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Enron Mail |
Cc: larry.campbell@enron.com
Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit Bcc: larry.campbell@enron.com X-From: John Shafer X-To: Louis Soldano X-cc: Larry Campbell X-bcc: X-Folder: \Larry_Campbell_Nov2001_1\Notes Folders\All documents X-Origin: CAMPBELL-L X-FileName: lcampbe.nsf Lou, I would like to "confidentially" discuss the issues Larry has raised with you and see where the Legal Department may or may not want to proceed with these issues. Thanks, John Shafer ---------------------- Forwarded by John Shafer/OTS/Enron on 08/30/2000 10:59 AM --------------------------- Larry Campbell 08/30/2000 10:47 AM To: Rich Jolly/ET&S/Enron@Enron, Michel Nelson/ET&S/Enron@Enron, Louis Soldano/ET&S/Enron@Enron cc: John Shafer/OTS/Enron@Enron, William Kendrick/OTS/Enron@Enron, Rick Cates/ET&S/Enron@Enron, Butch Russell/ET&S/Enron@Enron Subject: Compliance with the Large Quantity Generator Requirements, Transwestern Pipeline Company A review was completed of the storage tank requirements for large quantity generators of hazardous waste. These regulations apply to almost each mainline C/S in New Mexico, Arizona and California (initiating at Station 9, Roswell to Needles and including the tanks on the Topock Lateral). There are eighteen condensate tanks on the Transwestern mainline system which could potentially be impacted, however, only about 10 tanks have received hazardous waste liquids in the last 3-4 years. The constituents which make these tanks fall under Subtitle C of RCRA is the arsenic, lead and low flashpoint (VOC's) of the condensate. PCB's are another issue and are subject to other requirements. Briefly, the liquids which collect into the tanks is highly variable in quantity, contaminant concentration and with respect to when condensate enters the tanks. When the gas is extremely dry, no condensate is collected. During periods of wet gas movement, condensate with arsenic, lead and low flashpoint is collected. In the 1980's to mid 90's, all eighteen tanks collected sufficient condensate with arsenic, lead, flashpoint and PCB's that the contensate in the tanks was hauled away every 90 days. From 1995 up to 1999, the system was essentially dry and no liquids were collected. The tanks did not fall under the hazardous waste requirements. However, this year, we are seeing more liquids hauled away as hazardous waste than we have seen in the past 4-5 years. I would like to discuss the issue of compliance with these tanks. The consistency and volume of regulated liquids which are now being collected at the C/S tanks warrants a discussion. The El Paso incident may be a driving force in this issue.....
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