OK Ed try this:

 Tank 15 area-  Total petroleum hydrocarbons TPH concentrations in soil 
exceed 10,000 mg/kg.  This value has been identified in the "Leaking         
Underground Fuel Tank Field Manual, (State of Califonia, 1989).  This value 
was identified as a         potential threat to groundwater aquifers.  

 Glycol reboiler area- Total petroleum hydrocarbons  TPH concentrations in 
soil exceed 10,000 mg/kg.  This value has been identified in the 
"Leaking         Underground Fuel Tank Field Manual,(State of Califonia, 
1989).  This value was identified as a         potential threat to 
groundwater aquifers.  

 Hot oil heater area- Total petroleum hydrocarbons TPH concentrations in soil 
exceed 10,000 mg/kg.  This value has been identified in the "Leaking         
Underground Fuel Tank Field Manual, (State of Califonia, 1989) as a potential 
threat to          groundwater aquifers.  

   Wash rack area- Lead    Lead values exceed the Toxic Characteristic 
Leaching Procedure target levels as a  hazardous         waste (40 CFR 261)

 Propane comp. area Lead      Lead values exceed the Toxic Characteristic 
Leaching Procedure target levels as a  hazardous         waste (40 CFR 261)
    
    Total petroleum hydrocarbons TPH concentrations in soil exceed 10,000 
mg/kg.  This value has been identified in the "Leaking         Underground 
Fuel Tank Field Manual, (State of Califonia, 1989) as a potential threat 
to          groundwater aquifers.  
    
    Chromates   Chromate values exceed the Toxic Characteristic Leaching 
Procedure (TCLP) target levels as a          hazardous waste (40 CFR 261)

 Cooling tower area- Chromates   Chromate values exceed the Toxic 
Characteristic Leaching Procedure (TCLP) target levels as a          
hazardous waste (40 CFR 261)   

 Compressor area- BTEX    Benzene concentrations in soil exceed 1.0 mg/kg.  
This value has been identified in the "Leaking         Underground Fuel Tank 
Field Manual, (State of Califonia, 1989) as a potential threat to          
groundwater aquifers.   
    
    Chromates   Values exceed the Toxic Characteristic Leaching Procedure 
(TCLP) target levels as a           hazardous waste (40 CFR 261) 
    
    Lead    Values exceed the Toxic Characteristic Leaching Procedure (TCLP) 
target levels as a           hazardous waste (40 CFR 261)  



From: Edward Attanasio@EOTT on 05/21/2001 11:09 AM PDT
To: Larry Campbell/ET&S/Enron@ENRON
cc: Louis Soldano/ET&S/Enron@Enron, Scott Jones/Bakersfield/Eott@Eott, 
William Kendrick/OTS/Enron@Enron 

Subject: Re: Additional Soil Investigations, North Coles Levee  

In light of the Koch indemnity, at minimum we'll need to come up with a 
specific reason for each area, based on California standards, and to 
communicate that rationale to Koch prior to doing any substantial work -- 
certainly before boring.  Thanks.



	Larry Campbell@ENRON
	05/21/01 09:54 AM
		 
		 To: Edward Attanasio/Remote/Eott@Eott, Louis Soldano/ET&S/Enron@Enron, Scott 
Jones/Bakersfield/Eott@Eott
		 cc: William Kendrick/OTS/Enron@Enron
		 Subject: Additional Soil Investigations, North Coles Levee

After reveiwing the documents entitled, "Baseline Environmental Investigation 
of Arco North Coles Levee Plant 8, Rogas Loading Facility and Associated 
Natural Gas Pipeline Systems Kern County, California" and "Report of 
Preliminary Asessment Sampling North Coles Levee Gas Plant Loading Rack Area 
Tupman, California", it appears that the following areas should be 
investigated further to detemine horizontal and vertical extent of  
identified contamination from the above referenced reports:

 Tank 15 area-  total petroleum hydrocarbons

 Glycol reboiler area- total petroleum hydrocarbons

 Hot oil heater area- total petroleum hydrocarbons

   Wash rack area- lead

 Propane comp. area lead  
    total petroleum hydrocarbons
    chromates

 Cooling tower area- chromates

 Compressor area- BTEX
    chromates
    lead

In the "Baseline Environmental Investigation" report, sampling was only 
conducted to an approximate depth of 2.5'.  I am not comfortable with basing 
decisions for further investigations on such a shallow depth, in leau of the 
fact that  many times water soluble constituents may horizonatlly move 
vertically from surface shallow depths into the lower subsurface areas.  This 
is indeed the case for chromates.  I based my recommendations for metal 
concentrations on the federal RCRA Subtitle C hazardous waste target levels 
for metals and evaluated  the TPH and BTEX levels with the  underground 
storage tank guidlines for California.  There were references to a 1989 
document in the "Baseline" report for specific parameters, but there may have 
been an update to target contamination level requirements since that date and 
therefore, I used 10,000 ppm which is a general action level for most states 
for total petroleum hydrocarbons.  Again, I did not evaluate the mercury or 
the loading rack issues.

One last issue.  As you know, identification of contamination is usually 
accomplished by sight observations of visible contamination, knowledge of 
processes and or history.  Report results of the surface contamination do not 
show there to be an immediate environmental concern.  Due to the age of the 
facility, there may be concerns which were not identified in the reports.  
However, based upon the locations of the preliminary samplings which were 
conducted throughout the facility, it appears that the information presented 
in the reports would be adequate to address suspected contamination at the 
facility.