to Adewumi for his modeling input.
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.
By working through the process, we may be able to alleviate some potential concerns and increase the cleaning success.
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.
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.
| Conference Cal with Adewumi |
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.
The Laguna's have hired an environmental person to oversee environmental issues on pueblo lands.
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.
Transwestern provided a history of the above mentioned activiites and why these issues were unresolved in the "eyes" of the Laguna.
Transwestern committed to submitting closure requests for the UST and asbestos issues.
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.
Transwestern assured the Laguna environmental representative that all correspondance and data pertaining to environmental issues would be submitted to the pueblo agency.
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.
The meeting provided Transwestern and the Laguna's with the opportunity to meet and share ideas and opinions and initiate working relationships.
The Laguna's now have an understanding of the environmental activities at the site and what Transwestern's approach is to removing the contaminants.
The Laguna's appreciated Transwestern's efforts and commitment to environmental compliance on the Laguna pueblo.
| Results of the Environmental Meeting at C/S 6, Laguna |
The state of Texas conducted an air quality inspection of the NNG Seminole C/S.
There were no deficiencies or violations identified at the facilit during the inspection.
The State of New Mexico Air Quality Bureau conducted an inspection of the Transwestern Atoka No.
3 C/S.
The Agency conducted a record review and did portable emissions testing of 3 of the 5 emissions units at the facility.
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.
The State of New Mexico Air Quality Buureau conducted an inspection of the Transwestern Atoka No.
2 C/S.
The agency conducted a portable emissions testing of the two turbines and one recip at the facility.
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.
The agency requested sulfur readings from the fuel gas as required under Subpart GG NSPS for the last twelve months.
The Artesia team has contacted Gas Control in Houston for the for the monthly sulfur values at the facility.
| Environmental Activity Report-Roswell Area |
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).
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.
These DAILY records include measurements on Saturdays and Sundays.
3) The measurement must be taken at the location.
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.
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 retrival.
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.
Approval of a CFMS allows a greatly reduced recordkeeping and reporting for nitrogen and sulfur.
CFMS requests have been submitted for the following facilities: P-1 C/S Plains Turbine C/S Atoka No 2 C/S Monument C/S Crawford C/S Bloomfield C/S Approvals have not as yet been obtained.
Until issuance of a CFMS, an applicable facility is required to continue daily sampling for nitrogen and sulfur.
Facilities which have received CFMS from the EPA include: La Plata C/S P-2 C/S Please be advised that there may be certain reporting requirements that might be required for each CFMS.
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.
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.
| Nitrogen and Sulfur reporting and Recordkeeping for Turbines |
The biennial hazardous waste reporting for 1999 for Transwestern Pipeline Company was submitted to the states of Texas, and New Mexico.
A meeting was held in Roswell to discuss air permitting activites and the recent agency inspection of the TW Atoka No.
3 C/S.
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.
Also discussed was NSPS fuel gas monitoring for nitrogen and sulfur and other miscellaneous air issues.
Texaco has initiated soil excavation of an abondoned pit which may be the source of groundwater contamination at the NNG Eunice C/S.
An Enron contractor is onsite to oversee the activities by Texaco and to assist in the results of the investigation.
The 3rd request to Region VI EPA was completed requesting approval of 5 Transwestern and 1 NNG facilities for custom fuel monitoring schedules.
Initial requests dating back to 10/8/98 were included with the packet.
A phone call to the Regional Administer of Region VI was also completed.
Pending additional lack of response, a meeting will be requested to the agency requesting action and approval of the requests.
Data requests from Argent Consulting have been distributed to the field for the 1999 emissions inventories.
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.
There were no positive concerns or impacts identified which would require additoinal actions.
| Weekly Activity Report-Roswell Area |
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.
ARIZONA Priority 1 Priority 2 C/S No.
3 C/S No.
4 C/S No.
2 C/S No.
1 NEW MEXICO C/S No.
7 Atoka No.
2 C/S No.
8 C/S N. 5 Eunice C/S P-1 C/S No.
9 Monument Turbine Maljimar C/S Crawford C/S Bloomfield C/S Jal C/S Atoka No.
1 C/S Atoka No.
3 C/S COLORADO La Plata TEXAS WT-2 C/S Keystone P-2 C/S Lone Star Valero C/S
| Transwestern's Facilities List |
On a related note, I spoke to Vector concerning the equipment which was suggested for cleaning on the PG&E system.
It is as follows: 2 scrubbers, some underground C/S piping, filter separator, horizontal tank, 2-10.84 drip locations The Vector proposal for mobilization, demobilizataion and cleaning the above PG&E equipment will be approx.
$ 75, 000.
I approached Vector about the pipeline cleaning between our M/S and their C/S.
They quoted a turn key price of $34,000.
Because this piping belongs to Transwestern, we should contract this cleaning ourselves.
If the decision is made to address this cleaning, I think we would want to have it done during the same time period as the PG&E cleaning activities.
I will also need some lead time to notify Vector and determine an appropriate methodology to be used.
