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Enron Mail |
ENVIRONMENTAL STRATEGIES
Legislation Pipeline Safety - The Senate Pipeline Safety Bill (McCain bill, S. 2438) wa= s=20 defeated in the House of Representatives on Tuesday 10/10. The bill was= =20 brought up under "suspension of the rules" in order to avoid possible=20 amendments, a procedure which required a two-thirds vote for passage. The= =20 bill fell short by 28 votes, with 232 voting for, and 158 against. Althou= gh=20 the McCain legislation imposed a number of new requirements on pipelines, t= he=20 pipeline industry supported S. 2438 as the best achievable legislation, giv= en=20 recent accidents and the possible political climate next year. The=20 legislation was defeated in a last minute effort by House Democrats, on mor= e=20 political than substantive grounds. With only a few days remaining in the= =20 congressional session, the debate will now turn to efforts to possibly atta= ch=20 some form of legislation to a fast-moving appropriations bill. Industry c= an=20 not likely support movement of any legislation other than the Senate bill -= -=20 anything suggested by House Democrats at this point to make the legislation= =20 stronger would likely be "deal breakers" for industry. Jeff Keeler will=20 remain active in the legislative process until the issue is resolved. MTBE - Senate MTBE legislation (S. 2962) which passed the Environment=20 Committee several weeks ago is not expected to move on a stand-alone basis,= =20 but we are watching to see if efforts to move all or portions of the bill= =20 (such as a simple MTBE ban) will take place in the various appropriations= =20 efforts. While we have commitments from various House and Senate leaders= =20 that an anti-MTBE measure will not be included, the powerful ethanol forces= =20 are working hard to find a way to pass legislation this year. We have=20 avoided inclusion in Agriculture and VA-HUD (EPA) appropriations bills so f= ar=20 -- which were the most likely targets for inclusion. We are prepared to= =20 counter any last minute anti-MTBE amendments with amendments providing=20 transition funding for MTBE producers, which a number of Senators, includin= g=20 ethanol proponents like Tom Daschle, have indicated they would not oppose. = =20 It is most likely that action on this legislation will take place in the ne= xt=20 Congress. Competitive Intelligence Climate Change - Jeff Keeler continues to participate in activities leading= =20 up to the COP 6 meeting in November in the Hague, The Netherlands. Jeff i= s=20 coordinating with EES, ENA, EWC and others within Enron in order to provide= =20 the best coverage for these business units during the events before and=20 during the COP 6 meeting. At the Hague meeting, Enron will participate in= =20 activities of the Business Council for Sustainable Energy, Pew Center on=20 Climate Change, INGAA, and Emissions Marketers Association. In particular= ,=20 Jeff is working with several organizations on efforts to develop a response= =20 to recent U.S. proposals on Clean Development Mechanism "baselines" that=20 could potentially disadvantage gas, renewables, and energy efficiency. On= =20 October 20, Jeff will be speaking at the Forbes Environmental Superconferen= ce=20 in Washington, D.C. on a panel addressing "Business Opportunities Resulting= =20 from Climate Control". The panel includes Jeff Seabright from Texaco and D= an=20 Reicher from DOE. Landfill Gas projects - Stacey Bolton has been working with ENA East=20 Origination on regulations, incentive funding, and tax issues affecting=20 potential landfill gas projects.=20 Green Power Marketing - Stacey Bolton attended the Mid-atlantic power=20 marketers meeting in order to receive information on the latest development= s=20 that could affect EES, ENA, NPC power marketing efforts. Clean Air Act (Multi-pollutant legislation) - Jeff attended a meeting with= =20 Ken Lay at Resources for the Future to discuss future legislative options f= or=20 pollution control in the electric utility sector, including a=20 "multi-pollutant" strategy (for NOx, SO2, Mercury, CO2). This will likely= =20 be the predominant Clean Air Act issue addressed in the next Congress. Coa= l=20 utilities and environmental groups have been meeting to develop some initia= l=20 recommendations for the legislation, and Jeff and consultant Joel