Enron Mail

From:laura.glenn@enron.com
To:steven.kean@enron.com
Subject:EHS Weekly Report - week ending 3/16/01
Cc:maureen.mcvicker@enron.com
Bcc:maureen.mcvicker@enron.com
Date:Mon, 19 Mar 2001 03:07:00 -0800 (PST)

ADMINISTRATIVE

Evaluation of Support Requirements - Donnie Willmann, Bill Curra and Edgar=
=20
Zuleta completed an evaluation of support requirements for the Caribbean an=
d=20
Latin America that includes both continuous support activities and special=
=20
projects for 2001. This will be presented to Mike Terraso.=20

EHS Corporate Operations Monthly Report - The February 2001 Monthly Report=
=20
was completed and submitted to Mike Terraso.=20

EUROPE

Nederlands, Enron Wind - Alan Stringer reviewed monitoring data from soil a=
nd=20
groundwater investigation. Identified that no further actions was required=
=20
in terms of soil and groundwater contamination. He is also finalizing the=
=20
EHS up-grade requirements to meet local laws and regulations, using local E=
HS=20
management from Enron Wind in Nederlands and Germany to gather costs. Will=
=20
produce final report by March 19th. Report will provide details on needs,=
=20
who will be responsible for the tasks and costs.

All Assets - Alan Stringer and Bal Wong reviewed and submitted February 200=
1=20
EHS Performance Report to Houston. =20

ENRON GLOBAL ASSETS
(Central America, South America, India and Asia)

Panama, Bahia Las Minas (BLM) Stack Testing - currently scheduled for mid=
=20
April, 2001.

Puerto Rico, San Juan Gas Remediation Project - Donnie Willmann and Bill=20
Curra participated in a weekly conference call with project team members to=
=20
discuss project status. The agency approval of the Feasibility Study (FS)=
=20
is causing delays in obtaining the permits. The agency was provided with t=
he=20
FS in October, 2000. San Juan Gas personnel are following up daily with th=
e=20
agency about formal written approval. Approval would allow remediation to=
=20
begin. Efforts continue to procure access agreements on adjoining propert=
y.=20

Bolivia, Transredes and GasOriente Boliviano - - Edgar Zuleta completed the=
=20
Crisis Management Plan. A draft version was submitted for review to=20
Transredes and GasOriente Boliviano management.=20

EHS Performance Data - Edgar Zuleta revised the February 2001 EHS performan=
ce=20
data for Cuiaba and Transredes and submitted it to Gavin Dillingham to upda=
te=20
database. Also, Edgar requested missing EHS performance data for remaining=
=20
South America assets.

India, Dabhol Power Company - Alan Stringer is scheduled to participate=
=20
March 19 - 30 in an environmental audit at Dabhol Power Plant. =20

Guam, Marianas Energy Company - Bal Wong conducted a 1 hour training on Loc=
k=20
Out/Tag Out (LOTO) Program. Annual LOTO review lessons learned were=20
reviewed. Bal reviewed and commented on the Continuous Emission Monitoring=
=20
Relative Accuracy Test Audit (RATA) test procedure. The test will be=20
conducted on March 20 - 21, 2001. The procedure was submitted to Guam EPA=
. =20
He also began the review of the Marianas Power Plant Crisis Management Plan=
.

ENRON ENERGY SERVICES

EES - Distributed Power Generation =01) Gus Eghneim is continuing to provid=
e=20
permitting support to the distributed power generation team. Several=20
generation facilities are planned for year 2001.

Alabama, Mobile Energy Services Company =01) Scott Watson has been coordina=
ting=20
the implementation of the EHS Transition Plan he prepared. Also he will=
=20
conduct an EHS Audit at this facility the week of March 25th, 2001. Ramir=
o=20
Garcia and Gus Eghneim are developing an environmental compliance Manual fo=
r=20
Mobile Energy Services. This manual is based on the review of facility=20
environmental documents and permits.=20
=20
Massachusetts, New Albany Power - Gus Eghneim is working to resolve the=20
environmental issues identified in the plant's 2000 audit report. All, bu=
t=20
two issues will be resolved by March 26th, 2001. The work involves finalizi=
ng=20
the plant's environmental compliance manual.

Enron EHS Statistics Report =01) Scott Watson updated the database reports =
for=20
Garden State and Daishowa Paper Mills. Both facilities are under Enron=20
Industrial Makerts.

