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Enron Mail |
Two points were apparent after my last conversation with Bill Olson about a
month ago: 1) Texaco has convinced Bill that the plume of elevated TDS originates from an offsite source; an old waterflood operation toward the northwest and upgradient of the Texaco and NNG facilities. Although our data from 2-3 years ago indicated the source as Texaco's old brine ponds, Bill indicated that Texaco has more recently presented data that is more regional in scope and implicates the waterflood operation. I have not seen any of this recent data. 2) Bill has accepted Texaco's single soil boring in the former crude oil pit area as evidence that the pit was not the source of oil found in NNG's monitor well MW-3. I don't agree, but our best chance of convincing him otherwise will not come until Texaco excavates the old pit area and completes the additional assessment activities we agreed to in our meeting with them last year. In light of these two points, I think it is going to be difficult to convince Bill that NNG should not adhere to the biennial sampling until things are settled between Texaco and NNG. However, if you are going to give it a shot, I suggest that you present the position that: 1) Texaco has already demonstrated (whether correctly or not) that the dissolved phase plume of TDS originated from another source; 2) Texaco has already demonstrated that they were the source for the dissolved phase plume of benzene measured in NNG's fenceline monitor wells; and, 3) The only unresolved issue is the presence of PSH in monitor well MW-3. In light of this, the only monitoring NNG should be responsible for is measuring PSH thickness in well MW-3 since it makes no sense to collect groundwater samples from a well containing free product. Also, the last information I have on Texaco's activities is an assessment report dated July 1997. If you would get a copy of any more recent reports and correspondence it would be a big help. Another thought to consider, prior sampling history indicated a declining trend of benzene concentrations at NNG's fenceline monitor wells. If this trend has continued, additional sample data would be beneficial to our future discussions with Texaco and the OCD. Larry Campbell 10/22/99 09:44 AM To: George Robinson/OTS/Enron@Enron, Bret Reich/ET&S/Enron@ENRON cc: Subject: Re: NNG Eunice Station Bret, what do you think about this? We have pretty much proven that we are not the culprits is this activity. I have a problem conducting an ongoing sampling for an issue that were not responsible for, even though we initiated the sampling activity. I plan on visiting the OCD about this issue and either forcing them to justify why we should continue the sampling when the data points to our neighbors. Additionally, because of the turnover and inability to get the guilty party to get moving on this, spending additional money and not receiving any return seems like a waste of time. Thoughts.... George Robinson 10/22/99 08:42 AM To: Larry Campbell/ET&S/Enron@Enron cc: Bret Reich/ET&S/Enron@ENRON Subject: NNG Eunice Station The last groundwater sampling event at the Eunice Station was completed in August 1997. Subsequently, the OCD approved our revised sampling plan that calls for biennial sampling. In light of this we were due to sample this past August. I held off on sampling in hope that Texaco would soon assume this responsibility, however, since it does not appear that this is going to occur anytime soon enough I will schedule a sampling event within the next four weeks. Since there are only six monitor wells to sample at this site, sampling can be completed in one day by one person at a cost of about $2500 (including expenses and lab costs).
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