Bluestien= =20 have organized a meeting with environmental groups on 10/25 to ensure that= =20 gas, renewables, energy efficiency are included as solutions in any trading= =20 or compliance programs. Clean Air Act (California offsets) - Mary Schoen is working with ENA West= =20 Origination and EGM Emissions Trading on strategies for finding emissions= =20 offsets for Enron power projects planned in several air quality districts i= n=20 California. Offsets are scarce, due to hoarding by PGE and So. Cal Edison= =20 from their utility days. Mary is working on solutions including offsets= =20 generated by energy efficiency and diesel engine retrofits on mobile source= s. Clean Air Act (NOx State Implementation Plans) - Mary continues to negotia= te=20 with TVA and the TN air pollution control board over the allocation of=20 allowances for Enron facilities in Tennessee. TVA has agreed that Enron= =20 should be granted 500 tons of NOx (our permitted levels), but there are sti= ll=20 details being worked out in the amendment to Tennessee's SIP which Mary is= =20 attending to so that our deal remains in tact. Power Quality - Jeff and Mary will be working with EES' new "power quality"= =20 group to provide regulatory intelligence on environmental issues that affec= t=20 the power quality, reliability and distributed generation markets, includin= g=20 opportunities for federal and state financial incentives. Jeff is setting= =20 up meetings with DOE and EPA on October 19 for EES in Washington, D.C. Regulatory Compliance: Environmental Disclosure/Labeling - Stacey Bolton is working w/ EES on two= =20 disclosure issues involving their quarterly label in California and=20 Massachusetts. Renewable/Disclosure Credit Trading - Stacey Bolton worked out a potentiall= y=20 problematic issue with environmental groups in New England that could have= =20 prevented the credit trading information system from moving forward in NEPo= ol. ASSET OPERATIONS Administrative EH&S Manager, South America - Edgar Zuleta will now be responsible for EH&S= =20 activities in S. America. Edgar completed the Smith System Trainer course= =20 and received Certification. OEC/ North America Military Base Projects (Texas, Air Force and Navy) - Scott Watson contacted= =20 Allen Rose (Black & Veatch) to ensure environmental issue costs such as=20 asbestos abatement, lead paint blasting and transformers (PCB=01,s) were al= l=20 addressed in the bid package. Enron Corporation=01,s Safety Management System - Scott Watson met with Gar= y=20 Allen ETS Safety to discuss the integration of ETS computer based safety=20 audit system into the overall corporate project. Scott is supervising the= =20 completion of this project. Enron=01,s petition to EPA to waive NSPS stack testing at Wheatland power -= Gus=20 Eghneim received official approval from the EPA of our petition to waive NS= PS=20 stack testing at Wheatland power. This petition saved Enron approximately= =20 $500,000 as per EES OEC's Mark Dobler=01,s assessment. Enron=01,s petition to MDEQ - Gus Eghneim submitted a petition to the=20 Mississippi Air pollution Control department to waive stack testing=20 requirements currently mandated in the new source review permits of Caledon= ia=20 and New Albany Power. Permit Revisions for Doyle Power - Gus Eghneim is currently working with th= e=20 Georgia department of environmental Quality to revise the new source review= =20 permit for Doyle power to relax the opacity requirement and make the permit= =20 consistent with current plant operations. Georgia DEQ agreed to increase th= e=20 opacity limit from 20% to 40% on gas turbines. State Inspection at New Albany Power - New Albany power was subject to a=20 state inspection on October 2, 2000. No noncompliance issues were identifi= ed. EPA=01,s acid rain reports for the 2000 peakers - Gus Eghneim and Ramiro Ga= rcia=20 are working with Lincoln, Gleason, and Doyle, to ensure submittal of the=20 first acid rain EDR reports to the EPA by October 30, 2000. Asia/India Marianas Power Plant, Guam - Bal Wong submitted the US EPA PSD Permit,Fuel= =20 Switching Protocol 3rd Quarter 2000 reporting. Marianas,Batangas Power Corporation and Subic Power Corporation 1999=20 Greenhouse Gas=20 Emission Data Report - Bal Wong responded to clarification required by Arth= ur=20 D Little. SK Enron - Translation of Enron EH&S Guidelines into Korean language has be= en=20 initiated by Bal Wong.