gw- general correspondence year(s)ocdimage.emnrd.state.nm.us/imaging/filestore/santa... · (ow-8) -...

GW-

GENERAL CORRESPONDENCE

YEAR(S):

93 0Cr 7

.H Division U N I T E D

^DEPARTMENT OF THE INTERIOR f\n 8 £&H AND WILDLIFE SERVICE

Ecological Services Suite D, 3530 Pan American Highway, NE

Albuquerque, New Mexico 87107 October 5, 1993

Permit #GW93031

Mr. William J. Lemay Director, State of New Mexico O i l Conservation Division P.O. Box 2088

Santa Fe, Mew Mexico 87504-2088

Dear Mr. Lemay:

This responds to the notice of publication received by the U.S. Fish and W i l d l i f e Service (Service) on September 15, 1993, regarding the O i l Conservation Division (OCD) discharge plan applications submitted by El Paso Natural Gas Company on f i s h , s h e l l f i s h , and w i l d l i f e resources i n New Mexico.

The Service has the following comments on the issuance of the following discharge permits.

(GW-8) - El Paso Natural Gas Company, Monument Gas Plant located i n the NW/4, Section 1, Township 20 South, Range 36 East, Lea County, New Mexico. Approximately 9,600 gallons per day of process waste water w i l l be collected and stored i n steel tanks p r i o r to disposal at an OCD approved o f f s i t e Class I I i n j e c t i o n w e l l .

(GW-46) - El Paso Natural Gas Company, Eunice Gas Plant located i n the NW/4, Section 5, Township 21 South, Range 36 East, Lea County, New Mexico. Approximately 17,000 gallons per day of cooling tower blowdown water w i l l be collected and stored i n steel tanks p r i o r t o disposal at an OCD approved o f f s i t e Class I I i n j e c t i o n w e l l .

The st e e l tanks capacities should be able t o contain a l l the water produced during periods of inclement weather when i t i s not possible to drain the tank on a regular schedule. The tanks should also ex h i b i t strong corrosion resistance t o those f l u i d s the tank w i l l store. The tanks should be exposed e n t i r e l y to v i s u a l l y detect leaks. I f leaks are detected surface s o i l monitoring and runoff prevention measures should be implemented. The permit requests also did not disclose whether the tanks were completely closed. I f the top i s open, the tank should be netted so as t o not present a p o t e n t i a l threat t o endangered species or t o migratory birds t h a t may be found i n the area.

Mr. William J . Lemay 2

I f you have any questions concerning our comments, please contact Mary Orms at (505) 883-7877.

Sincerely,

Jennifer Fowler-Propst State Supervisor

cc: Director, New Mexico Department of Game and Fish, Santa Fe, New Mexico Regional Administrator •, U. S.. Environmental Protection Agency, Dallas, Texas

NOTICE OF PUBLICATION STATE OF NEW MEXICO

ENERGY, MINERALS & NATURAL RESOURCES DEPARTMENT

OIL CONSERVATION DIVISION Notice is hereby given that pursuant to New Mexieo Water Quality Control Commission Regulations, the following discharge plan renewal application has been submitted lo the Director of the Oil Conservation Division, State Land Office.Building, P.O. Box 2088, Santa Fe, New Mexico 87504-2088, Telephone (505) 827-5800:

(GW-8) - El Paso Natural Gaa Company, Donald N. Bigbie, Vice President, 304 Texas Street, El Paso, Texas 79901, has submitted an application for renewal of a previously approved discharge plan for the Monument Gas plant located In the NW/4 Section 1 Township 20 South, Range 38 east, NMPM, Lea County, New Mexico. Approximately 9600 gallons per day of processed waste water wfth total dissolved solids at an OCD approved Class 0 Injection weU. Groundwater most likely to be affected In the event of an accidental discharge Is at a depth of approximately 35 feet wtth a total dissolved solids concentration of 500 mg/L The discharge plan addressee how apllla, leaks, and other accidental discharges to the surface will be managed.

(GW-48) • El Paso Natural Gas Company, Donald N. Bigbie, Vice President, 304 Texas Street, a Paso, Texas 78901, has submitted an application for renewal of a previously approved dicharge plan for the Eunice Gaa Plant located In the NW/4 Section 8, Township 21 South, Range 36 East, NMPM, Lea County, New Mexico. Approximately 17,000 gallons par day of cooling tower blowdown was the total dissolved solids concentration of 1300 mg/l is stored in steel tanks prior to offstte disposal at an OCD approved Class II Injection well. Groundwater most likely to ba affected In the event of an accidental dscharge Is at a depth of approximately 35 feat with total dissolved solids concentration of approximately 1000 mg/l. The discharge plan addresses how spills, teaks, and other accidental^ discharges surface will ba managed. 1 Any interested parson may obtain further information from the Oil Conservation Division and may submit! written commaras to tha Director of the Oil Conservation Division and may submit written comments to the Director of the Oil Conservation Division at the address given above. The, discharge plan application may be viewed at the above address between 8:00 a.m. and 530 p.m., Monday through Friday. Prior to ruling on any proposed discharge plan or its modification, the Director of the OUI Conservation Division shall allow at least thirty (30) days after the date oi publication of this notice during which comments may be submitted to him and public hearing may be requested by any interested person. Request for public hearing shad set forth the reasons why a hearing shall be held. A hearing will be held it the Director determines that there is public interest.

GIVEN under the Seal ot New Msxico Oil Conservation Division al Santa Fe, New Mexico, on this 2nd day of September. 1993.

STATE OF NEW MEXICO OIL CONSERVATION DIVISION

sAVUIIam J. LeMay Director

Journal: October 8,1993

STATE OF NEW MEXICO ^.CONSERv- uN DJV.SIQN County of Bernalillo ss REC:! VED

'93 OC" 12 Rfl 9 28 p , n Camobell being duly sworn declares and says that he is National Paul D Campbell being o * a n d t h a t t n i s newspaper is

b n made or Lessed as court costs; that the notice, copy of which is hereto attached, was published in said paper in the regular daily edition Zr \ times, the first publication being on the__U day o f _ ^ £ Z T l 9 9 3 , and the subsequent consecutive publications

^ o ^ n l s ^ i b S d l o b e f ^ m e , alwt^Tublic in and for the County of Bernalillo and State of New Mexico, this La day of , _ U £ i — i y y ^

S\!CG

13 (0-^3

PRICE. Statement to come al end of month

CLA-22-A(R-l/93) ACCOUNT NUMBER

Affidavit of Publiccfton

STATE OF NEW MEXICO

COUNTY OF LEA

) ss.

)

Joyce Clemens being first duly sworn on oath

deposes and says that he is M v « Director o f

THE LOVINGTON DAILY LEADER, a daily newspaper

of general paid circulation published in the English

language at Lovington, Lea County, New Mexico; that

said newspaper has been so published in such county

continuously and uninterruptedly for a period in excess

of Twenty-six (26) consecutive weeks next prior to the

first publication of the notice hereto attached as here

inafter shown; and that said newspaper is in all things

duly qualified to publish legal notices within the mean

ing of Chapter 167 of the 1937 Session Laws of the

State of New Mexico.

That the notice which is hereto attached, entitled

Notice Of Publication

M$>mrtim*&xx i«x*fto

_ mmwws <2 <t X x xJfX JH()yc w a s published in a regular and

entire issue of THE LOVINGTON DAILY LEADER and

not in any supplement thereof, oMê'lr^xW8Kx<jy{3lrW

<m»mfw*m*mw for .?.!!!L.0.Ld.?y. r^Kn^WSfS^S^ fX, beginning with the issue of

September 15 l 9 93

and ending with the issue of

September 15 ... 19.. 93

And that the cost of publishing said notice is the

48.60 sum of $ which /sum h\s been (PaidÂlSBss'eu') as Court Costs

^.ec------UJ^:^-^^ 23rd

Subscribed and sworn to before me this

of September ... 19.. 93

btary Public,' Lea County, New Mexico

My Commission Expires 1**>J*.

LEGAL NOTICE OF

PUBLICATION STATE OF NEW MEXICO

New Mexico. Approximately 17,000 gallons per day ol cooling tower blowdown water with total dissolved solids

ENERGY, MINERALS AND concentration of 1300 mg/1 NATURAL RESOURCES testoredlnsteei tanks prior to

DEPARTMENT . offsite disposal offsite at an OILCONSERVATION OCDapproved Class II injec-

DlVISION ' tton well. Groundwater most Notice Is hereby given that mealy to be affected in the pursuant to New Mexico event of an. accidental dis-Water Quality Control Com- charge is at a depth of ap-misston Regulations, the proximately 35 feet with a to-lowing discharge . platiî^M Dissolved solids concen-newal application has b e w ^ 1000 submitted to tiw Directormg/1.. The discharge plan BieCilCcnservatiatpivis^ now spills, leaks, State Land Office Buadjng., arid ofter accidental dis-P.O. Box:2D88KSaii i iifges^ jb the^surface" New MnaWTajr|o>1 l ^M be iianai^dlî,*..^^-"

- • •-&rÂ^^ ,^4lgfd^luilief fctfawnatfontom (GW-8). BPasortoturalGas jfieOPConservation Division Company, Donald N. Bigbie, ^ may submit written corn-Vice President 304>:Texas ments to ^ Director of the Street, EI Paso, Texas79901, Q|| conservation Division at has submitted an appllcatjon tMaddressgtVen above. The for renewal1 of a previously ^scnarge plan, application approved < ^ ^ ^ ^ ^ ^ v \ g ^ a at above the Monument Gas Plant kg B : 0 0 a m

through Friday. Prior to ruling Township 20 South, Range 36 East NMPM. Lea County, New Mexico. Approximately 9600 gallons per day of process wastewater with total

oh any proposed discharge plan or its modification, the Director of the Oil Conserva-i Hon Division'shall allow at!

dissolved soBda^csptra^,^,^ ton of 3500 mg/1 is stored toy jatg'of publication of this no-' steel tar*srwtotooffstea ; comments! posal ai an Cfctf approved Oassllinjecfjon wefl. Ground- hearing may be re-water most likely to be af- q u e sted by any interested fectsdintteeventofanacd- person. Requests for public cental discharge is atadepth hearing shall set forth the rea-o(approximateV35reetwilh son's why a hearing should a total dissotved soBds con- be heW. Ahearing will beheld eentraton of a^xima^j | . , j , 0 Director determines 500mg/1. The discharge plan £ £ Q fe significant p u b l l c m. addresses how spills, leaks, terest -i and other accidental dis- M i h . te h o J crêstothesurfacewiDbe L ^ S ^ S managed. A

• '% . u the Director will approve or,

disapprove the proposed plan

(GW-46) • EI Paso Natural Gas Company, Donald N.

based on information available. If a public hearing is held, the director will approve

79901, has submitted an application for renewal of a previously approved discharge plan for the Eunice Gas Plant located in the NW/4 Section

plan based on information in the plan and information sub-i mitted at the hearing. GIVEN under the Seal of New Mexico Oil Conservation

5,Townshlp21South.Range Commission at Santa Fe, 36EastNMPM,LeaCounty. New Mexico, on this 2nd day

of September, 1993. ] STATE OF NEW MEXICO OIL CONSERVATION DIVISION , ' WILLIAM J. LEMAY, • >\ Director (SEAL) | Published in the Lovington Dairy Leader September 15, 1993. !

19.. 94

nonce of PVBUCATKM STATE OF NEW MEXICO

ENERGY. MINERALS a NATURAL RESOURCES DEPARTMENT

OIL CONSERVATION DIVISION Note* • hereby g m trial pursuant to Now Mexico Waist Ouaity Control Commission Raouwnona. tna following dacnarga pan renewal appace-Bon naa been suomttad lo tna Director ot ms CX Coneerveuon OM-son. Stats Land Ontoe Btxtdng. P 0 Bo. 2068. S a m Fs. Nasi Mmrxo 87504-2088. Tewpnone (SOS) 827-5800

(OW-8) - D Psso Natural Oas Company. Donald N. Blgbra. Vlos Praerdent. 80s T a o s S u a * . El •aso, Texas 7M01. haa) i n M l W a d an application for renewal of a | NW 4 Section 1. Toamanip 20 l South, Reno* 38 Eaat, NMPM. Laa , County, Maw Maxico. Approxi- i mately 9800 gallons par day of I prncasesu weete watar arith total d issoivso sol lda at an OCD approved Class II Infection wen Groundwater moat liaary lo be a f fsc isd In the event of an accidental dlecharge ta at a depth of approummry 18 feet wrm a total dissolved solids ooocantradon of SOO me/ l The discnerga plan eddreeeee how spins, laeks, and other accidental diecnargee to tha surface wdl taa managed

(OW-48) - El Peso Natural Oaa Company, Donald N BtgtMe. Vice President. SO* Teaaa Straat D Paso, ra ise 79801. raw aubnuttad an application for renewal of a prsviousry spprovad dlcharye plan for ma Euruce Oaa Plant located In tha NW 4 Section 5, Tow nan lp 21 South. Range M Eaat. NMPM. Laa County, Near Mai ico Appro maisly 17.000 geHona por day or cooling tower blowdown wee the

don of 1300 mg/l la stored In steal tanas pnor to often* d lap oas I at an | OCO approved Case* I Injection wall OVounOWeaar most Isaty to be

effected In t h * event of en •ccJamal dacnaygo le at e depot of appioiswewiy IS feet arlth a

1000 m g i The dUcnorge pain atxlreasss how spuls. leaaa. and other accidental diacnargee surface wis be men- '

« f | intenxeted pareon may ootan further irvorrneoon from ow ON Corv lervsoon Dfvaaon end may autmi wrtnen oommersa lo the Director of the 01 Conservation Dtvaxon and may euOmt wrtten comment* 10 tha Director ol the Oil Conserva!ion Division et the • r vven given above. The dacnarga pan apparennn may De vwwad at the above eddrsee twtwsan eoo a m and 800 p m . Monday through Friday Pnor to rueng on any proposed dacnerge pan or ta mod-ficenon. me Director of the 01 r n f e u e m n Dtvaaon anal alow at wast Dwty (301 days after me dale of puoacapon of thai during when comments may be euornoed to nan and puouc naarmg may be requested Oy any mtarsetad parson. Requ est sx puotc neanng anal aet form the raaaone why a neenng enel be raid A heemg ara be nerd I the Director doterrranas mat mare • puotc m-tareet.

OWEN under the Seel of New Ueico CM Conservation Drvaon at Senta Fe. New Maxico. on (ha) 2nd aay ol Saptemoer. i f l M

STATE OF NEW MEX CO OIL CONSERVATION DIVISION

srWIaam J. LeMay Dreccr

Journal: September 22. 1803

STATE OF NEW MEXICO County of BcrnaJi llo s s

^ • » » V a , a p , e H 6 7 . S J s ^ been nude or assessed as c o u n c o s c s ' " ? " ' a ' , t e r e f ° ' = "as

" l ' l - U m c s - , h e first Publication being on the 3 Q H a v

- A ^ T ^ , and m s u b s c q u e n l c o n s e c u , f v e p u b ^ - ^ -- j t<? I Q Q K ^ 7

Sworn and subscribed to before me. a notary Public in and for the Countyof Bernalillo and State of New Mex,co. to*_a&_<to, of . ^ 0 _ . 9 < n

< u ~ ORTIZ ' -''-.-CHtW.'-IOlCO

" u 'tssaEXw * -757' PRICE.

Slaiement to come al end of monih.

Cl

CLA-22-A (R-1/93) ACCOUNT N U M B E R _ _ £ ^ J l £ M _

^ 5/92 State of New Mexico

Energy, Minerals and Natural Resources Department OIL CONSERVATION DIVISION

P.O. Box 2088 Santa Fe, NM 87501

DISCHARGE PLAN APPLICATION FOR NATURAL GAS PROCESSING PLANTS, OIL REFINERIES AND GAS COMPRESSOR STATIONS^^ (Refer to OCD Guidelines for assistance in completing the applicaaoki^^L-^ T., if \ff t^jC))

I. TYPE: Eunice Station - Natural gas compression SEP Q 7 1993

SANTA FE II. OPERATOR: El Paso Natural Gas Company Oil COiw M n;V

ADDRESS: P. 0. Box 1492, El Paso, Texas, 79978

CONTACT PERSON: Mr. Philip L. Baca PHONE:915/541-2323

III. LOCATION: l °M 6 ' ^ ^t ion 5_ Township 21-S Range 36-E Submit large scale topographic map showing exact location.

IV. Attach the name and address of the landowner(s) of the disposal facility site.

V. Attach description of the facility with a diagram indicating location of fences, pits, dikes, and tanks on the facility. !

VI. Attach a description of sources, quantities and quality of effluent and waste solids.

VII. Attach a description of current liquid and solid waste transfer and storage procedures.

VIII. Attach a description of current liquid and solid waste disposal procedures.

IX. Attach a routine inspection and maintenance plan to ensure permit compliance.

X. Attach a contingency plan for reporting and clean-up of spills or releases.

XI. Attach geological/hydrological evidence demonstrating that disposal of oil field wastes will not adversely impact fresh water. Depth to and quality of ground water must be included.

XII. Attach such other information as is necessary to demonstrate compliance with any other OCD rules, regulations and/or orders.

XIII. CERTIFICATION

I hereby certify that the information submitted with this application is true and

correct to the best of my knowledge and belief.

Name: Lori A. Saylor Title:Compliance Engineer

Signature: ^ ^ u . &%r. Date: nq-ny-q^

DISTRIBUTION: Original and one copy to Santa Fe with one copy to appropriate Division District Office.

El Paso ONE PETROLEUM CENTER / BUILDING TWO 3300 NORTH "A" STREET MIDLAND, TEXAS 79705 Natural Gas Companij

September 2, 1993

Mr. Roger Anderson New Mexico Oil Conservation Division State Land Office Building 310 Old Santa Fe Trail Santa Fe, New Mexico 87504

SEP 0 7 1993

Subject: El Paso Natural Gas Company's Eunice Station Discharge Plan GW-46 Renewal Application

Dear Mr. Anderson:

El Paso Natural Gas Company (EPNG) is submitting for your review the Discharge Plan GW-46 Renewal for the EPNG Eunice Gas Compressor Station, located in Lea County, New Mexico. Enclosed please find two copies of the renewal application. In addition, enclosed please find a check in the amount of $50.00 required by the NMWQCC as a filing fee assessment.

If there are any questions or comments regarding this subject or if additional information is found necessary, please feel free to contact me at 915/686-3226.

Enclosures

cc: New Mexico Oil Conservation Division District 1 - Hobbs Office P. O. Box 1980 Hobbs, NM 88240 Attn: Mr. Jerry Sexton

Sincerely,

Lori A. Saylor, Engineer Environmental Compliance Engineering

NOTICE OF PUBLICATION

STATE OF NEW MEXICO ENERGY, MINERALS AND NATURAL RESOURCES DEPARTMENT

OIL CONSERVATION DIVISION

Notice is hereby given that pursuant to the New Mexico Water Quality Control Commission Regulations, the following discharge plan applications have been submitted to the Director of the Oil Conservation Division, State Land Office Building, P.O. Box 2088, Santa Fe, New Mexico 87504-2088, Telephone (505) 827-5800:

(GW-8) - El Paso Natural Gas Company, Donald N. Bigbie, Vice President, 304 Texas Street, El Paso, Texas 79901, has submitted an application for renewal of a previously approved discharge plan for the Monument Gas Plant located in the NW/4 Section 1, Township 20 South, Range 36 East, NMPM, Lea County, New Mexico. Approximately 9600 gallons per day of process wastewater with total dissolved solids concentration of 3500 mg/l is stored in steel tanks prior to offsite disposal at an OCD approved Class II injection well. Groundwater most likely to be affected in the event of an accidental discharge is at a depth of approximately 35 feet with a total dissolved solids concentration of approximately 500 mg/I. The discharge plan addresses how spills, leaks, and other accidental discharges to the surface will be managed.

(GW-46) - El Paso Natural Gas Company, Donald N. Bigbie, Vice President, 304 Texas Street, EI Paso, Texas 79901, has submitted an application for renewal of a previously approved discharge plan for the Eunice Gas Plant located in the NW/4 Section 5, Township 21 South, Range 36 East, NMPM, Lea County, New Mexico. Approximately 17,000 gallons per day of cooling tower blowdown water with total dissolved solids concentration of 1300 mg/l is stored in steel tanks prior to offsite disposal offsite at an OCD approved Class II injection well. Groundwater most likely to be affected in the event of an accidental discharge is at a depth of approximately 35 feet with a total dissolved solids concentration of approximately 1000 mg/l. The discharge plan addresses how spills, leaks, and other accidental discharges to the surface will be managed.

#

Any interested person may obtain further information from the Oil Conservation Division and may submit written comments to the Director of the Oil Conservation Division at the address given above. The discharge plan application may be viewed at the above address between 8:00 a.m. and 5:00 p.m., Monday thru Friday. Prior to ruling on any proposed discharge plan or its modification, the Director of the Oil Conservation Division shall allow at least thirty (30) days after the date of publication of this notice during which comments may be submitted to him and public hearing may be requested by any interested person. Request for public hearing shall set forth the reasons why a hearing shall be held. A hearing will be held if the director determines that there is significant public interest.

If no hearing is held, the Director will approve or disapprove the plan based on the information available. If a public hearing is held, the Director will approve the plan based on the information in the plan and information presented at the hearing.

GIVEN under the Seal of New Mexico Oil Conservation Divisiom at Santa Fe, New Mexico, on this 2nd day of September, 1993.


SEAL

ACKNOWLEDGEMENT OF RECEIPT OF CHECK/CASH

I hereby acknowledge receipt of check dated ^/9-/c/3 ,

or cash received on ct fo in the amount of $ 30-00

from Ef /On So NcchjLt'/.i I Gd<; Co^psi^^

for E Gc<> Plan r (Feoliiy Hvmi

Submitted by:

Submitted to ASD by

Received i n ASD by xrtnr.tif flhki.

Date: (DPNs.1

.Date:

Date;

F i l i n g Fee \c* New Facility Renewal

Modification other

Organization Code S 3 ^0~7 Applicable FY 9 *V

To be deposited in the Water Quality Management Fund.

Full Payment or Annual Increment

Natural Gas Compani)

P.O. BOX 1492 EL PASO, TX 79978

PAYABLE AT CITIBANK DELAWARE A SUBSIDIARY OF CITICORP ONE PENN'S WAY NEW CASTLE, DE 19720

CONTROL NO.

232 CBD

62-20 311

CHECK NO.

007247388 *

09/02/93 Date

PAY TO THE ORDER OF

r NEW MEXICO WATER QUALITY MANAGEMENT P O BOX 2088 SANTA FE NM 87504

L j

PAY A M O U N T

$50 .00 Void After 1 Year

Authorized Signatory

l l i n D 1 I n m a m • e r-i - i 1 i < — i n i r i r - i . e - ! n n i n m

STATE OF NEW MEXICO

ENERGY, MINERALS AND NATURAL RESOURCES DEPARTMENT OIL CONSERVATION DIVISION

ANITA LOCKWOOD CABINET SECRETARY

BRUCE KING GOVERNOR

November 9, 1993

POST OFFICE BOX 208B STATE LANO OFFICE BUILDING

SANTA FE. NEW MEXICO 87504 (505) 837-5800

CERTIFIED MAIL RETURN RECEIPT NO.P-l11-334-279

Ms. L o r i Saylor El Paso Natural Gas Company One Petroleum Center/Building One 3300 N. "A" Street Midland, Texas 79705

RE: Discharge Plan GW-46 Eunice Compressor Station Lea County, New Mexico

Dear Ms. Saylor:

The New Mexico O i l Conservation Division (OCD) has received the discharge plan renewal application dated October 11, 1993 f o r the above referenced f a c i l i t y . The following request f o r additional information and commitments are based on a review of the appl i c a t i o n , the previously approved discharge plan and observations made during the September 28, 1993 OCD inspection of the f a c i l i t y .

The s i t e inspection revealed the lube o i l storage tank was inside a containment w a l l t h a t d i d not have concrete f l o o r i n g . Propose a method t o ensure t h a t contaminants do not reach the ground and become available f o r leaching i n t o the subsurface.

Submittal of the requested information and commitment i n a timely fashion w i l l expedite the f i n a l review of the application and approval of the discharge plan renewal.

I f you have any questions, please contact me at (505) 827-5824.

Sincerely,

Chris Eustice Geologist

xc: Hobbs OCD Office

STATE OF NEW MEXICO

ENERGY, MINERALS AND NATURAL RESOURCES DEPARTMENT


ir

BRUCE KING POST OFFICE BOX 2088 STATE LAND OFFICE BUILDING


GOVERNOR

ANITA L O C K W O O D CABINET SECRETARY

January 27, 1993

CERTIFIED MAIL RETURN RECEIPT NO.P-111-334-302

Mr. Donald Payne, Manager North Region Compliance Engineering El Paso Natural Gas Company P. O. Box 1492 El Paso, Texas 79978

RE: Discharge Plan GW-46 Eunice Mainline Engine Room Lea County, New Mexico

Dear Mr. Payne:

On June 6, 1989, the groundwater discharge plan , GW-46 for the Eunice Mainline Engine Room located in the NW/4 of Section 5, Township 21 South, Range 36 East, NMPM, Lea County, New Mexico, was approved by the Director of the Oil Conservation Division (OCD). This discharge plan was required and submitted pursuant to Water Quality Control Commission (WQCC) regulations and was approved for a period of five years. The approval will expire on October 11, 1993.

If your facility continues to have potential or actual effluent or leachate discharges and you wish to continue operations, you must renew your discharge plan. The OCD is reviewing discharge plan submittals and renewals carefully and the review time can extend for several months. Please indicate whether you have made, or intend to make, any changes in your discharge system, and if so, please include these modifications in your application for renewal.

+ Mr. Donald Payne January 27, 1993 Page 2

Note that the completed and signed application form must be submitted with your discharge plan renewal request.

If you no longer have any actual or potential discharges please notify this office. If you have any questions, please do not hesitate to contact Chris Eustice at (505) 827-5824.

Sincerely,

Roger C. Anderson Environmental Bureau Chief

RCA.cee

xc: OCD Hobbs Office

El Paso Natural Gas Compantj

P. O. BOX 1492 EL PASO, TEXAS 79978 PHONE: 915-541-2600

William J. LeMay, Director State of New Mexico Oil Conservation Division P.O. Box 2088 State Land Office Bunding Santa Fe, New Mexico 87504

July 18, 1989

JUL 2 3 198B

OIL cQflsmmm m

Re: Discharge Plan GW-46 Eunice Mainline Engine Room, Lea County, New Mexico

Dear Mr. LeMay:

In response to your letter of June 6, 1989, El Paso completed the design of the berming for the aboveground tanks and the drum storage containment on May 17, 1989. The construction is scheduled to begin on July 21, 1989 and should be completed by August 14.

