Message-ID: <10906676.1075848099175.JavaMail.evans@thyme> Date: Thu, 14 Sep 2000 10:18:00 -0700 (PDT) From: laura.glenn@enron.com To: steven.kean@enron.com Subject: Cc: maureen.mcvicker@enron.com Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit Bcc: maureen.mcvicker@enron.com X-From: Laura Glenn X-To: Steven J Kean X-cc: Maureen McVicker X-bcc: X-Folder: \Steven_Kean_June2001_4\Notes Folders\Discussion threads X-Origin: KEAN-S X-FileName: skean.nsf 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.