Message-ID: <25851368.1075851899830.JavaMail.evans@thyme>
Date: Fri, 16 Feb 2001 01:56:00 -0800 (PST)
From: larry.campbell@enron.com
To: john.shafer@enron.com, louis.soldano@enron.com, cutty.cunningham@enron.com, 
	william.kendrick@enron.com
Subject: Meeting with the Laguna's over the PCB remediation at C/S 6
Cc: george.robinson@enron.com
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John, Lou, Cutty, Bill, I want to bring this issue back up for your 
attention, as I know that everyone is very busy.  During the EPA Title V 
inspection at the Laguna C/S this past week, Barbara Bernacek, the Laguna 
environmental person was present.  She had been asked to be there by the 
EPA.  During our tour of the facility, she casually asked if any progress or 
decision had been made by Enron management towards remediation assistance in 
the groundwater issue at the Laguna C/S.  I had informed her that we were 
still actively discussing this issue and would contact her in the near future 
concerning management's decision.  I would appreciate it very much if each of 
you would revisit my memo below and  then lets discuss what should be done 
and the approach we should take in addressing the Laguna's concern about a 
proactive approach to reaching cleanup and closure.  
---------------------- Forwarded by Larry Campbell/ET&S/Enron on 02/16/2001 
08:43 AM ---------------------------


Larry Campbell
01/24/2001 10:07 AM
To: John Shafer/OTS/Enron@Enron, Louis Soldano/ET&S/Enron@Enron, Cutty 
Cunningham/OTS/Enron@Enron, William Kendrick/OTS/Enron@Enron
cc: Rich Jolly/ET&S/Enron@Enron, Rick Smith/ET&S/Enron@Enron, Butch 
Russell/ET&S/Enron@Enron, George Robinson/OTS/Enron@ENRON, Team 
Laguna/ET&S/Enron@Enron, Ted Ryther/OTS/Enron@ENRON 

Subject: Meeting with the Laguna's over the PCB remediation at C/S 6

I wanted to present this summary of the meeting Transwestern had with 
representatives of the Laguna Pueblo concerning the status of the PCB 
remediation activities by TW.  On the Laguna side were members of the Laguna 
pueblo, the PEOP a  technical oversight group that provides expertise and 
assistance on technical issues for all of the 19 pueblos in New Mexico 
(ranging from UST to superfund), and members of ETS ( 5 members of the Laguna 
team, Butch Russell, Rick Smith  (advisor for the Laguna team), myself)  and 
George Robinson.   This is the third meeting we had in the last year and a 
half with this group since the Lagunas have started showing renewed interest 
in environmental activities on their pueblo.

The meeting centered around two issues at the site: the closure of the UST 
and the PCB remediation activity.  With respect to the first, concensus was 
reached that we would continue monitoring and collecting groundwater samples 
at the two downstream well locations from the UST site on a quarterly basis, 
and send the results to POEP for review. 

With repsect to the PCB remediation issue, things were a little different.  
The POEP representatives expressed concern on behalf of the Laguna tribal 
Coucil that the progress of the remediation activities Transwestern is 
presently using to bring closure to the site is not showing positive goals 
toward  achieving cleanup at the site and that the data submittals to the 
Lagunas have verified this.  They indicated that that have been patient with 
Transwstern's attempts to allow natural attenuation to reduce the PCB 
contamination, but based upon the historic sampling results, that this 
technology is not proving to be very successful, in fact the results have 
shown stagnant results  (Im using their words).  They would like to see 
Transwestern implement other more proactive technologies to arrive at cleanup 
and closure of this site.   Members of the Laguna pueblo, who work for the 
POEP,  expressed concern that the PCB contamination could negatively impact 
future generations of Lagunas members and that it was the responsibility of 
Transwestern to clean up the contamination which they brought onto their 
lands.   One member of the Laguna pueblo called the contamination a "cancer"  
with potential to spread.   A comment was made by the POEP that there was a 
major potential of increasing the magnitude and spread of the contamination 
if we continue to just maintain  our present approach of just monitoring the 
site and installing additional wells..

A member of the POEP has been in contact with a consortum of individuals from 
North Dakota State University, (Energy and Environmental Research Center) who 
claim to be experts in reclamation of contaminated sites which are considered 
difficult to remediate (this site would certainly fall into this category due 
to the presence of the sandstone bedrock which has numerous cracks and 
channels present which direct  the PCB containing liquids present at the 
site).  Although the POEP was not recommending Transwestern utilize their 
service, they did strongly suggest that we should at least discuss this site 
with them.

It shold also be mentioned that Syed Risvi, the POEP Superfund representative 
was at this meeting.  He had mentioned that the  POEP has been in discussions 
with EPA Region VI concerning potential classification of the site on the 
CERCLIS list of sites for inclusion on the NPL..  He had indicated that he 
did not want to see this site included on the list, but stated that 
Transwetern needed to update and show postive results in our remediation 
efforts and that it was the tribal councils opinion that this was not being 
done.

At the conclusion of the meeting, I informed the POEP that Transwestern's 
internal remediation group  would contact the NDSU group and discuss the site 
characteristics with them and we would reprot back to them the results of our 
discussions.  This seemed to satisify the  POEP and they were content with 
this. 

John, I would like to schedule a conference call with the above list of 
people and discuss this issue.  A couple of things I want to bring out.  
First, we will be undergoing ROW and Compressor Station renewals with the 
Lagunas in the near future.  Second, on the Laguna tribal lands, they have 
experienced other releases of contimation and are currently very sensitive to 
this whole  contamination problem.  Although we are considered by the POEP as 
proactive up to this point  and very easy to work with (direct quote from the 
POEP)   they are wanting a more proactive and measurable effort from 
Transwestern to clean up the PCBs. 
Please get back with me on this.