Vector apparently has an approved methodology for cleaning pipes to 36".
One additional note, apparently PG&E has discovered PCBs in their gas compressors.
In wipe samples taken of the internal compressors PCBs were found at regulated levels.....
| Additonal Information Concerning PG&E |
A presentation was given to the Transwestern Marketing Group in Houston over the PCB issues affecting sales of natural gas into western markets.
The history and future potential impacts of market stratgies were also discussed.
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.
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.
Notification to the staes and EPA is due by June 17, 2000.
A conference call was attended to discuss the C/S 8 turbine project and its fate.
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.
The quarterly Transwestern/SoCal PCB management committee mtg was held via conference call.
Invoices and charges were discussed which So cal had charged to their management and handling of PCB's on their system.
At 86%, Transwestern's responsibility was $71,208.61.
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.
A custom fuel monitoring request wqas submitted to Region VI EPA for the Transwestern Lone Star Valero C/S.
Installation and testing has been initiated on the precombustion chambers for the Superiors at the Atoka No.
3 C/S.
While fabrication is in progress for the correct chamber, temporary Waukesha chambers were installed.
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%.
The correct chambers will be available and installed sometime next week.
| Weekly Environmetnal Activity Report |
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.
These releases include but may not be limited to the following: ESD's, startups, shutdowns, pipeline ruptures and maintenance activities.
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.
Maintenance, Startup or Shutdowns- 10 day prior to the expected exceedance.
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.
The agency's inquiry specifically addressed knowledge of compressor station venting for ESD, start ups and shutdowns.
It should also be mentioned that there has been inconsistencies in the TNRCC's position regarding this issue.
However, until a position has been adopted by Enron's GPG, I am recommending that each facility comply and report as appropriate.
| Natrual Gas Release Reporting Requirements for Texas |
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.
They will be discussing PCB issues and the sampling results from the PG&E system.
From discussions with Louie, a media statement is being prepared by them which Louie has a copy of.
The statement is a little harsh and makes some statements which are incorrect.
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.
The results of this meeting will be forwarded at a later date.....
| Media Statement |
Based upon valving constraints and the innaccessability to the inside of the pipe between our M/S and the Topock C/S, a decision has been made to postpone cleaning of his section of the pipeline.
should cleaning occur of this section, it is anticipated that it will not occur untill the installation of the filter separator at the PG&E C/S, sometime later this year.
Vector has been notified of this change in plans and will adjust their cleaning schedule accordingly.
| Cleaning Postponement of the pipeline between TW PG&E M/S and the Topock C/S |
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.
The sale of the TW Crawford C/S has been cancelled.
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.
Preparations are in place for the forthcoming meeting between PG&E and Transwestern over PCB issues on their mainline.
Analytical shows that the PCB's are continuing to move further downstream into their system.
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.
The annual certification for the Atoka No.
3 C/S was reveiwed for completion and submitted to M. Nelson for signature.
| Weekly Environmental Activity Repor |
Received the "permit by rule" approval for the turbine power unit changeout for the Keystone C/S.
The emissions testing results for the Plains Turbine Station was submitted to the TNRCC.
Discharge renewal applications for C/S No.
9 and Monument Turbine C/S were submitted to the OCD.
Notification to the New Mexico AQB was given for the power turbine changeout at the Atoka No.
2 C/S.
One employee was skill verified for level II environmental During the routine weekly sampling of the PG&E system, it was discovered that approx.
3 oz of liquid had collected in the new filter separator in the PG&E C/S yard.
A request was made to analyze the liquid for not only PCB's but also pH to determine if the liquids resulted from the caustic and water cleaning of the upstream portion of the pipe leading into the PG&E C/S .
This is the first occurance of liquids at this location since this new filter separator was installed and put inot service.
| Weekly Activity Report-Roswell Area |
The Title V air permit for C/S No.
4 has been issued.
There are some requirements and conditions under this permit that the team should be aware of and will be required to comply with.
I would like to visit with the team at their safety meeting in June or july to go over the conditions of the permit.
Please give the the dates in June and July when your next safety meeting is.
This Title V presentation should last about 3 hours.
Thanx
| Title V Permit for C/S No. 4, Klagetoh |
Guys, I received Harrell's memo concerning the fuel use for the turbine and the fact that you had to reduce gas producer speeds to comply with the permits fuel use requirements.
My question is, how does the fuel use compare with what Solar says the fuel use should be?
If we can get Solar to provide written guarantees and "UP" the fuel use value for the turbine, we can up the fuel value on the permit.
The state of Colorado perceives increased fuel use beyond manufacturers values as the turbine not operating correctly and in need of mechanical adjustment.
From their eyes, this would be a strong indication of excess emissions, and I think there evaluation would hold some merit.
Anyway, I dont want to send up a red flag to the state of Colorado.
Would you contact Solar and compare their fuel use values with what the monitors say the turbine is burning at La Plata?
Then let me know.
If worse gets to worse, I may be able to use another tactic, but only as a last resort.
| Fuel Consumption, La Plata A |