With the submission of this timetable, i t is El Paso's understanding that the discharge plan for Eunice Mainline Engine Room has been approved and will not expire until October 11, 1993.

I f you have any questions concerning this timetable, please contact me at (915) 541-5399.

Very truly yours,

Donald R. Payne, P.E. Manager, Compliance Engineering

mts

c: K.E. Beasley D.N. Bigbie J. Hill W.A. Johnson J.R. Midkiff J.W. Somerhalder H. Van J.P. Wheeler

STATE OF NEW IVIEXICO


GARREYCARRUTHERS POST OFFICE BOX 2088 STATE LAND OFFICE BUILDING

SANTA FE. NEW MEXICO 87504 (505) B27-5B00

GOVERNOR

June 6, 1989

CERTIFIED MAIL RETURN RECEIPT NO. P-106-675-533

Mr. Donald N. Bigbie 4 Vice President, North Region EL PASO NATURAL GAS COMPANY P. 0. BOX 1492 El Paso, Texas 79978

RE: Discharge Plan GW-46 Eunice Mainline Engine Room Lea County, New Mexico

Dear Mr. Bigbie:

The ground water discharge plan (GW-46) renewal for the El Paso Natural Gas Company's Eunice Mainline Engine Room located i n the NW/4 of Section 5, township 21 South, Range 36 East, NMPM, Lea County, New Mexico, i s hereby approved with the following conditions:

1. A timetable for the design and construction of the berming for above ground tanks w i l l be submitted for review by July 30, 1989.

2. A timetable for the design and construction of drum storage containment w i l l be submitted for review by July 30, 1989.

The o r i g i n a l discharge plan was approved on October 11, 1983 and expired on October 11, 1988.s. The renewal application consists of the o r i g i n a l discharge plan as approved October 11, 1983, the application Elated October, 1988 and materials dated A p r i l 17, 1989 submitted as supplements to the renewal application.

The discharge plan renewal was submitted pursuant to Section 3-106 of the New Mexico Water Quality Control Commission Regulations. I t is renewed pursuant to Section 3-109.F., which provides for the possible future amendments of the plan. Please be advised that the approval of t h i s plan does not relieve you of l i a b i l i t y should your operation result i n actual p o l l u t i o n of the environment which may be actionable under other laws and/or

V regulations.

— j

There w i l l be no routine monitoring or reporting requirements.

Mr. Donald N. Big; June 6, 1989 Page -2-

Please note that Section 3-104 of the regulations requires that "when a plan has been approved, discharges must be consistent with the terms and conditions of the plan." Pursuant to Section 3-107.C, you are required to n o t i f y the Director of any f a c i l i t y expansion, production increase, or process modification that would result i n any change i n the discharge of water q u a l i t y or volume.

Pursuant to Section 3-109.G.4, this plan approval i s for a period of f i v e (5) years. This approval w i l l expire October 11, 1993, and you should submit an application for renewal i n ample time before that date. I t should be noted a l l gas processing plants and o i l re f i n e r i e s i n excess of twenty-five years of age w i l l be required to submit plans f o r , or the results of an underground drainage testing program as a requirement for discharge plan or renewal.

On behalf of the s t a f f of the Oil Conservation Division, I wish to thank you and your s t a f f for your cooperation during t h i s discharge plan review.

Sincerely,

William J. Director

WJL/RCA/sl

cc: OCD Hobbs Office Henry Van - EPNG, El Paso D. R. Payne - EPNG, El Paso

El Paso P. O. BOX 1492 EL PASO, TEXAS 79978 PHONE. 915-541-2600 Natural Gas Companq

ay 22, 1989

Mr. Roger C. Anderson Environmental Engineer New Mexico Oil Conservation Division 310 Old Santa Fe Trail, 206 Santa Fe, NM 87504

JUN -2 1989

Re: Discharge Plant GW-46 and GW-8 EPNG Eunice and Monument Gas Plants

Dear Mr. Anderson:

During your May 22 telephone conversation with Henry Van, you asked about the dry and wet analysis conducted on the soil samples taken by the cooling towers at the above mentioned f a c i l i t i e s .

The specific conductance of the soil sample is f i r s t analyzed in the dry stage to record the "as received" condition of the s o i l . Measured amounts of d i s t i l l e d water are added to the sample to moisten the soil u n t i l the sample becomes normalized. At this stage the sample is again analyzed for specific conductance and recorded as the wet analysis. Of the two recorded readings, the wet analysis is the o f f i c i a l reading. The electrical conductivity testing has indicated that most of the salts have been retained in the upper two feet of the soil tested.

The cooling towers at both Eunice and Monument Plants have undergone maintenance repairs. This w i l l reduce the ponding caused by the over spray during the windy months. The following partial l i s t includes the work completed at both locations:

• The Water Distribution System - At Eunice replaced with a new system. At Monument, the system has been completely cleaned and repaired.

• Drift Pans (Top) - At both Eunice and Monument have been cleaned out and a 6" layer of honey cone plastic sheet has been installed to help control water flow. (Draft Eliminator).

• Field Pans (Bottom) - At both locations have been cleaned out and a 12" layer of honey cone plastic sheet installed to break the water flow. (Draft Eliminator).

• Wind Wall - A new Wind Wall has been installed for the Eunice cooling tower, the Wind Wall for Monument was reconditioned.

• Cooling Tower Joist Supports - At both locations some have been replaced, others repaired.

• Cooling Tower Doors - At both locations some minor repairs and recondition have been done.

May 22, 1989 Mr. Roger C. Anderson Page 2

If you have any questions or i f I may be of further assistance, please call me at (9i5) 541-2407.

Sincerely,

Osias Uribe

Environmental Technician Environmental & Safety Affairs Department OU/teb cc: L.J. Meyer

G. J. Odegard D.R. Payne H. Van f i l e : 5000, 5007

P.O. BOX 1492 EL PASO, TEXAS 79978

PHONE: 915-543-2600

ALEXANDER H. CARAMEROS VICE PRESIDENT

Mr. William J. LeMay, Director Energy, Minerals and Natural Resources Department New Mexico Oil Conservation Division

September 23, 1988

310 Old Santa Fe Trail #206 /• ;\:'}'- '\ Santa Fe, NM 87504 1

RE: Discharge Plan GW-46 for El Paso Natural Gas Company - Eunice Plant Mainline Engine Room

Dear Mr. LeMay:

Enclosed for your review is the completed Discharge Plan for the El Paso Natural Gas Company Eunice Plant Mainline Engine Room. The plan details proposed methods and techniques to ensure compliance with the New Mexico Water Quality Act and New Mexico Water Quality Control Commission Regulations.

El Paso respectfully requests approval of this plan and w i l l meet with agency personnel whenever necessary should clarification or further information be required. Information requests should be directed to Mr. Donald R. Payne, Manager of Compliance Engineering for the South Region at (915) 541-5399.

Thank you for your consideration in this matter.

Very truly yours,

EL PASO NATURAL GAS COMPANY

Alexander H. Carameros Vice President

AHC:cds

Enclosure

'^Aient Department BUSlON

New Mexico Health and Envj SCIENTIFIC LABORATORY 700 Camino de Salud NE Albuquerque, NM 87106 — (505) 841-2555

^ 0

GEWBRAL WATER CHEMISTRY and NITROGEN ANALYSIS

CODE • 59300 • 59600 & OTHER: 8 2 2 3 5 Collection OATE _

Collection TIME .

SITE INFORM- »•

ATION

Sample location

Collected by — Person/Agency

V^Wj^/&h? / 0 C D

Collection site description

SEND FINAL REPORT TO

ENVIRONMENTAL BUREAU NM OIL CONSERVATION DIVIS State Land Off ice Bldg, PO Santa Fe, NM 87504-2088^

Attn:—David Roypr 1

Phone: 827-5812 SAMPLING CONDITIONS

Owner J '

• Bailed ^ D i p p e d

• Pump • Tap

Water level Sample type

pH (00400) Conductivity (Uncorrected) Water Temp. (00010) Conductivity at 25 °C (00094) ^mho

Field comments

SAMPLE FIELD TREATMENT — Check proper boxes No. oi samples i submitted / .A'

l^p. Whole sample (Non-filtered)

• F: Filtered in field with 0.45 \ i membrane filter

• A: 2 ml H2S04/L added

15<NA: No acid added • Other-spec/ : •A: 5ml conc. HN03 added • A: 4ml fuming HN03 added

ANALYTICAL RESULTS from SAMPLES NA Units Date analyzed

H ( Conductivity (Corrected) / 25 °C (00095) 2399 ;,mhn \7~\\<\

• Total non-filterable residue (suspended) (00530)

^ Other.

• Other:

• Other:

mg/l

A-H2SQ4

• Nitrate-N+ , Nitrate-N total (00630)

• Ammonia-N total (00610)

• Total Kjeldahl-N ( )

• Chemical oxygen demand (00340)

• Total organic carbon ( )

• Other: • Other:

mg/l

mg/l

mg/l

mg/l

mg/l

From , NA Sample:

Calcium J 3 m g / 1

^Potassium

Magnesium

Sodium

Date Analyzed

ujosr

S3* I mg/l

mg/l 1 ^

Bicarbonate Chloride

0 \ Sulfate

57.3 mg/1 \zj\3> Z^(_mg/1_

mg/1

a Total Sol i ds mg/1 \zj\Z

E S Q * •• f— [203 •

a t ion /An ion Balance Analyst Date Reported Revie^wsdl^^

Laboratory remarks

FOR OCD USE — Date Owner Notified Phone or/Letter?) I n i t a

CATIONS

ANALYTE MEQ. PPM DET.

LIMIT |

ANIONS

ANALYTE MEQ. PPM DET.

LIMIT

Ca 16.57 332.00 <3.0 | HC03 0.94 57.30 <1. 0 Mg 4.36 53.10 <0.3 j S04 20.40 979.00 <10. 0 Na 8.48 195.00 <10.0 j CL 5.90 209.00 <5.0 K 0.90 35.00 <0.3 j

Mn 0.00 0. 00 | NO 3 0.00 0. 00 < 0. Fe 0.00 0. 00 j C03 0.00 0. 00 < 1.

| NH3 0.00 0.00 < 0.

1 P04 0.00 0.00 < 0.

SUMS 30.31 615.10 27.23 1245.30

T o t a l Dissolved Solids= 2144 | Ion Balance = 111.29% WC No. = 88.0.4772

Date out/By

HEAVY 0 E T A L ANALYSIS FORM Telephone: (505)841-2553

Date Received

User Code • 82235 • Other;

COLLECTION DATE & TIME: CO CTION SITE DES PTION

OWNER:

ENVIRONMENTAL BUREAU CSL COWSE NM OIL CONSERVATION DIVISK State Land Office Bldg., PO Box 2088 SANTA FE, NM 87504-2088

SITE LOCATION: County: LCs#_

$27-58

Township, Range, Section, Tract: (10N06E24342)

ATTN TELEPHONE: 827-5812 STATION/ WELL C O D E : l l l l

LATITUDE, LONGITUDE:1 I I I 1 1 1 1 I 1 I 1 -1 I I I SAMPLING CONDITIONS:

• Bailed Dipped

pH(00400)

• Pump • Tap

Water Level:

Conductivity(Uncorr.)

) M D Pmho

Discharge:

Water Temp.(00010)

Sample Type:

o— Conductivity at 25 C (00094)

',- jumho FIELD COMMENTS:

SAMPLE FIELD TREATMENT Check proper boxes:

LAB ANALYSIS REQUESTED:

pf WPN: Water Preserved w/HNQ_ Non-Filtered

• WPF: Water Preserved w/HNO, F i l t e r e d

I CAP Scan Mark box next t o metal i f AA i s required.

ANALYTICAL RESULTS (MG/L) ELEMENT ICAP VALUE AA VALUE ELEMENT ICAP VALUE AA VALUE Aluminum oA S i l i c o n Barium 0.2- S i l v e r • Beryllium <lo. / Strontium 2.3 Boron o.4 Tin Cadmium <c,\ n Vanadium o, 1 Calcium Zinc tf.i Chromium e>. 1 Arsenic n Cobalt jrt, Selenium • Copper Mercury n Iron n Lead <o.\ • n Magnesium • Manganese n Molybdenum

•<* / •

Nickel n LAB COMMENTS:

For OCD Use: Date Owner Notified:

Phone or Letter? I n i t i a l s :

ICAP Analyst

Date Analyzea/i

Reviewer

Date Revi

STATE OF NEW MEXICO


GARREY CARRUTHERS GOVERNOR

December 22, 1988

POST OFFICE BOX 2088 STATE LAND OFFICE SUILOING

SANTA FE, NEW MEXICO 87504 (5051 827-5800

CERTIFIED_MAIL RETURN RECEIPT REQUESTED

Mr. Charles W. Hagen, Vice P r e s i d e n t EL PASO NATURAL GAS COMPANY South Region P. 0. Box 1492 El Paso, Texas 79978

RE: Discharge Plan GW-46 Eunice M a i n l i n e Engine Room

Dear Mr. Hagen:

The O i l Con s e r v a t i o n D i v i s i o n (OCD) i s i n the process of r e v i e w i n g the above-referenced d i s c h a r g e p l a n renewal a p p l i c a t i o n . The renewal a p p l i c a t i o n , dated October 1988, was r e c e i v e d by the OCD on September 30, 1988. The f o l l o w i n g comments and re q u e s t s f o r a d d i t i o n a l i n f o r m a t i o n are based on our review of the data p r o v i d e d i n the a p p l i c a t i o n and o b s e r v a t i o n s d u r i n g the OCD s i t e v i s i t on November 29, 1988.

££t ion_3_:_ IIIIii£H£_i£HI£££2_ !li£££i£lilii££_iBi_£li££i£i

1. S e c t i o n 3.2.4 s t a t e s storm water i s c o l l e c t e d i n open d r a i n s and d i s c h a r g e d t o grade. Does t h i s i n c l u d e storm water t h a t f a l l s on or f l o w s through process areas? Does the storm water e n t e r any c o n d u i t s t h a t leave your p r o p e r t y ? I f so, i d e n t i f y where the storm water u l t i m a t e l y ends up.

2. S e c t i o n 3.3.2 s t a t e s Table 3-2 l i s t s the chemicals used a t the f a c i l i t y and Appendix A c o n t a i n s the MDS Sheets f o r chemicals not l i s t e d i n the 1983 p l a n . The f o l l o w i n g i s a l i s t of the MDS sheets not present or inc o m p l e t e i n the 1983 p l a n or the renewal a p p l i c a t i o n .

1. A n t i p a l - 6 6 2 2. Toxene 37 3. Hydrochem A-239 ( i n c o m p l e t e )

Mr. Charles W. Ha December 22, 1988 Page -2-

S ect ion_6_ 1 M£2.il££iH£_£.H^._B.£££££i:E.8.

1. T his s e c t i o n s t a t e s annual sampling and a n a l y s i s of the wastewater stream w i l l be conducted. Please supply the OCD w i t h the r e s u l t s of the a n a l y s i s .

2. This s e c t i o n a l s o s t a t e s the sludge from the c o o l i n g tower and c l a s s i f i e r w i l l be e v a l u a t e d and disposed of i n an approved l a n d f i l l . OCD a p p r o v a l w i l l be r e q u i r e d p r i o r to d i s p o s a l of these sludges. Please supply the a n a l y t i c a l r e s u l t s and e v a l u a t i o n of the sludges and how and where you propose to dispose of the sludges f o r OCD a p p r o v a l p r i o r to d i s p o s a l .

M_i s c e 1_ 1 a n e o us_

1. Are t h e r e any below grade or underground tanks o t h e r than the c l a s s i f i e r ?

2. Are a l l above grade tanks bermed to c o n t a i n one t h i r d more than the tank volumes?

3. Are t h e r e any t i l e d rainage c o n d u i t s i n use? How o l d are they? How are they t e s t e d ? What areas do they d r a i n and to where ?

4. Are a l l process and storage areas bermed and/or curbed? Are the bermed and/or curbed areas a l s o paved to prevent s p i l l e d l i q u i d i n f i l t r a t i o n ?

5. I s t h e r e an SPCC p l a n i n e f f e c t at t h i s f a c i l i t y ? I f so, please p r o v i d e a copy.

6. Where and how do you dispose of s o l i d wastes ( i . e . f i l t e r media, s l u d g e s , t r a s h , f i l t e r elements, e t c . ) ?

7. The c o o l i n g towers showed evidence of excessive spray d r i f t i n g and ponding of water at the base of the tower. How do you p l a n to e l i m i n a t e or c o n t a i n and i s o l a t e t h i s ponding to p r e v e n t i n f i l t r a t i o n of the water i n t o the ground?

8. The st o r a g e pads f o r t r e a t m e n t chemicals at the c o o l i n g towers have i n s u f f i c i e n t containment i n the event of tank f a i l u r e . What a c t i o n s w i l l be taken to i n c r e a s e containment volume c a p a b i l i t y ?

9. Drum st o r a g e areas throughout the f a c i l i t y have no containment or pads. What a c t i o n s w i l l be taken t o prevent any s p i l l s or leaks from i n f i l t r a t i n g i n t o the ground?

1 Mr. Charles W. Ha December 22, 1988 Page -3-

10. Some of the v a l v e s f o r the o i l c o o l i n g water showed evidence of leaks at the m a n i f o l d east of the c o o l i n g tower. Submit a p l a n f o r the e l i m i n a t i o n and/or containment of any leaks and f o r the cl e a n up of the s o i l where p r e v i o u s leaks have o c c u r r e d .

The submission of the i n f o r m a t i o n requested and commitments to c o r r e c t d e f i c i e n c i e s w i t h reasonable t i m e t a b l e s w i l l a l l o w the review of your a p p l i c a t i o n t o c o n t i n u e .

I f you have any q u e s t i o n s , please c o n t a c t me at (505) 827-5884.

S i n c e r e l y ,

•''0''-=/>^—' C„ 6. z'/*rt , Roger C. Anderson Env i r o n m e n t a l Engineer

RCA/sl

cc : OCD - Hobbs O f f i c e Donald R. Payne - EPNG H. Van - EPNG

UNITED STATES DEPARTMENT OF THE INTERIOR

FISH AND WILDLIFE SERVICE Ecological Services

Suite D, 3530 Pan American Highway, NE Albuquerque, New Mexico 87107

November 15. 1988

Mr. William J. Lemay, Director New Mexico Energy, Minerals and Natural Resources Department Oil Conservation Division State Land Office Building 310 Old Santa Fe T r a i l , Room 206 Santa Fe, New Mexico 37503

Dear Mr. Lemay:

This responds to your public notice received October 27, 1938 in which several proposed groundwater discharge plans were described. We have reviewed the plans and have not identified any resource issues of concern to our agency in the following:

GW-8, El Paso Natural Gas Company, Monument Gas Plant, Lea County, NM. GW-9, Phillips 66 Natural Gas Company, Eunice EP Gas Plant, Lea County, NM. GW-10, El Paso Natural Gas Company, Jal No. 3 Gas Plant, Lea County, NM. GW-46, El Paso Natural Gas Company, Eunice Main Line Engine Room, Lea

County, NM. TNT Construction Inc., Rio Arriba County, NM.

Discharge plan GW-49 is for El Paso Natural Gas Company's Blanco Plant located approximately 1 1/2 miles northeast of Bloomfield, New Mexico. El Paso Natural Gas Company proposes to close i t s unlined process ponds and discharge approximately 119.900 gallons per day of process and cooling tower wastewater to the Bloomfield Municipal Wastewater Treatment Plant.

The Bloomfield Municipal Wastewater Treatment Plant discharges i t s treated effluent to the San Juan River. The San Juan River from the Hammond Diversion upstream of Bloomfield to Farmington may provide habitat for the Federally endangered Colorado squawfish. Surveys conducted downstream of Farmington have documented the presence of both adult and juvenile squawfish in the San Juan River. The section of the San Juan River from Bloomfield to Farmington has a high likelihood of the presence of squawfish as well as other f i s h and aquatic organisms of importance to the rivers ecological balance.

The Bloomfield Wastewater Treatment Plant has received NPDES reauthorization (permit number NM0020770), to discharge to the San Juan River in Segment No. 2-401. The Fish and Wildlife Service would obiect to the addition of any new pollutants into the treatment works from an indirect discharger, such as the El Paso Natural Gas Company's Blanco Plant, that would cause an increase in biochemical oxygen demand, an increase i n t o t a l dissolved solids, or a pass-through of toxic or hazardous materials. The effluent limitations of NPDES permit number NM 0020770 must not be exceeded as a result of the addition of the process and cooling tower wastewater.

These comments represent the views of the Fish anc. Vil<t\: have any questions, please contact Terr. 0'3rien at (505' c 7877..

Sincerel~ yours.

cc: Director. New Mexico Department of Game and Fish, Santa F-- New Mex:<*o Regional Administrator. Environmental Protection Agency. Dallas. Texas DJ rector. Environmental Improvement Division, New Mexico Health and

Environmental Department. Santa Fe, New Mexico Regional Director. U.S. Fish and Wildlife Service. Fish and Wildlife Enhancement. Alauqueraue. New Mexico

i6r< •7S7"

AFFIDAVIT OF PUBLICATION

State of New Mexico, County of Lea.

of the Hobbs Daily News-Sun, a daily newspaper published at Hobbs, New Mexico, do solemnly swear that the clipping attached hereto was published once a week In the regular and entire issue of said paper, and not a supplement thereof for a period

of_

-One-Beginning with the issue dated

and ending with the issue dated

Or-t-nhpi- 9H

Publisher. Sworn and subscribed to before

me this_

Notary Public.

My Commission expires

November 14 [Seal)

, 1988_

This newspaper is duly qualified to publish N'nal notices ur adver-tisenients within the meaning of Section 3, Chapter 167, Laws of 1937, and payment of fees for said publication has been made.

L E G A L N O T I C E October IS, 1*88

N O T I C E O F P U B L I C A T I O N

S T A T E O F N E W M E X I C O E N E R G Y , M I N E R A L S

A N D N A T U R A L R E S O U R C E S

D E P A R T M E N T O I L C O N S E R V A T I O N

D I V I S I O N Not i ce is hereby Qlven

that pu rsuan t to Ihe New M e x i c o W a t e r Q u a l i t y Cont ro l Commiss ion Regula t ions , Ihe f o l l o w i n g disc h a r g e p l a n h a s b e e n s u b m i t t e d fo r r enewa l to the D i r e c t o r ot t h e O i i C o n s e r v a t i o n D i v i s i o n , State Land O f f i ce B u i l d i n g , 310 O ld Santa Fe T r a i l , Room 206, Santa Fe , New M e x i c o 87503, Te lephone (JOS) B27M00: .

( G W - 8 ) E l P a s o N a t u r a l Gas Comp a n y , D o n a l d N . B igb ie , V ice Pres i dent , No r th Region,

• P. O. Box 1492, E l Paso, Texas , 79978, h a s s u b m i t t e d ar i app l i ca t i on fo r ren e w a l of I t i p r e v i o u s l y a p p r o v e d d i scharge p lan fo r its- M o n u m e n t Gas P l a n t l o c a t e d ap p r o x i m a t e l y 3 .5 m i les southwest of the t own ot Monumen t In the N W / 4 of Sect ion 1, Townsh ip 20 South, Rangp 36 Eas t ( N M P M ) , Lea County , Now Mexico. A p p r o x i m a t e l y 9600 gal lons per day of process wastew a t e r w t t h a t o t a l d i s s o l v e d s o l i d s concen t ra t i on of app r o x i m a t e l y 3500 m g / l is d isposed ot in an OCD approved c o n t r a c t d i s p o s a l w e l l . The d i scharge p lan addresses how s p i l l s , l e a k s a n d o ther d ischarges to the g round at the p l a n t w i l l b e m a n a g e d . T h e g r o u n d w a t e r m o s t l i ke ly to be a f fec ted by any d ischarge to the sur face Is at a dep th r a n g i n g f r o m 35 to 60 feet w i t h l o l a l d isso lved sol ids concen t ra t ions f r o m 500IO30O0 m g / l . (GW-9) Ph i l l i ps 66 N a t u r a l Gas Comp a n y , M i c h a e l D. F o r d , E n v i r o n -m e n t a l Ana l ys t , 4001 P e n b r o o k , Odessa,

T e x a s , 7*762 h a s s u b m i t t e d a n app l i ca t i on fo r renewal of Ihe prev i o u s l y a p p r o v e d d ischarge p lan fo r Its Eun ice E P Gas P l a n t l o c a t e d ap p r o x i m a t e l y 8 m i les nor thwest of the c i t y of E u n i c e in t h e NW/4 of Sect ion 5, Townsh ip 71 South, R a n g e 36 E a s t ( N M P M ) , L e a County ,New M e x i c o . The p r e v i o u s d i s c h a r g e p l a n w a s a p p r o v e d f o r E l Paso N a t u r a l Gas Company and w a s t r a n s f e r r e d t o Ph i l l i ps 66 N a t u r a l Gas Company at the t i m e of o w n e r s h i p t r a n s f e r . T h e M a i n l i n e E n g i n e Room por t ion ot the f ac i l i t y w i l l r e m a i n the respons ib i l i t y of E) Paso N a t u r a l Gas C o m p a n y and the po r t i on of the ori g i n a l d i s c h a r g e p lan p e r t a i n i n g to the M a n l i n e Eng ine Room w i l l be renewed under a new discharge p lan designat ion (GW 46). Ap p r o x i m a t e l y 44,100 gal lons per day of process w a s t e w a t e r

I w i t h a t o t a l d i s so l ved so l i ds con c e n t r a t i o n of 1300 m g / t Is d isposed of In an OCD app roved c o n t r a c t d i s p o s a l w e l l . The d i scharge p lan addresses how s p i l l s , l e a k s a n d other d i scharges to the g round at the p l a n t w i l l b e m a n a g e d . T h e .

