Subject: EHS Weekly Report - 1/25/01
From: [email-masked]
To: [email-masked]
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Date: Fri, 26 Jan 2001 00:28:00 -0800 (PST)

ADMINISTRATIVE

2001 EHS Performance Targets - EHS Global Asset Operations has been working 
with the regions to develop EHS performance targets.  Targets will presented 
to Regional Senior Management next week. 

Constellation Energy EHS Benchmarking - The EHS group in response to a 
request met with Constellation Energy representatives and described Enron's 
EHS management system in a four hour session in Houston.

EHS Enron Corp. Website - The website was activated at the end of Dec. 2000.  
Since then approximately 400 users have visited the site registering 
approximately 39,000 inquiries.  Visitors are internal as well as external.  

Conservation Committee - The Enron Conservation Committee met on Jan. 24 to 
begin their activities for 2001.  An aggressive work plan was agreed on.  
Increased corporate visibility strategy was established.  

EUROPE, INDIA and ASIA

EHS Conservation Survey  - Bal Wong and Alan Stringer working with facilities 
to complete the conservation survey.  This survey will gather information 
about energy usage and waste management practices at their facilities.   The 
information will be used to develop energy and material conservation 
initiatives. 

UK, Severnside Project ) Alan Stringer supported UK Engineering team in 
assessing whether any guidelines exist for distance for development from 
underground cables.

Spain, Arcos Project ) Alan Stringer supported Enron Spain in gathering 
information on air impacts on vineyards.

Asia, 2001 EHS Support Plan  ) Alan Stringer and Bal Wong prepared the 2001 
EHS Support Plan.  The plan will be submitted to Asia Region Senior Mgmt. 

Guam, Marianas Energy Co.  - Bal Wong provided orientation about the spill 
plan (SPCC) to the  Operations Department and completed the plant weekly 
inspection.  Also assisted in a fire drill, which include respiratory 
protection training.  

CALME

Panama, Bahia Las Minas Power Plant (BLM) - Donnie Willmann, Gus Eghneim, 
Bill Curra, and Ramiro Garcia completed a fatal flaw analysis for a potential 
expansion project in Panama involving the addition of 3 internal combustion 
engines at BLM.  Preliminary results indicated that actual emissions 
monitoring should be conducted to confirm ambient air quality (estimated 
emission factors used show the proposed project would not meet SO2 ambient 
air quality standards.  BLM agree to conduct the emissions monitoring in 
February.   

SOUTH AMERICA

Brazil, Cuiaba - Edgar Zuleta completed the implementation of the emergency 
action plan for Bolivia Cuiaba Pipeline.

OEC / NORTH AMERICA

Quebec, Canada, Daishowa Paper Manufacturing Co. - Scott Watson participated 
in the Enron Corp. EHS Overview presentation  to Eric Conner (Enron North 
America).

Mobile Energy Services Company - Scott Watson provided presentation material 
requested by Sappi regarding 1). Safety Statistics for existing managed OEC 
facilities and 2). OEC,s Safety Vision and Safety/Health Program.  This is 
part of the  transition process.  OEC to operate this paper mill on April 
1st, 2001.

Enron North America, Crisis Management Plan - Scott Watson prepared a Crisis 
Management Plan Template for Enron (ENA) attorney Peter del Vecchio.

New Jersey, Garden State Paper Company - Scott Watson contacted Marty Blick 
(Acting General Manager) on 1/23/01 to discuss Enron,s Corporate EHS 
Services.  Scott Watson scheduled to conduct an EHS Audit during the 1st 
Quarter of  2001 at this facility. 

EES - Power Distribution Project - Gus Eghneim is supporting the 
environmental permitting activities for several western power distribution 
projects. The work includes developing permitting scenarios for several 
states and for various types of applications.

ENA, Cleburne Cogeneration Plant - Gus Eghneim is reviewing a draft Title V 
permit issued by the TNRCC.  Comments will be submitted to the State and the 
facility by January 29, 2001.

Enron Transportation Services, Cunningham Compressor Station - Gus Eghneim is 
reviewing a PSD permit application developed for Cunningham compressor 
station to allow for 100% natural gas firing.

GREENFIELD CAPITAL PROJECTS

UPDATES APPEAR IN BOLD BELOW:

RioGen/Eletrobolt PPs (Brazil)- Joe Kolb reports that permitting continues to 
proceed quickly.  A public meeting for the area where the pipeline will be 
constructed will occur shortly.  There are still issues with Petrobras and 
CEG to work out.  It could be that the pipeline will not be constructed as 
quickly as needed.

Metgas Pipeline (India) - Susan Worthen confirmed with Lauren Iannarone that 
the Metgas Pipeline has been cancelled due to the lack of customers and most 
development team members have been redeployed.