=20 Europe Site visit to Marmara, Turkey - Reviewed operations and Quality Assurance= =20 Audit Report. Working with plant management to determine what assistance i= s=20 required and provide support to operations in implementation of EH&S=20 Guidelines.=20 Acquisition of MG plc Metal trading company - Alan Stringer conducted EH&S= =20 reviews of European owned facilities and identified required improvements = in=20 HSE culture. US and Indonesia facilities will be audited for safety and=20 environmental issues in mid-Oct/2000. Limited baseline assessments may be= =20 required in the UK and Rotterdam. Acquisition of Metal Recycling Facility in Essen and Nuremberg, Germany -= =20 Essen to be leased and recommended baseline investigation at Essen and at= =20 Nuremberg to London Engineering Team who are managing this project. =20 Supporting the UK engineering team in the development of SPC plans to prote= ct=20 indemnities and warranties. New Power Project in the UK - Alan Stringer is working with the Engineerin= g=20 Team to determine level of support and review required, including building= =20 relationships with project stakeholders. Regulatory Database - Alan Stringer is developing current legislation=20 database for Turkey and Poland power plants. This database will summarize= =20 regulations these plants should be complying with. CALME San Juan Gas (SJG) Remediation - The Puerto Rico EQB sent SJG a letter=20 addressing issues related to our proposed waste characterization plan. Bill= =20 Curra and ThermoRetec developed various technical approaches to address=20 concerns from the PR EQB. A meeting with PR EQB will be set up in the= =20 next couple of weeks to discuss the issues. Panama, San Francisco Site - Bill Curra will travel to Panama next week t= o=20 coordinate the remediation work of the site under a Type I EIA established = in=20 the Panamian regulations. The project is expected to take two to three wee= ks. Fire Protection at BLM Plant in Colon - There is no reliable fire protectio= n=20 system for Units 2,3,4. BLM personnel will provide design guidelines to=20 Houston EH&S Department and to fire protection consultants for review. =20 BLM Plant in Colon - Secondary containment around fuel storage tanks is=20 inadequate to prevent a spill from the storage tank and existing controls t= o=20 prevent hydrocarbons from entering the stormwater channels is not functioni= ng=20 allowing hydrocarbons to travel to the ocean. Enron EHS will review=20 preliminary design and provide recommendations to BLM.=20 Regulatory Technical Analysis Natural Gas Star Workshop - Marc Phillips is attending the Natural Gas Star= =20 Workshop on October 12 and 13. OSHA Stakeholder Meeting - Russell Tucker attended and addressed the record= =20 during the OSHA Stakeholder meeting on Confined Spaces in Construction, a= =20 proposed rule in the design stage coming under the 29 CFR, Part 1926=20 Construction Standards. Current format for the new regulation is to mirror= =20 the existing General Industry standard on Permit Required Confined Space=20 contained in 29 CFR 1910.146. Statements centred on the areas of concern in= =20 amended 1910.146 that resulted in API filing a still unsettled suit in the= =20 D.C. Circuit Court, which reflect the same concerns for all Enron companies= =20 performing permit required confined space tasks. TXOGA Pipeline Environmental Committee - Jim Peterson is preparing=20 information on water and waste rulemakings for use at the TXOGA Pipeline=20 Environmental Committee Meeting next week. ENVIRONMENTAL COMPLIANCE Greenfield Capital Projects Cuiaba II - Joe Kolb reports that there is some confusion over the amount = of=20 gas needed at Cuiaba. As a result, an additional compressor station may be= =20 required. Another option is to install a booster station at the power plan= t=20 until the volume in the pipeline increases enough to justify a permanent=20 station. Cuiaba I Pipeline - Joe Kolb's trip was postponed by one week to October 28= -=20 November 8 as the request of GOB management. Lagos EPP - Joe Kolb has nothing new to report. RioGen - Joe Kolb reports that indeed the proposed pipeline route that will= =20 serve RioGen will need some rerouting because a portion of it is under a=20 now-paved road and through a congested area. The RioGen EIA includes the C= EG=20 pipeline route and