Duke's Tie In Into the Pipeline Liquids Tank at Wt-1

Rich, concerning the environmental liabilities which may impact Transwestern if Duke should direct the liquids from their 8" line into the pipeline liquids tank at Wt-1, I have a concern.

The liquids that are generated in the 8" line are exempt from hazardous waste regulations (RCRA) as long as they stay in the Duke line and are not transfered and collect in a mainline tank. Because WT-1 is a mainline compressor station, any chemicals or compounds which are regulated under Subtitle C of RCRA become the responsibility of the owner of the mainline tank. Within the past few years, we have experienced the collection of regulated liquids at Wt-1 which were not placed there by Tranwestern. Chemicals which producers and processing, upstream of Wt-1, have placed downhole to enhance gas production and other agents such as corrosion inhibitors and pipeline solvents have found their way into our tank and we have paid for the disposal. Unfortunately, there is no way to segregate the bad materials from the good recycleable materials.

Based upon this, I would recommend that we not allow Dukes pipeline liquids to collect into our tank.