Eli Lilly Project =01) Scott Watson, Henry Van and Bill Curra are preparin=
g the=20
EHS Policies and Procedures Manuals and Training Program. The Eli Lilly=20
account includes utility delivery service for 5 facilities. =20

GLOBAL INDUSTRIAL MARKETS

Quebec, Canada, Daishowa Pulp & Paper Co. =01) Scott Watson and Gus Eghneim=
=20
prepared the EHS Audit Report (audit conducted Feb. 27 March 2). The repor=
t=20
was submitted to the Transition Team. Both participated in a Transition=
=20
Team meeting to discussed audit findings. =20

ENRON AMERICAS

Michigan, White Pine Energy, Ada Cogeneration Plant =01) The U.S. EPA inclu=
ded=20
Ada Cogen Plant in its Section 126 rulemaking, adopted in January 2000. Th=
is=20
rulemaking established emission limits for electric generation plants in 12=
=20
states in the North East. The EPA also included Ada Cogen Plant on the list=
=20
of plants required to reduce emissions under the EPA SIP call. The Illinoi=
s=20
EPA is currently developing regulations to comply with the EPA SIP Call=20
requirements. Under the Section 126 rulemaking and the proposed Illinois=
=01,s=20
SIP call regulations, Ada Cogen Plant will be required to install Selectiv=
e=20
Catalytic Reduction (SCR) by 2003 to meet stringent NOx emission limits. A=
t=20
an estimated capital cost of $5 million and an O&M cost of $500,000 per yea=
r,=20
the plant may be forced to shut down.

Gus Eghneim filed a petition with the U.S. EPA to exclude Ada Cogen Plant =
=20
from the Section 126 rulemaking. The size of the plant and its operating=
=20
history were used as justification for the exemption. If and when this=20
petition is approved, Gus Eghneim will file a similar petition with the=20
Illinois EPA to exclude Ada Cogen from the SIP Call Rulemaking. A meeting=
=20
with the U.S. EPA will be scheduled in the next two weeks to discuss the=20
petition.

CAPITAL PROJECTS

Bahamas LNG (Project Calypso) - Don Stevens visited the proposed project si=
te=20
in the Bahamas this week for purposes of conducting a limited Phase I=20
assessment of the property and projecting potential clean-up costs for=20
contamination. Project developers will use the information to negotiate wi=
th=20
the seller, with the intent that the seller remediate the property before=
=20
Enron purchases it.

DEPARTMENT PROJECTS=20

Telework/NEPI Program =01) Gavin Dillingham is meeting with HR Work Perks=
=01, Sally=20
Alvarez and Sarah Davis and NEPI=01,s Elham Shirazi concerning teleworking =
at=20
Enron. The meeting is to help familiarize Enron Work Perks with the current=
=20
telework pilot program that NEPI and HGAC is launching in the Houston area=
=20
and to see if Enron would like to participate in such a program. The=20
consulting to develop a telework program is provided as a free service=20
through federal government funding and HGAC and NEPI have been given the=20
federal funding.=20
=20
Asset/Project Tracking Database -. Gavin Dillingham is currently enhancing=
=20
the Asset Tracking Database to include more information. The information=20
fields that are being added will track power plant capacity, liability=20
concerns, costs, operator, % ENE owned, actions and costs.=20

Sustainability Indicators and Benchmarking- Gavin Dillingham is currently=
=20
working with Lauren Iannarone in determining what=20
Sustainable/Environmental/Social indices Enron should work to be listed on.=
=20
They have just completed the initial stage of the project by determining th=
e=20
benchmarks and indicators that Enron should follow to be considered a=20
responsible corporate citizen.=20

Conservation International Biodiversity Forum - Susan Worthen and Catherine=
=20
McKalip-Thompson are drafting an outline for "Making the Business Case" for=
=20
discussion with their workgroups. It is intended to offer tools for variou=
s=20
stakeholders to use to assess the qualitative and quantitative value and ri=
sk=20
associated with incorporating biodiversity into oil and gas development.

Corporate Responsibility on the Internet Site - Susan Worthen is working wi=
th=20
Lauren Iannarone on the development/organization of a section on the Enron=
=20
web site for corporate responsibility. Lauren is coordinating a meeting wi=
th=20
HR, Community Relations, Brandon Rigney, and me for the week of 03/26 to=20
outline content, etc. Investor Relations has also expressed an interest in=
=20
linking to the corporate responsibility section or having it reside under=
=20
their section.

