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Enron Mail |
As I hope all of you have heard by now, it was a very productive meeting with
Nancy Wrona. The creative interpretations of the DEQ rules were not necessary as Jerry and Nancy hammered out a very date-specific sequence for the permit approval activities, as well as clarifying the facility-related activities he can do before actual permit issueance. Likely date for permit issuance is by Friday, November 16, but this will depend upon EPA cooperation in shortening its maximum time allowed for review and assuming no substantive public comments. Following is first draft of "thank-you" letter to Nancy from Jerry; edit freely: HAND DELIVERY Nancy Wrona Director, Air Quality Division 3003 North Central Avenue, 5th floor Phoenix, Arizona 85012 Re: Transwestern Pipeline, Permits No. 1001601 & 1001602 Schedule for Permits Issuance Dear Ms. Wrona; Thank you again for your significant assistance in detailing a specific strategy to complete the process to review and approve the two permit revisions for the Transwestern Pipeline compressor stations near Kingman and Flagstaff. We were impressed with your willingness and ability to focus on the practical approach to improving Arizona's air quality as promptly as possible. Working with you and your team of Cathy O'Connell and Prabhat Barghava gave our team from Enron Transportation Services and Transwestern Pipeline Company (TWP) a strong sense of accomplishment and cooperation. Following is the schedule that we detailed for subsequent activities: 1. By Friday morning, October 5, Prabhat and Shudeish Mahadev will have completed the draft permits; on Friday afternoon, October 5, the ADEQ team, including Prabhat and Cathy O'Connell, will conduct the internal review and the TSD; by close of business, Friday, October 5, ADEQ will email the draft permits revisions to the TWP team (Bill Kendrick, Larry Campbell and me; our contact numbers and email addresses are listed on the attached sheet). 2. On Tuesday morning, October 9, at 9 am Phoenix time, there will be a call-in conference call between the ADEQ and the TWP teams for final review, negotiation, and agreement on the terms and conditions of the draft permits revisions. 3. By Thursday, October 11, or Friday, October 12, ADEQ will do first publication in the daily newspapers in Mohave and Coconino Counties of the 30-day public comment period and 30-day notice of a public hearing (at TWP's request) for both permits revisions in Williams AZ. Toward meeting the agreed-upon permits revisions schedule, TWP hereby requests a hearing on each revision pursuant to R18-2-330(E) and asks that ADEQ include the required notices of hearing in all notices of the public's opportunity to comment pursuant to R18-2-330(C) and ARS sec 49-444(A). Second publication will occur a week later. We will research and confirm the mechanics for getting the notices published as soon as possible after the Tuesday, October 9 conference call; ADEQ will promptly prepare the form of notice, unless you wish TWP to do it. 4. On Tuesday, November 13, ADEQ will conduct the public hearing on the two permit revisions in Williams AZ. We have found nothing in the statutes or rules that would prevent having back-to-back hearings for the Kingman and Flagstaff facilities' permits revisions in the same place. 5. Promptly after the October 9 conference call that finalizes the draft permits revisions, ADEQ will send the drafts to EPA Region IX to commence EPA's review. TWP will confer with the EPA contacts to shorten the maximum 45 days allowed so that EPA will complete its review on or before Thursday, November 15; EPA will promptly notify ADEQ of its approval. 6. On the assumption that neither the public hearing nor the EPA review generated any substantive comments that require further review, ADEQ will issue the permits revisions by Friday, November 16. We recognize that the foregoing schedule will require significant cooperation among all parties, as well as working closely with EPA, but we are confident, based upon yesterday's meeting, that all of us from ADEQ and from TWP are committed to making this doable schedule work. The TWP team will promptly convey to ADEQ all materials it receives relating to the EPA permits revisions for the Leupp and Klagetoh facilities. We also appreciated your clarification of the facilities-related activities that we can proceed with prior to final permits issuance. Specifically, since there will be no emissions impacts from the routine maintenance of replacing equipment and making the srubbers' tie-ins, TWP can proceed with those activities at the Kingman and Flagstaff sites. Additionally, we can proceed with the off-site fabrication of piping. We also understand that, at the time of the first newspaper notices, we will post the appropriate signs at each facility duplicating the newspaper notices. Again, thank you very much for your assistance in setting up the foregoing schedule and procedures. It is a real pleasure working together to improve Arizona's air quality. Sincerely yours, Jerry D. Martin cc. Cathy O'Connell Prabhat Bhargava Steve Burr Van Wolf I will aim to get this letter out the door by mid-day Friday. Van The information contained in this electronic mail message is confidential information intended only for the use of the individual or entity named above, and may be privileged. If the reader of this message is not the intended recipient or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please immediately notify us by telephone (602-382-6000), and delete the original message. Thank you. G. Van Velsor Wolf Jr. Snell & Wilmer L.L.P. One Arizona Center Phoenix , Arizona 85004-2202 602.382.6201 (direct) 602.382.6000 (main number) 602.382.6070 (fax) vwolf@swlaw.com
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