E Power Corp, Japan Power Plant - Joe Kolb met with Brian Stanley last week 
to discuss the potential power plant project(s) in Japan.  Brian confirmed 
that there are three power plants at three separate locations being 
considered (rather than one power plant at three possible locations) and that 
each site is at a current industrial/port location.  Joe will coordinate his 
review and monitoring of the projects with Alan Stringer (EHS Europe).  
Preliminary indications are that it will take up to 7 years to obtain all of 
the environmental permits.

Isle of Grain Power Plant (England) ) Joe Kolb completed his review of the 
nontechnical summary of the 1998 environmental impact assessment.  The 
proposed power plant would be located within an industrial complex, which is 
good from an environmental standpoint.  It appears that the environmental 
review is being done well.

Project Quail/Tex Mex/Salsa - Joe Kolb reports that this project (known under 
various names) involves a 6-mile power line for transporting electricity to 
Mexico from the Brownsville, Texas area.  Joe spoke with Dave Kellermeyer 
(ENA) and received a project overview.  Joe asked Dave to be particularly 
attentive to issues associated with bird collisions with the proposed power 
lines.  Dave sent a copy of a letter from the US Fish and Wildlife Service 
that expressed similar concerns.

ACQUISITIONS

Project Crane (Quebec, Canada and Port Angeles, Washington Pulp and Paper 
Acquisition) - Don Stevens has been informed that Eric Connor (Director, 
Enron Industrial Markets) will be managing the transition for EIM.  Eric met 
with members of the corporate EHS and Responsibility staff to review our 
services.  He will have follow-up meetings directly with Gus Eghneim and 
Scott Watson regarding the transition and operations support.  Eric also 
expressed an interest in the EHS's assistance in a potential tissue factory 
being considered by EIM and will contact Susan Worthen for follow-up.

Military Base Privatization (Maxwell AFB) - RAC Underwriting contacted Susan 
Worthen regarding the DASH for Maxwell AFB.  Don Stevens provided follow-up 
with the RAC group.

CWT Thermo-Depolymerization (EES New Technology) - Don Stevens submitted the 
Environmental Issues Matrix to Bruce Stram, Gene O'Gorman and Susan Worthen.

North Carolina CF Power Plants - Don Stevens reports that ENSR has completed 
the monitoring well installations and groundwater/soil sampling at Lumberton 
and Elizabethtown.  Analytical results should be available early to mid next 
week.  

DEPARTMENT PROJECTS
Annual Report - Susan Worthen has received EHS performance data from GAO 
Europe and Asia and EES.  ETS and the remaining assets in GAO are expected to 
submit data by the end of the month.  Susan discussed possible storylines and 
data inputs with Community Relations.  Lauren Iannarone is leading the 
coordination with Diversity.  Susan is awaiting the image template 
information (from the 10K report) from Dennis Vegas to determine if the basic 
concept can be used fro the Corporate Responsibility report.  

BMPs -  Susan Worthen discussed with Shell International the prospect of 
performing a "peer review" of the Pipeline Construction BMPs.  Joe Kolb will 
follow-up with the Shell contacts.  Susan will also extend an invitation to 
Conservation International for a similar review.  In addition, there is a 
potential to discuss or revise the BMPs over the next year in coordination 
with the Biodiversity Forum (see below for discussion). 

EHS Web Site - Russ Tucker is providing more ergonomics information that will 
be placed on the website. Scott Watson is providing two health and safety 
training videos for the web site. These videos are intended to be viewed by 
new hires. Gavin Dillingham is persuading Enron Networks of the importance of 
having these videos on-line and is pressing for Enron Networks to quickly 
finalize a contract with a video streaming vendor.  

Telework/NEPI Program - Gavin Dillingham and Catherine Querioga, HR, will be 
attending a conference on the morning of January 31st, to gather more 
information on telecommuting. After this conference, a meeting will be set-up 
with NEPI to push this program along. There has been a positive response from 
Work Perks to possibly help pilot this program.

Hybrid Vehicle Program - Gavin Dillingham and a group from HR and the Fleet 
Vehicle group will be meeting with Toyota on Monday to finalize discussions 
on the discounts that Toyota can provide for Enron employees on the Toyota 
Prius. Also, Gavin Dillingham will meet with Bruce Martin and Colleen Raker 
of Enron Strategic Sourcing and Lilly Wells with HGAC on Tuesday, January 
31st, to discuss further how Enron can implement hybrids into its fleet. 

Asset Tracking Database - The database is currently being populated with 
data. Susan Worthen will discuss the prospect of a larger EHS audience using 
the database to update business unit project information at the next EHS 
Direct/Indirect Staff Meeting.