it mentions going through a Class III area. He does no= t=20 know yet why this problem was not discovered earlier in the project and wil= l=20 confer with Cristiane Ronza (Enron SA) on revisions to the EIA. Eletrobolt PP (Brazil) - Joe Kolb has nothing new to report. Metgas Pipeline - Joe Kolb reports that the new schedule has a target of a= =20 NTP in Sept. '01 and begin construction in Dec. '01. The main problem is= =20 acquiring all of the right-of-way. The Ministry of Forestry (MOF) has made= =20 it clear that we will not get permission to cross any forestry lands unless= =20 GAIL (Gas India Limited) is made a partner. The EIA review panel is expect= ed=20 to constituted in October along with a panel to run the public hearing. =20 Expect hearing to be in late November or early December. Venezuelan LNG - Joe Kolb has nothing new to report. Transredes Looping - Joe Kolb made contact with Tony Henshaw (new VP of EH= &S=20 for Transredes) who will arrange for updates on the Looping project while J= oe=20 is in Bolivia in early November. Project Dolphin - Joe Kolb had nothing new to report. Powertel - Joe Kolb has made contact with Annat Jain (Enron India) seeking = to=20 understand what environmental planning, studies, and clearances were done f= or=20 this project and what role Enron plays in the Joint Venture. Joe's efforts= =20 to arrange a meeting with Mr. Jain during his time in Houston this week we= re=20 to no avail. Joe will continue to seek the desired information between now= =20 and Mr. Jain's next visit to Houston, which is in two weeks. Acquisitions Privatenel (Nicaragua) - Don Stevens has been informed that Enron submitted= a=20 $0 bid for the two Gencos on Oct. 10. The other two bidders (Coastal and= =20 Amfels) did the same thing. ENEL declared void the privatization of=20 thermoelectric generators Geosa (115MW) and Gecsa (121MW). Now the burden = of=20 improving the deal is firmly in the hands of the government and we fully=20 expect our suggestions to be given full consideration and in large part to = be=20 implemented. As there is intense pressure on Nicaragua from the World Bank= ,=20 to sell these Gencos, we believe these modifications are already being=20 carried-out and that there will be a new bid date set shortly. Project ISAGEN (Colombia) - Sandy Verma has informed Don Stevens that the= =20 project is currently on hold. Project Crane (Quebec, Canada and Port Angeles, Washington) - Don Stevens h= as=20 been informed that we are still moving ahead to submit a non-binding bid on= =20 Oct. 16 for only the Quebec City facility. We may be required to bid on bot= h=20 assets but have no interest in retaining the Port Angeles mill. The goal is= =20 to make our bid attractive enough to move to the next round and gain access= =20 to more detailed data and information in phase II due diligence. Project INGA (California and Pennsylvania) - Don Stevens spoke with Bill=20 Keeney regarding EPA Section 112 issues. EPA has begun preliminary data=20 acquisition regarding mercury emissions from coal fired utilities in order = to=20 draft proposed regulation. Bill Keeney is attempting to understand the ris= ks=20 involved should the proposed regulations become final in the near term. At= =20 the request of Chip Schneider (RAC), Susan Worthen provided an environmenta= l=20 risk summary for the DASH . Project Dragon (Southeast Asia) - Don Stevens has been informed that we hav= e=20 terminated any further efforts on this transaction. Termoflores (Colombia) - Don Stevens has not heard any news this week on th= e=20 project status. Closing date was last targeting for November. Military Base Privatization (Texas AFB) - Don Stevens assisted Charlie=20 Thompson (EES) in a meeting with Michael Tribolet (Underwriting) regarding= =20 the issue of need for environmental insurance. Don, Susan Worthen, and Fra= nk=20 Smith have all conferred that potential environmental liabilities can be=20 identified through existing baselines and further clarified by limited=20 sampling near those utilities that EES will take over. Military Base Privatization (Maxwell AFB/Gunter Annex) - Don Stevens has no= t=20 heard any news this week on the project status. CWT Thermo-Depolymerization - Don Stevens has attempted to contact Bruce=20 Stram to discuss environmental issues. Bruce is out of the office until Oc= t.