Subject: ADEQ permit revisions
From: [email-masked]
To: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Cc: [email-masked]
Date: Thu, 27 Sep 2001 12:00:00 -0700 (PDT)

As I hope all of you have heard by now, it was a very productive meeting with 
Nancy Wrona. The creative interpretations of the DEQ rules were not necessary 
as Jerry and Nancy hammered out a very date-specific sequence for the permit 
approval activities, as well as clarifying the facility-related activities he 
can do before actual permit issueance. Likely date for permit issuance is by 
Friday, November 16, but this will depend upon EPA cooperation in shortening 
its maximum time allowed for review and assuming no substantive public 
comments. Following is first draft of "thank-you" letter to Nancy from Jerry; 
edit freely:

HAND DELIVERY

Nancy Wrona
Director, Air Quality Division
3003 North Central Avenue, 5th floor
Phoenix, Arizona 85012

Re: Transwestern Pipeline, Permits No. 1001601 & 1001602
        Schedule for Permits Issuance

Dear Ms. Wrona;

Thank you again for your significant assistance in detailing a specific 
strategy to complete the process to review and approve the two permit 
revisions for the Transwestern Pipeline compressor stations near Kingman and 
Flagstaff. We were impressed with your willingness and ability to focus on 
the practical approach to improving Arizona's air quality as promptly as 
possible. Working with you and your team of Cathy O'Connell and Prabhat 
Barghava gave our team from Enron Transportation Services and Transwestern 
Pipeline Company (TWP) a strong sense of accomplishment and cooperation.

Following is the schedule that we detailed for subsequent activities:
1. By Friday morning, October 5, Prabhat and Shudeish Mahadev will have 
completed the draft permits; on Friday afternoon, October 5, the ADEQ team, 
including Prabhat and Cathy O'Connell, will conduct the internal review and 
the TSD; by close of business, Friday, October 5, ADEQ will email the draft 
permits revisions to the TWP team (Bill Kendrick, Larry Campbell and me; our 
contact numbers and email addresses are listed on the attached sheet).

2. On Tuesday morning, October 9, at 9 am Phoenix time, there will be a 
call-in conference call between the ADEQ and the TWP teams for final review, 
negotiation, and agreement on the terms and conditions of the draft permits 
revisions.

3. By Thursday, October 11, or Friday, October 12, ADEQ will do first 
publication in the daily newspapers in Mohave and Coconino Counties of the 
30-day public comment period and 30-day notice of a public hearing (at TWP's 
request) for both permits revisions in Williams AZ. Toward meeting the 
agreed-upon permits revisions schedule, TWP hereby requests a hearing on each 
revision pursuant to R18-2-330(E) and asks that ADEQ include the required 
notices of hearing in all notices of the public's opportunity to comment 
pursuant to R18-2-330(C) and ARS sec 49-444(A). Second publication will occur 
a week later. We will research and confirm the mechanics for getting the 
notices published as soon as possible after the Tuesday, October 9 conference 
call; ADEQ will promptly prepare the form of notice, unless you wish TWP to 
do it.

4. On Tuesday, November 13, ADEQ will conduct the public hearing on the two 
permit revisions in Williams AZ. We have found nothing in the statutes or 
rules that would prevent having back-to-back hearings for the Kingman and 
Flagstaff facilities' permits revisions in the same place.

5. Promptly after the October 9 conference call that finalizes the draft 
permits revisions, ADEQ will send the drafts to EPA Region IX to commence 
EPA's review. TWP will confer with the EPA contacts to shorten the maximum 45 
days allowed so that EPA will complete its review on or before Thursday, 
November 15; EPA will promptly notify ADEQ of its approval.

6. On the assumption that neither the public hearing nor the EPA review 
generated any substantive comments that require further review, ADEQ will 
issue the permits revisions by Friday, November 16.

We recognize that the foregoing schedule will require significant cooperation 
among all parties, as well as working closely with EPA, but we are confident, 
based upon yesterday's meeting, that all of us from ADEQ and from TWP are 
committed to making this doable schedule work. The TWP team will promptly 
convey to ADEQ all materials it receives relating to the EPA permits 
revisions for the Leupp and Klagetoh facilities.

We also appreciated your clarification of the facilities-related activities 
that we can proceed with prior to final permits issuance. Specifically, since 
there will be no emissions impacts from the routine maintenance of replacing 
equipment and making the srubbers' tie-ins, TWP can proceed with those 
activities at the Kingman and Flagstaff sites. Additionally, we can proceed 
with the off-site fabrication of piping.

We also understand that, at the time of the first newspaper notices, we will 
post the appropriate signs at each facility duplicating the newspaper notices.

Again, thank you very much for your assistance in setting up the foregoing 
schedule and procedures. It is a real pleasure working together to improve 
Arizona's air quality.

Sincerely yours,

Jerry D. Martin

cc. Cathy O'Connell
      Prabhat Bhargava
     Steve Burr
     Van Wolf

I will aim to get this letter out the door by mid-day Friday.
Van

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G. Van Velsor Wolf Jr.
Snell & Wilmer L.L.P.
One Arizona Center
Phoenix , Arizona 85004-2202
602.382.6201 (direct)
602.382.6000 (main number)
602.382.6070 (fax)
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