Larry Campbell

Larry Campbell was an Environmental Specialist within Enron Transportation Services’ Environmental, Health & Safety division, responsible for air quality permitting, PCB remediation, and regulatory compliance across the company’s Southwest Region. Based in Roswell, New Mexico, he served as the primary environmental contact for Transwestern Pipeline Company operations in New Mexico and Arizona, Northern Natural Gas facilities, and EOTT Energy crude oil operations in the Midland Region. His work required direct interface with EPA Region IX, the Arizona Department of Environmental Quality (ADEQ), the Texas Natural Resource Conservation Commission (TNRCC), and tribal authorities on the Navajo Nation.

Campbell’s email archive in the Enron corpus contains 7,574 messages from 770 unique senders, spanning April 1999 to December 2002. Signature term analysis shows he held the #1 ownership rank across the entire corpus for “permit,” “emissions,” “facility,” and “regulations,” reflecting a degree of specialization in environmental compliance unmatched by any other individual in the 1.23 million-message dataset. His weekly environmental activity reports and regulatory correspondence provide a ground-level view of how a major energy company managed environmental obligations during both rapid expansion and corporate collapse.

Career at Enron

Position and Reporting Structure

Campbell served within the EH&S organization for Enron Transportation Services, reporting to Bill Kendrick, an EH&S Manager. He worked closely with John Shafer, Director of EH&S for ETS, and was part of a broader environmental hierarchy under Phil Lowry and Mike Terraso at senior leadership level. Peer environmental specialists included Mike Riedel and Leo Nichols in ET&S Environmental, and Kyle Purvis in GCO Environmental. The structure reflected Enron’s decentralized model, embedding specialists in geographic regions rather than concentrating them at Houston headquarters.

Geographic Responsibility

Campbell’s territory spanned the Southwest with primary responsibility for:

• New Mexico: Roswell area facilities, Laguna and Mountainair teams, Gallup team operations
• Arizona: Transwestern facilities in Kingman and Flagstaff areas, Red Rock Expansion project sites, compressor stations on tribal lands
• Texas: Midland Region EOTT facilities in Eunice, Hobbs, Lovington, and Jal
• Kansas: Northern Natural Gas facilities
• California: Coordination with Southern California Gas Company for PCB management on the Transwestern system

Air Permitting Program

Campbell managed the full spectrum of air quality permits for Transwestern Pipeline operations: Prevention of Significant Deterioration permits, Title V Operating Permits, New Source Performance Standards compliance, and State Implementation Plan permits. His technical work encompassed emission calculations and modeling, equipment operating hour limitations, and like-for-like equipment replacement determinations.

A significant portion of his permitting work involved compressor stations on Navajo tribal lands, specifically Stations 3, 4, and 5, which required coordination with EPA Region IX rather than state agencies. In May 2000, Campbell reported on the issuance of Title V air permits for the Leupp and Klagetoh compressor stations: “Title V air permit for the two Arizona C/S’s which are on the Navajo Indian reservation were issued by the USEPA. The permits seem to be very lenient in terms of requirements. Meetings have been scheduled with each field team to assign roles and responsibilities to ensure compliance with each permit.”

On November 30, 2001, Campbell documented EPA’s oversight requirements for tribal lands water monitoring, relaying instructions from EPA’s Danny Collier: “The EPA is to receive copies of all monthly water well sampling for C/S 3, 4, and 5 in addition to sending the monthly sampling results to Yolanda Barney of the Navajo Nation. Although Yolanda is the primary recipient, the EPA becomes secondary as they have the responsibility for oversight of Indian Lands environmental issues.”

TNRCC Compliance

Campbell handled compliance with the Texas Natural Resource Conservation Commission, including penalty resolution. On May 3, 2000, he reported in a weekly activity report: “A check in the amount of $5,250.00 was delivered to the TNRCC for the late annual certifications required under the Title V air permit program. All dehys in Albuquerque region were entered into the GRI GLYCALC software to determine applicability to the O&G MACT standard.”

PCB Remediation Program

Campbell coordinated the polychlorinated biphenyl compliance program in partnership with Southern California Gas Company. The Transwestern system contained PCB-contaminated equipment requiring ongoing monitoring, testing, and disposal under the Toxic Substances Control Act. Quarterly PCB management costs ran approximately $120,000, with Transwestern responsible for 86% of the shared expenses.

On November 27, 2001, Campbell reported on the third quarter PCB meeting with SoCal Gas: “SoCal presented a third quarter invoice of their PCB management and disposal activities for which Transwestern is responsible for $120,602.19. All charges were appropriate and considered normal operating expenses for PCB activities in California.”

The PCB program extended beyond California. In July 1999, Campbell organized a conference call to discuss analytical results from the Topock Lateral, coordinating with field personnel and contractor Bob Iverson. The Topock Lateral testing was part of broader pipeline contamination assessment across the Transwestern system.

