Gerald,

I don't have a computer copy of the report.  The main concern I had in my 
review of the Hard copy (which I have with me) was the suggestion that 
monitoring wells be installed at the 2 cogen sites.  Question that comes up 
from a "legal" perspective is how liability gets allocated to various owners 
if the wells later show environmental contamination.  I've left a voicemail 
to Heather outlining this  concern.

Steve
----- Forwarded by Steve Van Hooser/HOU/ECT on 01/02/2001 09:34 AM -----

	Heather Kroll
	12/22/2000 10:54 AM
		 
		 To: Fred Mitro/HOU/ECT@ECT, Reagan Rorschach/NA/Enron@Enron, Steve Van 
Hooser/HOU/ECT@ECT
		 cc: 
		 Subject: Lumberton, Elizabethtown Phase II

I'm getting a copy of the official Phase II report Fed Exed to me today.  
Here is Dave Kellermeyer initial report.  Basically they are very clean coal 
plants.

Heather
---------------------- Forwarded by Heather Kroll/HOU/ECT on 12/22/2000 10:57 
AM ---------------------------


Dave Kellermeyer
12/20/2000 07:17 AM
To: Ozzie Pagan/HOU/ECT@ECT, Heather Kroll/HOU/ECT@ECT, Dwight 
Beach/HOU/ECT@ECT, Glenn Wright/Corp/Enron@ENRON, Janet R Dietrich/HOU/ECT@ECT
cc:  
Subject: Lumberton, Elizabethtown Phase II

ENSR has obtained the analytical results from the Phase II investigation and 
is in the process of writing up the results.  I spoke at length with the 
individuals responsible for the investigation and can provide you with some 
preliminary conclusions.  Keep in mind, that these are my interpretations of 
our conversation and that they may produce a slightly different spin on the 
results.

Railcar Unloading Site

There were no detectable petroleum hydrocarbons detected at the site of the 
former 10,000 gallon diesel tank, either in soil or groundwater.
Groundwater sampling around the former coal pile area produced some 
detectable substances (sulfates, lead, iron).  However, these substances were 
not present in quantities that would indicate a contamination problem.  The 
levels of these substances in groundwater is comparable to that in nearby 
groundwater monitoring wells.

Lumberton Plant

The small diesel tank area that had been identified in the Phase I as having 
evidence of contamination was sampled.  Concentrations of total petroleum 
hydrocarbons were marginally detectable in the soil and at extremely small 
quantities in the groundwater.  The levels in the groundwater are at least 
six times lower than the appropriate Action Level.  No further action is 
warranted.
The area around the silo has soil is heavily stained with ash down to about 6 
inches from the surface.  In general, the soil samples taken did not have 
particularly elevated concentrations of metals with the exception of a sample 
that was taken by scraping off the surficial ash.  Even this surficial sample 
did not have metal concentrations significantly above typical soil background 
levels.  Overall, the presence of this material is probably the result of 
runoff of an ash slurry from the ash trucks as a result of the use of water 
for dust suppresion.  There does not appear to be any widespread, significant 
contamination.   Removal of some of the soil around the ash silo might be 
contemplated, as well as engineering measures to prevent any future 
contamination.  
ENSR detected some substances in the groundwater near the coal pile 
(sulfates, nickel iron chromium), but indicated that the quantities don't 
appear significant.  No further action is warranted.
The area around the oil/water separator (OWS) had detectable quantities of 
oil and grease in the soil and groundwater.  These levels are marginally 
significant.  ENSR feels that the in-ground OWS tank is leaking.  I believe 
that they will probably recommend that the OWS tank is emptied, inspected, 
and sealed, if necessary.  At worst, I believe this to be a localized 
contamination issue that can be easily addressed.  ENSR may suggest follow up 
monitoring.

Elizabethtown

Silo area - similar findings to Lumberton
Coal pile - similar findings to Lumberton.  ENSR was able to obtain a sample 
from only one well due to the extremely confining nature of the native clay 
soils.  This is probably creating a natural barrier to the transport of 
contaminants that complements the coal pile liner.
OWS -  similar findings to Lumberton

Overall

Nothing that ENSR reported to me seems to be indicative of any significant 
large scale contamination.  The railcar unloading facility is in good shape.  
Both power plant sites appear to have in-ground oil/water separators that may 
be leaking oil.  The coal pile areas do not appear to be a concern.  The ash 
silo area has some surficial staining of ash and associate elevated metal 
concentration in the soil.  I don't think this is significant problem, but 
it's likely that the process of ash handling and shipping could be improved 
to avoid future releases to the soil.

ENSR will be providing the draft report on Friday.