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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.
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