Red Rock Expansion Crisis

The Red Rock Expansion project in Arizona became Campbell’s most challenging permitting episode in 2001. The project required air permits from both EPA Region IX and ADEQ for new compressor station facilities at Kingman and Flagstaff. Campbell had submitted applications in February 2001 and conducted pre-submission meetings with both agencies to confirm requirements and timelines.

When permit issuance slipped past the September target, Campbell documented the failure in detail on September 17, 2001.

The delay of one to four months beyond the September target threatened the construction timeline and generated significant correspondence within Enron. Technical disputes with ADEQ included the agency’s application of 10% safety factors in permit conditions and disagreements over generator operating hour limitations – 8,760 hours versus 7,800 hours. A public hearing held in Williams, Arizona in November 2001 drew no public comments or attendees, but the bureaucratic timeline remained unchanged.

Equilon Pipeline Due Diligence

In August 2000, Campbell conducted environmental due diligence for EOTT Energy’s acquisition of Equilon Pipeline Company assets. His assessment revealed sweeping compliance gaps. On August 28, 2000, he documented the findings.

The memo demonstrated Campbell’s thoroughness as an environmental auditor. An 80,000-barrel tank built in the 1930s with a concrete bottom that had never been emptied for inspection represented precisely the kind of legacy liability that environmental due diligence is meant to uncover.

EOTT Energy Integration

Beyond the Equilon acquisition, Campbell managed broader environmental compliance for EOTT Energy’s crude oil operations in the Midland Region. The integration required field visits to 13 teams with EOTT facilities across Hobbs, Lovington, Jal, and Eunice. Responsibilities included:

• Field verification of tank inventories and compliance status
• Emission fee determinations for tank batteries
• Development of databases and spreadsheets for compliance tracking
• Coordination of EPA 308 request responses for releases
• Hazardous waste generator status determinations

On January 10, 2001, Campbell reported on compliance problems at the EOTT Bakersfield facility, where emissions testing failures triggered a Notice of Violation: “I have spoken to the agency inspector about one of the NOV issues and have been told that EOTT will definitely receive an NOV and fine for failure to conduct the emissions testing on a heater that apparently should have been tested approx. 6 months ago.”

Northern Natural Gas Operations

Campbell managed Title V permit renewals for multiple Northern Natural Gas compressor stations, including facilities at Kermit, Plainview, Seminole, and Brownfield. This work required coordination with the Kansas Department of Health and Environment in addition to Texas and New Mexico agencies, and included semi-annual and annual compliance reporting requirements.

Key Correspondents

Campbell’s correspondence network reveals the pattern of a field-based environmental professional bridging operations teams, Houston leadership, and external regulators.

The heavy volume with Kendrick (582 messages) reflects the direct reporting relationship. Field operations contacts – Kinser, Stepenovitch, Acevedo, Hernandez, Jolly – represent the compressor station teams and pipeline crews that Campbell trained and coordinated with on compliance matters. The NYISO automated feeds, which contributed to Campbell’s #1 corpus ranking for the term “nyiso,” appear to be market operations data routed to his mailbox, likely related to Transwestern’s gas delivery scheduling.

Email Activity

Campbell’s email volume tracked the intensity of permitting and compliance work across his portfolio.

The dramatic spikes in November 2000 and May 2001 – roughly five to ten times his typical monthly volume – reflect periods of overlapping project demands, particularly the EOTT integration and Red Rock expansion permitting. The near-total drop in 2002 likely reflects either Campbell’s departure from Enron or the cessation of email archiving during the bankruptcy period.

Conservation Partnerships

Beyond regulatory compliance, Campbell developed corporate partnerships with conservation organizations including the Rocky Mountain Elk Foundation and the Wild Turkey Federation. He coordinated with RMEF’s Vice President of Development on a Memorandum of Understanding and engaged state directors in New Mexico, Texas, and Arizona. These initiatives aligned with Enron’s pipeline right-of-way land management and reflected Campbell’s personal interest in wildlife conservation.

Collapse Period

Campbell continued managing environmental compliance obligations through Enron’s bankruptcy filing and into December 2001. On December 17, 2001, he wrote to a colleague.

He added: “This whole thing doesnt seem to be bothering me, as I am relying on Jesus, my higher power and that has been my strength and comfort.”

The email captures the experience of a field employee distant from Houston headquarters, watching the collapse from Roswell while managing environmental obligations that would persist regardless of the company’s financial status – PCBs in the pipeline do not care about bankruptcy filings.

Legal Status

Larry Campbell does not appear in Department of Justice or Securities and Exchange Commission proceedings related to the Enron collapse. His work in environmental compliance for pipeline operations was unrelated to the financial and accounting issues that led to criminal prosecutions.

See Also

• Don Baughman – Operations contact in Campbell’s correspondence network
• Juan Hernandez – Field operations correspondent
• Drew Fossum – Transwestern Pipeline executive

References

This article is based on Larry Campbell’s email archive containing 7,574 messages from 770 unique senders, spanning April 1999 to December 2002. Secondary sources include SEC 10-K filings confirming Transwestern Pipeline and EOTT Energy as Enron subsidiaries, and Natural Gas Intel reporting on Transwestern operations during the California energy crisis.