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Enron Mail |
Bill, Just a short note to let you know whats going on at Bakersfield. I
have spoken to the agency inspector about one of the NOV issues and have been told that EOTT will definately receive a an NOV and fine for failure to conduct the emissions testing on a heater that apparently should have been tested approx. 6 months ago. With repsect to the other NOV issue, Rick Suderman had a testing company in to perform emissions testing on another heater which was required to be tested by today. As the testing contractor began his testing, an 02 issue developed with the equipment the testing company was using and a miscommunication on the part of the testing contractor was directed to Rick. As a result, the the inspector observed elevated CO readings from the heater that Rick had made adjustments in the heater set points (based upon recommendations from the contractor) causing the elevated CO readings to result. The inspector stated that the facility would receive another NOV for this exceedance. In any event this isssue was NOT Rick's fault and was due to some bad communication on the part of the contractor. We have sent the testing company home and will be bringing in another testing company (AEROS) on thursday. This is the contractor who has done the majority of the previous emissions testing for the facility to complete the heater testing and substantiate the innaccuracy of the first testing company's data. With this new data, we shold be able to demonstrate inaccuracy in the first testing company's QA/QC. It should also be mentioned that we have identified other environmental issues which we should discuss at your convenience. Butch and I will have completed the permit compliance investigataion and be available for discussions on friday. William Kendrick 01/10/2001 07:53 AM To: Rich Jolly/ET&S/Enron, Edward Attanasio/Remote/Eott@Eott cc: John Shafer/OTS/Enron, Larry Campbell/ET&S/Enron Subject: Re: Environmental -- NCL Rich/Ed--- Larry Campbell is going to Bakersfield this week to address the situation. I have asked him to put together a compliance calendar for the Bakersfield facility outlining regulatory deadlines required by the permits and regulations. He has discussed the testing due on one of the heaters this week with the regulators and there does not appear to be an issue. It is my understanding that the heater will be performed this week. Larry will look into the best course of action necessary to address the engine testing that was apparently missed last year. He will be discussing the matter with Gary. Please call with any questions. Thanks, Bill 713.646.7644 Rich Jolly 01/09/2001 05:24 PM To: Edward_Attanasio@eott.com cc: Molly_Sample@eott.com, lsoldano@enron.com, Bob_Jacobs@eott.com, Rjolly@enron.com, Rick_Suderman@eott.com, Larry Campbell/ET&S/Enron@Enron, William Kendrick/OTS/Enron@ENRON Subject: Re: Environmental -- NCL Ed thanks for the information. Bill Kendricks from Houston has asked Larry Campbell to work with Rick on getting this resolved. I talked with Larry today and he was going to give Rick a call. Rich Edward_Attanasio@eott.com on 02/23/2000 12:53:54 PM To: Molly_Sample@eott.com, lsoldano@enron.com cc: Bob_Jacobs@eott.com, Rjolly@enron.com, Rick_Suderman@eott.com Subject: Environmental -- NCL I just spoke with Gary Fuller who informed me that we have been notified by the Air District that we are getting an NOV for missing a source test in December (apparently on one of our IC engines.) Now, while this is not the end of the world, we put ourselves at potential risk if we do not follow up properly -- especially given the history of this plant with this Air District (that is, the Koch troubles that resulted in a criminal investigation from some relatively minor problems, really.) In fact, I believe that if we act promptly and conduct the source test now we stand a very good chance of having this NOV rescinded. But we must act. I am please to see that we still have Gary on the job, and I hope he can follow through with this. I have asked him to do so, and also to handle reporting of the soil contamination at NCL that we have all discussed at length. I have done so because delay works against us on both of these issues. Gary, though, is somewhat reluctant to act without instruction directly from ETS (which is understandable, given that ETS runs things.) He seems to feel that he should be getting direction from Cutty Cunningham, although I must confess I don't know enough yet about the structure of ETS to know why this is the case. In any event, I asked Gary to talk to whomever he needed to, but these matters needed to be handled in the short run. Obviously, we will discuss next week what is to be done for the long run. In the meantime, I would greatly appreciate whatever you folks can do to help grease the wheels to make Gary feel he has authority to act to get these more immediate problems addressed. Thanks a bunch.
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