Enron Mail

From:laura.glenn@enron.com
To:steven.kean@enron.com
Subject:
Cc:maureen.mcvicker@enron.com
Bcc:maureen.mcvicker@enron.com
Date:Thu, 14 Sep 2000 10:18:00 -0700 (PDT)

EPA Stormwater Phase II Regulations - Jim Peterson provided information to
EES in response to an inquiry about the effect of the stormwater phase II
regulations on military installations.

EPA Guidance on BACT for Combined Cycle Turbines - Marc Phillips is
preparing comments supporting EPA's guidance on BACT for combined cycle
turbines. The document indicated that SCR may not always be required and that
dry-low NOx controls may all that is required in some circumstances. Jeff
Keeler is circulating the comments for internal review. Comments are due
September 18.

TNRCC Houston Non-Attainment Regulations - Marc Phillips is preparing
comments on the proposed Houston non-attainment regulations. It is
anticipated that the comments will generally support the Business Coalition
for Clean Air (BCCA) comments with some added technical issues raised. Ken
Lay sits on the BCCA board and Mike Terraso and Rob Bradley sit on the
coordinating committee.

Enron Proposed Ergonomic Program - Russell Tucker and Linda Adels (Corporate
Wellness) began loading the proposed pilot ergo training and analysis
programs on the employee computers that are to participate in the program
evaluations. It was found that the computers in the Enron building are locked
down so much that neither of the programs could be loaded, requiring a long
process of EDS involvement to affect the loading process on several different
LANs. No problems have been encountered in 3AC.

EES/Eli Lilly Project - Susan Worthen gave a presentation to Eli Lilly
regarding the corporate EHS organization, policy and management system, and
performance, as well as participate in discussions of our operating
experience and procedures in a Q&A session. Other Enron participants
included Rick Wood (Enron Bldg Services Inc - a subsidiary of EES) and Dave
Nutt (Corp environmental counsel). The presentation and discussions were in
response to a 10 page EHS questionnaire Lilly submitted as part of a due
diligence they are conducting prior to signing a multi-million dollar
out-sourcing agreement with EES.

Annual EHS Report - Positive feedback is being received externally and
internally on our first report. It will go to press this week with copies
anticipated the week of the 25th. Requests for copies have been received (so
far) from John Hardy, Kelly Kimberly, EES, and EGE&P.

New Hire Orientation - Angela Sprock (Orientation) has relinquished 5 minutes
during the Vision and Values for the EHS/Corporate Responsibility info. The
panel for the booth is awaiting Kelly Kimberly's final approval.

Project INGA - ENA East/West - ENA is investigating a stock purchase of
Ahlstrom Development Corporation's holdings in five coal fired facilities.
Two of the facilities (ACE Generation Company and Mt. Poso Cogeneration
Company) are located in California. Three of the facilities (Panther Creek
Partners, Inter-Power Ahlcon LP (Colver) and Gilberton Power Company) are
located in Pennsylvania. ENA has contracted RTP Environmental Associates to
conduct the due diligence (fatal flaw) and site visits. The site visits were
conducted 9/5/00 - 9/8/00 for the California facilities and 9/12/00 - 9/15/00
for the Pennsylvania facilities. Don Stevens will be conducting the
environmental review of RTP's report. The commercial objective is to
restructure the PPA.

Project Dragon - Asia - Don Stevens was requested to supply a revised copy of
the environmental due diligence to the Enron's Bangkok, Thailand office. The
lenders engineers will be reviewing the report within the next two weeks.
The lenders engineers will submit any questions regarding the acquisitions to
Don Stevens for further discussion.

Project Crane - ENA - ENA is looking to acquire 100% of Daishowa Paper Mfg.
Co. Ltd's forest products operations in Quebec City, Quebec, Canada, and in
Port Angeles, Washington. The assets include seven paper and board machines,
four major pulping facilities and integrated utility systems, a sawmill, a
chip handling facility and forestlands in Quebec and Maine. Wayne Mays ENA
requested EHS review assistance . Don Stevens will review the due diligence
report and submit comments to ENA. The environmental due diligence was
conducted by AGRA Simons Engineering Global Solutions.

EHS Intranet Site - Gavin Dillingham has been working on the EHS Intranet
site. The current status of the site is that the elaboration document is
being completed. The intention is to hand over the document to the Internet
developers/architects by the 1st of October. They say it is possible to have
a rough mock-up of the site by the middle of October.

Compliance Calendar - Gavin Dillingham and Gary Allen have been in talks with
DS&S about locating a Compliance Management Calendar, which will be a modular
software program that will allow the addition of other EHS modules to this
system such as audit software and Health and Safety tracking software.

EHS Management System document - Gavin Dillingham is also working on the EHS
Management System document. All the data for roles and responsibilities has
been gathered and placed in the document, as well as the EHS Management
Description document. Also, the latest EHS council charter, the latest
organizational chart, the standardized forms and documents and the due
diligence schematic have been added. Gavin Dillingham will be moving over to
the 3AC on Monday, the 18th of September.

Environmental Disclosure:Stacey Bolton made a presentation to the TX PUC in
their kickoff meeting for environmental disclosure. A trader accompanied her
in order to familiarize the desk with some of the overlapping issues between
environmental disclosure and the renewable energy program. Stacey filed two
sets of comments with the PUC, and subsequently met with Chairman Wood,
Commissioner Judy Walsh and Evan Roe (staffer to Commissioner Perlman) to
discuss environmental reporting and the trading program. Hap Boyd was also
in the meeting. We got nearly everything we wanted in the renewable energy
protocol, except for emission data on the credit itself. Stacey will
continues to advocate this issue and try to find a forum to get emissions
data included (due to bypassed emissions opportunities and it puts more value
on cleaner renewable fuels like wind).

