As a reminder, the state of Texas requires releases of natural gas greater  than 119 mscf  to the atmosphere (in a 24 hour period), to be reported to the  Regional Offices of the TNRCC.
These releases include but may not be limited  to the following:  ESD's, startups, shutdowns, pipeline ruptures and  maintenance activities.
Should any of the above activities release natural  gas in excess of 119 mscf, a written notification should be faxed to the  Regional Office of the TNRCC  within the following timeframes:   Unanticipated Upsets- within 24 hours after the discovery of the upset.
Maintenance, Startup or Shutdowns- 10 day prior to the expected exceedance.
This reminder is being sent to all ET&S teams within Texas because in the  last two Northern Natural Gas compressor station inspections conducted by the  TNRCC,  they specifically requested backup data and reporting documentation  of the natural gas releases to the atmosphere which were greater than 119  mscf.
The agency's  inquiry specifically addressed knowledge of compressor  station venting for ESD, start ups and shutdowns.
It should also be mentioned that there has been inconsistencies in the  TNRCC's position regarding this issue.
However, until a position has been  adopted by Enron's GPG, I am recommending that each facility comply and  report as appropriate.

Natrual Gas Release Reporting Requirements for Texas
As a reminder, the state of <STATE> requires releases of natural gas greater than <NUMBER> mscf to the atmosphere (in a <NUMBER> hour period), to be reported to the Regional Offices of the TNRCC.
These releases include but may not be limited to the following: ESD's, startups, shutdowns, pipeline ruptures and maintenance activities.
Should any of the above activities release natural gas in excess of <NUMBER> mscf, a written notification should be faxed to the Regional Office of the TNRCC within the following timeframes: Unanticipated Upsets- within <NUMBER> hours after the discovery of the upset.
Maintenance, Startup or Shutdowns- <NUMBER> day prior to the expected exceedance.
This reminder is being sent to all ET&S teams within <STATE> because in the last two Northern Natural Gas compressor station inspections conducted by the TNRCC, they specifically requested backup data and reporting documentation of the natural gas releases to the atmosphere which were greater than <NUMBER> mscf.
The agency's inquiry specifically addressed knowledge of compressor station venting for ESD, start ups and shutdowns.
It should also be mentioned that there has been inconsistencies in the TNRCC's position regarding this issue.
However, until a position has been adopted by <COMPANY>'s GPG, I am recommending that each facility comply and report as appropriate.
specifically requested backup day include limited following esd startups shutdowns written notification faxed pipeline ruptures maintenance inconsistencies tnrcc number mscf agency natural gas releases