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Enron Mail |
Lou -=20
Below is language from EPA guidance that confirms that only liquid samples= =20 are required for characterization purposes. Sue Q: Under o761.30(i), is use of organic liquids for characterization of the= =20 natural gas pipeline system required? A: Yes. EPA=01,s intention was for organic liquids to be used to characteri= ze=20 the PCB contamination in the natural gas pipeline system. EPA will make a technical= =20 correction to o761.30(i)(4) to clarify this. Q: When conducting the annual sampling under o761.30(i), what do you do if= =20 you don=01,t have liquids present annually? A: Under the use authorization provisions at o761.30(i), if a pipeline syst= em=20 once contained liquids at 50 ppm or greater but is now relatively dry (i.e., there are no= =20 liquids available to test at existing condensate collection points), then the owner/operator of= =20 the pipeline system has no further sampling and analysis to do until such time as liquid= s=20 appear. EPA did not intend to require wipe sampling for characterizing natural gas=20 pipeline systems in use; hence, EPA has made a technical correction at o761.30(i)(4) to drop th= e=20 reference to wipe samples. For these relatively dry systems with no liquids, the=20 sampling requirements at o761.30(i)(1)(iii)(A)(5) don=01,t apply. However, EPA would expect the=20 owner/operator of the pipeline system to continue to check at least annually for liquids and= =20 document their absence under the recordkeeping requirements in o761.30(i)(1)(iii)(C). Shou= ld=20 any liquids appear later, the liquids should be tested. 10/30/2000 05:43 PM Louis Soldano Louis Soldano Louis Soldano 10/30/2000 05:43 PM 10/30/2000 05:43 PM To: Butch Russell/ET&S/Enron@ENRON, Larry Campbell/ET&S/Enron@ENRON, Leo=20 Nichols/ET&S/Enron@ENRON, Ron Beidelman/ET&S/Enron@ENRON, Ron=20 Harkrader/ET&S/Enron@ENRON, Mike Riedel/ET&S/Enron@ENRON, Rick=20 Loveless/ET&S/Enron@ENRON, William Kendrick/OTS/Enron@ENRON, Susan=20 Fernandez/OTS/Enron@ENRON cc: Rich Jolly/ET&S/Enron@Enron, Jan Cobden/ET&S/Enron@ENRON,=20 lsoldano@wt.net, Michel Nelson/ET&S/Enron@ENRON, Randy Rice/OTS/Enron@ENRON= =20 Subject: Re: Mega Rule PCB sampling - year end =20 =09 env guys - look over the attached and let me know your=20 thoughts/changes/addititons - i also need new list of names..... sue - can you check me on the wipe tests question??? the cc's - just fyi - for now Butch Russell 10/30/2000 04:02 PM To: Louis Soldano/ET&S/Enron@ENRON, Rich Jolly/ET&S/Enron@Enron cc: =20 Subject: Mega Rule PCB sampling Mr. Lou is it about time we did a PCB Mega Rule characterization sampling = of=20 the Transwestern Pipeline system west of Corona Sta # 8. I was thinking it= =20 was every six months that you were wanting that ? Let me know and if you do= =20 want a sample run done I will get it started. thanks Butch =20
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