- g roundwa te r most l i ke l y to be a f fec ted by any d i s c h a r g e t o t h e sur face is at a depth r a n g i n g f r o m 80 to 150 feet w i t h t o t a l d i s s o l v e d s o l i d s concent ra t ions f r o m 1000IO17O0 m g / l . ( G W - 1 0 ) E l Paso N a t u r a l Ons Com p a n y , C h ^ r l f l W. Hagen, Vice Prcs l dent . South Region, P. O. Box 1472, E l Paso, Texas , 79978, has s u b m i t t e d an app l i ca t i on fo r ren e w a l of I t * p r e v i o u s l y a p p r o v e d d ischarge p l a n lo r i ts tlfJI NO. 3 (5(1%

n o r t h of t ^ ^ t t y of J a l I n ^ B V / I N W / 4 , N ^ ^ H M of Sect ion s ^ s ^ H n s f c l p ' 24 South, RBnge 37 East ( N M P M ) , Lea Coun ty , New M e x - S ico. A p p r o x i m a t e l y , ' 28,600 g a l l o n s p e r .; d a y o f p r o c e s s was tewa te r w i t h a *j t o ta l d isso lved sol ids concen t ra t i on of ap- j p r o x i m a t e l y 5410 '.< m g / 1 IB d isposed of 1

In an OCD app roved d isposal w e l l located on t h e . p l a n t p r o p e r t y . The d i scha rge p lan addresses how . | s p i l l s , . l e a k s a n d i o the r d ischarges fo the g r o u n d at tha ^ p l a n t w i l l b e "•

- m a n a g e d . T h e • g r o u n d w a t e r m o s t *« 1 l i ke l y t o be a f fec ted v

by any d i scharge to the su r f ace is at a f

d e p t h of a p p r o x l i ^ j m a t e l y 90 feet w i t h a

., t o ta l d isso lved sol ids . concen t ra t i on of ap- • p r o x i m a t e l y 900 '? m g / 1 . ( G W - 4 6 ) E l P e s o N a t u r a l Gas Com- j p a n y , C h a r l e s W. Hagen , V i ce Pres l - |

' dent , South Reg ion , P. O. Box 1492, E l Paso, T e x a s , 79976, h a s s u b m i t t e d a n app l i ca t i on t o renew I t s p r e v i o u s l y a p p r o v e d d l s h a r g e p lan fo r I ts Eun i ce M a i n l i n e E n g i n e R o o m l o c a t e d ap -

' p r o x i m a t e l y B m i les N o r t h w e s t of t h e C i t y of Eun i ce In the A

N W / 4 of Section 5, Townsh ip 21 South, • R a n g e 3 6 E a s t ( N M P M ) , L e a County , New M e x - 1

I c o . The p r e v i o u s d i scharge p l a n w a s d e s i g n a t e d G W - 9 and Is now tho re- s

spons ib l l l t y of and Is b e i n g r e n e w e d by Ph i l l i ps 66 N a t u r a l Gas Company . The M a i n l i n e E n g i n e Room r e m a i n s the respons ib i l i t y o l E l Paso N a t u r a l Gas C o m p a n y a n d t h e por t ions of the pre- • v ious d ischarge p lan p e r t a i n i n g t o t h e M a i n l i n e E n g i n e Room a re be ing ren e w e d u n d e r D i s charge P lan GW-46. A p p r o x i m a t e l y 17,000 g a l l o n s pe r '• day of coo l ing tower

w a s t e w a t e r w i t h a to ta l d isso lved sol ids • c o n c e n t r a t i o n s of

• a p p r o x i m a t e l y 1300 m g / l is d isposed of In an OCD app roved ' c o n t r a c t d i s p o s a l w e l l . The d i scharge p lan addresses how s p i l l s , l e a k s a n d o the r d i scharges to the g round at the < p l a n t w i l l b e m a n a g e d . T h e g round wa te r most l i ke l y to be a f fec ted by any d i s c h a r g e s a t t he su r face is at a depth r a n g i n g f r o m 80 to 150 feet w i t h to ta l d i s s o l v e d s o l i d s concen t ra t ions f r o m 1000 toUOO m g / l .

A n y In te res ted pe rson m a y o b t a i n f u r t h e r In f o r m a t i o n f r o m the O i l Conserva t ion D iv i s ion and m a y s u b m i t w r i t t e n c o m m e n t s to the D i rec to r of t he OII C o n s e r v a t i o n D i v i s i o n at I he address g i ven above. P r i o r to r u l ing on any proposed disc h a r g e p l a n o r I t s . m o d i f i c a t i o n , the D i r ec to r I h e O i l C o n s e r v a t i o n D i v i s i on sha l l a l l ow at least t h i r t y (30) days a f te r the da te of pub l i ca t i on of t h i s , n o t i c e d u r i n g w h i c h c o m m e n t s m a y be subm i t t e d fo h i m and pub l i c hea r i ng m a y be requested by any In terested pe rson . Requests fo r pub l i c heari n g s h a l l set f o r t h the r e a s o n s w h y a h e a r i n g shou ld be he ld . A h e a r i n g w i l l be he ld If the D i r e c t o r d e t e r m i n e s the re Is s i gn i f i can t pub l i c In terest . ,

i f no pub l i c hea r i ng is • h e l d , t h e D i r e c t o r w l l l f app rove o r d i sapprove the p roposed p l a n based on I n f o r m a t i o n ava i l ab l e . I f a pub l i c h e a r i n g Is he ld , the D i r e c t o r w i l l app rove o r -d i s a p p r o v e the p roposed p l a n based on i n f o r m a t i o n '. in the p lan and I n f o r m a t i o n ? s u b m i t t e d a t tha h e a r i n g . 1

G I V E N under the Seat of New M e x i c o Oi l Conservat ion C o m m i s s i o n a t Santa Fc , New M e x i c o , on Ih ls 31st day ot October . To be p u b l i s h e d on or b e l o r e November 4, i f f t f l .

S T A T E OF N E W M E X I C O O I L C O N S E R V A T I O N D I V I S I O N W I L L I A M J , L E M A Y ,

NOTICE OF PUBLICATION STATE OF NEW MEXICO ENERGY, MINERALS AND

NATURAL RESOURCES DEPT OIL CONSERVATION DW

Notice te hereby given that pursuant ID the New Mexioo Water Quality Control Commission Regulations, the following discharge plan has been submitted (or renewal to the Director of the Oil Conservation Division, State Land Office Building, 310 Old Santa Fe Trail, Room 206, Santa Fe, New Mexico 87503, Telephone (505) 827-5800:

(GW-8) El Paso Natural Gas Company, Donald N. Bigbie, Vice President, North Region, PO. Box 1492, B Paso, Texas, 79978, has submtted an application for renewal of its previously approved discharge plan for Its Monument Gas Plant located approximately 3.5 miles southwest of the town ot Monument In the NW/4 of Section 1, Township 20 South, Range 36 East (NMPM), Lea County, New Mexioo. Approximately 9600 gallons per day of process wastewater with a total dissolved solids concentration of approximately 3500 mg/1 is disposed of In an OCD approved contract disposal well. The discharge plan addresses how spills, leaks and other discharges to the ground at the plant will be managed. The groundwater most likely to be affected by any discharge to the surface is at a depth ranging from 35

! to 60 feet with total dissolved solids i concentrations from 500 to 3000 mg/1.

! (GW-9) Phillips 66 Natural Gas Company, Michael 0. Ford, Environmental Analyst, 4001 Penbrook, Odessa. Texas. 79762 has submitted an' application tor renewal ot the previously approved discharge plan

i tor ts Eunice EP Gas Plant located approximately 8 miles northwest of the city of Eunice in the NW/4 of Section 5, Township 21 South, Range

, 36 East (NMPM), Lea County, New Mexico. The previous discharge plan was approved for El Paso Natural 0ns Company and was transferred to Phillips 66 Natural Gas Company at the time of ownership transfer. The Mainline Engine Room portion of the facility will remain the responsibility of

. E) Paso Natural Gas Company and the portion of the original discharge plan pertaining to the Mainline Engine Room will be renewed under a new discharge plan designation (GW-46). Approximately 44,100 gallons per day of process wastewater with a total dissolved solids concentration of ,1300 mg/1 is disposed of in an OCD approved contract disposal well. The discharge plan addresses how spills, teaks and other discharges to the ground at the plant will be managed. The groundwater most likely to be 'affected by any discharge to the surface Is at a depth ranging from 80 to 150 feet with total dissolved solids concentrations from 1000 to 1700 mg/1. ' (GW-10) El Paso Natural Gas

Company, Charles W. Hagen, Vice President, South Region, P.O. Box 1492, El Paso, Texas, 79978. has submitted an application lor renewal ' of its previously approved discharge plan for Its Jal No. 3 Gas Plant

ptocess wnntev/ater with n total dissolved solids concentration ol approximately 5410 mg/1 is disposi in an OCD approved disposal located on the plant property.' discharge plan addresses how spins; leaks and other discharges to the ground at the plant will be managed. The groundwater most likely to be affected by arty discharge to the surface Is at a depth of approximately 90 feet with a total dissolved solids concentration of approximately 900 mg/1.

(GW-46) El Paso Natural Gas Company. Charles VV. Hagen, Vice President, South Region, P.O. Box 1492, El Paso. Texas, 79978, has submitted an application to renew its previously approved discharge plan for its Eunice Mainline Engine Room located approximately 8 miles Northwest ol the City of Eunice in the NW/4 of. Section 5, Township 21 South, Range 36 East (NMPM), Lea County, New Mexico. The previous discharge plan was designated GW-9 and is now the responsibility of and is being renewed by Phillips 66 Natural Gas Company. The Mainline Engine Room remains the responsbility ol El Paso Natural Gas Company and the portions ot the previous discharge plan pertaining to the Mainline Engine Room are being renewed under Discharge Plan GW-46. Approximately 17,000 gallons per day of cooling tower wastewater with a total dissolved solids concentrations of approximately 1300 mg/1 is disposed of In an OCD approved contract disposal well. The discharge plan addresses how spills, leaks and other discharges to the ground at the plant j will be managed. The groundwater most likely to be affected by any ' discharges at the surface is at a depth ranging from 80 to 150 feet with total dissolved solids concentrations from 1000 to 1700 mg/1.

Any Interested person may obtain further Information from the Oil Conservation Division and may submit written comments to the Director of the Oil Conservation Division at the address given above. Prior to ruling on any proposed discharge plan or its modification, the Director the Oil Conservation Division will albw at least thirty (30) days after the date ot publication of this notice during which comments may be submitted to him and public hearing may be requested by any interested person. Requests for public hearing shall set forth the reasons why a hearing should be held. A hearing will be held If the Director determines there is significant public interest.

If no public hearing is hetd, the Director will approve or disapprove the proposed plan based on information available. If a public hearing is held, the Director will approve or disapprove the proposed plan based on information in the plan and information submitted at the hearing.

GIVEN under the Seal of New Mexico Oil Conservation Commission at Santa Fe, New Mexico, on this 21st day of October. To be published on or before November 4, 1988.


s/WILLIAM J. LEMAY, Director Journal, October 30, 1988

VIEXICO I ss

5 I SMTTHSON being duly sworn declares and

r.». AT>y... MGR.. of the Albuquerque Journal, and that this fied to publish legal notices or advertisements within the meaning of session Laws of 1937, and that payment therefore has been made or that the notice, a copy of which is hereto attached, was published in ir daily edition,

times, the first publication being on the day

198.5> and the subsequent consecutive

EDJ-1S (R-2/86)

Sworn and subscribed to Wore me, a Notary Public in and for the County of BernalUlo and State of New Mexico, 0

this ,.3.V... day of .C^.Q_^^SCxOs^ 198ft.

PRICE

Statement to come at end of month.

ACCOUNT NUMBER . . C ^ f t O ^ j b . X^v.

STATE OF NEW MEXICO


GARREY CARRUTHERS GOVERNOR

October 24, 1988

POST OFFICE BOX 20B8 STATE LAND OFFICE BUILDING


CERTIFIED MAIL RETURN RECEIPT REQUESTED

Charles W. Hagan, Vice President, South Region El Paso Natural Gas Company P.O. Box 1492 El Paso, TX 79978

RE: Discharge Plan Renewals GW-8, Monument GW-10, Jal No. 3 GW-40, Eunice Mainline Engine

Room

Dear Mr. Hagan:

The Oil Conservation Division has received your applications dated September 23, 1988 for renewal of the above-referenced discharge plans. Part of the review process includes a v i s i t to the f a c i l i t i e s . Members of the Environmental Bureau's staff are planning a trip to southeast New Mexico for the latter part of November and would like to include a v i s i t to the three f a c i l i t i e s during that time. We w i l l be finalizing our plans the f i r s t or second week of November and I wi l l be contacting you concerning convenient times for the v i s i t .

After the f a c i l i t y v i s i t s and further OCD review of the plans, specific comments and information can be exchanged. A public notice w i l l be published on or before November 4, 1988.

I f there are any questions, please do not hesitate to c a l l me at (505) 827-5885.

Sincerely,

Environmental Engineer

RCA/ag

cc: Oil Conservation Division - Hobbs Donald R. Payne - EPNG Dr. Henry Van - EPNG

ENERGY

NOTICE OF PUBLICATION STATE OF NEW MEXICO

MINERALS AND NATURAL RESOURCES DEPARTMENT OIL CONSERVATION DIVISION

Notice i s hereby given t h a t pursuant t o the New Mexico Water Q u a l i t y C o n t r o l Commission Regulations, the f o l l o w i n g discharge plan has been submitted f o r renewal t o the D i r e c t o r of the O i l Conservation D i v i s i o n , State Land O f f i c e B u i l d i n g , 310 Old Santa Fe T r a i l , Room 206, Santa Fe, New Mexico 87503, Telephone (505) 827-5800:

(GW-8) El Paso Natural Gas Company, Donald N. Bi g b i e , Vice President, North Region, P. 0. Box 1492, E l Paso, Texas, 79978, has submitted an a p p l i c a t i o n f o r renewal of i t s p r e v i o u s l y approved discharge plan f o r i t s Monument Gas Plant located approximately 3.5 miles southwest of the town of Monument i n the NW/4 of Section 1, Township 20 South, Range 36 East (NMPM), Lea County,, New Mexico. Approximately 9600 gallons per day of process wastewater w i t h a t o t a l d i ssolved s o l i d s concentration of approximately 3500 mg/l i s disposed of i n an OCD approved c o n t r a c t disposal w e l l . The discharge plan addresses how s p i l l s , leaks and other discharges t o the ground a t the p l a n t w i l l be managed. The groundwater most l i k e l y t o be a f f e c t e d by any discharge t o the surface i s a t a depth ranging from 35 to 60 f e e t w i t h t o t a l d issolved s o l i d s concentrations from 500 t o 3000 mg/l.

(GW-9) P h i l l i p s 66 Natural Gas Company, Michael D. Ford, Environmental Analyst, 4001 Penbrook, Odessa, Texas, 79762 has submitted an a p p l i c a t i o n f o r renewal of the pr e v i o u s l y approved discharge plan f o r i t s Eunice EP Gas Plant located approximately 8 miles northwest of the c i t y of Eunice i n the NW/4 of Section 5, Township 21 South, Range 36 East (NMPM), Lea County, New Mexico. The previous discharge plan was approved f o r Elj Paso Natural Gas Company and was t r a n s f e r r e d t o P h i l l i p s 66 Natural Gas Company a t the time of ownership t r a n s f e r . The Mainline Engine Room p o r t i o n of the f a c i l i t y w i l l remain the r e s p o n s i b i l i t y of E l Paso Natural Gas Company and the p o r t i o n of the o r i g i n a l discharge plan p e r t a i n i n g t o the Mainline Engine Room w i l l be renewed under a new discharge plan designation (GW-46). Approximately 44,100 gal l o n s per day of process wastewater w i t h a t o t a l d i s s o l v e d s o l i d s concentration of 1300 mg/l i s disposed of i n an OCD approved c o n t r a c t disposal w e l l . The discharge plan addresses how s p i l l s , leaks and other discharges t o the ground a t the p l a n t w i l l be managed. The groundwater most l i k e l y t o be a f f e c t e d by any discharge t o the surface i s a t a depth ranging from 80 t o 150 f e e t w i t h t o t a l d i s s o l v e d s o l i d s concentrations from 1000 t o 1700 mg/l.

I f no public hearing i s held, the Director w i l l approve or disapprove the proposed plan based on information available. I f a public hearing i s held, the Director w i l l approve or disapprove the proposed plan based on information i n the plan and information submitted at the hearing.

GIVEN under the Seal of New Mexico O i l Conservation Commission at Santa Fe, New Mexico, on t h i s 21st day of October. To be published on or before November 4, 1988.


WILLIAM J. LEMAYJ Director

S E A L

DISCHARGE PLAN GW-46 RENEWAL APPLICATION

FOR EL PASO NATURAL GAS CO.

EUNICE PLANT MAINLINE ENGINE ROOM

El Paso Natural Gas Company

LEA COUNTY. NEW MEXICO OCTOBER. 1988

DISCHARGE PLAN GW-46 RENEWAL APPLICATION

FOR


EUNICE PLANT MAINLINE ENGINE ROOM

LEA COUNTY, NEW MEXICO

October 1988

Submitted to:

NEW MEXICO OIL CONSERVATION DIVISION P.O. Box 2088

Santa Fe, New Mexico 87501

AFFIRMATION:

" I hereby c e r t i f y t h a t I am f a m i l i a r w i t h che in f o r m a t i o n contained on and submitted w i t h t h i s a p p l i c a t i o n and t h a t such i n f o r m a t i o n i s t r u e , accurate and complete to the best of my knowledge and b e l i e f . "

^ y & ^ ^ M l ^ C September 23, 1988

Signature Date A. H. Carameros Vice President

TABLE OF CONTENTS

PAGE

1.0 EXECUTIVE SUMMARY 1

2.0 GENERAL INFORMATION 1 2.1 NAME OF DISCHARGER/LEGALLY RESPONSIBLE

PARTY 1 2.2 LOCAL REPRESENTATIVE OR CONTACT 1 2.3 LOCATION OF DISCHARGE 2 2.4 LOCAL LAND USE 2 2.5 DESCRIPTION OF OPERATIONS 2 2.6 REGULATORY INDEX 3

3.0 EFFLUENT SOURCES, CHARACTERISTICS AND DISPOSAL 4 3.1 WASTE SOURCES, QUANTITY AND FLOW

CHARACTERISTICS 4 3.1.1 Gas-Liquid Scrubbers 4 3.1.2 Cooling Tower Blowdown 4 3.1.3 Domestic Sewage 4 3.1.4 Storm Water 4

3.2 WASTE QUANTITY AND FLOW CHARACTERISTICS 4 3.2.1 Gas-Liquid Scrubbers 4 3.2.2 Cooling Tower Blowdown 4 3.2.3 Domestic Sewage 5 3.2.4 Storm Water 5 3.2.5 Wastewater Analysis 5

3.3 SPILL/LEAK PREVENTION AND HOUSEKEEPING PRACTICES 5 3.3.1 Operating and Maintenance

Procedures 5 3.3.2 Chemical and Environmental Hazards 5 3.3.3 Cleanup Procedures 5 3.3.4 Reporting 6 3.3.5 General Housekeeping Procedures 6

4.0 EFFLUENT DISPOSAL 7 4.1 EXISTING OPERATIONS 7 4.2 OFF-SITE DISPOSAL 7 4.3 PROPOSED MODIFICATIONS 7

5.0 SITE CHARACTERISTICS 7 5.1 REGIONAL GEOLOGY 7 5.2 LOCAL GEOLOGY 8 5.3 REGIONAL AND LOCAL HYDROLOGY AND GROUNDWATER

QUALITY 8 5.4 SURFACE WATER HYDROLOGY AND FLOODING

POTENTIAL 8

i i

0 MONITORING AND REPORTING 8

7.0 BASIS FOR APPROVAL 8

8.0 REFERENCES CITED 9

i i i

LIST OF TABLES

TABLE PAGE

2- 1 REGULATORY INDEX 3

3- 1 CHEMICALS USED AT THE EUNICE PLANT 6

i v

LIST OF APPENDICES

APPENDIX

A MATERIAL SAFETY DATA SHEETS

B RESULTS OF DRAIN LINE TESTING

V

1.0 EXECUTIVE SUMMARY

El Paso Natural Gas Company, P.O. Box 1492, El Paso, Texas 79978, proposes t o discharge approximately 6,205,000 gallons per year of wastewater t o an i n t e r n a l l y and e x t e r n a l l y epoxy-coated s t e e l tank-type c l a s s i f i e r which i s operated by P h i l l i p s . The wastewater from the c l a s s i f i e r tank i s pumped through an a n t h r a c i t e / r o c k f i l t e r and disposed i n the Rice Engineering Disposal System, Monument Branch. The wastewater i s generated at the Eunice Plant Mainline Engine Room which i s located i n Sections 5 and T-21-S, R-36-E, Lea County, New Mexico. Approximately 99% of the wastewater i s blowdown from the Mainline Engine Room's c o o l i n g tower, and 1% from domestic sewage and engine room d r a i n s .

Presently, the Mainline Engine Room discharges commingled wastewater i n t o a wastewater c l a s s i f i e r and i t s e f f l u e n t i s disposed i n the Rice Engineering Disposal System. EPNG proposes to continue t o discharge the Mainline Engine Room wastewater to the c l a s s i f i e r and t o dispose the e f f l u e n t from t h i s c o l l e c t i o n system t o the Rice Engineering Disposal System.

EPNG i s wholly committed t o c a r r y i n g out sound disposal p r a c t i c e s and t o t h i s end submits the plan o u t l i n i n g the proposed procedures. Likewise, EPNG i s committed t o cooperating f u l l y w i t h NMOCD i n honoring requests f o r a d d i t i o n a l i n f o r m a t i o n or c l a r i f i c a t i o n of e x i s t i n g i n f o r m a t i o n r e l a t e d t o the Discharge Plan.

2.0 GENERAL INFORMATION

2.1 NAME OF DISCHARGER/LEGALLY RESPONSIBLE PARTY

A l l correspondence regarding t h i s discharge plan should be sent to EPNG South Region headquarters at the address below:

Charles W. Hagen Vice President South Region El Paso Natural Gas Company P. 0. Box 1492 El Paso, TX 79978 (915) 541-2600

2.2 LOCAL REPRESENTATIVE OR CONTACT

A copy of a l l correspondence and a l l questions should be d i r e c t e d t o the South Region Compliance Engineer:

1

Donald R. Payne El Paso Natural Gas Company South Region P. 0. Box 1492 El Paso, TX 79978 (915) 541-5399

EPNG requests t h a t copies of correspondence also be sent t o :

Environmental and Safety A f f a i r s El Paso Natural Gas Company P. 0. Box 1492 El Paso, TX 79978 ATTN: H. Van (915) 541-2832

2.3 LOCATION OF DISCHARGE

The Eunice Plant i s located i n Sections 5 and 6, T-21-S, R-36-E, Lea County, New Mexico, approximately 11 miles northwest of Eunice, New Mexico. Figures 1, 2 and 3 (pp. 3, 4, 5 and 6) of the 1983 Discharge Plan show the l o c a t i o n of the p l a n t .

2.4 LOCAL LAND USE

The Eunice Plant occupies approximately 12 acres and can be seen i n the 1981 a e r i a l photograph i n Figure 2 of the 1983 Discharge Plan. However, the Plant does not have the 60-house camp f o r the employees. This camp has been closed permanently, and the houses have been removed.

In f o r m a t i o n regarding land ownership i s contained i n Figure 3 (pp. 5 and 6) of the 1983 Discharge Plan.

2.5 DESCRIPTION OF OPERATIONS

El Paso Natural Gas Company's Eunice Plant i s engaged i n the compression of n a t u r a l gas. The p l a n t has been sold t o P h i l l i p s Natural Gas Company w i t h the exception of the Mainline Engine Room.

The Eunice Mainline Compressor Room (EMER) has twelve gas fu e l e d engine d r i v e n compressor u n i t s t o t a l i n g 12,100 horsepower w i t h a designed n a t u r a l gas handling capacity of 344 m i l l i o n cubic f e e t per day. Entrained l i q u i d s are removed from the gas stream p r i o r t o compression by two h o r i z o n t a l g a s - l i q u i d scrubbers. The compressed gas passes through c o o l i n g c o i l s i n a mechanical d r a f t c o o l i n g tower, then through twelve small g a s - l i q u i d scrubbers. The primary purpose of the separators i s t o remove any small

2

quantities of l i q u i d s from the gas stream p r i o r to entering the mainline transportation system.

2.6 REGULATORY INDEX

Table 2-1 presents the regulatory index. This table provides a cross reference between WQCC Regulations and t h i s discharge plan.

TABLE 2-1

REGULATORY INDEX

WQCC Regulation Required in Discharge Plan

1-201

1-202

1-203

3-106 C l

3-106 C.2

3-106 C.3

3-106 C.4

3-106 C.5

3-106 C.6

3-106 C.7

3-107

3-108 .B

Section in Discharge Plan

1.0, 2.0

3.2.3

3.3.4

3.2

2.3, Fig. 2-1,5.3.2.

1.0, 5.3

5.4

3.0, 4.0

5.1

7.0

6.0

1.0

NMOCD Regulation Required in

Discharge Plan Section in Discharge Plan

116 3.3.4

3

3.0 EFFLUENT SOURCES, CHARACTERISTICS AND DISPOSAL

3.1 WASTE SOURCES, QUANTITY AND FLOW CHARACTERISTICS

3.1.1 GAS LIQUID SCRUBBERS

Wastewater discharge from the scrubbers i s n e g l i g i b l e .

3.1.2 COOLING TOWER BLOWDOWN

The mainline c o o l i n g tower blowdown i s approximately 16,850 gall o n s per day, or 11.7 gallons per minute.

3.1.3 DOMESTIC SEWAGE

The domestic wastewater discharges from the four t o i l e t s i s routed t o an i n t e r n a l l y and e x t e r n a l l y epoxy-coated s t e e l tank-type c l a s s i f i e r . Figures 15 and 16 of the 1983 Discharge Plan show the e x i s t i n g wastewater-producing processes and schematic of the c o l l e c t i o n system. Although P h i l l i p s 66 Natural Gas Company owns the wastewater c l a s s i f i e r system, El Paso Natural Gas Company (EPNG) has an agreement w i t h P h i l l i p s t o discharge the domestic wastewater and the g a s - l i q u i d separation waste to the c l a s s i f i e r system described i n the 1983 Discharge Plan.

3.1.4 STORM WATER

The arrangement of the wastewater c o l l e c t i o n / c l a s s i f i e r system precludes the p o s s i b i l i t y of storm water r u n - o f f e n t e r i n g the system and appreciably changing the volume of discharge. No open drains which c o l l e c t storm water are connected t o the system.

