Problem: BODY: 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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A: SUBJECT: Additional Soil Investigations, North Coles Levee

Problem: BODY: Attached is the latest draft of the Transport Option Program filing. There are a couple of important changes from the last draft. One is that we're no longer stating that the option fee is going to be "market-based." At FERC, the term "market-based" has connotations of having to prove to FERC that a non-cost-based rate is appropriate because we lack market power. While we probably do lack market power, the consensus of the legal/regulatory team was to try to portray the option fee as a built-in feature of the transport rate, which is simply being disaggregated into a separate option fee. If this theory is not clear to you after you read the filing letter, let's discuss how it should be improved. The other significant change (also based on my meeting with legal/regulatory) is that I've structured the tariff language and the agreement so that every shipper, regardless of whether they currently use transport on TW, will have to have a firm transportation agreement when they buy an option. In other words, a shipper that does not currently have a service agreement will simply execute an agreement with a MAXDTQ of zero. This structure has two advantages: 1) it's consistent with our option-fee-as-part-of-transport-rate theory, and 2) it will help support that theory in our next rate case. I'd like to meet next week, either Wednesday afternoon or Thursday, to discuss the following topics: 1) Your comments and questions on this draft, 2) Some examples of options, to make sure the tariff provisions and contract work from a logistical standpoint, 3) The bidding process, and how bids for options will be evaluated, and 4) Comments received from shippers thus far. I'll be working on 41 tomorrow; let's talk about what would be a good meeting time. I will be out Mon. and Tues.
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A: SUBJECT: Transport Options Program

Problem: BODY: Dear Susan, Ready to start your Halloween celebrating early? Scare up a good time with information about haunted houses, costume shops and the party scene. At citysearch.com, getting the details is no big trick. HALLOWEEN--Be afraid, be very afraid ... of not planning to make the most of the holiday.
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SUBJECT: CITYSEARCH WEEKEND PREVIEW: Halloween Tricks & Treats, Tool and Tannhauser.