Subject: EHS Weekly Report - week ending 3/16/01
From: [email-masked]
To: [email-masked]
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Date: Mon, 19 Mar 2001 03:07:00 -0800 (PST)

ADMINISTRATIVE

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

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

EUROPE

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

All Assets - Alan Stringer and Bal Wong reviewed and submitted February 2001 
EHS Performance Report to Houston.  

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

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

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

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

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

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

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

ENRON ENERGY SERVICES

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

Alabama, Mobile Energy Services Company ) Scott Watson has been coordinating 
the implementation of  the EHS Transition Plan he prepared.   Also he will 
conduct an EHS Audit at this facility the week of March 25th, 2001.   Ramiro 
Garcia and Gus Eghneim are developing an environmental compliance Manual for 
Mobile Energy Services.   This manual is based on the review of facility 
environmental documents and permits. 
 
Massachusetts, New Albany Power - Gus Eghneim is working to resolve the 
environmental issues identified in the plant's 2000 audit report.   All, but 
two issues will be resolved by March 26th, 2001. The work involves finalizing 
the plant's environmental compliance manual.

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

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

GLOBAL INDUSTRIAL MARKETS

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

ENRON AMERICAS

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

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

CAPITAL PROJECTS

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

DEPARTMENT PROJECTS 

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

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

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

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

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

REGULATORY TECHNICAL ANALYSIS

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

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

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

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

ADVOCACY COORDINATION & COMMERCIAL SUPPORT

Air Quality/Multipollutant Strategy -- Carbon Dioxide Regulation -  Jeff 
Keeler coordinated Enron's involvement in activities surrounding President 
Bush's statement (in a letter to several Senators) that mandatory caps on CO2 
emissions should not be included in any multipollutant approaches for the 
power sector.  Jeff maintained communications with EPA, White House, and 
congressional contacts on the subject, and advised our "Clean Power Group" 
coalition and congressional staff on possible responses and future 
strategies.  Jeff is working closely with Senate Environment Committee staff 
to craft legislation that will still move forward on NOx, SO2 and mercury 
while continuing to look at meaningful approaches to carbon reduction.

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

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

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

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

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

COMPETITIVE INTELLIGENCE

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

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

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

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