3.2 WASTE QUANTITY AND FLOW CHARACTERISTICS

3.2.1 GAS-LIQUIDS SCRUBBERS

The i n l e t mainline gas i s t r e a t e d by the scrubber u n i t s which discharge n e g l i g i b l e amounts of wastewater. This wastewater i s discharged t o the P h i l l i p s 66 Natural Gas Company wastewater c l a s s i f i e r .

3.2.2 COOLING TOWER BLOWDOWN

Evaporative c o o l i n g tower water i s used t o cool compressed p i p e l i n e gas f o r transmission. Cooling tower water i s recycled as much as poss i b l e , but some i s blowndown and replaced t o prevent TDS buildup. The blowdown i s approximately 16,850 gallons per day, or 11.7 gallons per minute.

4

3.2.3 DOMESTIC SEWAGE

About 150 gpd are generated from the four restrooms. The domestic sewage discharges to the c l a s s i f i e r system.

3.2.4 STORM WATER

Storm water i s collected i n open drains and discharged to grade.

3.2.5 WASTEWATER ANALYSIS

Table 3 (p. 20) of the 1983 Discharge Plan contains the wastewater analyses f o r the composite samples. However, these results r e f l e c t the q u a l i t y of the composite sample taken i n July 1983. But there i s no reason to believe that the character of th i s waste stream has changed, especially the wastewater stream from the Mainline Engine Room.

3.3 SPILL/LEAK PREVENTION AND HOUSEKEEPING PRACTICES

3.3.1 OPERATING AND MAINTENANCE PROCEDURES

The Eunice Mainline Engine Room i s operated i n a manner to prevent and mitigate any unplanned releases to the environment. EMER processes are regularly observed by a number of personnel during d a i l y operations, and any evidence or sign of s p i l l s or leaks are routinely reported to supervisory personnel so that repairs or cleanup can be promptly effected. Routine maintenance procedures conducted at the EMER also help to assure that equipment remains functional and minimize the p o s s i b i l i t y of s p i l l s or leaks.

3.3.2 CHEMICAL AND ENVIRONMENTAL HAZARDS

Process and non-process chemicals or additives (Table 3-1) used at the EMER could present a threat to the environment only i n the event of a major s p i l l or release. Appendix A contains the new Safety Material Data Sheets for chemicals now being used not l i s t e d i n the 1983 Discharge Plan. The majority of the chemicals are used i n small quantities (25 gallons to 4,000 gallons per year). Hence any s p i l l s or leaks would be very small i n volume and easily contained i n the immediate area.

3.3.3 CLEANUP PROCEDURES

Cleanup procedures would obviously vary with the nature and extent of any unplanned release. S p i l l s of acids are r e l a t i v e l y easy to control and general procedures would include n e u t r a l i z a t i o n of the material in-place before a f i n a l evaluation i s made on i t s ultimate disposal. Once neutralization i s confirmed by sampling and pH determination, i t i s quite probable

t h a t no f u r t h e r actions would be re q u i r e d to ensure p r o t e c t i o n of human h e a l t h and the environment.

S p i l l s or leaks of hydrocarbons could p o t e n t i a l l y occur from the lube o i l , or waste o i l storage tanks. Lube o i l i s stored i n a 24,000 g a l l o n above-ground h o r i z o n t a l tank. The l o c a t i o n of these drums and the s t r u c t u r e s i n the area would preclude any releases from reaching n a t u r a l drainage.

TABLE 3-1

CHEMICALS USED AT EUNICE PLANT MAINLINE ENGINE ROOM (AVERAGE ANNUAL AMOUNTS)

COOLING TOWERS

A n t i p o l - 662 * Toxene 35 Toxene 37

SChlorine /Hydrochem D-300 Hydrochem A-239 <s\\c.c™~ofe£^

A n t i - c o r r o s i o n Biocide Biocide Hydpochlorite-biocide Dispersant

2,080 lbs 30 gal 30 g a l

1,000 lbs 548 g a l 5 gal

v/ Chromine T

CLOSED JACKET AND OIL COOLING WATER SYSTEM

Anti-corrosion

LUBE OIL

/Mobil Pega sus 490 5/Molylube 890

/ V a r s o l

Engine Crankcase Air Compressor

DEGREASER

General Purpose Degreaser

50 gal

25,000 g a l 42 g a l

1,000 gal

3.3.4 REPORTING

Should a release of mate r i a l s occur, EPNG w i l l provide verbal n o t i f i c a t i o n t o NMOCD as soon as possible a f t e r discovery as requi r e d by NMOCD and WQCC Regulation 116 and 1-203, r e s p e c t i v e l y .

3.3.5 GENERAL HOUSEKEEPING PROCEDURES

EPNG s t r i v e s t o reduce the p o t e n t i a l f o r s p i l l s and leaks i n a l l areas. E x i s t i n g records and in t e r v i e w s w i t h p l a n t personnel i n d i c a t e t h a t no re p o r t a b l e s p i l l s have occurred at Eunice Plant.

6

Non-process chemicals are used i n r e l a t i v e l y small quantities at the Plant and are managed i n a manner to prevent discharges to the environment. Any chemical s p i l l s which might occur would be immediately contained and disposed of according to proper guidelines.

Chemicals such as cleaning solvents are collected and recycled. EPNG currently uses a non-halogenated solvent, Varsol i s used for degreasing operations. Used Varsol i s discharged to the c l a s s i f i e r .

4.0 EFFLUENT DISPOSAL

4.1 EXISTING OPERATIONS

EPNG disposes of a l l i n d u s t r i a l aqueous wastes i n an on-site i n t e r n a l l y and externally epoxy-coated steel tank-type c l a s s i f i e r * Figures 15 and 16 (pp. 32 and 33) of the 1983 Discharge Plan show the existing wastewater-producing processes and the c o l l e c t i o n system i n schematic forms. No changes have been made to t h i s system since 1983.

4.2 OFF-SITE DISPOSAL

I n d u s t r i a l and domestic refuse generated i n the EMER i s being pumped through an anthracite/rock f i l t e r , then metered and disposed of i n the Rice Engineering Disposal System, Monument Branch. El Paso began delivering wastewater to the Rice Engineering system on October 26, 1982. The i n d u s t r i a l s o l i d waste i s comprised of used o i l f i l t e r s from compressor engines and o f f i c e garbage. A l l the s o l i d waste i s hauled and disposed i n the City of Hobbs l a n d f i l l .

4.3 PROPOSED MODIFICATIONS

EPNG proposes to continue to discharge i t s wastewater generated at the Eunice Plant Mainline Engine Room to the c l a s s i f i e r located on the Plant property and the c l a s s i f i e r e f f l u e n t discharged to Rice Engineering Disposal System, Monument Branch.

5.0 SITE CHARACTERISTICS

Site characteristics of the area where the Eunice Plant Mainline Engine Room i s are described i n the 1983 Discharge Plan (pp. 39-46) .

5.1 REGIONAL GEOLOGY

The regional geology i s described i n the 1983 Discharge Plan (pp. 39-45) .

5.2 LOCAL GEOLOGY

The l o c a l geology i s described i n the 1983 Discharge Plan (pp. 39-46).

5.3 REGIONAL AND LOCAL HYDROLOGY AND GROUNDWATER QUALITY

The r e g i o n a l and l o c a l hydrology and groundwater q u a l i t y i s discussed i n the 1983 Discharge Plan (pp. 21-26).

5.4 SURFACE WATER HYDROLOGY AND FLOODING POTENTIAL

The surface water hydrology and f l o o d i n g p o t e n t i a l of the Eunice Plant Mainline Engine Room i s described i n the 1983 Discharge Plan (p. 23).

6.0 MONITORING AND REPORTING

Because the "discharge s i t e " i s under the care and c o n t r o l of Rice Engineering, El Paso w i l l perform the f o l l o w i n g e v a l u a t i o n to ensure t h a t the wastewater c o l l e c t i o n systems operated by El Paso i n the Plant do not also become "discharge s i t e s . " The Plant underground d r a i n systems (shown i n Figure 22 of the 1983 Discharge Plan, Map Pocket) w i l l be test e d to ensure the i n t e g r i t y of the d r a i n system. Appendix B contains the 1988 r e s u l t s of the pressure t e s t i n g of the d r a i n l i n e s . Test procedures are s t r u c t u r e d so t h a t each l i n e i s pressure tested f o r a s p e c i f i e d time p e r i o d to v e r i f y t h a t no l i n e i s l e a k i n g . Any leaks i d e n t i f i e d w i l l be r e p a i r e d . The d r a i n l i n e t e s t procedure i s found i n Appendix J of the 1983 Discharge Plan.

Annual sampling and analysis of the wastewater stream ( c l a s s i f i e r , e f f l u e n t ) d e l i v e r e d t o the disposal system w i l l be conducted and^ a Plant f i l e maintained. A monthly r e p o r t t o NMOCD on Form C 120-8, d e s c r i b i n g disposal volumes, i s now being submitted. The wastewater flow records w i l l be p e r i o d i c a l l y reviewed t o determine i f any unexplained changes i n disposal volumes have developed. I f any such anomalies occur, an i n s p e c t i o n of the c o l l e c t i o n system w i l l be conducted t o i d e n t i f y the cause. Any records r e l a t e d t o i n t e g r i t y t e s t i n g and waste c h a r a c t e r i s t i c s w i l l be r e t a i n e d by El Paso f o r f i v e years.

Sludge w i l l be removed from the c o o l i n g tower basin and the c l a s s i f i e r as needed and w i l l be evaluated and disposed of i n an approved l a n d f i l l . Any changes, a n t i c i p a t e d or otherwise, t o the disposal system w i l l , of course, be reported t o NMOCD.

7.0 BASIS FOR APPROVAL

The e x i s t i n g s i t e c onditions and proposed continued use of the present wastewater disposal system at the EPNG EMER act together to ensure t h a t there w i l l be no present or f u t u r e adverse e f f e c t s

8

t o groundwater as a r e s u l t of discharges to e x i s t i n g wastewater management u n i t s . No present or f u t u r e users of groundwater i n the EMER area would be a f f e c t e d by the f a c i l i t y ' s waste management p r a c t i c e s f o r the f o l l o w i n g reasons:

o EPNG proposed t o continue using e x i s t i n g waste management u n i t s and t h e i r e f f l u e n t discharged t o the Rice Engineering Disposal System, Monument Branch.

o There i s no s i g n i f i c a n t p o t e n t i a l f o r wastewater release due t o f l o o d i n g by a 100-year storm (1983 Discharge Plan, p. 23).

8.0 REFERENCES CITED

EPNG Discharge Plan f o r Eunice Plant, Lea County, New Mexico, August 1983.

9

>< a ui a. a. <

APPENDIX A

MATERIAL SAFETY DATA SHEETS

IrPi^C Co A*.

Continental Products of Texas / ¥ \ ( H Y D R O C H E M )

<3r3 ( b * / 100 Industrial • P.O. Box 3627 • Odessa, Texas 79760 • (915)337-4681 \ t t &

Hydrochem A-239

SECTION I - IDENTIFICATION

TRADE NAME Hydrochem A-239 REVISED DATE February 4, 198S IHEMICAL NAME Aqueous Mix t u r e -A3 NUMBER............... Not Ap p r o p r i a t e 3SHA HAZARD CLASS Physical hazard - Corrosive, Health hazard - Eye

hazard. Skin hazard. Kidney t o x i n . EPA HAZARD CATAGORY Immediate (acute) h e a l t h hazard.- Corrosive ;0T LABEL REQUIRED Ccrro s i v e EMERGENCY PHONE NUMBER... 1-800-592-4684 OR 1-915-337-4681

SECTION I I - HAZARDOUS INGREDIENTS

-^•lARDCUS COMPONENTS HAZARDOUS V. HAZARDOUS COMPONENT DATA

IsoDrcpyl Alcchcl <CAS# Ccr.r. OSHA (PEL) : TWA = 400 ppm, 980 mg/m3. _63-0) ACGIH (TLV): TWA = 400 ppm, 980 mc/mO,

STEL - 500 ppm, 1,225 mg/rr.3.

SECTION I I I - PHYSICAL DATA

S O L U B I L I T Y I N H 2 0 . -- 'REARANOE/DDOR. . . . . . . .

v'OLAl i L l T v / VOL {'/.} . . . . . . = H GF SOLUTION

Ccmoletelv s o l u b l e E.-c-nn l i q u i d / Pungent odor

% "» 60 2 t o 3

SECTION IV - FIRE AND EXPLOSION HAZARD DATA

7LASH en.*NT, None r_AMMAELE LIMITS None :XTINGUISH MEDIA Foam, C02, Dry Chemical, Halon, Water Fog "IRE FIGHTER PROTECTION.. EeH Contained Breathing Apparatus DECOMPOSITION PRODUCTS... CC, C02 NUSUAL FIRE HAZARD This m a t e r i a l may be burned a-fter evaporation o-f the

water phase.

O.o . f . i / j - Z ^ / d ^ t / j ^

U j t . S S a ^ l Dei**,: S~// * -1 -

Kz^!$PWM£!$&}cts of Texas \Ju & # J ; Z • • -.-IOO Industrial • P.O. Box 3627 • Odessa, Texas 79760 ^•-. (915) 337-4681

"' -• ~ ~ — ~ -~ T- ••- :._ -J:; :- — .- .'* -'— •._ _ - ^ ,

- ~ -. - - _. - --• ~ ^ - - =, =; ~ - — = _ _ L \ ! L L ^ C ^ ^

IN CASE QF_SRR:L. ..... T~1 f r i r ^ ^^ :zz -: - R,i.ck,..,up:: f.p'i'1. V J^i.tl^ "sd.#o^berrt'"ma^sri-ai" 4 - ~ ^r"""\.;C.

WASTE DISPOSAL METHOD. ~. Send '"to' ' a n '\appVbVed- - d i y a q z a 1 s i t e i n a c c o r d a n c e w i t h F e d e r a l , ' S t a t e , and Loca'P r e g u l a t i o n s .

.SECTIQN.VI . i l - SPEQI AL _PROTECTIQN r r r r r r r — ~ = ~ = = r r r ^ = = = = — = = s = z£= = zrzr = r r ^ = = ^ ' ^ — z r = ; = : ~ r r = = — r r :

P.ESF'-RATGRY..PROTECTION. Not" normaly needed. '.'•-' '•• •' —:MT I LAT I QN •- ............ Avoid ' breach i nc vapors. " " V e n t i l a t e as needed. SPECIAL. .-. . . ..'."None PROTECTIVE Ci-O'v'ES. ...... . C-smical r e s i s t a n t EYE PROTECTION........... Splash proof goggles and s a f t y glasses OTHER PROTECTIVE EQUIPMENT. .............. Eyewash S t a t i o n , Safety Shower

— ~ — — ~zr. — ~ — ~ — — 'sz — = = ~ = — — ~ — ~ = - z~ — — —11 = = r=zrrr==IZ^": = =I = — — = = — = = — — = = —rz=:=:i=r:rr=r = iz=:r=rr = r:

SECTION IX - SPECIAL PRECAUTIONS

HNDLING AND STORAGE Do not s t o r e wi^.h Strong Eases (Al kai ine materials:'. Do not get i n eyes, on s k i n , or on c l o t h i n g . Keep c o n t a i n e r s closed. The h e a l t h and sa f a t y c h a r a c t e r i s t i c s cf t h i s mi/tur are not f u l l y known. Ws advise t h a t i t oe h a n d s : and., managed as a nazsroous substance.

A l l empty drums or container's should b"e sent t'o a c e r t i f i e d recondi t i oner or c e r t i f i e d disposal site...for "proper d i sposal .'_ "Empty c o n t a i n e r s should not be used i n any.- other, way. . Mi suss ' of '" empty 1 , drums cr c o n t a i n e r s has r e s u l t e d i n many s e r i o u s accidents. ..... " '_ _ ' ' • -•* '• .

Mobil • 605816 PAGE 1 OF 4

MOBIL O IL CORPORATION MATERIAL SAFETY DATA B U L L E T I N

R E V I S E D : 0 3 / 2 3 / 8 3 * * * * * * * * * * * * * * * * * * * * * * i . PRODUCT IDENTIFICATION * * * * * * * * * * * * * * * * * * * * * *

MOBIL PEGASUS 485 S U P P L I E R : HEALTH EMERGENCY TELEPHONE:

MOBIL O IL CORP- ( 2 1 2 ) 883 -4411 CHEMICAL NAMES AND SYNONYMS: TRANSPORT EMERGENCY TELEPHONE:

P E T . HYDROCARBONS AND ADDIT IVES ( 8 0 0 ) 4 2 4 - 9 3 0 0 (CHEMTREC) USE OR D E S C R I P T I O N : PRODUCT TECHNICAL INFORMATION:

INDUSTRIAL LUBRICANT ( 8 0 0 ) 6 6 2 - 4 5 2 5

* * * * * * * * * * * * i l . T Y P I C A L CHEMICAL AND PHYSICAL PROPERTIES * * * * * * * * * * * * *

APPEARANCE: ASTM 5 . 0 L I Q U I D ODOR: MILD PH: NA V I S C O S I T Y AT 100 F / S U S : 6 5 0 . 0 AT 40 C * C S : 7 2 . 0 V I S C O S I T Y AT 210 F * SUS: 7 0 . 0 AT 100 C * C S : 1 3 . 0 FLASH POINT F(C): 480(249) (ASTM D-92) MELTING POINT F(C): NA POUR POINT F(C): 10(-12) BOILING POINT F( C ) : > 600(316) RELATIVE DENSITY* 15/4 C: 0.89 SOLUBILITY IN WATER: NEGLIGIBLE VAPOR PRESSURE-MM HG 20C: < .1

NA=NOT APPLICABLE NE=NOT ESTABLISHED D=DECOMPQSES FOR FURTHER INFORMATION* CONTACT YOUR LOCAL MARKETING OFFICE.

************************** I I I . INGREDIENTS *************************** WT PCT EXPOSURE LIMITS SOURCES (APPROX) MG/M3 PPM (AND NOTES)

HAZARDOUS INGREDIENTS: NONE

OTHER INGREDIENTS: REFINED MINERAL OILS >90 ADOITIVES ANO/OR OTHER INGREDS. <10

KEY TO SOURCES: A=ACGIH-TLV* A*=SUGGESTED-TLV* M=MOBIL* 0=0SHA NOTE: LIMITS SHOWN FOR GUIDANCE ONLY. FOLLOW APPLICABLE REGULATIONS.

*********************** IV. HEALTH HAZARD DATA ************************ INCLUDES AGGRAVATED MEDICAL CONDITIONS* IF ESTABLISHED

EFFECTS OF OVEREXPOSURE: NOT EXPECTED TO BE A PROBLEM.

*************** V. EMERGENCY AND FIRST AID PROCEDURES ***************** FOR PRIMARY ROUTES OF ENTRY

EYE CONTACT: FLUSH WITH WATER. SKIN CONTACT: WASH CONTACT AREAS WITH SOAP AND WATER. INHALATION: NOT EXPECTED TO BE A PROBLEM. INGESTION: NOT EXPECTED TO BE A PROBLEM. HOWEVER* I F GREATER THAN 1/2

LIT ER(PINT) INGESTED* IMMEDIATELY GIVE 1 TO 2 GLASSES OF WATER AND CALL A PHYSICIAN* HOSPITAL EMERGENCY ROOM OR POISON CONTROL CENTER FOR ASSISTANCE. DO NOT INDUCE VOMITING OR GIVE ANYTHING BY MOUTH TO AN UNCONSCIOUS PERSON.

Mobil • MOBIL PEGASUS 4 85 605816 PAGE 2 OF 4

***************** VI. FIRE ANO EXPLOSION HAZARD DATA ****************** FLASH POINT F<C>: 480(249) (ASTM D-92) FLAMMABLE LIMITS. LEL: .6 UEL: 7.0 EXTINGUISHING MEDIA: CARBON DIOXIDE* FOAM* DRY CHEMICAL AND WATER FOG. SPECIAL FIRE FIGHTING PROCEDURES: FOR FIRES IN ENCLOSED AREAS *

FIREFIGHTERS MUST USE SELF-CONTAINED BREATHING APPARATUS. UNUSUAL FIRE AND EXPLOSION HAZARDS: NONE NFPA HAZARD ID: HEALTH: 0* FLAMMABILITY: 1* REACTIVITY: 0

************************ VI I . REACTIVITY DATA ************************* STABILITY (THERMAL* LIGHT* ETC.): STABLE

CONDITIONS TO AVOID: EXTREME HEAT INCOMPATIBILITY (MATERIALS To AVOID): STRONG OXIDIZERS HAZARDOUS DECOMPOSITION PRODUCTS: CO. HAZARDOUS POLYMERIZATION: WILL NOT OCCUR

******************** V I I I . SPILL OR LEAK PROCEDURE ******************** ENVIRONMENTAL IMPACT: REPORT S PILLS AS REQUIRED TO APPROPRIATE

AUTHORITIES. U. S. CO AST GUARD REGULATIONS REQUIRE IMMEDIATE REPORTING OF SPILLS THAT COULD REACH ANY WATERWAY INCLUDING INTERMITTENT DRY CREEKS. REPORT SPILL TO COAST GUARD TOLL FREE NUMBER 800-424-8802.

PROCEDURES IF MATERIAL IS RELEASED OR SPILLED: ADSORB ON FIRE RETARDANT TREATED SAWDUST* DIATOMACEOUS EARTH* ETC. SHOVEL UP AND DISPOSE OF AT AN APPROPRIATE WASTE DISPOSAL FACILITY IN ACCORDANCE WITH CURRENT APPLICABLE LAWS AND REGULATIONS* AND PRODUCT CHARACTERISTICS AT TIME OF DISPOSAL.

WASTE MANAGEMENT: PRODUCT IS SUITABLE FOR BURNING IN AN ENCLOSED* CONTROLLED BURNER FOR FUEL VALUE OR DISPOSAL 8Y SUPERVISED INCINERATION. SUCH BURNING MAY BE LIMITED PURSUANT TO THE RESOURCE CONSERVATION AND RECOVERY ACT. IN ADDITION* THE PROOUCT IS SUITABLE FOR PROCESSING BY AN APPROVED RECYCLING FACILITY OR CAN BE DISPOSED OF AT AMY GOVERNMENT APPROVED WASTE DISPOSAL FACILITY. USE OF THESE METHODS IS SUBJECT TO USER COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS AND CONSIDERATION OF PRODUCT CHARACTERISTICS AT TIME OF DISPOSAL.

***************** ix. SPECIAL PROTECTION INFORMATION ****************** EYE PROTECTION: NO SPECIAL EQUIPMENT REQUIRED. SKIN PROTECTION: NO SPECIAL EQUIPMENT REQUIRED. HOWEVER* GOOD PERSONAL

HYGIENE PRACTICES SHOULD ALWAYS BE FOLLOWED. RESPIRATORY PROTECTION: NO SPECIAL REQUIREMENTS UNDER ORDINARY

CONDITIONS OF USE A NO WITH ADEQUATE VENTILATION. VENTILATION: NO SPECIAL REQUIREMENTS UNDER ORDINARY CONDITIONS OF USE

AND WITH ADEQUATE VENTILATION.

*********************** X. SPECIAL PRECAUTIONS ************************ NO SPECIAL PRECAUTIONS REQUIRED.

MOBIL PEGASUS 485 605816 PAGE 3 OF 4

*********************** XI. TOXICOLOGICAL DATA ************************ ACUTE

ORAL TOXICITY (RATS): SLIGHTLY TO XIC(ESTIMATED) BASED ON TESTING OF SIMILAR PRODUCTS A ND/OR THE COMPONENTS.

DERMAL TOXICITY (RABBITS): SLIGHTLY TOXIC(ESTIMATED) BASED ON TESTING OF SIMILAR PRODUCTS AND/OR THE COMPONENTS.

INHALATION TOXICITY (RATS): NOT APPLICABLE HARMFUL CONCENTRATIONS OF MISTS AND/OR VAPORS ARE UNLIKELY TO BE ENCOUNTERED THROUGH ANY CUSTOMARY OR REASONABLY FORESEEABLE HANDLING* USE* OR MISUSE OF THIS PROOUCT.

EYE I R R I T A T I O N ( R A B B I T S ) : EXPECTED TO BE NON- IRRITATING. BASED ON TESTING OF SIMILAR PROOUCTS AND/OR THE COMPONENTS.

SKIN IRRITATION (RABBITS): EXPECTEO TO BE NON-IRRITATING. BA SEO ON TESTING OF SIMILAR PRODUCTS AND/OR THE COMPONENTS.

CHRONIC OR SPECIALIZED (SUMMARY) THE BASE OILS IN THIS PRODUCT ARE SEVERELY SOLVENT REFINED AND/OR

SEVERELY HYDROTREATED. TWO YEAR MOUSE SKIN PAINTING STUDIES OF SIMILAR OILS SHOWED NO EVIDENCE OF CARCINOGENIC EFFECTS. SEVERELY SOLVENT REFINED ANO SEVERELY HYDROTREATEO MINERAL BASE OILS HAVE BEEN TESTED AT MOBIL ENVIRONMENTAL ANO HEALTH SCIENCES LABORATORY BY DERMAL APPLICATION TO RATS 5 DAYS/WEEK FOR 90 DAYS AT DOSES SIGNIFICANTLY HIGHER THAN THOSE EXPECTED DURING NORMAL INDUSTRIAL EXPOSURE. EXTENSIVE EVALUATIONS INCLUDING MICROSCOPIC EXAMINATION OF INTERNAL ORGANS AND CLINICAL CHEMISTRY OF BODY FLUIDS* SHOWED NO ADVERSE EFFECTS.

********************* XII . REGULATORY INFORMATION ********************* TSCA INVENTORY STATUS: ALL COMPONENTS REGISTERED. 0.0.T. SHIPPING NAME: NOT APPLICABLE D.O.T. HAZARD CLASS: NOT APPLICABLE US OSHA HAZARD COMMUNICATION STANDARD: PRODUCT ASSESSED IN ACCORDANCE

WITH OSHA CFR 1910.1200 ANO DETERMINED NOT TO BE HAZARDOUS. RCRA INFORMATION: THE UNUSED PROOUCT* IN OUR OPINION* IS NOT

SPECIFICALLY LISTED BY THE EPA AS A HAZARDOUS WASTE (40 CFR* PART 2610); DOES NOT EXHIBIT THE HAZARDOUS CHARACTERISTICS OF IGNITABILITY* CORROSIVITY* OR REACTIVITY* AND IS NOT FORMULATED WITH THE METALS CITED IN THE EP TOXICITY TEST. HOWEVER* USED PROOUCT MAY BE REGULATED.

