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Enron Mail |
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.
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