postbot/aeslc_kw huggingface dataset:
Subject: Nitrogen and Sulfur reporting and Recordkeeping for Turbines

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.
Subject: Weekly Activity Report-Roswell Area

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.
Subject: Transwestern's Facilities List

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
Subject: Additonal Information Concerning PG&E

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.....
Subject: Weekly Environmetnal Activity Report

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.
Subject: Natrual Gas Release Reporting Requirements for Texas

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.
Subject: Media Statement

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.....
Subject: Cleaning Postponement of the pipeline between TW PG&E M/S and the  Topock C/S

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.
Subject: Weekly Environmental Activity Repor

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.
Subject: Weekly Activity Report-Roswell Area

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.
Subject: Title V Permit for C/S No. 4, Klagetoh

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
Subject: Fuel Consumption, La Plata A

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.
Subject: Additonal PCB Sampling on the SoCal System

During the quarterly conference call with SoCal in which we discuss PCB costs  on the SoCal system, for which Transwesten is 86% responsible, Ralph Komai,  SoCal's PCB person provded some addtional information with respect to what is  going on with the PCB activities on the SoCal system.
As a result of the  PG&E press release, SoCal management directed additional sampling to be done  at their interconnect with Transwestern and downstream of this interconnect.
Ralph reported that a number of liquid samples came back at around 7 ppm,  however one sample at their Kelso Station, near Barstow,  came back at 77  ppm.
Ralph had indicated that there has been an increase in the PCB's coming into  their collection locations in the Needles area as evidenced by the following:   Based upon 1997 data, almost no liquids greater than 50 ppm were revcovered   Data collected in 1998 showed that approx.
8% of the liquids were greater  than 50 ppm   Data collected in 1999 showed that approx.
9% of the liquids were greater  than 50 ppm  Based upon this, Ralph had stated that SoCal would be collecting additional  sampling information and possibly entering into an internal montoring  program, somewhat like PG&E is currently doing now.
I had informed Ralph that our Needles M/S facility had seen almost no liquids  in the last 5 years, other than a recent accumulation of a one time pigging  in early 2000 when a small volume of liquids (less than 55 gallons) had been  collected.
We discussed that the accumulations seen on the SoCal system  were probably from existing liquids on their system which had collected in  low points in their pipeline and were moving downstream due to the increased  flows from TW into SoCal.
Ralph gave the impression that there were no immediate management tensions  resulting from the recent "hits".
He just indicated that they would be  watching their system and sampling at a more frequent basis.
Subject: Weekly Environmental Activity Report-Roswell Area

Atttended the NMOGA meeting in Farmington, NM.
It appears that the BLM will  implement its own noise criteria in areas within New Mexico that are deemed  sensitive by the BLM.
The proposed noise threshold will be 48.6 DBA(A).
There are no Transwestern facilities in the Farmington resource area which  will be impacted by this proposed level, however the potential exists for  several Transwestern locations in southeast New Mexico to be impacted.
A meeting was held with the president of Del Mar, concerning the issues  associated with the lead in their lead acetate tape for monitoring sulfur  concentrations in the natural gas.
A  request  was made to the company to  determine the feasability of recycling the tape and eleviate the management  and disposal issues associated with the tape as a hazardous waste.
The quarterly SoCal Transwestern PCB conference call was held this week.
Transwesten's share (86%) of SoCal's PCB management activities was approx.
$79,000.
Due to the press release  by PG&E concerning the increased  occurance of PCB's into their system, SoCal has initiated increased sampling  activities on their system and will be proposing to do additional monitoring  to track liquids from Transwestern's M/S into the SoCal system.
Preliminary  sampling results at strategic liquids locations on the SoCal system has  revealed hits of PCB's in the range of 7-10 ppm, although, a  hit of 77 ppm   was discovered.
As a result of an isolated hit of PCB's into the new filter separator at the  PG&E C/S in excess of regulated levels, a  conference call was held the ET&S  VP to determine forthcoming activities with PG&E.
A meeting has been  scheduled at the PG&E C/S next week to reveiw sampling on the PG&E system and  discuss the recent hit of PCB's in the F/S and what forthcoming activities  will be conducted at the site.
Subject: Weekly Environmental Activity Report-Roswell Area