THE FOLLOWING PRODUCT INGREDIENTS ARE CITED ON THE LISTS BELOW:

CHEMICAL NAME ZINC (ELEMENTAL ANALYSIS) PCT)

(0.025 CAS NUMBER 7440-66-6

LIST CITATIONS 15

1 = OSHA Z* 2 = 6 = EPA CARC* 7 = 11 = IL RTK* 12 = 16 = FL RTK* 17 =

KEY TO LIST CITATIONS ACGIH* 3 = IARC* 4 = NTP* 5-= NCI * NFPA 49* 8 = NFPA 325M* 9 * DOT HMT* 10 * CA RTK* MA RTK* 13 = MN RTK* 14 = NJ RTK* 15 = MI 293* PA RTK.

NTP* IARC* AND OSHA INCLUDE CARCINOGENIC LISTINGS

Mobil • MO STL PEGASUS 485 605 81 6 PAGE 4 OF 4

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * INFORMATION GIVEN HEREIN IS OFFERED IN GOOD FAITH AS ACCURATE* BUT WITHOUT GUARANTEE. CONDITIONS OF USE AND SUITABILITY OF THE PRODUCT FOR PARTICULAR USES ARE BEYOND OUR CONTROL; ALL RISKS OF USE OF THE PRODUCT ARE THEREFORE ASSUMED BY THE USER AND W,£ £ i £ f i £ 5 5 i l BISfiLAJM ALL M f lBBAMII£5 fiE £Y£BI K.JJD AND J|Aiy.R£* INCLUDING WARRANTIES fl£ MERCtjAaiASIlIII AND fIJJ£23 £SB 4 E&BI I IUL IYEUBI55 i " jS" l l 5 f I i I 12 ™£ U££ SB SUITABILITY OF TH£ ££flByCJ. NOTHING IS INTENDED AS A RECOMMENDATION~FOR USES WHICH INFRINGE VALID PATENTS OR AS EXTENDING LICENSE UNDER VALID PATENTS. APPROPRIATE WARNINGS AND SAFE HANDLING PROCEDURES SHOULD BE PROVIDED TO HANDLERS AND USERS.

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * PREPARED BY: MOBIL OIL CORPORATION

ENVIRONMENTAL AFFAIRS AND TOXICOLOGY DEPARTMENT* PRINCETON* NJ FOR FURTHER INFORMATION* CONTACT:

MOBIL OIL CORPORATION* PRODUCT FORMULATION ANO QUALITY CONTROL 3225 GALLOWS ROAD* FAIRFAX* VA 22037 (703) 849-3265

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * APPENDIX * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * FOR MOBIL USE ONLY: ( F I L L NO: RN1022D1001) MHC: 1* 1* NA 0* 0* PPEC: US83-002 APPROVE REVISED: 0 8 / 2 3 / 8 3

X a z Ui Q. CL

'<

APPENDIX B

RESULTS

OF

DRAIN LINE TESTING

El Paso MEMORANDUM Natural Gas Company,

TO Larry Meyer DATE September 21 , 1988

FROM Johnny M. Owen PLACE Pipel ine Maintenance

RE: DRAIN LINE TESTS

JAL #3 Drain Lines

Replaced all bad pipe that was found during test of these lines. All drain lines were tested for one hour. All tests showed no leaks.

EUNICE PLANT Drain Lines

Replaced all .bad pipe that was found during test of these lines. All drain lines were tested for one hour. All tests showed no leaks.

MONUMENT PLANT Drain Lines

All drain lines are in good shape at Monument. No pipe was replaced at this plant. All pipe was tested for one hour. All tests showed no leaks.

ps

cc: File

) FM-tG-OGT

EUNICE DRAIN LINES

2" H.P. Blowdown - M/L Scrubber to Classifier

1. Close 2" valve on downstream side of regulator from scrubbers. 2. Install 2" Blind at check valve.

REMARKS: Fil l and test line from location #2.

TEST PRESSURE: 50# for One Hour

DATE TESTED: September 1, 1988

TESTED BY: Johnny M. Owen (EPNG) Mike Hall (Merryman Const.)

EUNICE DRAIN LINES

2" ESD Blowdown (North Bottle) 1. Close 2" valve located in box. 2. Install blind 2" - 150# Flanges.

Flanges are located in valve box approx. 16' south, 30' east of Valve #1.

REMARKS: Fill line from Location #2, purge air from Location #1.


DATE TESTED: August 30, 1988 TESTED BY: Johnny M. Owen - EPNG

Mike Hall - Merryman Const.

•4.

EUNICE DRAIN LINES

2" ESD Blowdown (South Bottles)

1. Close 2" valve off west bottle (bottle located in box).

2. Close 2" valve off east bottle (bottle located in box).

3. Blind 2" 150# Series flanges. (Located 24' from east bottle, flanges are in box).

REMARKS: Fil l line from 3/4" collar located at Location #3. Purge air from h collar located at Location #3.


DATE TESTED: August 30, 1988

TESTED BY: Johnny M. Owen - EPNG Mike Hall - Merryman Const.

EUNICE DRAIN LINES

4" L.P. from Phillips Water Treating Plant to Classifier Line 1. Blind 6" flanges - (Fill & test from this point). 2. Close 2" Valve off starting air tank. 3. Plug line off starting air tank.

4. Plug 4" funnel drain. 5. Close 1" valve at air condensate tank at utility building. 6. Close 1/2 valve on east side of utility building. 7. Pull trap and plug 4" plastic sewer line. 8. Blind 6" flanges.

REMARKS: This line was originally 6" steel line. It was replaced with 4" Schedule 80 plastic pipe. There is a 12' trap starting at sewer line and running north.

TEST PRESSURE: 20# for One Hour TEST DATE: September 8, 1988

TESTED BY: Johnny M. Owen (EPNG) Mike Hall (Merryman Const.)

EUNICE DRAIN LINES

6" L.P. from Apron Drains to Classifier Lines

1. Blind apron drain - 4" flanges are located approx. 1' off apron. 2. Install expandable plug in apron drain from cooling tower blowdown. 3. Install 6" blind at Junction of sewer line & 6" blowdown line. 4. Install 6" blind at junction of classifier line (located in valve box).

REMARKS: Sewer line comes from bathroom on south side of compressor building. It is 6" clay tile line. This line has to be out of service during test. Fill line from this point.

TEST PRESSURE: 20# for One Hour DATE TESTED: September 1, 1988 TESTED BY: Johnny M. Owen - EPNG


Eunice Drain Lines

4" H.P. Cooling Tower Blowdown to Classifier Line

1. Plug 12 pots coming off cooling tower - 12 - 1" Plugs. All of these pots have valves.

2. Close 1% valve. 3. Close \h valve. 4. Blind 4" Flanges.

TEST PRESSURE: 50# for one hour DATE TESTED: September 6, 1988 TESTED BY: Johnny M. Owen - EPNG


•4.

STATE OF NEW MEXICO

ENERGY, MINERALS AND NATURAL RESOURCES DEPARTMENT


GARREY CARRUTHERS POST OFFICE BOX 2088 STATE LAND OFFICE BUILDING

SANTA FE. NEW MEXICO S7504 (505) 827-5800

GOVERNOR

A p r i l 6, 1988


Mr . John C. Br idges , Manager Environmental Engineer ing El Paso Natural Cas Co. P. 0 . Box 1492 El Paso, Texas 79978

RE: Discharge Plan GW-46 Eunice Gasoline Plant Mainline Engine Room Lea Coun ty , New Mexico

Dear Mr . B r idges :

On October 11 , 1983, the g round water d ischarge p lan , GW-9, for the Eunice Gasoline Plant located in Lea County was approved by the Director of the Oil Conservat ion Division (OCD) . This discharge plan was requ i red and submit ted pursuan t to Water Qual i ty Control Commission Regulations and it was approved for a per iod of f ive yea rs . The approval wi l l exp i re on October 1 1 , 1988. On January 5 , 1987 th is d ischarge plan was t rans fe r red to Phi l l ips 66 Natural Gas Company wi th the except ion of the "Mainline Engine Room." The OCD wil l separate the discharge plan into two pa r t s . GW-9 wil l re fer to the processing plant wi th renewal and compliance wi th the terms and condit ions of the processing plant d ischarge plan the responsib i l i ty of Phi l l ips 66 Natural Gas Company. GW-46 wil l re fer to the mainline engine room wi th renewal and compliance wi th the terms and condit ions of the "Mainline Engine Room" discharge plan the respons ib i l i ty of El Paso Natural Gas Company.

I f your section of the fac i l i ty cont inues to have e f f luen t or leachate discharges and you wish to cont inue d i scha rg ing , please submit your appl icat ion for renewal of plan approval as qu ick l y as possible. The OCD is rev iewing discharge plan submittals and renewals care fu l ly and the review time can of ten extend for several months. Please indicate whether you have made, or in tend to make, any changes in your discharge system, and i f so, include an appl icat ion for plan amendment w i th your appl icat ion for renewal . To assist you in preparat ion of your renewal app l icat ion, I have enclosed a copy of the OCD's guidel ines for preparat ion of g round water d ischarge plans at natura l gas processing p lan ts . These guidel ines wil l be used in review of your renewal appl icat ion.

Mr. John C. Br idges A p r i l 6, 1988 Page 2

I f you no longer have such discharges and d ischarge plan renewal is not needed, please no t i f y th is o f f i ce .

I f you have any quest ions, please do not hesitate to contact Roger Anderson at (505) 827-5885.

David C. Boyer , Chief Environmental Bureau

DCB:s l

Enclosure

cc: OCD-Hobbs

Natural Gas Oxnpanq November 30, 1987

•-. El Paso Q P. O. BOX 1492 EL PASO, TEXAS 79978

PHONE: 915-541-2600

Mr. Roger Anderson New Mxico O i l Conservation Division P. 0. Box 2088 Santa Fe, New Mexico 87504-2088

Subject: Addition of Septic Tank at El Paso Natural Gas Company's Eunice Plant, Lea County, NM

Dear Mr. Anderson:

On November 24, 1987 a c a l l was made to David Boyer to f i n d out the permit requirements for i n s t a l l i n g an underground septic tank at El Paso Natural Gas Company's Eunice Plant. He said that a leak detection system would not be required because the new tank i s upstream of the point at which i n d u s t r i a l waste i s co-mingled with sewage. He also said that the discharge plan would not have to be revised because there i s no net increase i n sewage e f f l u e n t or in-plant personnel.

I am also enclosing, at Mr. Boyer's request, a drawing showing the location of the proposed tank and another drawing showing the tank size and materials of construction. I f you have any questio n s , please f e e l free to c a l l me at 915/541-5341.

Very t r u l y yours,

L. E. Gearhart, P. E. Sr. Environmenal Engineer Environmental & Safety A f f a i r s

ka

Enclosures

cc: David Boyer, NMOCD

Superior in-ground performance and long life are built-in.

soils. Deeply formed corrugations and longitudinal ribs lend extra strength and stability.

Rotomolded, Hancor septic tanks are manufactured as single-piece units.

A product of computer modeling techniques, the Hancor polyethylene septic tank is designed and built to give years of trouble-free service. Hancor septic tanks will not rust, rot or corrode even without an external protective coating. They are ready for burial as delivered.

All Hancor septic tanks are subject to stringent laboratory conducted quality control checks, and every tank produced is individually

•y checked for watertightness before shipment. Their arch-shaped profile maximizes soil loading

^potential to resist flotation in wet or less cohesive

l u l l IUI,»IHU1

SPECIFICATIONS: /

CODE DESCRIPTION 500

GAL. 750

GAL. 1,000 GAL.

— WEIGHT (lbs.) 185 245 300

L LENGTH (in.) 90 92 115

H HEIGHT (in.) 42 54 59

W WIDTH (in.) 62 67 67

H| HEIGHT TO INLET G_ (in.) 34 45 48

H 0 HEIGHT TO OUTLET C_ (in.) 31 42 45

F FLUID LEVEL (in.) 29 40 43

A AIRSPACE (in.) 9.5 12 13.5

fHANCOR SEPTIC TANK 3-Year Limited Warranty

Hancor, Inc., of 401 Olive Street, Findlay, Ohio 45840, warrants to the original purchaser, that its septic tank, when properly installed and properly maintained, will be free from defects in material and workmanship under normal use and service within three (3) years from the

date of manufacture. The provisions of this LIMITED WARRANTY apply

ONLY during the first THREE (3) years after the date of manufacture.

This LIMITED WARRANTY shall only be effective il the following conditions are met:

1. The septic tank must be installed and used in accordance with Hancor's instructions supplied with the tank. The tank must be buried underground and must be kept at least one-halt tull of water or sewage at all times.

2. The septic tank user must maintain written evidence of all maintenance done on the septic tank, including pumping to remove sludge accumulation.

3. The tank must be used as a septic/septage tank. Tanks used in non-septic applications are not covered by this LIMITED WARRANTY.

4. The owner registration card must be filled in and returned to Hancor within THIRTY (30) days from the date of purchase.

Hancor, Inc., will, if it's properly installed and maintained septic tank fails because of

HANGAR

defects in material or workmanship within three (3) years from the date of manufacture, at its election repair the defective septic tank or supply a new equivalent Hancor septic tank in replacement thereof.

In the event Hancor, Inc., is unable to provide a replacement septic tank and repair is not commercially practicable or cannot be timely made, Hancor, Inc., may refund the wholesale purchase price in lieu of repair or replacement. Hancor's liability is limited to the value of the tank itself and specifically excludes the costs of installation and/or removal and indirect or consequential damages.

Before any claims under this LIMITED WARRANTY will be considered by Hancor, Inc., notice of any defect must be given to Hancor, Inc., in writing. This written notice must be received by Hancor within a reasonable period of time after the defect becomes apparent. The written notice must include the serial number of the septic tank which can be found near the rims of the top access holes. The written notice should be

sent to Hancor, Inc., P.O. Box 1047, Findlay, Ohio 45839. Warranty matters may be discussed by calling the following number: (419) 422-6521.

THERE ARE NO WARRANTIES WHICH EXTEND BEYOND THE DESCRIPTION ON THE FACE HEREOF. HANCOR. INC., DISCLAIMS ANY IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE.

IN NO EVENT SHALL HANCOR, INC.. BE LIABLE TO THE PURCHASER OR ANY OTHER PERSON FOR INDIRECT OR CONSEQUENTIAL DAMAGES DUE TO BREACH BY HANCOR, INC., OF THIS WRITTEN LIMITED WARRANTY OR ANY IMPLIED WARRANTY.

Some states do not allow limitations on how long an implied warranty lasts and/or do not allow the exclusion or limitation of incidental or consequential damages, so the above limitations or exclusion may not apply to you.

This warranty gives you specific legal rights, and you may also have other rights which vary from state to state.

J

Hancor waste water management products

(A) Co-extruded SDR-38 Dual Wall Pipe and Corrugated Channelflow® tubing...all in self-coupling 10 feet lengths for fast system construction.

(B) A variety of fittings are available for both Dual Wall Pipe and Channel-flow® Tubing.

(C) Dual Chamber Alternator Valve for ground level switching of alternating disposal fields. Comes complete in kit form with extension tube and lid, hardware and installation instructions.

(D) Standard Alternator Valve performs same function as deluxe unit above. A smaller, simpler valve, it also comes complete in kit form with instructions.

(E) Distribution Box has outlets to accommodate up to 7 lines for maximum system design versatility. Inlet accepts both SCD-40 and sewer and drain pipe, PVC,

ABS, etc. Ground level extentslon and lid are optional.

(F) Multi-Purpose Distribution Sump has unique "either end up" design and offset outlets which make it ideal as drop sump in hillside

- disposal fields and in many other waste management system applications.

California P.O. Box 608, Patterson, CA 95363 (209) 892-3351

Georgia P.O. Box 744, Cordele, GA 31015 (912) 273-1081 1-800-841-6500

Iowa P.O. Box 550, Oelwein, IA 50662 (319) 283-3324

Hancor, Inc., P.O. Box 1047, Findlay, Ohio 45839

Indiana P.O. Box 367, Brazil, IN 47634 (812) 446-2385

Michigan P.O. Box 8, Chesaning, Ml 48616 (517) 845-2013 1-800-525-0052 (Ml only)

Minnesota P.O. Box 808, Fairmont, MN 56031 (507) 238-4791 1.800-862-5575 (MN only) Outside MN (800) 533 0424

New York P.O Box 726, Union Station, Endicott, NY 13760 (607) 748-7336 Outside NY (800) 847 5880

North Carolina P.O. Box 249 Mebane, NC 27302 (919) 563-5551

Ohio P.O. Box 1047, Findlay, OH 45839 (800) 472 9557 Outside OH (800) 537-9520

Texas P.O. Box 271, Yoakum, TX 77995 (800) 242-3521 Outside TX (512) 293-6313

Washington PO. Box 352, Olympia, WA 98501 (206) 943-3313 1-800-654 5401 (WA only) Outside WA (800) 544-1001

©Copyright, Hancor, Inc., 1985 ST-01-10985H

' STATE OF NEW MEXICO Mk

ENERGY AND MINERALS DEPARTMENT OIL CONSERVATION DIVISION

January 5, 1987 GARREY CARRUTHERS

GOVERNOR

POST OFFICE BOX 2088 STATE LAND OFFICE BUILDING

SANTA FE. NEW MEXICO 87501 (505! 827-5800


Mr. J. C. Mikm, Agent Permian Basin Region Phillips 66 Natural Gas Co. 4001 Penbrook Odessa, Texas 79762

Mr. C. W. Hagen, Vice Pres. El Paso Natural Gas Co. P. 0. Box 1492 El Paso, Texas 79978

Re: Discharge Plan Transfer GW-9 Eunice Gasoline Plant El Paso Natural Gas Co. To Phillips 66 Natural Gas Co.

Gentlemen:

Pursuant to your request dated December 15, 1986, and Section 3-111 of the Water Quality Control Commission Regulations, effective December 31, 1986, responsibility for compliance of the terms and conditions of the approved Discharge Plan GW-9, Eunice Gasoline Plant, Lea County, New Mexico, i s transferred from El Paso Natural Gas Company to Phillips 66 Natural Gas Company with the following exception:

1. Any s p i l l s , leaks, reporting requirements and disposal of any wastes generated i n the "mainline engine room" w i l l remain the responsibility of El Paso Natural Gas Company. EPNG must comply with the terms and conditions of discharge plan GW-S as they apply to the "mainline engine room".

Please note that Section 3-104 of the regulations requires that "When a plan has been approved, discharges must be consistent with the terms and conditions of the plan." Pursuant to Section 3-107.C. you are required to notify the director of the f a c i l i t y expansion production increase, or process modification that would result i n any significant modification i n the discharge of water contaminants.

Discharge plan GW-9 was approved October 11, 1983 and w i l l expire October 11, 1988, and application for renewal should be submitted i n ample time for

review. Please be advised a retirement for renewal w i l l be testing of a l l underground piping at f a c i l i t i e s i n excess of 25 years of age.

An inspection t r i p by members of the OCD staff w i l l be scheduled with you i n the near future.

I f there are any questions, please do not hesitate to c a l l Dave Boyer at (505) 827-5812 or Roger Anderson at (505) 827-5885.

Sincerely,

CHARLES R0YBAL7 Acting Director

CR:RCA:dp

cc: OCD-Hobbs

JAN 5! r r v / :•!

PHILLIPS 86 NATURAL GAS COMPANY A S U B S I D I A R Y OF P H I L L I P S P E T R O L E U M C O M P A N Y

ODESSA, TEXAS 79762 4001 PENBROOK

CERTIFIED MAIL RECEIPT NO. P 140 239 509

December 15, 1986

Request for Discharge Plan Transfer El Paso Natural Gas Co., Eunice Gasoline Plant to Phillips 66 Natural Gas Co.

Mr. Richard L. Stamets, Director New Mexico Oil Conservation Division P. 0. Box 2088 Santa Fe, New Mexico 87501

Dear Mr. Stamets:

This letter is written as a joint request by El Paso Natural Gas Company and Phillips 66 Natural Gas Company to transfer the approved discharge plan for El Paso's Eunice Plant to Phillips 66 Natural Gas Company, with one provision. This provision is El Paso will continue to operate and maintain what is referred to as their "mainline engine room". Wastes from the "mainline engine room" which are normally disposed of in the plant's waste system will continue to be disposed of in this manner. However, spill or leak clean-up from the "mainline engine room" and reporting requirements to the Oil Conservation Division will be the responsibility of El Paso Natural Gas Company.

This letter also serves as written notification the requirements of New Mexico Water Quality Control Commission Regulation 3 - 111, relating to transfer of discharge plans, has been met. Transfer of the fac i l i t y operations is tentatively scheduled for December 31, 1986.

Questions regarding this request should be directed to Mr. John Cunningham, El Paso Natural Gas Co., at (915) 684-5701 or Mr. Mike Ford, Phillips Petroleum Co., at (915) 367-1316. Your timely response is appreciated.

Yours very truly,

^ J . C. Mihm Agent, Permian Basin Region

C. W. Hagen Vice President, El Paso Natural Gas Co,

JCM:MDF:ggp MDF\ELPNW.1

CERTIFIED/RETURN RECEIPT REQUESTED

EIPaso P. O. BOX 1492 EL PASO, TEXAS 79978 PHONE: 915-541-2600 Natural Gas Companq

May 5, 1986

New Mexico O i l Conservation Division P.O. Box 2088 Santa Fe, New Mexico 87501

Reference: Underground Storage Tank No t i f i c a t i o n s

Dear Sirs:

Enclosed please f i n d copies of completed underground storage tank (UST) n o t i f i c a t i o n s f o r those tanks located at El Paso Natural Gas (El Paso) locations i n New Mexico. Only those forms containing information on tanks related to a c t i v i t i e s associated w i t h the exploration, development, or production of o i l , gas or geothermal resources are included.

As you are w e l l aware, one of the categories of tanks which are not required to be registered and are excluded according to specific statutory language are those at pipeline f a c i l i t i e s (including gathring lines) regulated under the Natural Gas Pipeline Safety Act of 1968.

On the advice of El Paso's Legal Counsel, n o t i f i c a t i o n forms have been completed f o r a l l tanks which might otherwise be subject to the n o t i f i c a t i o n requirements and have been sent to the appropriate o f f i c e of the Department of Transportation (DOT). DOT regulates a l l f a c i l i t i e s which are used i n the transportation of gas. A l l the above mentioned tanks meet the d e f i n i t i o n of equipment used i n the transportation of gas. As a courtesy, copies of the completed forms being sent to DOT are enclosed.

Please note that each form includes the following disclaimer:

"The tank for which t h i s r e g i s t r a t i o n i s made i s excluded from the r e g i s t r a t i o n requirement because i t i s a pipeline f a c i l i t y regulated under the Natural Gas Pipeline Safety Act of 1968. El Paso Natural Gas Company i s providing t h i s form to DOT as a courtesy with copies to the appropriate state agency."

New Mexico O i l Conservation Division May 5, 1986 Page 2

Should you need further information please contact Howard Reiquam, Director of Environmental A f f a i r s Department or myself at (915)541-3292 or 541-2869, respectively.


John C. Bridges Manager, Environmental Engineering Environmental A f f a i r s Department

JCB:gb

Notification for Underground Storage Tanks FORM APPROVED OMR NO. 2050-0048 APPROVAL EXPIRES 6-30-M

FOR TANKS

IN

NM

RETURN COMPLETED

FORM TO

New Mexico Environmental Improvement Division Ground Water/Hazardous Waste Bureau P.O. Box 968 (505) 827-2933 Santa Fe, NM 87504 (505) 827-2918

GENERAL INFORMATION

I.D Number STATE USE ONLY

Oate Received

Notification is required by Federal law for all underground tanks that have been used to store regulated substances since January 1,1974. that are in the ground as of May 8,1986, or that are brought into use after May 8.1986. The information requested is required by Section 9002 of the Resource Conservation and Recovery Act, (RCRA), as amended.

The primary purpose ol this notification program is to locate and evaluate underground lanks that store or ha\e stored petroleum or ha/ardous substances. It is expected that the information you provide will be based on reasonably available records, or. in the absence oi such records, vour knowledge, belief, or recollection

Who Must Notify? Section 9002 of RCRA. as amended, requires that, unless exempted, owners of underground tanks that store regulated substances must notil v designated State or local agencies of the existence of their tanks. Owner means -

(a) in the case of an underground storage tank in use on November 8. 1984. or brought into use after that date, any person who owns an underground storage tank used for the storage, use. or dispensing of regulated substances, and

(b) in the case of anv underground storage tank in use before November 8. 1984. but no longer in use on that date, anv person who owned such tank immediately before the discontinuation of its use.

What Tanks Are Included? Underground storage tank is defined as anv one or combination of tanks that ( I ) is used to contain an accumulation of "regulated substances."and (2) whose volume (including connected underground piping) is I0' j or more beneath the ground. Some examples are underground tanks storing: I . gasoline, used oil. or diesel fuel, and 2. industrial solvents, pesticides, herbicides or lumiganis.

What Tanks Are Excluded? Tanks removed from the ground are not subject to notification. Other tanks excluded from notification are: 1. farm or residential lanks of 1.100 gallons or less capacity used lor storing motor fuel for noncommercial purposes; 2. tanks used for storing heating oil for consumptive use on the premises w here stored: 3. septic tanks:

4. pipeline laciiities (including gathering lines) reg ula led under ihe Natuiul l \u-Pipeline Safety Act ol 1968. or the Hazardous l iquid Pipeline Salety Act ol I9~9. ot which isan intrastate pipeline tacilitv regulated under Stale laws. 5. surlace impoundments, pits, ponds, or lagoons: 6. storm waler or waste waler collection sy stems; 7. Ilow-through process tanks: 8. liquid traps or associated gathering lines directly related lo oil or gas product ion and gathering operations: 9. storage tanks situated in an underground area (such as a basement, ccllai. mineworking. drift, shall, or tunnel) il the storage lank is situated upon or above the surface of the Hour.

What Substances Are Covered? The notilication requirements applv to underground storage tanks that contain regulated substances 1 his includes anv substance defined as hazardous in section 101 (14) of the Comprehensive Fmironmcmal Response. Compensation and liability Aci ol I98()(CERCI A), with ihe except ion ol those substances regulated as hazardous waste under Subtitle C ol RCRA l l also includes petroleum, e.g.. crude oil or any traction thereol which is liquid al standard conditions ol temperature and pressure (60 degrees Fahrenheit and 14.7 pounds pet square inch absolute)

Where To Notify? Completed notification forms should be sent to the address given at the top ol this page.

