Subject: Re: Mega Rule PCB sampling - year end
From: [email-masked]
To: [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Date: Tue, 31 Oct 2000 03:07:00 -0800 (PST)

Lou - 

Below is language from EPA guidance that confirms that only liquid samples 
are required for characterization purposes.  Sue

Q: Under o761.30(i), is use of organic liquids for characterization of the 
natural gas
pipeline system required?
A: Yes. EPA,s intention was for organic liquids to be used to characterize 
the PCB
contamination in the natural gas pipeline system. EPA will make a technical 
correction to
o761.30(i)(4) to clarify this.

Q: When conducting the annual sampling under o761.30(i), what do you do if 
you don,t
have liquids present annually?
A: Under the use authorization provisions at o761.30(i), if a pipeline system 
once contained
liquids at 50 ppm or greater but is now relatively dry (i.e., there are no 
liquids available to
test at existing condensate collection points), then the owner/operator of 
the pipeline
system has no further sampling and analysis to do until such time as liquids 
appear. EPA
did not intend to require wipe sampling for characterizing natural gas 
pipeline systems in
use; hence, EPA has made a technical correction at o761.30(i)(4) to drop the 
reference to
wipe samples.  For these relatively  dry systems with no liquids, the 
sampling requirements at
o761.30(i)(1)(iii)(A)(5) don,t apply. However, EPA would expect the 
owner/operator of
the pipeline system to continue to check at least annually for liquids and 
document their
absence under the recordkeeping requirements in o761.30(i)(1)(iii)(C). Should 
any liquids
appear later, the liquids should be tested.

10/30/2000 05:43 PM
Louis Soldano
Louis Soldano
Louis Soldano
10/30/2000 05:43 PM
10/30/2000 05:43 PM
To: Butch Russell/ET&S/Enron@ENRON, Larry Campbell/ET&S/Enron@ENRON, Leo 
Nichols/ET&S/Enron@ENRON, Ron Beidelman/ET&S/Enron@ENRON, Ron 
Harkrader/ET&S/Enron@ENRON, Mike Riedel/ET&S/Enron@ENRON, Rick 
Loveless/ET&S/Enron@ENRON, William Kendrick/OTS/Enron@ENRON, Susan 
Fernandez/OTS/Enron@ENRON
cc: Rich Jolly/ET&S/Enron@Enron, Jan Cobden/ET&S/Enron@ENRON, 
[email-masked], Michel Nelson/ET&S/Enron@ENRON, Randy Rice/OTS/Enron@ENRON 

Subject: Re: Mega Rule PCB sampling - year end  

	

env guys - look over the attached and let me know your 
thoughts/changes/addititons - i also need new list of names.....

sue - can you check me on the wipe tests question???

the cc's - just fyi - for now

Butch Russell
10/30/2000 04:02 PM
To: Louis Soldano/ET&S/Enron@ENRON, Rich Jolly/ET&S/Enron@Enron
cc:  

Subject: Mega Rule PCB sampling

Mr. Lou  is it about time we did a PCB Mega Rule characterization sampling of 
the Transwestern Pipeline system west of Corona Sta # 8. I was thinking it 
was every six months that you were wanting that ? Let me know and if you do 
want a sample run done I will get it started.   thanks Butch