Message-ID: <32741550.1075851903570.JavaMail.evans@thyme> Date: Thu, 28 Jun 2001 12:42:00 -0700 (PDT) From: billglushko@hotmail.com To: larry.campbell@enron.com Subject: Fwd: EOTT PL Tanks (compliance) database Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: "Bill Glushko" X-To: larry.campbell@enron.com X-cc: X-bcc: X-Folder: \Larry_Campbell_Nov2001_1\Notes Folders\Discussion threads X-Origin: CAMPBELL-L X-FileName: lcampbe.nsf >From: "Bill Glushko" >To: billglushko@hotmail.com >CC: jfields@argentinc.com >Subject: EOTT PL Tanks (compliance) database >Date: Thu, 28 Jun 2001 17:11:35 -0500 > >Latest tank list. >99% complete, unless you request otherwise. > >Note that this list includes tanks that are still standing, >regardless of whether they are inactive or permanently out of >service. > >There are 8 sites which are affected by Texas annual inspection >fees, with a cost of $58,000. (but possibly, after checking the >tank strapping tables, might reduce to $51,000.) These fees would >be due by 11/01 each year if the tank was operated during the >previous Fiscal Year (Sep 1-Aug 31). > >The Teams told me that electric pumps are the norm at EOTT PL tank >farms. Crane has a Title V permit, but there were no combustion >sources that would cause another site to exceed 100 TPY. > >The Texas tanks subject to NSPS K, Ka, or Kb are subject to an >emissions fee, unless they are subject to an inspection fee and it is >higher. > >In Texas, E&P facilities, crude oil and refined product pipelines, natural >gas and LPG are regulated by the Railroad Commission. >However, TNRCC has jurisdiction over the petroleum bulk stations. >SIC code for a petroleum bulk station is 5171; for a crude pipeline >is 4612. SIC 5171 either as a primary or secondary code is correct, >and it generates a TNRCC inspection fee for 8 of the sites. >Designating a 5171 code and/or paying an inspection fee will get the >facility more attention from the state inspectors. The need to document (2 >years recordkeeping required) tank seal inspections becomes critical. > >For TNRCC inspectors in south and east Texas, seal inspections >on petroleum storage tanks with floating>roofs have been an item of >interest for some time. There is even a >requirement to notify the local >environmental agency 30 days in >advance of refilling a floating roof tank >or measuring the seal gap. It is likely that >the EOTT stations have not >been inspected because of the changes >in ownership, use of only 4612 SIC >code, no TNRCC account number >assigned and no inspection/emissions fee >paid. But, sometime sooner than later, the inspector will come, and you >want to be ready. > >Larry, I am very familiar with what is required with your crude >stations and am finalizing a memo which will specify exactly what is >needed. I recommend you move forward with the sugggested changes. With >regard to the seal inspections... I can do them, or I can show you what >you'll need for 100% compliance. Let me know. Thanks! - Bill Glushko 281 953-1014 >Argent > > _________________________________________________________________ Get your FREE download of MSN Explorer at http://explorer.msn.com - EOTT PL Tks 6-27.xls