International Environmental Emergency Responders - David Ronkainen gave Don
Hawkins (corporate crisis response manager) a list of International
Responders, so that a decision could be made in regard to negotiating
agreements.

Dabhol Community Relations Management - Henry Van met with Dabhol Community
Relations Management and visited all the community projects (technical
school, elementary school, horticulture project and jetty for fishing
village) in relation to the offsite impacts of the oil leaks. The
communities did not express active concern.

Spill Update - Ed Zuleta participated on the TR conference call on spills. A
summary was prepared and mailed to key personnel in HSE group.

Wheatland Power - Enron (Gus Eghneim) submitted a petition to EPA Region 5
to waive the stack testing requirements and rely on CEMS ( continuous
emission monitoring) certification to demonstrate compliance. If approved,
the waiver will save Enron approximately $400,000. The savings are realized
by not operating the plant during a low demand period only for the purpose of
conducting stack test. In low demand period, plants operate at a huge loss.

Pipeline Safety Legislation - Jeff Keeler continues to actively participate
in the GPG efforts in the House to get passage of a bill similar to the
Senate bill passed last week.

MTBE Legislation - Jeff Keeler continues to follow the progress and advocates
including a transition costs to a new production process if a rider is placed
on an appropriations bill.

Environmental Product Strategy Meeting - Stacey Bolton has organized a
meeting with business units involved or interested in pursuing various
opportunities arising from environmental policies, such as renewables, energy
efficiency, and green power marketing. Representatives of EES, ENA
Origination, ENA West Desk, Enron Wind, and Enron Global Markets will be in
attendance. Stacey and Mary Schoen will present updates on environmental
regulations and incentives for green power oppportunities. They will also
foster discussion among businesses about upcoming bids/commercial partnering
opportunities, evolving markets for renewable credit trading, and potential
product offerings. This meeting is aimed at adding value and creating
business opportunities for the Enron busniess units.

Pipeline safety legislation - Jeff Keeler is working with members of
Congress and others in industry on a strategy that would get the House of
Representatives to pass the pipeline safety legislation recently passed by
the Senate. This strategy avoids several procedural steps in Congress and
allows the House to pass a bill that is fairly acceptable to industry, rather
than waiting for the House to produce its own bill and move it
independently. This is a very fluid situation right now, but we hope to
have a positive result by next week.

MTBE legislation - the Senate Environment Committee passed MTBE legislation
last week, containing a number of provisions that are bad for MTBE producers,
including a ban of MTBE, granting states the ability to waive the fuel oxygen
standard, and mandating increased ethanol use over 10 years. Two Enron
amendments were voted on -- liability protection and an MTBE producer
"transition retrofit fund" -- and defeated, but Senator Kay Bailey Hutchison
received a commitment that transition fund issue would be addressed before
the bill moves on to the Senate floor. Jeff will be working on this issue
with Senate staff over the next few weeks.

TVA environmental litigation - we supported the Enron Global Markets
emissions/coal desk in getting information on TVA's appeal of lawsuits by EPA
on violations of New Source Review rules. A is expected by an EPA
Administrative Appeals Board on 9/15, in which TVA will likely lose. TVA is
appealing in Federal Court, arguments to be held in early November.
Intelligence on this is extremely important to several Enron business units,
as much of the electric utililty industry is watching to see whether EPA can
prevail in its enforcement activities against coal plants, and utilities'
future decisions about fuel choice, control technologies, etc. could be
affected by action in this case.

EPA enforcement activities- we have learned that EPA is now targeting 14
non-utility, coal-fired boilers in Pennsylvania for New Source Review
enforcement. We will be providing more detailed information to traders that
could find opportunities from this action, as well as Enron originators
currently working on acquisition of several QF coal assets in Pennsylvania.

TX Disclosure - Stacey Bolton made a presentation to the TX PUC in their
kickoff meeting for environmental disclosure, in which Enron power traders
also participated to gain insights on the relationship between the disclosure
and renewable energy trading programs. Stacey also filed two sets of
comments w/ the PUC, and subsequently met w/Chairman Wood, Commissioner Judy
Walsh and Evan Roe (staffer to Commissioner Perlman) to discuss environmental
reporting and the trading program. Enron Wind was also involved in these
meetings. Enron got nearly everything we wanted in the renewable energy
protocol, except for putting emissions data on the credit itself -- which is
an issue Stacey will continue to pursue in TX and other states.

Pew Center symposium on Climate Change - Mary Schoen will be representing
Enron in a Pew Center symposium on climate change in New Orleans on Thursday
9/21. Members of industry, government and environmental groups will be in
attendance, and Mary's panel will be discussing what businesses are doing
about climate change.

America's Clean Air Celebration - Enron will be honored next week at
America's Clean Air Celebration, a dinner put on in conjunction with the
Hart/IRI World Fuels Conference in Washington, D.C. Enron and Ken Lay will
be presented with an award recognizing excellence in energy, environment and
innovation, which Jeff Keeler will accept and present remarks following.
Other participants are BP/Amoco, Texaco, GM and a number of other industry
peers. President George Bush and Senator George Mitchell are co-chairs of
the event -- Bush will make videotaped remarks including a mention of Ken
Lay's contribution to clean air, and Mitchell will MC the event.