Re: Compliance with the Large Quantity Generator Requirements, ,
 Environmental needs to make any calls /decisions on this. Any Capital /O&M 
requirements will have to be put into 2002 Plan at this stage.  




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.....
larry.campbell@enron.com