VOLUNTEER ACTIVITIES/COMMUNITY RELATIONS
=20
Enron Earth Day Festival =01) Gavin Dillingham had a meeting with Trash Bas=
h=20
yesterday and today to discuss the bayou cleanup challenge coming up on Mar=
ch=20
31st. Currently, there is a committee that is looking for volunteers and is=
=20
coordinating the logistics of the clean up. Our corporate challenge partne=
rs=20
have committed between 130 - 150 volunteers.

REGULATORY TECHNICAL ANALYSIS

Greenhouse Gas Technology Conference - Marc Phillips presented information =
at=20
a Greenhouse Gas Technology Conference on the methane reductions documented=
=20
by ETS under the EPA Natural Gas STAR Program and their potential use as=20
emission reduction credits.

Texas Grandfather Legislation - Marc Phillips has prepared cost estimates o=
n=20
the impact of the Texas grandfather legislation on the pipeline industry an=
d=20
ETS facilities and is participating in conference calls with industry group=
s=20
to present an industry position on the legislation.

ANSI's Proposed Z365 Standard for Ergonomics - Russell Tucker worked on the=
=20
API task force to assemble comments for the second public comment period fo=
r=20
the Z365 proposed ANSI standard. Addressing concerns in this proposed=20
standard has become more important in view of the demise of OSHA's ergonomi=
cs=20
final rule.=20

Participation in Bureau of Labor Statistics (BLS) Survey - Russell Tucker h=
as=20
established the process and information links necessary to record the weekl=
y=20
data requested by the U.S. Department of Labor, BLS, for a survey of=20
occupational injuries and illnesses during 2001 for the ECT Strategic Value=
=20
Corp. A final report is due this Agency in January 2002.

ADVOCACY COORDINATION & COMMERCIAL SUPPORT

Air Quality/Multipollutant Strategy -- Carbon Dioxide Regulation - Jeff=20
Keeler coordinated Enron's involvement in activities surrounding President=
=20
Bush's statement (in a letter to several Senators) that mandatory caps on C=
O2=20
emissions should not be included in any multipollutant approaches for the=
=20
power sector. Jeff maintained communications with EPA, White House, and=20
congressional contacts on the subject, and advised our "Clean Power Group"=
=20
coalition and congressional staff on possible responses and future=20
strategies. Jeff is working closely with Senate Environment Committee staf=
f=20
to craft legislation that will still move forward on NOx, SO2 and mercury=
=20
while continuing to look at meaningful approaches to carbon reduction.

EPA Appointments - Jeff Keeler worked on gathering information and vetting=
=20
candidates withing Enron on two EPA appointments critical to Enron business=
es=20
-- EPA Asst. Administrator for Air and Radiation and EPA Region 9=20
Administrator. Final recommendations are being prepared for Enron to=20
communicate to the White House.

California Energy Crisis & Environmental Regulation - ESG continued its=20
leadership in providing intelligence and analysis to commercial and=20
government affairs groups on environmental policy activities affecting the=
=20
California crisis. =20
Mary Schoen produced analysis of new California bills and executive actions=
=20
affecting permitting and environmental regulation of power generation=20
sources, and provided feedback to Enron commercial groups, government affai=
rs=20
and regulators. Mary also worked on further analysis of actions being take=
n=20
by state CARB officials and local authorities in the SCAQMD to potentially=
=20
revise air quality programs.
Stacey Bolton worked w/Janel Guererro and the California Crisis Team on=20
opportunities to enhance Enron's California messages with Enron's green=20
messaging and environmental business opportunities.

Trading Market Development - Stacey Bolton continued her leadership in=20
developing market-based systems for trading renewable energy credits:
PJM: Drafted a "strawman" detailing a credit trading program to submit to=
=20
PJM, asking them to form a working group. Organizing a stakeholder meeting=
=20
for March 20th in Philadelphia to form a coalition to lobby for a credit=20
trading program. Stakeholders include Community Energy, PG&E National Ener=
gy=20
Group, Green Mountain, Center for Resource Solutions, Penn Futures, Nationa=
l=20
Exchange Carriers and NCE-Pearson.
NePool: Submitted comments on an RFP that NePool is issuing for the=20
Generation Information System on March 21
Renewable Energy Desk: Coordinating with Elliot Mainzer of ENA West on=20
forming a team to respond "holistically" to the regulatory and public=20
relations/messaging needs of the new commercial venture. =20