=20 16. Don Stevens discussed various issues with Gene O'Gorman regarding air= =20 emissions from the proposed project. Don and Susan Worthen will meet with= =20 Bruce upon his return next week. Project Delta - ENA is investigating the possibility of buying underground= =20 storage facilities under various stages of development in the U.S. with th= e=20 potential of turning over the asset before they become operational. As a= =20 follow-up to a meeting last week with John Allario (ENA), Don Stevens is=20 reviewing Dames & Moore's Preliminary Environmental Reviews of four potenti= al=20 underground natural gas storage well locations. The proposed locations are= =20 in the states of Washington, Utah and New Mexico. Combined Cycle Plant (Brooklyn, NY) - Don Stevens has been contacted by Way= ne=20 Mays regarding permit timing for the installation of 2 each 500,000 lb/hr= =20 natural gas fired boilers at an existing combined cycle plant in Brooklyn,= =20 NY. The project is to install two auxiliary boilers so that during peak=20 hours all capacity can be shifted to electrical generation. The current=20 target date for installation of the boilers is June 2001. Enron would be a= =20 partner in the plant. HVAC Company - At the behest of Dave Nutt, Kyle Roblee (EES) contacted Susa= n=20 Worthen about potential due diligence support on a HVAC company EES is=20 reviewing. Originally, Pilko Associates was slated to perform the assessme= nt=20 at an extremely high cost. Kyle has not returned any e-mails or voicemails= ;=20 therefore, little else is known. Dept. Projects Quantitative Risk Module - Don Stevens received ThermoRetec's 'red-lined'= =20 Agreement for Project Services and delivered copies to Lanie Borgman. =20 Failure to secure a contract for the project within the next week will affe= ct=20 the current completion schedule. Environmental Professional Services Agreements - Susan Worthen sent Global= =20 Strategic Sourcing's Contracts group the environmental professional servic= e=20 agreements obtained from ETS and EE&CC. She was not successful in obtainin= g=20 such agreements from ENA or EES. This initiative is the result of Susan's= =20 experience that rate structures are not consistent among the business units= =20 and the desire to streamline the system. New Hire Orientation - The EHS/Social Responsibility booth will be ready fo= r=20 Monday, October 16. Orientation is every Monday. Various documents have= =20 been assembled for participants to take. e-TV - Susan Worthen is coordinating the production of corporate=20 responsibility videos to be featured on e-TV. Kelly Kimberly and Mike=20 Terraso will invite executives to participate. Annual Report - The Annual Report has been distributed internally to select= ed=20 recipients and senior management. Intranet Site - The deadline for the content on the EHS web site was on=20 October 11th. There was good participation in information provided for the= =20 site, however, we are still lacking information/content in some areas. Onc= e=20 the IT group receives all documents, development will begin on the site. Th= e=20 web site is still expected to be functional by November 15th regardless of= =20 the status of missing content. Two third party vendors, CPI and ELR, have= =20 submitted their proposals/contracts and they are currently being scrutinize= d=20 by the legal department. CPI and ELR will provide EHS legislative and=20 regulatory information for the United States on the EHS web site.=20 Globalization - Gavin Dillingham completed research regarding whether Enron= =20 should develop a policy or statement concerning free trade and=20 globalization. His research indicates that we should . Lauren Goldblatt,= =20 Kelly Kimberly, Mike Terraso, and Susan Worthen will meet the week of the= =20 23rd to determine next steps. =20 Volunteer Activities/Community Relation Buffalo Bayou Challenge - Gavin Dillingham is currently working with Joe Ko= lb=20 on developing the Buffalo Bayou Challenge. The proposal will be discussed= =20 with Mike Terraso and then a follow-up with Community Relations. Other Clean Energy Incubator - Gavin Dillingham is researching the possibility of= =20 Enron developing a clean energy technology incubator and will report his=20 findings to Mike and Susan. Susan Worthen Director Environmental Compliance, Enron Corp 713/646-6579 713/345-6164 fax 3AC 1525
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