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Enron Mail |
Jerry, I have not cancelled the Station 4 air permit. I have spoken to Roger
Kohn,EPA permit engineer, about the possibility of not doing the turbine installation at station 4 only due to what you described as not enough market commitment. My plans are to hold off on making any decisions and have the EPA issue the station 4 permit. If we do not initiate any construction pertaining to the turbine or auxillary generators, then the new permit doesnt apply and we can still operate under the existing permit which was issued about 2 years ago. In Enron, 6 months is an eternity and who knows what will happern then? By having the permit, but not constructing, we will be OK. If we decide to do the turbine project within the period of time that the permit is valid, then were ahead of the game. If not, and a more firm decision is made to not do anything in the future, Ill contact EPA and request termination of the permit. Usually, the agency places a caveot that if construction does not proceed in a specified time then the permit automatically cancels itself and the facility must comply witht he conditions of the existing permit for the facility.. From: Jerry D Martin/ENRON@enronXgate on 11/15/2001 05:33 PM CST To: John Shafer/ENRON@enronXgate, Larry Campbell/ET&S/Enron@ENRON cc: William Kendrick/ENRON@enronXgate, Ruth Jensen/ENRON@enronXgate, Bret Reich/ENRON@enronxgate, Louis Soldano/ENRON@enronXgate, Arnold L Eisenstein/ENRON@enronXgate Subject: RE: FW: Red Rock Expansion Station 4 John, I agree with your points. Has EPA already been notified? If not, we should put the proper spin on it, which, in my opinion, should come from Marketing. Something like, "we tried hard, and continue to try hard, to sell more capacity, but the market has not cooperated, so we must defer (not cancel) the station for now. We haven't even told FERC yet, so you are the first to know." Jerry -----Original Message----- From: Shafer, John Sent: Thursday, November 15, 2001 2:51 PM To: Campbell, Larry Cc: Kendrick, William; Martin, Jerry D.; Jensen, Ruth; Reich, Bret; Soldano, Louis Subject: RE: FW: Red Rock Expansion Station 4 Larry, (Caveat: The following is just an observation at this point and the view expressed is my own). What concerns me most about this scenario is that we pressured the EPA Region IX quite a lot to get this permit and now we are just going to let a portion of it go "null and void". At least, the portion applicable to Station 4. I know we didn't lean on the EPA as hard as we did the AZDEQ, but we did repeatedly call them. Even the FERC Environmental Staff was calling Region IX asking when were they going to get the draft out - because the FERC was under the assumption that we needed all or none. At a time when Enron's veracity has come into question all across America, its too bad there isn't a better way to handle this. Don't be surprised the next time you go in asking for expedited treatment on a federal air permit, if the regulators look at you with a "question" mark. I wouldn't say we "burned bridges", but we definitely used some "green stamps". There are only so many "green stamps" that we can use with an agency and we used a bundle on this one - and now we don't need it. John -----Original Message----- From: Campbell, Larry Sent: Thursday, November 15, 2001 2:12 PM To: Arnold.L.Eisenstein.enronXgate@enron.com Cc: Byron.Rance.enronXgate@enron.com; Steve.Crabtree.enronXgate@enron.com; Campbell, Larry; Donna.Martens.enronXgate@enron.com; Earl.Chanley.enronXgate@enron.com; Kendrick, William; Shafer, John; Jensen, Ruth Subject: Re: FW: Red Rock Expansion Station 4 Arnold, I take care of cancelling the air permit for Station 4. Based upon other EPA permits that TW has withdrawn, if the construction activity does not take place, the permit by itself becomes null and void. I have a call into the EPA permit engineer to verify this. Ill let you know...... << OLE Object: Picture (Device Independent Bitmap) << Arnold.L.Eisenstein.enronXgate@enron.com on 11/14/2001 03:28:41 PM To: Byron.Rance.enronXgate@enron.com, Steve.Crabtree.enronXgate@enron.com, Larry.Campbell@enron.com, Donna.Martens.enronXgate@enron.com, Earl.Chanley.enronXgate@enron.com cc: Subject: FW: Red Rock Expansion Station 4 THIS MAKES IT OFFICIAL.. Larry - It looks like we will not accept the air permit at station 4 and will withdraw the application. Is this correct? Donna - what about FERC? Arnold -----Original Message----- From: Pribble, Dan Sent: Wednesday, November 14, 2001 3:15 PM To: Harris, Steven Cc: Petersen, Keith; Kendrick, William; Martens, Donna; Eisenstein, Arnold L.; Lowry, Phil; Miller, Mary Kay; Keller, John R.; Jolly, Rich Subject: Red Rock Expansion Station 4 This is to confirm our conversation today, the Transwestern Red Rock expansion currently is scheduled to replace the existing units at Station 1, 2, 3 and 4 with a new unit at each station. Due to market conditions, Marketing and Operations have agreed to officially remove Station 4 from the Red Rock expansion. We will need to prepare (overhaul) the existing units at Station 4 to flow the new incremental 120 mmcf/d. With this information Environmental Affairs can withdrawal the air permit application for Station 4 and Regulatory Affairs can make necessary filings. Thanks for your help. Dan
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