A meeting was held in Laughlin, Nv with PG&E to discuss the liquids which  were received and analytical result of 505 ppm which occurred at the PG&E  F/S.
Additional discussions centered around the latest migration of PCB's  into the PG&E system and control technologies to stop additional migration of  PCB's into PCB free portions of their distribution system.
Annual emission fees were paid to the ADEQ for C/S No.
1, Kingman in the  amount of  $31,145.26  Annual hazardous waste fees were paid to the DTSC for the facilities that  operate in the state California  A  meeting was held in Albuquerque to discuss and apprise involved parties of  histoirc and proposed activities for 2000 for the 10 groundwater remediation  projects currently being conducted in Texas and New Mexico.
Received a call from the TNRCC about an air quality inspection at the Irion  Co. No.
1 C/S on 6/30.
the team was notified and preparations are currently  being completed to ensure that all recordkeeping, permits and monitoring  reports are onsite during the inspection.
Subject: Testing at Station 3

When we do the emissions testing at C/S No.
3, Luepp, we should be aware of  the positives and negatives.
The positives being the information which Steve  and company will collect.
This appears to be a  very useful tool.
There is  also is no permit emission limits associated with the permit at this  facility.
There also exists the potential to pay lower emissions fees should  this investigation show that the emissions from the units to be significantly  lower than what was placed into the permit application.
The downside to this  effort is that the data we collect may in fact show that our emissions fees  which we have been paying actually under estimate those submitted in our  application and we would more than likely be held accountable for the  difference (1996 to the present).
Additionally, enforcement action could  result by the Navajos.
I say this to apprise everyone of the positive and  negative potentials involved in completing this study.
From the emission  estimates which were placed into the permit application we included a  defendable buffer or excess of emissions to account for variations in the  temperature, humidity, engine age and poor engine mechanics should they  exist.
And finally, we have the unknown of not knowing what the three units actually  emit.
These units have never been tested.
This uncertanty in itself may be  the driver to know so as not to have a situation which was similar to what  happened at Atoka No.
3 several months ago.
Subject: Weekly Activity Report- Roswell Area

A meeting was held with the Eunice Team to assign roles and responsibilities  for the newly issued Title V air permit for the NNG Eunice C/S.
The permit  is similiar to the other title V permits issued to New Mexico faciliites.
Assisted the Gallup Team with the preparation, completion and submittal of  the Title V semi anual compliance monitoring report and annual certification  report.
The state of New Mexico Air Quality Bureau conducted an inspection of the  Wt-1 C/S.
This inspection is interesting in the fact that all combustion  equipment has been removed and dismantled and replaced by electric units.
Written notification was submitted to the agency several months ago and a  written reply was received from the agency that the facility is exempt from  any and all permitting requirements.
A meeting was held with the Artesia Team to assign roles and responsibilities  for the newly issued Title V air permit for the Atoka No.
3 C/S.
Also  discussed was the permitting approach which will be followed for the approval  to install micro pre combustion chambers on two White units which were found  to be out of compliance with the air permit emissions limits when the New  Mexico Air Quality Bureau conducted a surprise inspection at the facility.
Subject: PCB Study on the SoCal System

I received a call from Ralph Komai, PCB engineer with SoCal, about a pipeline  liquids collection SoCal wants to take at our Needles facility.
Ralph said  that SoCal will be undertaking a study on their pipeline to determine why the  concentration and liquids volume of PCB's has reduced into their system in  the past couple of  years (97-2000).
I shared with Ralph and up until this  year, we have not had liquids at the Needles facility since 1994.
He stated  that they have seen reduced concentrations and are curious as to why this  trend is occurring (sounds like good news to me).
He said that their data  shows the following:   1998 liquids concentrations  only 1% regulated at the federal level   1999 liquids concentrations only 8% regulated at the federal level  Ralph has requested that SoCal be allowed to collect a  liquids sample at the  Needles M/S and I have contacted the Needles team about assisting SoCal with  the collection.
I would expect that this may have implications with respect to slight  increased billing for analytical charges that SoCal will be charging us for  and we reveiw on a quarterly basis with them.