When To Notify? I . Owners of underground storage tanks in use or I hai have been taken out of operation alter January I . 1974. but still in the giound. ntusi noiilv by May 8. 1986. 2.Owners who bring underground storage tanks into use alici Mav 8. 1986. must notify within 30 days of bringing the tanks into use-

Penalties: Any owner who knowingly fails to notify or submits false information shall be subject to a civil penalty not to exceed $10,000 for each tank for which notification is not given or for which false information is submitted.

INSTRUCTIONS

Please type or print in ink all items except "signature" in Section V. This form must by completed for each location containing underground storage tanks. If more than 5 tanks are owned at this location, photocopy the reverse side, and staple continuation sheets to this form.

Indicate number ol continuation sheets attached 1 *

I. OWNERSHIP OF TANK(S)

Owner Name (Corporation. Individual. Public Agency, or Other Entity)

Street Address

P. 0. Box 1492 County

El Paso City State ZIP Code

El Paso Texas 79978 Area Code Phone Number

9 1 5 5 4 1 - 2 8 7 9

Type of Owner (Mark all that apply 12 )

(~1 Current CD State or Local Gov't • fy l Private or

Corporate

I " ! Former F l federal Gov't U l t-ormer | _ l (GSA facility I.D. no.

|~"1 Ownership """* uncertain

)

I I . LOCATION OF TANK(S)

(If same as Section 1. mark box here O )

Facility Name or Company Site Identifier, as applicable

r Street Address or State Road, as applicable

P-O- BT,,X <37 County

Us? 3 City (nearest) ,

Oil le*t*<r Indicate number of tanks at this location 4

State

MM ZIP Code

Mark box here if tank(s) are located on land within i—i an Indian reservation or L—l on other Indian trust lands

Name (If same as Section I, mark box here E ] )

III. CONTACT PERSON AT TANK LOCATION

Job Title Area Code Phone Number

IV. TYPE OF NOTIFICATION

l~l Mark box here only if this is an amended or subsequent notification for this location.

V. CERTIFICATION (Read and sign alter completing Section VI.)

I cert i fy under penalty of law that I have personally examined and am familiar with the information submitted in this and all attached documents, and that based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the submitted information is true, accurate, and complete.

Name and official title of owner or owner's authorized representative

J o h n C.. R r i H o o c

Date Signed

„ CONTINUE ON REVERSE SIDE

EPA Form 7530-1 (11-85)

9ge 3 3

*Disclaimer

The tank for which t h i s r e g i s t r a t i o n i s made i s excluded from the regis

t r a t i o n requirement because i t i s a pipeline f a c i l i t y regulated under the

Natural Gas Pipeline Safety Act of 1968. El Paso Natural Gas Company i s

providing this form to DOT as a courtesy with copies to the appro

priate state agency.

X VE

STATE OF NEW MEXICO


TONEY ANAYA GOVERNOR

March 4 , 1985


SANTA FE. NEW IVIEXICO 87501 (505) 897-5800


El Paso Natural Gas Co. One Petroleum Center/Building Two 3300 North "A" Street Midland, Texas 79707 Attenti o n : Mr. J. W. Cunningham

Re: EPNG Discharge Plans -Lea County Plants Drain Line Testing

Dear Mr. Cunningham:

We have reviewed the resul t s of the drain l i n e t e s t i n g program which was conducted by EPNG as part of the discharge plan f o r the Jal No. 3 (GWR-10), J a l No. 4 (GWR-7), Eunice (GWR-9), and Monument (GWR-8) gas processing plants.

Upon analysis of the result s and an estimation of the corrosion rates, we concur with your suggestion that yearly t e s t i n g of the drain systems would be excessive. Therefore, by t h i s l e t t e r , hydrostatic t e s t i n g of the underground drain systems f o r the J a l No. 3, Jal No. 4, Eunice, and Monument gas processing plants w i l l be required as part of the discharge plan renewal process. The t e s t i n g program for each plant should be completed p r i o r to the submittal of the discharge plan renewal. The discharge plan renewal s h a l l include drawings of, and procedures f o r , the t e s t i n g program as w e l l as the res u l t s obtained from the t e s t i n g program. A l i s t of a l l piping replaced should also be included.

I t should be noted that i n the fu t u r e , a l l gas processing plants and o i l r e f i n e r i e s i n excess of twenty-five years of age w i l l be required to submit plans f o r , or the res u l t s of, an underground drainage t e s t i n g program as a requirement f o r discharge plan approval or renewal.

I f you have any questions concerning t h i s l e t t e r and the ef f e c t i t may have on other EPNG plants, please f e e l free to c a l l P h i l Baca or Dave Boyer at (505) 827-5812.

Director

RLS/PB/dp

cc: William F. Lorang, EPNG OCD-Hobbs Office

/

P 505 905 861 RECEIPT FOR CERTIFIED MAIL

NO INSURANCE COVERAGE PROVIDED-HOT FOR INTERNATIONAL MAIL

(See Reverse)

£TPaso Natural Gas Street ^ 3 ^ . N . I I A „ ^

P.O., State and ZIP Code

Midland, Texas 79707 Postage $

Certified Fee

Special Delivery Fee

Restricted Delivery Fee

Return Receipt Showing to whom and Date Delivered Return Receipt Showing to whom.

Oate, and Address of Delivery

TOTAL Postage and Fees $

Postmark or Date

El Paso ONE PETROLEUM CENTER / BUILDING TWO 3300 NORTH "A" STREET MIDLAND, TEXAS 79705 Natural Gas Campanij

February 25, 1985

Mr. Philip L. Baca Environmental Engineer Oil Conservation Division P. 0. Box 2088 Santa Fe, New Mexico 87501

Dear Mr. Baca:

Per our telephone conversation of this date, enclosed are copies of our Jal No. 3 and Jal No. 4 Plant drain system drawings. I have placed a check mark by the lines that were replaced or repaired.

Items b, c, d and e, as noted in 0. R. Dakan's memorandum to J. W. Cunningham dated February 15, 1985, for Jal No. 3 Plant were installed in 1950. Items a and f were installed in 1959.

Items a and b for Jal No. 4 Plant were installed in 1952.

Hopefully, this information, along with the information supplied to you last week, will enable OCD to relax the annual drain line testing requirements of our Discharge Plans and also enable you to develope testing intervals that are realistic and can be justified by companies in our industry.

If additional information is needed, please let me know.

Sincerely,


JWC:gfc

Enclosures

4"

6". , 3 l t

, 3 ^ .148" , l£5.

!ScMp _

5 4" 4"

Id

.Life

>22& ...

_ $4*. AO

^5

11

aio. • izo"

v

Sen JO

7,4 Y

3 . 4"' :j. 6 \ . .

10 'I

Life

) 6 y

5c ~2fe%. X -V*>,6^

Igo' * 4 V 'ripe :„„.,.32„.,^.—. dlJL.

El Paso Natural Gas Companu,

TWO PETROLEUM CENTER / SUITE 200 MIDLAND. TEXAS 79705 PHONE: 915-684-5701

Pebruary 19, 1985

New Mexico O i l Conservation Division P. 0. Box 2088 Santa Fe, New Mexico 87501

Attention: Mr. R. L. Stamets, Director

RE: EPNG DISCHARGE PLANS - LEA COUNTY PLANTS DRAIN LINE TESTING

Gentlemen:

This l e t t e r is to advise that El Paso Natural Gas Company has just recently completed the hydrostatic drain l i n e t e s t ing of our Lea County Plants for the year 1984. This testing was done pursuant to our approved Discharge Plans for Eunice, Jal No. 3, Jal No. 4 and Monument. Drain lines i n the Jal No. 1 Plant were not tested because the plant i s currently shut down. There are no plans at the present time to reactivate the plant.

Attached for your information and to be considered as part of th i s report are two (2) memorandums from Mr. 0. R. Dakan to J. W. Cunningham d e t a i l i n g the results of the tests, repairs or actions taken and cost i n f o r mation associated with the tests.

As you w i l l note a l l lines not meeting the test requirements were either repaired, replaced, or taken out of service except for l i n e No. TDL-15"-L1, which i s a clay t i l e l i n e running beneath the Jal No. 3 gasoline plant concrete drain aprons and a 4" low pressure drain l i n e running beneath the concrete drain apron i n the t r e a t i n g plant at Jal No. 3. I t would be extremely expensive to repair or replace these l i n e s .

Because of the extraordinary time and expense involved i n annual testing of the drain lines and because of the remote p o s s i b i l i t y of ground water contamination from leaking drain l i n e s , El Paso Natural Gas Company respectf u l l y requests that the annual drain l i n e testing provision of the Discharge Plans be rescinded or at least be extended to no more than once every f i v e years. Also, as support for our request to rescind t h i s provision is the fact that we have been advised by P h i l l i p s Petroleum Company and Northern Natural Gas Company, who also operate plants i n the Lea County Area that they do not have these requirements i n t h e i r approved Discharge Plans.

February 19, 1985

I f there are any questions regarding the test results or our request to rescind the test requirements, please advise the undersigned at your e a r l i e s t convenience.

Sincerely,


J. W. CunninghagK Coordinator, Technical Operations

JWC:dc

a El Paso Natural Gas Companu.

MEMORANDUM

TO: J. W. Cunningham

FROMQ. R. Dakan

OATE: February 15, 1985

PLACE: Permian Division-Midland

RE: RESULTS OF DRAINLINE TESTING AT SOUTHEASTERN NEW MEXICO PLANTS

After checking available drawing information, i t has been determined that the underground portion of the drain systems are as follows:

PLANT Jal #4 Jal #3 Eunice Monument

LENGTH OF DRAIN LINES, ALL SIZES 33,045 f t . 26,115 f t . 15,535 f t . 4,665 f t .

Currently, the status of the above drain systems is as follows:

Jal No. 4 Plant-Lines which would not hold test pressure were:

a) 4" low pressure drain from reflux accumulator to 16" drain header (line has been rerouted and replaced).

b) 10"/8" boiler and evaporator blowdown header (line has been replaced).

No. 3 Plant-Lines which would not hold test pressure were:

Line: 0DL-6"-L3 Leaks in 3" drains from intercoolers were repaired. Line in service. Cl^S'^') Line: 0DL-3"-L17 Opendrain from the reflux accumulator. This steel line (70') is being replaced with PVC line. Line: 6" L.P. from hot wells to-line 0DL-8"-Ll0-10' section replaced and line retested. Line: 4" L.P. drain from Solution exchangers to Line 0DL-8"-L12 leaking under concrete apron. No repairs have been made. Line: 6" L.P. drain to solution sump - 9' Section replaced and line retested. Line: TDL-15"-L1 Open Apron and storm water drain. This ti l e line would not pressure because of joint design (Mortar joints) and inability to get a tight seal with the expandable plugs. This drain handles liquids from the Aprons during bundle cleaning operations, steam condensate from the heat tracing line steam traps, and rain water. The discharge end of the line empties into an open distribution sump and has no pressure in the line during normal operations. Under these conditions any leakage at the joints will be minimal since the liquid will take the path of least resistance (i.e. the open end of the line). The line is located under all the concrete aprons North of the Gasoline Pump house and would be extremely expensive to replace. Considering the types of fluids that this

FM 10-0003

Re: Results of Drainline TMting Page 2 w

line transports and the cost of replacement, unless ordered otherwise, this line will be left as is.

At Eunice Plant, the lines which would not hold test pressures were:

a) Line: 6" from water treating building to 8" open drain header. A short section of this line has apparently been subjected to corrosion in a "Hot Spot" where cathodic protection was interrupted. This condition is to be corrected and the clamped section of line replaced. Fluid is water treater backwash water.

b) Line: 4" Drain from Mainline inlet scrubber area to 8" open drain header (Taps F43 and F28). This drain was found to be inactive and was permanently isolated at the 4" to 8" junction. Line is now inactive.

At Monument Plant, there were no leaks on the drain lines. All lines shown on Drainline drawing are in service.

Other than those lines, or sections, previously mentioned, all drain lines in these systems tested leak-free. Pressure charts are on fi l e at the plant for verification of pressures and durations in accordance with the respective drain line test procedures previously published.

0. "R. Dakan : 1

0RD:cd

cc: L. E. Anderson Harold Franklin B i l l Lorang Charlie Mathis G. T. Thurman P. E. Wieland File - 2

IT

@El Paso Natural Gas Companq

MEMORANDUM

T 0 J. W. CUNNINGHAM

F R 0 M 0. R. DAKAN

DATE: FEBRUARY 7, 1985

PLACE PERMIAN DIVISION-MIDLAND

RE: 1984 DRAINLINE TESTING COSTS

Listed below are the actual costs of Pressure Testing the drainlines at the southeastern New Mexico plants.

Monument EPNG Labor EPNG Equipment Material & Parts Contractor Charges

Eunice EPNG Labor EPNG Equipment Materials & Supplies Contractors Charges

Jal No. 3 EPNG Labor EPNG Equipment Materials & Supplies Contractor Charges

Jal No. 4 EPNG Labor EPNG Equipment Materials & Supplies Contractors Charges

Total direct cost - 4 Plants

(402) (420) (417) (429)

Total

(402) (420) (417) (429)

Total

(402) (420) (417) (429)

Total

(402) (420) (417) (429)

Total

$2052.07 1333.37 530.19 5279.00 $9194.63

$3743.67 1610.25 1118.15 6375.96

$12,848.03

$4646.74 1530.15 3948.18 7414.60

$17,539.67

$10354.93 3741.80 6097.82 6097.82

$26,292.37

$65,874.70

FM 10-0003

krainline Testing Costs

After discussions with Hardy Cook and personnel at the respective plants, i t has been estimated that approximately $5000 additional EPNG labor and equipment charges were spent as indirect or unlabeled expenses. Plant personnel were involved in location of lines, valves and drains at various times during the: testing procedure.

It is recommended that the Oil Conservation Division (OCD) be petitioned to extend the testing interval to 5 years instead of the present annual schedule. Although the next test will not be as expensive as this initial test, an annual outlay of approximately $40,000 to $50,000 for drain line testing is not warranted. Testing on a 5 year basis would serve the same purpose at a reduced average annual cost.

ORD:jlr

cc: L. E. Anderson Harold Franklin Bill Lorang Charlie Mathis G. T. Thurman P. E. Wieland File - 2

0. R. Dakan Chief Division Project Engineer

STATE OF NEW MEXICO

ENERGY ANO MINERALS DEPARTMENT OIL CONSERVATION DIVISION

ONEY ANAYA GOVERNOH October 11, 1983

POST OFFICE BOX 208B STATE LAND OFFICE BUILDING SANTA FE, NEW MEXICO 67501

(505) 827-5800

El Paso Natural Gas Company Box 1492 El Paso, Texas 79978

Att e n t i o n : Mr. B. J. Mathews

Re: GWR-9 Discharge Plan

Gentlemen:

The discharge plan submitted pursuant to the Water Quality Control Commission Regulations for the c o n t r o l l e d discharge of waste water and associated f l u i d s from the Eunice Plant located i n Section 5, Township 21 South, Range 36 East, NMPM, Lea County, New Mexico, i s hereby approved.

The discharge plan was submitted pursuant to Section 3-106 and i s approved pursuant to Section 3-109 of the Water Quality Control Commission Regulations. The plan i s approved on October 11, 1983, and i s i n e f f e c t f o r f i v e years.

Yours very t r u l y ,

JOE D. RAMEY Director

JDR/fd

/£> /£>-9-8/ £/tf^6

2€> ?-7

2 / 2 -

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STATE OF NEW MEXICO


TDNEY ANAYA P 0 S T 0 F F I C E B 0 X 2 0 8 8

rnvcQMna r \ ~ 4 - ~ U ~ - 1 1 I O O O - STATE LAND OFFICE BUILDING GOVERNOR O c t O b e r 1 1 , 1 9 8 3 SANTAFE.NEWMEXICOB7501

(505) 827-5BOO

El Paso N a t u r a l Gas Company Box 1492 El Paso, Texas 79978

A t t e n t i o n : Mr. B. J. Mathews

Re: GWR-9 Discharge Plan

Gentlemen:

The discharge p l a n submitted pursuant t o the Water Q u a l i t y C o n t r o l Commission Regulations f o r the c o n t r o l l e d discharge of waste water and associated f l u i d s from the Eunice P l a n t l o c a t e d i n Section 5, Township 21 South, Range 36 East, NMPM, Lea County, New Mexico, i s hereby approved.

The discharge plan was submitted pursuant t o Section 3-106 and i s approved pursuant t o Section 3-109 of the Water Q u a l i t y C o n t r o l Commission Regulations. The plan i s approved on October 11, 1983, and i s i n e f f e c t f o r f i v e years.


JOE D. RAMEY D i r e c t o r

JDR/fd

NOTICE OF PUBLICATION

STATE OF NEW MEXICO

ENERGY AND MINERALS- DEPARTMENT


SANTA FE, NEW MEXICO

Notice i s hereby given that pursuant to New Mexico Water Quality Control

Commission Regulations, the following proposed discharge plan has heen submitted

for*approval to the Director of the O i l Conservation Division, P. 0. Box 2088,

State Land Office Building, Santa Fe, New Mexico 87501, telephone (505) 827-5803.

EL PASO NATURAL GAS COMPANY, Eunice Plant (Section 5, Township 21 South,

St

Range 36 East, NMPM, Lea County, New Mexico) P. 0. Box 1384, J a l , New Mexico

88252, also P. 0. Box 1492, El Paso, Texas 79978, telephone (915) 541-3292,

proposes to discharge approximately 1280 barrels of waste water per day. The

waste water i s derived from plant process, boil e r and cooling tower water, and

domestic e f f l u e n t . The waste water w i l l be disposed of into an i n j e c t i o n system

operated by Rice Engineering Operating, Inc. and ultimately i n t o an i n j e c t i o n

w e l l ( s ) . The t o t a l dissolved solids content of the waste water i s approximately

1250 mg/L.

Any interested person may obtain further information from the O i l Conserva

t i o n Division and may submit w r i t t e n comments to the Director of the O i l Conserva

tio n Division at the address given above. Prior to r u l i n g on any proposed d i s

charge plan or i t s modification, the Director of the O i l Conservation Division

s h a l l allow at least t i i i r t y (30) days a f t e r the date of publication of t h i s notice

during which comments may be submitted to him and a public hearing may be

requested by any interested person. Requests for a public hearing s h a l l set f o r t h

the reasons why -a> hearing should be held. A hearing w i l l be held i f the Director

determines there i s s i g n i f i c a n t .public i n t e r e s t .

GIVEN Under the Seai o f the New Mexico Oil Conservation Commission at Santa Fe, New Mexico, on this 24th day of August, J983.

STATE OF NEW MEXICO OIL CONSERVATION DIVISION JOE D. RAMEY Director

(SEAL)

tt

" ' . • i f no public l i c i r i i i j ' , i s lii/M, the I) i I'i'C lor w i l l approve or il I sappi'ove the

proposed plan based on information available. I f a public hearing is held, the

Director w i l l approve or disapprove the proposed plan based on information i n il

the plan and information submitted at the hearing.

GIVEN Under the Seal of the New Mexico O i l Conservation,Commission at Santa

Fe, New Mexico, on t h i s 24th day of August, 1983.

STATE OF NEW MEXICO

Director

S E A L

GIVEN Under the SearoT the New Mexico Oil Conservation Commission at Santa Fe, New Mexico, on this Z4th day of August, 1983.

; STATE OF NEW MEXICO OIL CONSERVATION DIVISION JOED. RAMEV Director

(SEAL)

DIVISION

Hatural Gas Companq

P. O. BOX 1492 EL PASO, TEXAS 79978

PHONE: 915-543-2600

BILLY J. MATTHEWS VICE PRESIDENT

August 23, 1983

Mr. Joe Ramey, Director New Mexico O i l Conservation Division P. 0. Box 2088 Santa Fe, NM 87501

Re: The Enclosed Discharge Plan for El Paso Natural Gas Company's Eunice Plant

Dear Mr. Ramey:

Please f i n d enclosed the complete discharge plan for El Paso's Eunice Plant.

El Paso has set f o r t h therein i n d e t a i l the methods and techniques proposed to be used which w i l l ensure compliance with the New Mexico Water Quality Act and the New Mexico Water Quality Control Commission regulations.

El Paso hereby requests that you act on the proposed plan pursuant to Sections 3-108 and 3-109 of the regulations.

Thank you for your consideration of t h i s matter.


B. f t Matthews

El Paso NATURAL GAS COMPANY Memorandum

OIL CONSERVATION DIVISION SANTA FE

TO: Oscar Simpson

FROM: Permian Division-Plant Operations

DATE: AugUSt 10 , 1983

PLACE: J a l ^ N . M .

RE: EUNICE WASTE WATER DISCHARGE TO RICE ENGINEERING

DISPOSED WATER CUMULATIVE DISPOSED AVERAGE INJECTION DATE BARRELS WATER BARRELS PRESSURE

July, 1983 81,260 401,000 1 lb.

'I. C. Franklin(jffi

Form 10-3

a Natural Gas Companu, JUL 15 MEMORANDUM

•SANTA

TO: Oscar Simpson P D A T E : July 12, 1983

FROM: Permian D i v i s i o n - P l a n t Operations PLACE: J a l , N.M.

RE: EUNICE WASTE WATER DISCHARGE TO RICE ENGINEERING

DATE DISPOSED WATER

BARRLES CUMULATIVE DISPOSED

WATER BARRELS AVERAGE INJECTION

PRESSURE

June, 1983 8 0 , 4 5 0 319,740 1 LB.

W. C~. Frankl in <=^xJ

FM 10-0003

e Natural Gas Companu,

liSl JUN 13 1983 k.


MEMORANDUM

TO: Oscar Simpson

FROM: Permian Divis ion Plant Operations

DATE: June 7, 1983

PLACE: J a l , N . M .

RE: Eunice Waste Water Discharge to Rice Engineering

DATE DISPOSED WATER

BARRELS CUMULATIVE DISPOSED

WATER-BARRELS AVERAGE INJECTION

PRESSURE

May, 1983 71,500 239,290 1 Lb.

jb

FM 10-0003

fit El Paso Natural Gas Campanu.

OiL CONSERVATION DIVISION SANTA f l

MEMORANDUM

T 0 : Oscar Simpson

FROM. Permian Plant Operations

DATE: 4-13-83

PLACE: J a l ^ N .M.

RE: Eunice Waste Water Discharge to Rice Engineering

DATE DISPOSED WATER BARRELS

CUMULATIVE DISPOSED WATER-BARRELS

AVERAGE INJECTION PRESSURE

Jan., 1983 41,400

Feb., 1983 35,060

March, 1983 38,800

41,400

76,460

115,260

35 lbs.

1 lbs.

1 l b .

H. C. Franklin

FM 10-0003

STATE OF NEW MEXICO ENERGY *NO MINERALS (DEPARTMENT

O I L C O N S E R V A T I O N D I V I S I O I f . O . B O X 2 0 3 8 ,

S A N T A r C . N E W M E X I C O 8 7 3 0 1

Fori) C-120-A R*vli t<i 10-1-78

,o--ol System ^ ' ; i l o r _ _ _ _ _

MONTHLY WATER DISPOSAL REPORT

Submit chis report in triplicate: to the approriatc District Off ice, Oi l Conservation D iv i s ion

EL PASO NATURAL GAS CO. Pitr^™'w~n Eunice Plant Discharge Plan

•v-.ty. LEA

Di iposo l System .

Month APRIL 19. 83

L E A S E W E L L

NO.

L O C A T I O N

U L

DISPOSED V/ATER

B A R R E L S

C U M U L A T I V E DISPOSED

W A T E R - B A R R E L S

A V E R A G E I N J E C T I O N PRESSURES

Eunice P l an t Rice Eng.

21 36

TOTAL 1 6 7 , 7 9 0

>-r-by c e r t i f y tha t Iha a b o v e l a t r u a and c o m p l e t e t o the bea t o f cay I t n o w l t i i g ? nnd b e l i e f .

--"VJ: , • , Name . / V / / P . J / _ ^ _ ^

Company EL PASO NATURAL GAS CO.

T | , | 0 PLANT SUPERINTENDENT

STATE Or NEW MEXICO

'G'.nHGY AMO MINLP.AL5 DEPARTMENT

O I L C O N S E f f V A T I O N D 1 V I 3 I O J

P. O , t l O X 2 1 5 0

S A N T A F C . N E W M I . " X I C O 0 7 3 0 1

»0r ; i C-1?0-A f i e v l i c J 1U-1-7Q

401 System

MONTHLY WATER DISPOSAL RCiPORT Submit tins report in trip) ietsie to tlie uppror i;itc Distr ict-Office, Oil Conservation D iv i s i on

EL PASO NATURAL GAS CO.

• i / — LEA

Disposal System

Month M M E

EUNICE PLANT

1 9 _ - _ L

LEASE

Eunice Plant

T O T A L

W E L L

NO.

R i c e En£ t

L O C A T I O N

U L

21 36

DISPOSED W A T C H

B A R R E L S

38 ,800

C U M U L A T I V E DISPOSED

W A T E R - D A R R E L S

j jy_i_6jp_ • t.-by cerl i ly tlml th* nbove Is t r i n find complctu to tho be*t of >i>y knowloi!<« »n>l bol lof , '

— Name.

—- Company.

. . . T l t lo


1 l b ,

EL PASO NATURAL GAS CO.

PLANT SUPERINTENDENT

El Paso P. O. BOX 1492 EL PASO, TEXAS 79978

Natural Gas Campanu, PHONE: 915-541-2600

March 18, 1983

Mr. Joe Ramey New Mexico Oil Conservation Division P.O. Box 2088 Santa Fe, New Mexico 87501

Re: El Paso Natural Gas Company Eunice and Monument Discharge Plan

Dear Mr. Ramey:

The following is to confirm the discussions during the meeting held in your office on March 15, 1983 and to respond more f u l l y to the technical comments offered by Mr. Oscar Simpson, You called the meeting to discuss the draft addendum to the Eunice and Monument Discharge Plan which El Paso submitted on February 5, 1983. For c l a r i t y and brevity, the following numbered responses correspond to the specific numbered sections of the attached NMOCD comments:

1. The reasons for combining the original discharge plan into one report were the similarities of the plants and especially the method of disposal into the Rice Engineering system. The submitted draft addendum merely continued the original format. El Paso w i l l separate the plans and assemble a l l relevant information i n one rewritten plan i n i t i a l l y . Subsequent submittals (discharge plans) w i l l l i b e r a l l y reference this i n i t i a l rewritten plan and depart from i t only where location specific information dictates.

