Subject: Re: Environmental -- NCL
From: [email-masked]
To: [email-masked], [email-masked], [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked]
Date: Wed, 10 Jan 2001 15:15:00 -0800 (PST)

Bill, Just a short note to let you know whats going on at Bakersfield.  I 
have spoken to the agency inspector about one of the NOV issues and have been 
told that EOTT will definately receive a an NOV and fine for failure to 
conduct the emissions testing on a heater that apparently should have been 
tested approx. 6 months ago.  With repsect to the other NOV issue, Rick 
Suderman had a testing company in to perform emissions testing on another 
heater which was required to be tested by today.  As the testing contractor 
began his testing, an 02 issue developed with the equipment the testing 
company was using and a miscommunication on the part of the testing 
contractor was directed to Rick.  As a result,  the  the inspector observed 
elevated CO readings from the heater that  Rick had made adjustments in the 
heater set points (based upon recommendations from the contractor) causing 
the elevated CO readings to result.  The inspector stated that the facility 
would receive another NOV for this exceedance.   In any event this isssue was 
NOT Rick's fault and was due to some bad communication on the part of the 
contractor.  We have sent the testing company home and will be bringing in 
another testing company (AEROS) on thursday.  This is the contractor who has 
done the majority of the previous emissions testing for the facility to 
complete the heater testing and substantiate the innaccuracy of the first 
testing company's data.  With this new data, we shold be able to demonstrate 
inaccuracy in the first testing company's QA/QC.

It should also be mentioned that we have identified other environmental 
issues which we should discuss at your convenience.  Butch and I will have 
completed the permit compliance investigataion and be available for 
discussions on friday. 

William Kendrick
01/10/2001 07:53 AM

To: Rich Jolly/ET&S/Enron, Edward Attanasio/Remote/Eott@Eott
cc: John Shafer/OTS/Enron, Larry Campbell/ET&S/Enron 

Subject: Re: Environmental -- NCL  

Rich/Ed---

Larry Campbell is going to Bakersfield this  week to address the situation.  
I have asked him to put together a compliance calendar for the Bakersfield 
facility outlining regulatory deadlines required by the permits and 
regulations.  He has discussed the testing due on one of the heaters this 
week with the regulators and there does not appear to be an issue.  It is my 
understanding that the heater will be performed this week.  Larry will look 
into the best course of action necessary to address the engine testing that 
was apparently missed last year.  He will be discussing the matter with 
Gary.   Please call with any questions.

Thanks, Bill
713.646.7644 

Rich Jolly
01/09/2001 05:24 PM
To: [email-masked]
cc: [email-masked], [email-masked], [email-masked], 
[email-masked], [email-masked], Larry Campbell/ET&S/Enron@Enron, 
William Kendrick/OTS/Enron@ENRON 

Subject: Re: Environmental -- NCL  

Ed thanks for the information. Bill Kendricks from Houston has asked Larry 
Campbell to work with Rick on getting this resolved. I talked with Larry 
today and he was going to give Rick a call.

Rich

[email-masked] on 02/23/2000 12:53:54 PM
To: [email-masked], [email-masked]
cc: [email-masked], [email-masked], [email-masked] 

Subject: Environmental -- NCL

     I just spoke with Gary Fuller who informed me that we have been
notified by the Air District that we are getting an NOV for missing a
source test in December (apparently on one of our IC engines.)  Now, while
this is not the end of the world, we put ourselves at potential risk if we
do not follow up properly -- especially given the history of this plant
with this Air District (that is, the Koch troubles that resulted in a
criminal investigation from some relatively minor problems, really.)

     In fact, I believe that if we act promptly and conduct the source test
now we stand a very good chance of having this NOV rescinded.  But we must
act.  I am please to see that we still have Gary on the job, and I hope he
can follow through with this.  I have asked him to do so, and also to
handle reporting of the soil contamination at NCL that we have all
discussed at length.  I have done so because delay works against us on both
of these issues.  Gary, though, is somewhat reluctant to act without
instruction directly from ETS (which is understandable, given that ETS runs
things.)   He seems to feel that he should be getting direction from Cutty
Cunningham, although I must confess I don't know enough yet about the
structure of ETS to know why this is the case.

     In any event, I asked Gary to talk to whomever he needed to, but these
matters needed to be handled in the short run.  Obviously, we will discuss
next week what is to be done for the long run.  In the meantime, I would
greatly appreciate whatever you folks can do to help grease the wheels to
make Gary feel he has authority to act to get these more immediate problems
addressed.  Thanks a bunch.