Clean Power Product Development - Stacey Bolton worked on several initiativ=
es=20
toward developing Enron commercial opportunities
PA C&I Negawatts Program: Presented proposal for a C&I Negawatt program in=
=20
Pennsylvania to the Green-e Negawatt Subc. Received clearance on conceptua=
l=20
idea to present the proposal to the full Mid-Atlantic Advisory Committee on=
=20
Monday, March 19th. If approved, we will work through the fine details of=
=20
the program w/ Green-e, submit it for final approval to their Green Power=
=20
Board, and launch the program this June.
Energy Efficiency Allowances: Met with EES (Heather Mitchell and Elizabeth=
=20
Howley) regarding developing a proposal for energy efficiency savings to be=
=20
eligible as NOx allowances to the TNRCC. Spoke with Bill Jordan at the TNR=
CC=20
regarding this issue, timeframe, and method for presenting a proposal to=20
them. Also set a goal to attempt to get Negawatt Credits to trade on TX RE=
C=20
and voluntary certificates of generation system.

Environmental Reporting/Compliance - Stacey Bolton worked with EES to advis=
e=20
them on various reporting requirements:
CEC Annual Report: EES submitted their annual report to the California=20
Energy Commission and Green-e on March 1st. The CEC had several questions=
=20
regarding tying EES purchases to specific generators. Worked w/ EPMI and E=
ES=20
to help tie our purchase numbers (between EPMI, the APX and EES) in our=20
annual report in response to CEC's questions.=20
Patagonia & Fetzer: Worked w/ Mike Smith and Peggy Mahoney to get them up =
to=20
speed on our disclosure requirements in CA (given that EES is no longer=20
delivering commodity to large customers) and that the CEC was okay w/ our=
=20
green tag product to Fetzer and Patagonia.

COMPETITIVE INTELLIGENCE

Commercial Opportunities
Abbott Laboratories: Jeff Keeler forwarded to EES information about an=20
opportunity to provide energy/environmental outsource services to Abbott=20
Labs, based on contact with their head of energy/EHS operations at the GEMI=
=20
new members meeting.
Landauer Deal: Stacey Bolton presented EES w/ a business opportunity to jo=
in=20
w/ a large real-estate development company to install solar panels and=20
distributed generation on large strip malls, starting in NY. Organized a=
=20
call for next Wednesday to discuss potential partnership.
Greening the Enron Building: Stacey Bolton is assisting Enron Wind and the=
=20
East Desk forward an idea to be the first Fortune 500 company to "go 100%=
=20
green" in our headquarter building. Facilities is interested in commodity =
as=20
well (wants to switch from Reliant). Organizing meeting of internal=20
stakeholders (ENA, EES, Enron Wind) for next week to discuss full commodity=
=20
and outsourcing options coupled w/ green tags from our Enron Wind facility =
in=20
West Texas.
Wind supply in PA: Stacey Bolton was contacted by Community Energy in PA=
=20
regarding a new wind facility w/ available credits. Let EES renewable des=
k=20
know of this new green supply as an opportunity given their procurement of=
=20
green power responsibilities for New Power's 2% renewable obligation in PA.

Energy Efficiency/Renewable energy - Stacey Bolton informed EES and ENA abo=
ut=20
$358 million in funding recently approved by New Jersey for new energy=20
efficiency and renewable energy programs.

EPA Diesel Sulfur Regulations - Jeff Keeler provided EGM with information o=
n=20
the EPA's regulations requiring additional removal of sulfur content from=
=20
diesel gasoline. New Diesel sulfur requirements will require significant=
=20
increased capital expenditures by refiners, which affects the EGM price cur=
ve=20
for fuels, as well as trading, risk management and origination opportunitie=
s=20
with refiner customers. This information may also be the basis for explori=
ng=20
new markets for cleaner diesel products.

Distributed Generation - Equity Investments - Jeff Keeler provided follow u=
p=20
advice and analysis to Enron Principal Investments group on environmental=
=20
regulatory drivers affecting markets for distributed generation technologie=
s=20
and federal/state incentive monies available for projects involving=20
distributed generation technologies. Principal investments has made equit=
y=20
investments in a number of new technologies, and is considering many future=
=20
investments -- environmental regulation is a significant driver for many of=
=20
these technologies.