2. Because the cross-sections wouldn't add to the information already provided i n the previous submittals, you made the decision that El Paso w i l l not be required to submit additional North-South, East-West geologic cross-sections of the Ogallala.

Mr. Joe Ramey -2- March 18, 1983

3. This information was requested to identify possible points of withdrawal. El Paso offered that a l l the available information that could be obtained from the State Engineer's maps had been previously provided to OCD. In addition, such information served no purpose in the demonstration that groundwater degradation is prevented. Based on these and other arguments, El Paso w i l l not be required to submit this information.

4. Although related to question No. 3, El Paso w i l l name the immediately adjacent property user (surface user), i f possible. No t i t l e search is intended, however.

5. El Paso w i l l add statements to the plan text verifying that no j o i n t use agreements exist or easements are granted on Plant property, and that El Paso owns a l l plant property.

6. Same as No. 5.

7. El Paso acknowledged that corrections are appropriate and w i l l be made.

8. El Paso has already provided a verbal description of the soil types, with references. Xerox copies of the appropriate Soil Conservation Service maps w i l l , however, be provided.

9. El Paso w i l l add a statement that storm runoff can't enter the plants' collection systems. The physical r e a l i t i e s preclude such a problem at these plants. Also, please see item number 21, below.

10. El Paso has already provided as much information as could be found on past operations with a photo history. Consequently El Paso does not have to submit the information requested in number 10.

11. El Paso is i n the process of preparing closure plans for both locations. Closure plans cannot be submitted with the discharge plan u n t i l after the April 6 meeting alluded to later; however, El Paso w i l l make a determination, and inform the OCD, when they w i l l be submitted.

12. Following considerable discussion as to the reason for this request, a desire by OCD to know i f something was being stored or is leaking in the shut-down equipment was identified. To •!:his end El Paso w i l l incorporate a statement that nothing is being stored or is leaking i n shut-down equipment.

, ™„«^ - March 18, 1983

13. The ponds at Eunice and Monument are known to be drying; however, the exact status of the ponds could not be discussed. The important point was that nothing is being discharged to them now. Despite this, El Paso w i l l incorporate a statement into the plan text indicating that El Paso w i l l pump out any remaining fluids, and the remaining sludge w i l l air dry by evaporation. In addition, a statement on the fate of rainwater i n such ponds is expected, i f practical.

14. Following a demonstration that standard engineering practices were used to estimate volumes of sewage, you indicated that El Paso w i l l not have to submit any more information on the sewage than has already been given.

15 § 16. El Paso w i l l provide a composite analysis protocol to meet Sec. 3-106 (C-l) of the Water Quality Control Commission (WQCC) Regulations. The protocol to be developed by the Environmental Affairs Department (EAD) w i l l include a general discussion of the sampling and testing procedures, data, documentation, and records. The protocol w i l l demonstrate that the composite analysis achieves a proportional-time weighted sampling, reflecting the fluctuating flow characteris t i c s of the plant on a daily to yearly basis. The protocol is to be reviewed with the Agency on April 7, 1983 i n Santa Fe. El Paso can develop a protocol which w i l l comply with the regulations.

17. El Paso w i l l provide evapotranspiration vs. i n f i l t r a t i o n data to show that WQCC standards w i l l not be exceeded i n ground water i f classifier and tower sludges are placed in a dedicated p i t on plant property. The data w i l l be used to show that monitoring i n the vados zone is not necessary (Sec. 3-107A 3). Discussions on this topic w i l l be included with the composite analysis protocol on April 7, 1983 in Santa Fe. Part of the same demonstration of no leachate formation is tied to the organic chemical analysis and disposal methods for Jal No. 4 which w i l l also be discussed April 7.

18. El Paso w i l l again verify that, u t i l i z i n g the referenced methods, hazardous waste is not generated. This methodology was u t i l i z e d previously. In a l l probability, a statement w i l l be added to the plan indicating that appropriate hazardous waste analyses w i l l be performed on the classifier and tower sludges to verify non-hazardous characteristics. Considerable time and expense is involved i f a l l wastes must be evaluated accordingly.

Marcn 18, 1983

19. This item is related to Item 18. Since this meeting, El Paso's EAD has requested and obtained a legal determination from company lawyers that the o i l and gas industry is indeed exempt from the RCRA law. In addition, the mixture rule has been reviewed and within certain guidelines, El Paso can implement collection (retention) systems to capture and re-use closed cooling systems containing chromium over 5 ppm, which w i l l constitute legitimate re-use and recycling. Such use is exempt from the hazardous waste regulations. El Paso would welcome the opportunity to review the EPA and New Mexico Hazardous Waste Regulations with you, so that you may satisfy yourself that El Paso's interpretations are correct.

El Paso also respectfully requests that the jurisdiction of the NMOCD over the plants under discussion be reaffirmed by the Water Quality Control Commission.

20. Because this information has already been submitted, no further information is required by the OCD.

21. El Paso w i l l incorporate a statement into the discharge plan text indicating that no flooding potential exists for the collection and drainage system and no open drains are tied into the classifier system.

22. El Paso w i l l incorporate a statement into the discharge plan text indicating that cleaning and disposal of debris and sludge from the collection system w i l l be on an "as-needed" basis, because the system has not been i n operation long enough with regular flows to establish a schedule.

23. El Paso's response to this request is contingent on OCD approval of disposal in a dedicated p i t on plant property.

24. El Paso w i l l incorporate a statement into the discharge plan text showing that products are not discharged. A brief summary of product types and handling methods w i l l be included.

25. El Paso w i l l indicate that drainlines w i l l be hydrotested on a yearly basis. Verbal agreement was given by you that i t is more appropriate, and not a part of this discharge plan, to obtain a separate permit for any hydrostatic testing. I f disposal of the hydrotest water would happen to involve the plant effluent disposal system, then OCD would be notified consistent with the WQCC regulations.

26. Similiar to question No. 18, El Paso w i l l again verify that hazardous waste act i v i t y i s not being conducted.

27. This w i l l be covered i n the sampling protocol to be supplied by El Paso and reviewed with OCD on April 7, 1983. The point of sampling w i l l be put on one of the many previously submitted drawings.


28. Section 3 - 107A (11 is addressed in the draft addendum. Section 3-107A (2 through 10) w i l l not be necessary contingent on the April 7 meeting. However, pursuant to 3-107A (7) El Paso w i l l incorporate a statement into the discharge plan text indicating that a l l records w i l l be retained for 5 years.

Pursuant to 3-107A (11). El Paso w i l l add a statement that upon abandonment of f a c i l i t i e s a l l discharges shall cease.

29. The only appropriate response is to reference the wording in the contract between Rice and El Paso.

30. El Paso w i l l not have to submit such a map.

31. I f a successful demonstration of the integrity of a l l gravity flow drains can be made, showing that i t is very unlikely that big leaks w i l l develop between yearly tests, this request w i l l be deleted.

32. The testing plans are already referenced i n the discharge plan. These plans w i l l be submitted when completed.

33. This request is similiar to Item 24 and El Paso w i l l not have to submit such a plan.

34. This information has already been submitted.

35. The discussions of the various protocols on April 7 w i l l determine the appropriateness of the requests and responses. El Paso does not believe the recommended monitoring wells would provide useful information.

36. Since the EID well i s PVC cased, the request is dropped.

37. This request i s also part of the protocols to be discussed.

38. The missing figures were located.

39. El Paso w i l l supply engineering specifications on the meters. The location has already been provided.

In summary, El Paso feels that these specific responses and general comments c l a r i f y a l l the remaining questions that must be addressed on the captioned discharged plan. El Paso f u l l y expects to address a l l the remaining unanswered questions during our upcoming meeting on April 7, 1983. The primary objective of the submittal of discharge plans is to make the demonstrations that degradation of groundwater is prevented. During the nearly three years that have passed since the f i r s t request for a discharge plan for Eunice Plant (April 29, 1980), El Paso has spent over $5,000,000 on wastewater collection systems i n Lea County, New Mexico. The systems meet the standards of performance consistent


with technical pr a c t i c a b i l i t y and economic reasonableness required by the New Mexico Oil Conservation Division as a constituent member of the Water Quality Control Commission. The wastewater systems now installed and working at Eunice and Monument Plants are designed exactly li k e the one at El Paso's Jal No. 4 Plant which was approved by the OCD from construction drawings prior to the construction of the disposal system. El Paso now wishes the approval process of the captioned discharge plan to catch up with the r e a l i t i e s that exist at both locations; namely, expensive and effective wastewater collection systems are installed and operating properly at both locations. El Paso believes that the operating systems meet the requirements and objectives of the New Mexico Clean Water Act ["to prevent or abate water pollution"], and respectfully requests the New Mexico Oil Conservation Division's early approval of the plans.


D. N. Bigbie u

Assistant Division Superintendent

DNB/mts

A ETATE OF r.'EW MEXICO A

ENERrfr AND MINERALS DEPARTMENT OIL CONSERVATION DIVISION

TONEY ANAYA GOVERNOR March 14, 1983


SANTA FE NEW MEXICO 87501 (50S1827-5B00

El Paso Natural Gas Conpany Two Petroleum Center/ Suite 200 North "A" at Wadley Midland, Texas 79701

Attention. D. N. Bigbee

Re: CCD Review of Eunice and Monument Discharge Plan Drafts

Dear Sir:

Pursuant to the submittal of the draft of the Eunice and Monument discharge plans on February 8, 1983, attached are the Oil Conservation Division's technical comments.

I f you have any Questions concerning this matter, please c a l l me at (505) 827-5822.

Sincerely,

OSCAR A. SIMPSON, I I I Water Fesource Specialist

OAS/dp

Enc.

[ICE AND MONUMENT DISCHARGE PlZSNS

I t would be gre a t l y appreciated i f the Eunice and Monument dicharge plans were separated i n t o independent re p o r t s . Also please assimilate i n t o the reports i n a coherent manner any information and data t h a t may be forthcoming as the r e s u l t of the f o l l o w i n g comments on your Eunice and Monument discharge plans.

I I I . DESCRIPTION OF THE ENVIRONMENT (pp. 4 to 10)

A. Submit a d e t a i l e d N-S and E-W geologic cross-section of the Ogallala formation .for both Eunice and Monument. Show the water table and the c o n t r o l points. The cross-sections should extend 1/2 mile beyond the property boundaries i n a l l d i r e c t i o n s .

B. Show on a map of appropriate scale, a l l land use w i t h i n one mile of each p l a n t .

1) I n d u s t r i a l

2) Commercial

3) Residential

4) I r r i g a t e d Land

5) Recreational

6) State and Federal Lands

7) Unused Land

8) Abandoned and Present Water Wells

9) Wells Proposed t o be Monitored

10) Pipelines

11) Location of Geologic Cross Sections

C. On figures 5A and B or a re v i s i o n thereof:

1) Show ownership of adjacent property t o EPNG's Eunice and Monument properties (Names and Mailing addresses)

2) Show a l l right-of-ways and easements on plant properties and ownership thereof.

3) Show and name any parent w i t h i n plant p r o p e r t i e s , owned.

companies l y i n g Show f a c i l i t i e s

IV. SURFACE HYDROLOGY (pp. 11-17)

7

8

ao

11

A. Correlate Appendix A and B which have number systems to Tables 5 and 6 and Figures 5A and B which have l e t t e r systems as to drainage areas. (Eunice Plant)

B. Submit a map showing the d i s t r i b u t i o n of the s o i l types f o r each plant. Show s o i l sample locations.

C. Describe what e f f e c t storm runoff w i l l have on each plant's c o l l e c t i o n and drainage system. At what point (volume) w i l l storm runoff cause overflow and flooding of the c o l l e c t i o n and drainage systems f o r each plant? Are there any storm drain systems? Derive c a l c u l a t i o n s f o r each drainage area (figures 5A and B) th a t w i l l p r e d i c t the extent storm runoff w i l l be degradated due to flooding of the c o l l e c t i o n and drainage systems. Submit a contingency plan or c o r r e c t i v e plan of action that w i l l resolve t h i s problem.

D. Submit a more d e t a i l e d h i s t o r y of past operations concerning waste disposal areas and ponds chat include: (For Eunice and Monument Plants)

1) Date b u i l t ?

2) Used for what length of time?

3) Volume and type of waste disposal including chemicals (chemical c o n s t i t u e n t s - t h e o r e t i c a l or a n a l y t i c a l )

4) From what processes were they from?

5) Show on a map or a e r i a l photo the sequence of events and locations thereof.

E. Submit a detailed closure plan (both plants) f o r past and present waste disposal areas and ponds.

-2-

DICHARGE PLANS - EUNICE AND MONUMENT

J A. Submit a description of the whole e x i s t i n g p l a n t ( t h i s includes that p o r t i o n which i s shut down and not

12 j presently operating). When was section or process shut down? j Were a l l f a c i l i t i e s properly shut down so t h a t discharges or j p o t e n t i a l discharges of wastes, products, or chemicals cannot I occur. I f not, how and when w i l l the problem be abated?

B. Show present status of e x i s t i n g ponds as to whether they are dry, being drained, and i f applicable,

13 a n t i c i p a t e d date when ponds w i l l be drained. How are ponds being drained? Drainage by evaporation w i l l not be allowed.

14

C. I s a l l sewage being disposed of through Rice Engineering System? I f not, where and how? Describe how volumes of sewage were determined. Show measuring point. Show the lo c a t i o n of the c h l o r i n a t i o n s t a t i o n . What mechanism or apparatus i s c h l o r i n a t i n g the sewage ef f l u e n t ? Define the flow c h a r a c t e r i s t i c s of the sewage. Describe the flow measurement apparatus i n d e t a i l . Define the q u a l i t y of the sewage as per Section 3-103 A, B and C.

Under Section 3-106 (C-l) of the WQCC I Regulations 82-1, the quantity, q u a l i t y , and flow

c h a r a c t e r i s t i c s of the discharge are required to be defined. The information i n the discharge plans has no supporting data to v e r i f y the statements made i n the report. A complete analysis of the plant e f f l u e n t was not submitted as required by 3-103 (A, B and C) . Organic substances were not

15 addressed. Methods and locations of flow measurement were not defined or described. Flow c h a r a c t e r i s t i c s of the sources of waste water were . not addressed. Flow c h a r a c t e r i s t i c s r e f l e c t or represent plant f l u c t u a t i o n s , seasonal v a r i a t i o n s , and maintenance and repair of a plant. These f l u c t u a t i o n s r e f l e c t q u a l i t y and quantity i n a plant e f f l u e n t . Data, documentation, and records of sampling and

j t e s t i n g were not submitted.

Under Sections 3-104 and 3-106 (C-l) WQCC regulations 82-1 EPNG i s required t o define the qu a n t i t y , q u a l i t y , and flow c h a r a c t e r i s t i c s of any discharge (s) whether i n the form of a e f f l u e n t or leachate. Therefore each source poi n t of the discharge whether separatic or constant i n nature w i l l be characterized as to i t s q u a n t i t y , q u a l i t y , and flow c h a r a c t e r i s t i c s . The q u a l i t y of each discharge s h a l l be characterized f o r those constituents as

-3-

I 1

l i s t e d i n Section 3-103 (A, B, and C). The quantity s h a l l be measured by standard engineering' practices such as those described i n the "Handbook f o r Monitoring I n d u s t r i a l Wastewater, August 1973, PB-259 146". Refer ro chapters 3, 6, and 7 f o r guidance. The flow c h a r a c t e r i s t i c s r e f l e c t d a i l y t o yearly plant f l u c t u a t i o n s which i n tur n r e f l e c t changes i n q u a l i t y and quantity.

j The flow c h a r a c t e r i s t i c s should be used to 16 j s t a t i s t i c a l l y define the quantity and q u a l i t y of the e f f l u e n t

CONT'D: and or lechate. EPNG i s requested to s t a t i s t i c a l l y ; characterize t h e i r e f f l u e n t and or leachate by the flow I proportional-time weighted composite sampling technique as | described i n the "Handbook for Monitoring I n d u s t r i a l ': Watsewater". This i s the only method t h a t represents the

i n t e n t and requirements of Section 3-106 (C-l) of the WQCC j reg u l a t i o n s .

. Submit a l l documents, records, and data necessary t o achieve the flow proportional-time weighted sampling.

1) Submit graphs or i l l u s t r a t i o n s which i l l u s t r a t e your r e s u l t s

2) Show calculations

3) Show measuring and sampling points on figu r e 5A and on the flow schematic

i I n reply to EPNG's l e t t e r of January 31, 1983, from 0. iR. Dakan and the Eunice and Monument Discharge Plans, the OCD would l i k e t o c l a r i f y the difference between New Mexico WQCC regulations and the EPA's (RCRA) Hazardous Waste Regulations:

17 1) T n e WQCC regulations have lower standards than RCRA.

2) I f a substance i s leachable and that leachate w i l l v i o l a t e WQCC standards, then disposal of that substance or leachate must be disposed of i n such a manner t h a t ground water cannot be effected.

18 3) The Rice Engineering i n j e c t i o n system or wells are

considered to be Class I I Wells. Disposal of substances up to the l i m i t of the RCRA standards can be disposed of i n a Class I I we l l without changing the

-4-

1 c l a s s i f i c a t i o n , and the monitoring and mechanical integrity requirements cf the well.

18 CONT'D 4) Liquids, sludges, solids and any leachate thereof

that are above the standards of the WQCC regulations cannot be disposed of in unlined pits where ground water has the potential to be effected. The RCRA standards do not supersede the WQCC standards in this case and cannot be applied to this case.

5) RCRA Hazardous Waste - land disposal - has a system of monitor wells on and around the disposal area-I f any leachate from the hazardous material i s detected in any quantity, then the disposal system-must be modified, corrected or discontinued and removed .

EPNG i s requested to submit a detailed procedural outline that w i l l set forth the methodology of sampling, testing, evaluating and prescribing modes of disposal for a l l sludge in every plant. A l l sources or areas that generate sludge in a plant must be identified as to quality, quantity, and flow characteristics. I f a data base line of analysis i s su f f i c i e n t to show that future testing i s not required, then the testing requirements w i l l be dropped.

Those constituents as lis t e d in Section 3—103 (A,B, and C) are the parameters which the sludges and associated waste w i l l be analyzed for.

The test methods to be used are:

1) The extraction procedure - Appendix I I of 40 CFR, Part 261 (RCRA) Section 7 - for metals

2) EPA leachate extraction method (for organics) -40-CFR, Part 261

3) EP Toxicity Test - 40 -CFR-261

The OCD w i l l request that EPNG designate a specific disposal area for disposal of a l l on sit e wastes which cannot be disposed of by injection and in conjunction pose a threat to ground water.

The OCD requests that a l l leachable substances and fluids that cannot be disposed of by injection be placed in a double-lined disposal p i t with a leak detection system

-5-

lb i CONT'D1

19

20

21

22

23

between the l i n e r s . P i t plans and sp e c i f i c a t i o n s must be approved p r i o r to construction. Other disposal methods may be s u b s t i t u t e d upon approval.

The hazardous waste section i n Dallas, Texas and the EID section concur t h a t :

1)

2)

The o i l and gas industry does not have e;:empt status once production begins from the wellhead.

The fo l l o w i n g i s considered to be p o t e n t i a l hazardous waste sources and generators of hazardous waste i f they meet c e r t a i n c r i t e r i a :

a) Wastewater c l a s s i f i e r s (sludge)

b) Closed cooling systems containing chromate over 5ppm

c) Carbon f i l t e r materials

d) Cooling towers greater than 5 ppm CR

e) DGA bottoms

f ) Tank bottoms

g) Any non-hazardous material that i s mixed w i t h a hazardous substance automatically becomes a hazardous substance i t s e l f .

Submit a d e t a i l e d description of the types of c o l l e c t i o n systems used to c o l l e c t the various sources of plant e f f l u e n t .

Submit d e t a i l e d plans which i l l u s t r a t e and decribe the various types of c o l l e c t i o n and drainage systems.

Submit calculations to v a r i f y the flow c a p a b i l i t y of the c o l l e c t i o n system.

What i s the maintenance schedule for cleaning debris and sludge from the c o l l e c t i o n system?

Where and how i s the sludge from the c o l l e c t i o n system to be disposed of?

-6-

Describe what products are produced from the raw gas and what i s the d i s p o s i t i o n o i these'substances and how are they stored and tr a n s f e r r e d . (Define the chemical composition of the raw and re f i n e d products.)

Address hydrostatic t e s t i n g and discharge of hydrostatic t e s t water sources, include major transmission l i n e s coming i n and out of the plants. Describe past disposal practices and what intended disposal practices w i l l be implemented f o r the Eunice and Monument plants and appurtenances thereof.

Submit a l i s t and de s c r i p t i o n f o r a l l substances used or generated a t each p l a n t t h a t include RCRA's - Lis t e d Wastes and C h a r a c t e r i s t i c Wastes.

Please address Section 3-106 (C-5)

The OCD requests t h a t a l l of the requirements as set f o r t h i n Section 3-107 A (1-11) be addressed to the discharge plans of Eunice and Monument.

Submit a monitoring and inspection plan which i s e i t h e r administered by you or Rice Engineering and that assumes r e s p o n s i b i l i t y of the p i p e l i n e and contents thereof from EPNG1s property to the i n j e c t i o n system and wel l s .

Show on a map Rice Engineering i n j e c t i o n systems that take e f f l u e n t from Eunice and Monument plants.

MONITORING PLAN (pp. 24 and 46)

To f u r t h e r demonstrate that Eunice and Monument plants are c o l l e c t i n g a l l e f f l u e n t and wastes i r an appropriate manner (not p o l l u t i n g ) and are. monitoring e f f l u e n t ; the OCD suggests t h a t a mass balance accounting system of a l l incoming and outgoing materials i n the e f f l u e n t and wastes be performed on a frequency s u f f i c i e n t to monitor and account f o r mass i n , out, and any losses thereof. (WQCC 82-1 -Section 3-106 (C-7) and 3-107-(A-l)

Submit the underground drain pipe pressure t e s t i n g system i n greater d e t a i l f o r both the Eunice and Monument p l a n t s .

Submit a S p i l l Prevention Control and Counter Measures Plan (SPCCP) as p a r t of your contingency plan f o r both plants - Section 3-107 (a-10).

ADDRESS SECTION 3-106, (C-3).- WQCC 82-1

EPNG i s requested to submit a plan that w i l l cr.ccr.pass d r i l l i n g of monitor wells up and down gradient of the Eunice plant property. Configuration and spacing of the wells in respect to the plant w i l l be determined by hydrologic and geologic conditions of the Ogalalla. The wells should be d r i l l e d to a depth of 75 feet below the ground water table or to the base of the red beds which ever i s greater. The wells s h a l l be of a minimum diameter of 2 inch I.D. and of st a i n l e s s s t e e l construction.

The EID monitor well should be resampled for those organic compounds as found in Section 3-103 (A) WQCC.

Submit data on EPNG Quality Assurance Programs for the labs that performed tests.

Figures - 12b and 13b are missing.

Describe the metering systems for the Eunice and Monument plants that meter effluent going to Rice Engineering.

Show locations on aerial photographs 5A and 5B.

•

El Paso P. O. BOX 1492 EL PASO, TEXAS 79978

Natural Gas Campamj PHONE: 915-541-2600

March 18, 1983

Mr. Joe Ramey New Mexico Oil Conservation Division P.O. Box 2088 Santa Fe, New Mexico 87501

Re: El Paso Natural. Gas Company Eunice and Monument Discharge Plan

Dear Mr. Ramey:

The following: is to. confirm the discussions during the meeting held in your office on March 15 y 1983 and to respond more fully to the technical comments offered by Mr. Oscar Simpson. You called the meeting to discuss the draft addendum to the Eunice and Monument Discharge Plan which El Paso submitted on February 5, 1983. For clarity and brevity, the following numbered responses correspond to the specific numbered sections of the attached NMOCD comments:

1. The reasons for combining the original discharge plan into one report were the similarities of the plants and especially the method, of disposal into the Rice Engineering system. The submitted draft addendum, merely continued the original format. El Faso will separate the plans and assemble al l relevant information in one rewritten plan initially. Subsequent submittals (discharge plans) will liberally reference this i n i t i a l rewritten plan and depart from i t only where location specific information dictates..

2. Because the cross-sections wouldn*t add to the information already provided in the previous submittals, you made the decision that, El Paso will not be required to submit ad-r ditional North-South, East-West geologic cross-sections of the Ogallala.

Mr. Joe Ramey March 18, 1983

3. This information was requested to identify possible points of withdrawal. El Paso offered that all the available information that could be obtained from the State Engineer's maps had been previously provided to OCD. In addition, such information served no purpose in the demonstration that groundwater degradation is prevented. Based on these and other arguments, El Paso will not be required to submit this information.

4. Although related to question No. 3, El Paso will name the immediately adjacent property user Csurface user), if possible. No title search is intended,, however.

5. El Paso will add statements to the plan text verifying that no joint use agreements exist or easements are granted on Plant property, and that El Paso owns all plant property.

6. Same as No. 5.

7. El Paso acknowledged that corrections are appropriate and will be made.

8. El. Pas©> h&s already provided a verbal description of the soil types,, with; references;^ Xerox copies of the appropriate Soil Conservations Service, maps. will,, however,, be provided.

SL EX Pasos will add; & statement that stornc runoff can't enter the plants* collection systems. The physical realities preclude such: » problem at these plants. Also, please see item, number 21,, below.

10. El Paso has, already provided as much, inf ormation as* could be found on past operations with: a photo history. Consequently El Paso- does; not have to submit the information requested in number 10..

11. El. Fasat is in the process of preparing, closure plans for both locations. Closure plans cannot be submitted with the discharge plan until after the April 6 meeting alluded to later;, however, EI Paso will make a determination, and inform the 0CD„ when they will be submitted.

12V FoiLlQwingi coasssdseafaJJle discussions as. tov the reason; foj? thisi request,, a desire by> OCD to know i f something, was being stored' or is leaking; in the shut-down equipment was* identified. To this end EI Paso will incorporate a statement that nothing is being stored or is? leaking in;: shut-down equipment.


