Subject: Natrual Gas Release Reporting Requirements for Texas
From: [email-masked]
To: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Date: Tue, 7 Mar 2000 08:26:00 -0800 (PST)

As a reminder, the state of Texas requires releases of natural gas greater 
than 119 mscf  to the atmosphere (in a 24 hour period), to be reported to the 
Regional Offices of the TNRCC.  These releases include but may not be limited 
to the following:  ESD's, startups, shutdowns, pipeline ruptures and 
maintenance activities.  Should any of the above activities release natural 
gas in excess of 119 mscf, a written notification should be faxed to the 
Regional Office of the TNRCC  within the following timeframes:

 Unanticipated Upsets- within 24 hours after the discovery of the upset. 

 Maintenance, Startup or Shutdowns- 10 day prior to the expected exceedance.

This reminder is being sent to all ET&S teams within Texas because in the 
last two Northern Natural Gas compressor station inspections conducted by the 
TNRCC,  they specifically requested backup data and reporting documentation 
of the natural gas releases to the atmosphere which were greater than 119 
mscf.  The agency's  inquiry specifically addressed knowledge of compressor 
station venting for ESD, start ups and shutdowns.

It should also be mentioned that there has been inconsistencies in the 
TNRCC's position regarding this issue.  However, until a position has been 
adopted by Enron's GPG, I am recommending that each facility comply and 
report as appropriate.

The fax numbers for the following Regional offices are as follows:

 Midland (915)  570-4795    Included facilities-  Wt-2, Walton, Keystone, 
Lone Star Valero, Spraberry, Seminole

 Lubbock (806)  796-7107  Included facilities-  P-2, Plainview, Brownfield

 San Angelo (915)  658-5431  Included facilities- Reagan Co. 2, Irion Co. 1, 
Eldorado

Reporting forms for the release can be faxed to your location by request by 
contacting me at (505) 625-8022.