Message-ID: <19136425.1075851881528.JavaMail.evans@thyme> Date: Mon, 28 Aug 2000 10:40:00 -0700 (PDT) From: larry.campbell@enron.com To: louis.soldano@enron.com, john.shafer@enron.com Subject: Due Diligence, Equilon Pipeline Company Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: Larry Campbell X-To: Louis Soldano, John Shafer X-cc: X-bcc: X-Folder: \Larry_Campbell_Nov2001_1\Notes Folders\All documents X-Origin: CAMPBELL-L X-FileName: lcampbe.nsf Louie/John, this memo summerizes the results of the environmental due diligence which was performed on the Texas Panhandle and Cortez, Colorado portions of Equilon pipline system for which EOTT may be interested in purchasing. This memo presents those environmental issues which may be or were identified as a potential environmental concern. Lefors (Texas Panhandle Segment) Assets on this portion of the system which may have environmental issues were the following: 1-80,000 bbl. liquids product storage tank, 41 small tank batteries consisting of 1-3 product storage tanks each. Average tank size is 210 bbl. Approximately 15 tank locations are within 1/4 mile of an existing waterway. There are stream and river crossings included in this package. The pipeline crossings viewed appeared to have sufficient soil coverage and did have block valves on the upstream and downstream portions of the pipeline crossings. 1. Clean Air Act. There were no records kept at any office or location which would assist in the determination of compliance with Title III, or Title V. The following documents were not present: emissions inventories and or records of fees paid, O&G MACT compliance (HAP's), operating permits. NSPS Supart Kb compliance could not be determined also. The 80,000 bbl tank construction date was in the 1930's and has a fixed roof. It has a concrete bottom and the tank has never been emptied for inspection. No Railroad Commission 653 inspection has ever been conducted. 2. Clean Water Act. Although soil berm and containments were present around all tanks that were inspected, SPCC plans were not available at any location. Interviews with the Equilon personnel stated that there had never been a reportable release from this tank. In addition, location Texaco MB Davis pump station had a small 3'x4' UST which received liquids from leaking packing material which had overflowed and visible soil staining was present. At this location a T-stand pipe had been constructed into the soil berm to allow discharge of rainwater from the containment area. This water discharged into an ephermal arroyo which ultimately collects into the North Fork of the Red River, a perennial stream. 3. NESHAPS. At the Lefors Station, there exists several joints of new and used pipe which is suspected of having external coating and pipe wrapping containing asbestos. 4. NORMS. A NORM survey has not been conducted on any portion of the assets which are identified in the bid package. 5. Soil Staining. There was minor soil staining at all locations inspected. 6. There is one active groundwater remediation in progress identified as the "10 mile hole". Equilon will retain ownership of this issue. There had been two pipeline remediation projects for which Equilon had reported to the TRRC and had remediated the site. 7. TSCA. One electrical transformer was discovered at the Lefors Station. It had been tested and determined to not have PCB's. 8. Safe Drinking Water Act. There was an abandoned drinking water well at the Lefors Station. It had not been in service for an undetermined period of time. 9. RCRA. There was an abandoned out of service Fox boro meter at the Lefors Station. Status of the potential releases of mercury could not be visibally determined. Bug-Patterson Gathering System (Cortez, Colorado) This system includes the following: Lady Bug Station minor incidental equipment at this location. 1. There were no environmental issues at this site from assets owned by Equilon. Adjacent to this site was a producer site which had been blowing hydrocarbon liquids into an earthern unlined pit. There was historic use of this pit. Although surface contamination from this pit was present, it was not known whether subsurface soil and groundwater conditions underlying the Equilon assets had been impacted. Patterson Station 1-10,000 bbl floating roof steel product storage tank with fiberglass bottom, installation date 1981, one propane driven waukesha F817GU engine horsepower unknown, 1. Clean Air Act. There were no records kept at any office or location which would assist in the determination of compliance with Title III, or Title V or the construction permit notification process administered by the Colorado Department of Public Health and Environment. The following documents were not present: emissions inventories and or records of fees paid, O&G MACT compliance (HAP's), operating or construction permits. NSPS subpart Kb compliance could not be determined. Determination of the permitting status for the six cylinder Waukesha could not be determined. 2. Clean Water Act. Although soil berm and containments were present, an SPCC plan was not available at this location. Interviews with the Equilon personnel stated that there had never been a reportable release from this tank. Rainwater which collected into the containment was discharged into an ephermal arroyo by a pipe constructed into and through the dirt containment. 3. NORMS. A NORM survey has not been conducted on any portion of the assets which are identified in the bid package. 4. Minor soil staining was present around the 10,000 bbl tank. 5. Adjacent to this site was a producer site which had been blowing hydrocarbon liquids into an earthern unlined pit. There was historic use of this pit. Although surface contamination from this pit was present, it was not known whether subsurface soil and groundwater conditions underlying the Equilon assets had been impacted. Patterson Junction 1-10,000 bbl floating roof steel product storage tank with fiberglass bottom installation date 1987. Electrical pumps were present to transfer liquids from the 10,000 bbl tank to the truck loading facilities. 1. Clean Air Act. There were no records kept at any office or location which would assist in the determination of compliance with Title III, or Title V or the construction permit notification process administered by the Colorado Department of Public Health and Environment. The following documents were not present: emissions inventories and or records of fees paid, O&G MACT compliance (HAP's), operating or construction permits. NSPS subpart Kb compliance could not be determined. Determination of the permitting status for the six cylinder Waukesha could not be determined. 2. Clean Water Act. Although soil berm and containments were present, an SPCC plan was not available at this location. Interviews with the Equilon personnel stated that there had never been a reportable release from this tank. Rainwater which collected into the containment was discharged into an ephermal arroyo by a pipe constructed into and through the dirt containment. 3. NORMS. A NORM survey has not been conducted on any portion of the assets which are identified in the bid package. 4. Minor soil staining was present around the 10,000 bbl tank and transfer pumps. 5. A small bucket had been placed into the ground, below ground surface to collect liquids from meter. Cortez Office. In the office yard, several environmental issues were present and are listed as follows: old spent 12 volt batteries empty drums open buckets containing oil and oilfield sludge The pipeline stream crossing at the Montezuma Creek showed the pipeline to be exposed in the bottom of the creek for a distance of approx. 12 feet. There were block valves on the upstream and downstream segments of this crossing. and the equipment in the Cortez office building.