13. The ponds at Eunice and Monument are known to be drying; however, the exact status of the ponds could not be discussed. The important point was that nothing i s being discharged to them now. Despite t h i s , El Paso w i l l incorporate a statement into the plan text indicating that El Paso w i l l pump out any remaining fluids, and the remaining sludge w i l l air dry by evaporation. In addition, a statement on the fate of rainwater i n such ponds is expected, i f practical.

14. Following a demonstration that standard engineering practices were used to estimate volumes of sewage, you indicated that El Paso w i l l not have to submit any more information on the sewage than has already been given.

15 § 16. El Paso w i l l provide a composite analysis protocol to meet Sec. 3-106 (C-1) of the Water Quality Control Commission (WQCC) Regulations. The protocol to be developed by the Environmental Affairs Department. (EAD) w i l l include a general discussion of the sampling and testing procedures, data, documentation^ and records. The protocol w i l l demonstrate that the composite analysis achieves a proportional-time weighted' sampling, reflecting the fluctuating flow characteristics; o£ tfte-plaartt om a daily t o yearly basis., The protocol i s t a be re^iewecfe witte the Agency; om April 7, 1983 i n Santa Fe. El, Fase caa develop, a protocol which w i l l comply with the-regulations.

17. El Pasor vstll- provide evapotranspirationf vs. i n f i l t r a t i o n data t c show tha* WQGC- standards w i l l not be exceeded i n ground water i f classifier and tower sludges are placed in a dedicated p i t on plant, property. The data w i l l be used to show that monitoring i n the vados zone is. not necessary (Sec. 3-107A 3) . Discussions on this topic w i l l be included with the composite analysist protocol on April 7, 1983 i n Santa Fe. Part of the same demonstration of no leachate formation i s tied, to the organic chemical analysis and disposal methods for- Jal No. 4 which? w i l l a l s * be discussed April 7 .

18. El Paso w i l l again verify that, u t i l i z i n g the referenced methods* hazardous- waste i s not generated. This methodology was u t i l i z e d previously. l i t a l l probability,, a statement w i l l be added; to; the plant indicating that appropriate hazardous waster ansa&ysies? w*LUL berpejEfnoemed oa the- classifier andl tower sludgesf tos verify ro3n>-hazaajdms characteristics^ Considerable time and expense is? involved i f a l l wastes muit be evaluated accordingly/^.


19. This item is related to Item 18. Since this meeting, El Paso's EAD has requested and obtained a legal determination from company lawyers that the oil and gas industry is indeed exempt from the RCRA law. In addition, the mixture rule has been reviewed and within certain guidelines, El Paso can implement collection (retention} systems to capture and re-use closed cooling systems containing chromium over 5 ppm, which will constitute legitimate re-use and recycling. Such use is exempt from the hazardous waste regulations. El Paso would welcome the opportunity to review the EPA and New Mexico Hazardous Waste Regulations with you, so that you may satisfy yourself that El Paso's interpretations are correct.

El Paso also respectfully requests that the jurisdiction of the NMOCD over the plants under discussion be reaffirmed by the Water Quality Control Commission.

20. Because this information has. already been submitted, no further information i s required by the OCD.

21. El Paso will incorporate a statement into the discharge plan text ind&cating that no. flooding potential exists for the collectxom and drainage system: and no open drains are tied into the classifier system*

22. EL Paso will incorporate a statement into, the discharge plan text- indicating; that cleaning and. disposal of debris and sludge frost the collection; system; w i l l be on an "as-needed"5

basis, because the system, has not' been in operation long, enougte with? regulaxr flows to establish: a schedule.

23. El Pasa"s response to* this request i s contingent on OCD approval of disposal in a dedicated pit on plant property.

24.. E l Paso will incorporate a statement into the discharge plan text, showing that; products are not discharged. A brief summary of product types and handling methods will be included.

25. EI Paso? will indicate that drainlines will be hydrotested on a yearly basis. Verbal agreement was given by you that i t is more appropriate,, and not a part of this discharge plan, ta obtain; a separate permit fox- any hydrostatic testing. I f disposal of the hydEotest water would happen, to- involve the plant:: effluent disposal system?,, then- CCD would be notified consistent with the? WQEC regulations.

26.. Similiar ta questioit No?* I&„ EI Paso will again, verify- that hazardous- waste activity i s not. being conducted.

27. This will be covered in? the sampling protocol to be supplied by EE Pasoi and reviewed with? OCD on April 7, 1983'. The point of sampling w i l l be put on one of the many previously submitted drawings.


28. Section 3 - 107A Ql is addressed in the draft addendum. Section 3-107A (2 through 101 will not be necessary contingent on the April 7 meeting; However, pursuant to 3-107A (71 El Paso will incorporate a statement into the discharge plan text indicating that a l l records will be retained for 5 years.

Pursuant to 3-107A El Paso will add a statement that upon abandonment of facilities a l l discharges shall cease.

29. The only appropriate response is to reference the wording in the contract between Rice and El Paso.

30. El Paso will not have to submit such a map.

31. If a successful demonstration of the integrity of a l l gravity flow drains can be made, showing that i t is very unlikely that big leaks will develop between yearly tests, this request will be deleted..

32. The testing, plans are already referenced in the discharge plan.. TRese plans will, be submitted when completed.

33v This, request: is? similiar: to Item 2* and El Paso; will not have t o submi t sucfe a, pla n.

34V This, information; has already been submitted.

35V The discussions of thevariousprotocols on April 7 will determine the appropriateness of the requests and responses. El Paso-' does not believe the recommended monitoring wells would provide, useful information''.

36. Since the-EID1 well i s PVC cased, the request is dropped..

37. Tbis request i s also; part of the: protocols to be discussed.

38. The missing figures were located.

39. El Paso will supply engineering specifications on the meters. The location has already been provided.

lit; summary,. E l Paso feels; that: theje specif i c responses and general comments clarify a l l the remaining questions; that must be addressed, on the captioned discharged!, plan* E l Paso fully expects to address, a l l the remaining unanswered: questions during, our upcoming: meeting, on April 7, 1983. Ther primary objective of the submittal of discharge plans, i s to make the-demonstrations that. degradatioit of groundwater is prevented. During the nearly three years that have passed since the f i r s t request far a discharge plan for Eunice Plant CApril 29 > 19801, El Paso has spent over $5,000,000: on wastewater collection systems in Lea County, New Mexico. The systems meet the standards of performance consistent


#

with technical practicability and economic reasonableness required by the New Mexico Oil Conservation Division as a constituent member of the Water Quality Control Commission. The wastewater systems now installed and working at Eunice and Monument Plants are designed exactly like the one at El Paso's Jal No. 4 Plant which was approved by the OCD from construction drawings prior to the construction of the disposal system. El Paso now wishes the approval process of the captioned discharge plan to catch up with the realities that exist at both locations; namely, expensive and effective wastewater collection systems are installed and operating properly at both, locations. El Paso believes that the operating systems meet the requirements and objectives of the New Mexico Clean Water Act £"to prevent or abate water pollution"], and respectfully requests the New Mexico Oil Conservation Division's early approval of the plans.

Very truly yours,

Di. N_ Bigbie u

Assistant Division Superintendent

DNB/mts

STATE OF NEW MEXICO Cf JERGY #NO MINEFIALS DEPARTMENT

->iol System

O I L C O N S E R V A T I O N D I V I S I O f». O . I I O A 7 0 3 »

S A N T A F E . N L W M E X I C O 8 7 5 0 1

MONTHLY WATER DISPOSAL REPORT Submit t h i s report i n t r i p l i cu t c to the nppror i i i tc D i s t r i c t O f f i c e , O i i Conserva t ion D i v i s i o n

form C-1Z0-A 8*v(»c<l 10-1-78

ro lo f El Paso Natural Gas Disposal System - Eunice Pi t .

-nty . Lea Month .February 19 83.

L E A S E W E L L

N O .

L O C A T I O N

U L

OISPOSEO WATER

BARRELS

C U M U L A T I V E OISPOSEO



Eunice Plant Rice Eng. 21 36

T O T A L 35.060 76.460 1 lb -: TPby cert i fy that the above 1* t ru* »r»d complete to Ihe bent of my knowledge nnd belief . '

Name.

Compony El Paso Natural Gas

STATE ENERGY awo f

i',posal System

•-cunty Lea ; Momh J a n . )9 83

L E A S E W E L L L O C A T I O N DISPOSED

WATER B A R R E L S




L E A S E NO. U L S T R

DISPOSED WATER

B A R R E L S




Eunice P lan t Rice Eng.

5 21 36

^

< /

/ ,

T O T A L 41,400 41,400 35 l b * .

I heraby cert ify that tho above Ja truo and complete to tho boot o i my knowledge end boliof. '

Company El Paso Natural Gas Company

_ _ „ Title Sup. P lan t

STATE OF NEW MEXICO


BRUCE KING GOVERNOR

LARRY KEHOE SECRETARY

POST OFFICE BOX 2088 STATE LAND OFFICE BUILDING SANTA FE NEW MEXICO 87501

(505) 827-2434

October 28, 1981

El Paso Natural Gas Company Two Petroleum Center / Suite 200 North "A" at Wadley Midland, Texas 79701

ATTENTION: Mr. M. E. McEwen

RE: Monument & Eunice Discharge Plan

Dear Mr. McEwen:

In response to our telephone conversation on October 28, 1981, the Oil Conservation Division w i l l grant El Paso Natural Gas Company an extension of time to the date of November 21, 1981, for Monument and Eunice discharge plans.

The extension was granted on the premise that El Paso needs additional time to firm up negotiations with Rice Engineering. Please disregard my l e t t e r of October 27, 1981, for the exception of the request to submit a detailed progress report for the Monument and Eunice plants since no t i f i c a t i o n . These reports should include estimated time frames and completion dates for use of Rice Engineering injection system and other alternatives such as El Paso's own injection system. The OCD requests that the report be submitted to me within one month from the date of this l e t t e r .

I f you have any questions on this matter, please c a l l me at (505) 827-2534.

Sincerely,

Oscar A. Simpson,III Water Resource Specialist

OAS/dp

STATE OF NEW MEXICO


BRUCE KING GOVERNOR


POST OFFICE BOX 8068 STATE LAND OFFICE BUILDIN SANTA FE. NEW MEXICO 8750

1505) 827-2434

October 27, 1981

. El Paso Natural Gas Company Two Petroleum Center/ Suite 200

1 North "A" at Wadley Midland, Texas 79701

ATTENTION: Mr. M. E. McEwen

Dear Mr. - McEwen: .

In response to El Paso's letter of September 11, 1981 and October 9, 1981, . requesting six-month extensions for Monument and Eunice Discharge Plans respectively, the Oil Conservation Division w i l l not grant the extensions .. without sufficient evidence that such extensions are necessary.

The Oil Conservation Division requests that El Paso submit such documenta-" tion to substantiate your requests, and provide progress reports for Monument and Eunice Plants since notification began. The letters of September and October only reiterate reasons for extension of time that were given in a previous letter of March 24, 1981 by Mr. Smythe.

Sincerely,

Oscar A. Simpson, Water Resource Specialist

cc: E. F. Smythe Environmental Affairs P.O. Box 1492 El Paso, Texas 79978

El Paso Natural Sas Companq

TWO PETROLEUM CENTER / SUITE 200 NORTH "A" AT WADLEY MIDLAND, TEXAS 79701

PHONE: 915-684-5701

October 9, 1981

Mr. Joe D. Ramey, Director New Mexico O i l Conservation Division P. 0. Box 2088 Santa Fe, NM 87501

Subject: Waste Water Discharge Plans: El Paso Natural Gas Company Eunice Plant

Dear Mr. Ramey:

This l e t t e r i s to request a six-month extension of the present due date f o r the referenced discharge plan from October 16, 1981 to A p r i l 16, 1982.

This extension i s requested to allow s u f f i c i e n t time to complete negotiations with Rice Enginfij&ring-and Operations Company (Rxre) nf Hohbs, and perform economic a l t e r n a t i v e evaluation to include drilJJLiig--^n4^per-alJjigL our own disposal well*-

Enclosed please f i n d a copy of a l e t t e r d e t a i l i n g Rice's policy regarding additions to the Eunice-Monument-Eumont (E-M-E) SWD System. El Paso's proposed wastewater disposal involves the same system (E-M-E- SWD System) ., onl^a_dif_fjerent branch. El Paso must_await budget approval and approval bY_thj&_pwners before Rice„jcLlJ.^onsider disposal of additional waste water from our Eunice Plant.

Respectfully,

M. E. McEuen Division Superintendent

MEMcE/kgs

Enclosures

RICE 1 2 2 W E S T T A Y L O R T E L E P H O N E ( S O S ) 3S

HOBBS. NEW MEXICO 88240 S A N l A ^ ^ ° '^ 'S/ON

September 10, 1981 " '' ? :

Ff ; ;1

Sl Paso Natural P. 0. Box 1384 Jal , New Mexico

Gas Company

88252

Attention: Mr. Larry E. Anderson

Gentlemen:

Re: E-M-E SWD System lea County, New Mexico (EPNG Monument Plant • BispoiSIT^g

This is i n response to your telephone request as to the time frame of a l l e v i a t i o n of capacity problem i n the v i c i n i t y of your Monument Plant i n the E-M-E SWD System. Our APE No. H-388 has been prepared and circulated to convert an existing P & A well to an SWD Well i n the rest r i c t e d area. Contingent upon approval by the Operators, iWW, we anticipate successful conversion and completion of the well by around December, 1981 with construction of terminal f a c i l i t i e s and t i e l i n e to the existing system i n the f i r s t quarter of 1982. At such time we can further con- -— sider the disposal of waste water from your Monument Plant.

Please advise i f we can supply any additional i n f o r mation at this time.

.7


NEERING & OPERATING, INC.

I . B.\ Goddheart Division Manager

JEL/ac


PHONE: 915-543-2600

A p r i l 9, 1981

Mr. Joe D. Ramey, Director New Mexico O i l Conservation Division P.O. Box 2088 Santa Fe, New Mexico 87501


Subject: Waste Water Discharge Plans - El Paso Natural Gas Company Eunice, Jal No. 1, and Monument Plants

Dear Mr. Ramey:

In your recent correspondence granting due date extensions for the discharge plans f o r the above referenced plants, you asked what alternative methods El Paso i s considering i n the event Rice Engineering and/or the City of Jal deny us the use of t h e i r f a c i l i t i e s .

We have discussed t h i s with our f i e l d management and they advise that the only p r a c t i c a l alternative presently ;bjg4fiffee^i^-df^gd—in - the event t h i s should happen, i s to dispose of tji£_j s:teL ater - ^ owned and operated disposal wells.

The wells would be budgeted for FY 1982 and would be d r i l l e d and equipped after receipt of a permit from the O i l Conservation Division.


E. F. Smythe, P.E. Chief - Permits Environmental A f f a i r s

sg

STATE OF NEW MEXICO

ENERGY AND ERALS DEPARTMENT OIL CONSERVATION DIVISION

BRUCE KING GOVERNOR

LARRY KEHOE SECRETARY March 30 , 1981

POST OFFICE BOX 2088 STATE LAND OFFICE BUILDING SANTA FE. NEW MEXICO 87501

(505) 827-2434

Mr. E. F. Smythe El Paso Natural Gas Company Box 1492

El Paso, Texas 79978

Dear Mr. Smythe: An extension of s i x months f o r discharge plans f o r your Eunice, Monument, and Jal No. 1 Plants i s granted f o r the reasons o u t l i n e d i n your l e t t e r of March 24, 1981.

The only question I would have i s what a l t e r n a t i v e methods are you loo k i n g at should Rice and the City of Ja l deny you the use of t h e i r f a c i l i t i e s .

Your^ very t r u l y ,

JOE D. RAMEY Di r e c t o r

JDR/fd

March 24, 1981

Mr-..- Joe- D. Ramey, Director- ------New Mexico Oil Conservation Division P.O. Box 2088 Santa Fe, NM 87501

Subject: Waste Water Discharge Plans - El Paso Natural Gas Company (El Paso) Eunice, Jal No. 1 and Monument Plants

Dear Mr. Ramey,

During a recent meeting between yourself and representatives of the El Paso Natural Gas Company, i t was pointed out that f i n a l determinations regarding the waste water discharge plans for the Eunice, Jal No. 1, and Monument Plants were contingent upon the results of El Paso's ongoing negotiations with third parties. The specific details include:

1. El Paso is presently negotiating with the Rice Engineering and Operation's Company (Rice) of Hobbs, the operating company of a cooperatively owned disposal system, to take the waste waters from the KnTTj_r.fi and Monument Plants for deep well disposal.

A decision among the members of the cooperative regarding the financial charges for the extension of service to El Paso, w i l l not be forthcoming for at least three more months. When the decision is reached, El Paso w i l l .then have ?toi conduct.. a ^sT7be

nefit analysis tp,„ascertain v i a b i l i t y of. this, approach as well as other.possible alternatives. "

^ 2 . El Paso is negotiating with the City of Jal regarding the possibility of sending waste water from the Jal No. 1 plant to the City's EPA approved sewage treatment plant that is now under construction and scheduled for completion in 1982. Here again, a cost/benefit analysis must be conducted to determine the v i a b i l i t y of a l l alternatives.

Mr. Joe D. Ramey March 24, 1981 Page Two

On the basis of these uncontrollable third party actions, El Paso would like to request 6-month extensions to the present discharge plan due dates of the Eunice, Jal No. 1, and Monument Plants. These due dates being April 16, May 25, and March 27, respectively.

v. • \ ^ Yours very truly, C ^ , , "V• "

E. F. Smythe, P.E. '^.^ Chief, Permits § Inventories Environmental Affairs Department

mh

STATE OF NEW MEXICO


BRUCE KING GOVERNOR

LARRY KEHOE SECRETARY J a n u a r y 1 6 , 1 9 8 1

POST OFFICE BOX 20BB STATE LAND OFFICE BUILDING SANTA FE. NEW MEXICO 87501

(505) 827-2434

Mr. E. F. Smythe, P.E. Chief, Permits & I n v e n t o r i e s Environmental A f f a i r s Department El Paso Natural Gas Company P. 0. Box 1492 El Paso, Texas 79978

Re: Time Extension f o r Eunice , Plant Waste Water Discharge

Dear Mr. Smythe:

We have received your l e t t e r of January 12, 1981, concerning your request f or an extension of 90 days.

The i n f o r m a t i o n El Paso submitted shows good cause why the O i l Conservation D i v i s i o n should grant a time extensi o n . The due date i s hereby extended to A p r i l 16, 1981.

Please l e t us know i f you have any problems w i t h t h i s arrangement.

-""Yxiurs very t r j i

•/'JOE D. ''RAMEYf D i r e c t o r

JDR/TP/fd

cc: O i l Conservation D i v i s i o n - Hobbs El Paso Natural Gas Co., P. 0. Box 66, O i l Center 88266


s PHONE: 915-543-2600

January 12, 1981

Mr. Thomas Parkhill New Mexico Oil Conservation Division P.O. Box 2088 Santa Fe, NM_87501 ... .. . . —

Subject: El Paso Natural Gas Company (El Paso) Eunice, Jal No. 2 and Jal No. 3 Waste Water Discharge Plans

Dear Mr. Parkhill:

During the recent telephone conversation between yourself and our Mr. Larry Anderson, Larry ppinted_out that the classifier s^stem_at_the Eunice Plant w i l l not be operational u n t i l micUFebruary /at the earliest And because of this, he w i l l not be able to obtain the actual plant waste water flows necessary to develop the plant waste water discharge plan before the plan's current due date.

Larry also advised that the in-service date for the Jal No. 3 waste water in j er.ti on system wi 1J_ occur after the current due date for the Jal No. 3 Plant waste water discharge plan. As Larry explained, i t is necessary to have the injection system in operation to determine i f the well canJiandle.. a l l the waste waters produced at the Jal No. 3 Plant. And, inasmuch as the p i t at the old Jal No. 2 location is used for sewage from Jal No. 3 and w i l l be included in the Jal No. 3 total flow, the Jal No. 2 discharge plan cannot be developed u n t i l the results of the Jal No. 3 injection system have been determined.

On the basis of these contingencies, El Paso hereby request^_JHl^daX--extensifljjLS_to the current due dates for the Eunice, Jal No. 2 and Jal No _j> waste, water discharge plans^

Very truly yours,

E. F. Smythe, P.E. Chief, Permits § Inventories Environmental Affairs Department

EFS:gb

El Paso NATURAL GAS COMPANY

•

PHONE: 915-543-2600

October 30, 1980

Mr. Joe D. Ramey Director New Mexico Oil Conservation Division P. 0. Box 2088 Santa Fe, New Mexico 87501

Subject: El Paso Natural Gas Company -Eunice Treating Plant Waste Water Discharge Plan

Dear Mr. Ramey:

Pursuant to your letter dated June 10, 1980, the El Paso Natural Gas Company (El Paso) hereby offers the following information in regard to progress being accomplished on the waste water discharge plan for the Eunice Plant.

As you know, several equipment and operating changes had been planned which have the effect of changing the actual discharges to be controlled. Several of these changes have since been accomplished:

1. The treating plant, with its associated cooling tower and boiler plant,were taken out of service during the early part of October.

2. The QjJLxlaj|sjfT^^ however, the material has been ordered with an expected delivery date of December 22, 1980.

3. Tbe small boilers necessary for operation-of- thp sulfur recovery unit have been installed but are experiencing startup problems at this time. The blowdown from these boilers is important in the reduction of hexavalent chromium to trivalent chromium in the water disposal system.

Mr. Ooe D. Ramd^ -2- OctJ^r 30, 1980,.

Sampling and analysis of the waste water is now in progress. Results from these analyses w i l l assist in the determinaCtoioccofoa-flnaT disposal method for the water. SANTAF*

Yours very t ru ly ,

E. F. Smythe, P.E. Chief, Permits & Inventories Environmental Affairs

pb

cc: File PDP-12

EI Paso P. O. BOX 1492 EL PASO, TEXAIi 79978

PHONE: 915-543 2600

Mr. Joe D. Ramey New Mexico Oil Conservation Commission P. 0. Box 2088 Santa Fe, New Mexico 87501

September 18, 1980

Subject: Waste Water Discharge Plans

Dear Mr. Ramey,

As you are aware, the U. S. Environmental Protection Agency (EPA) recently promulgated a comprehensive set of regulations pertaining to the management of hazardous waste activity.

Pursuant to the regulations, El Paso has been making analytical evaluations necessary to determine i f hazardous waste activities are conducted at any of its plants.

One of the characteristics established by EPA for determining hazardous waste activity is the Extraction Procedure Toxicity (EP Toxicity) test. The test procedure was designed to identify wastes likely to leach hazardous concentrations of particular constituents into the groundwater under conditions of improper management.

Under the E P Toxicity procedure, constituents are extracted from the waste in a manner designed to simulate leaching action. This extract is then analyzed to determine whether i t possesses any of the contaminants identified in the Natiopal Interim Primary Drinking Water Standards. (NIPDWS). If the extract contains any of the contaminants in concentr-ations 100 times greater than that specified in the National Interim Primary Drinking Water Standards, the waste is considered to be hazardous. (To duplicate the attenuation in concentration expected to occur between the point of leachate generation and the point of human or environmental exposure, EPA applied a dilution factor of 100 to the concentration of constituents observed in the test extract.)

STATE DF NEW MEXICO


BRUCE KING GOVERNOR


June 10 , 198 0

POST OFFICE BOX 2088 STATE LAND OFFICE BUILDING SANTA FE. NEW MEXICO 87501

1505) 827-2434

Mr. E. F. Smythe, P.E. Chief, Permits & I n v e n t o r i e s Environmental A f f a i r s E l Paso N a t u r a l Gas Company P. O. Box 14 9 2 El Paso, Texas 79978

Re: Time Extension f o r Eunices Txj2aJ i g_J&± #*t Waste Water Discharge Plan

Dear Mr. Smythe:

We have received your l e t t e r of June 2, 1980, concerning your request t o change the e f f e c t i v e date of the Eunice. T r e a t i n g P l a n t discharge plan n o t i c e . The O i l Conservation D i v i s i o n i s not p e r m i t t e d t o change the e f f e c t i v e date of the discharge p l a n , but we can g r a n t a time extension f o r completing the discharge p l a n .

The i n f o r m a t i o n E l Paso submitted shows good cause why the D i v i s i o n should g r a n t a time e x t e n s i o n . The due date i s hereby (extended t o February_2, I 9 ^ l ) , w i t h the, prov i s i o n t h a t E l Paso sjjbmit_a d_jscharge plan progress r e p o r t t o the D i v i s i o n on November 3, 1980.

Please l e t us know i f t h i s arrangement i s s a t i s f a c t o r y .



JDR/TP/fd

4 ^ STATE OF NEW MEXICO


BRUCE KING GOVERNOR

LARRY KEHOE SECRETARY A p r i l 29, 1980

POST OFFICE BOX 2088 STATE LAND OFFICE BUILDING SANTA FE, NEW IVIEXICO 87501

(505) 827-2434

Mr. M. E. McEuen D i v i s i o n Superintendent Permian D i v i s i o n El Paso N a t u r a l Gas Company 600 B u i l d i n g o f the Southwest Midland, Texas 79709

Re: Request f o r Discharge Plan

Dear Mr. McEuen:

Under p r o v i s i o n s of the r e g u l a t i o n s of the Water Q u a l i t y C o n t r o l Commission I am hereby requesting the f i l i n g of a discharge plan f o r El Paso's Eu^iiceJProj^e^^ l o c a t e d i n Section 5, Township 21 South, Range 36 East, Lea County, New Mexico.

This plan should cover a l l discharges of e f f l u e n t a t the p l a n t s i t e or adjacent t o the p l a n t s i t e . Section 3-106 A. of the r e g u l a t i o n s r e q u i r e s s u b m i t t a l of the discharge plan w i t h i n 120 days of r e c e i p t of t h i s n o t i c e unless an extension of t h i s time p e r i o d i s sought and approved.

The discharge plan should be prepared i n accordance w i t h Part 3 of the Regulations, a copy of which i s forwarded herewith. Due t o a recent c o u r t d e c i s i o n references t o " t o x i c p o l l u t a n t s " may be ignored.

I f t h ere are any questions on t h i s matter, please do not h e s i t a t e t o c a l l me or Thomas P a r k h i l l a t 827-3260. Mr. P a r k h i l l has been assigned r e s p o n s i b i l i t y f o r review of a l l discharge plans.



JDR/fd enc.

cc: OCD Hobbs D i s t r i c t O f f i c e

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