From: [email-masked]
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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.