GAO EHS Tracking Database ) Gavin Dillingham is taking on the responsibility 
of streamlining this database and improving its workability and capabilities. 
b
Biodiversity Forum - Susan Worthen and Catherine McKalip-Thompson attended 
the 2nd meeting of the Biodiversity Forum in London last week.  This is a 
forum representing 5 NGOs and 5 multinational energy companies.  Enron will 
host the next meeting, which has been scheduled for April 19 & 20.  Susan is 
co-chairing a work group to draft a paper on the business value of 
biodiversity/conservation. This activity allows Enron to develop a positive 
response to shareholder proxy requests.

Corporate Responsibility Sub-Committee Meetings - Susan Worthen participated 
in several sub-committee meetings in support of the Corporate Responsibility 
Task Force.  Mike Terraso was elected to chair the Internal Communications 
sub-committee.

Green Sourcing Initiatives - Susan Worthen provided a summary of 
GreenOrder.com's capabilities and possible business upsides (for Enron) to 
Eric Melvin (EES) and Darryl Cleveland (Global Strategic Sourcing).  A 
follow-up meeting with Global Strategic Sourcing will be scheduled to discuss 
supplier considerations and possibly setting green sourcing/purchasing 
targets.  This meeting will be coordinated with Henry Van as the chairperson 
of the Conservation Committee.

EHS Guidelines Revision - The EHS Council sub-committee will meet 02/08/01 to 
discuss and agree on the preferred method of revising the EHS Guidelines, as 
well as the selection of consultants to submit proposals.

VOLUNTEER ACTIVITIES/COMMUNITY RELATIONS

MOPS 686 Donation - Joe Kolb reports that the Texas A&M meeting on January 12 
to review Enron's proposal went well.  The university is pursuing additional 
funding sources and participants with the goal of developing a 5-year funding 
program.  They expect it will be about the end of March before they report 
their results to Enron.

Enron Earth Day Festival - Gavin Dillingham and Charla Reese met with Trash 
Bash on Tuesday, the 23rd, to discuss the logistics of leveraging Trash Bash 
with the Buffalo Bayou Challenge. Trash Bash provided great information 
concerning supplies and how to efficiently and effectively pick-up the trash. 
Charla Reese, Gavin Dillingham and Joe Kolb are meeting today to finalize 
some of the aspects of this challenge. 

REGULATORY TECHNICAL ANALYSIS

Methanol Plant Emission Credits - Marc Phillips provided an evaluation of the 
potential value of emission credits for the Enron methanol plant to their 
management.

Louisiana Title V Permit Renewals - Marc Phillips provided information from 
LMOGA about Title V permit renewals in Louisiana to the appropriate ETS 
personnel. Applications for renewal of the permits are required 6 months 
prior to expiration, but the state agency is apparently not notifying 
companies about this deadline.

Reciprocating Engine Control Technology - Marc Phillips provided ETS 
personnel with industry studies about control technology that has been 
applied to reciprocating engines, and data that SCR was not an effective 
control technology for load-following engines. An ETS station in Kansas could 
be subject to PSD regulations and the agency may require SCR technology.

National Academy of Sciences (NAS) Report Issued -  the NAS  study released 
1/17/01 justified the need for an ergonomics standard. The report indicates 
that MSDs show evidence of being caused by workplace exposures and that 
interventions can reduce those exposures and injuries. The importance of this 
study is in its being funded by Congress, which now is faced with the 
decision to activate the never before used Congressional Review Act in an 
effort to send to the President a resolution that would retract the recently 
effective OSHA Ergonomics Program final rule.

Three New OSHA Final Rules - Russell Tucker is reviewing 3 new OSHA final 
rules issued in the last week. They are the amendments to the Bloodborne 
Pathogen standard, amendments to the Employee Injury Recordkeeping rule, and 
a completely new Steel Erection standard, all of which are extensive in their 
content and importance in their impact on all Enron companies under OSHA 
enforcement, except for the Steel Erection standard, which applies to the ECC 
and NEPCO operations.

Enron Houston Work Related Injury/Illness/Accident Reporting, Investigation 
and Record Keeping Protocol - Russell Tucker is making final revisions to 
this protocol for use within the Houston office complex with publication to 
the Enron Corp EH&S Intranet scheduled for this week. Revisions reflect 
reviews and input from Wellness, Fair Employment, Legal, and Risk Management.

Environmental Strategies Group

Competitive Intelligence

Power/Gas/Emissions Markets -- California Energy Crisis & Emissions 
Regulation:  ESG has given high priority to assisting Enron business units in 
developing a strategy related to the impact of environmental regulation on 
California's energy crisis.  Jeff Keeler provided ENA traders and competitive 
analysis groups with information regarding potential federal actions and Bush 
administration political pressure for California to ease emissions 
requirements on generators.   Jeff also coordinated with Mark Palmer and the 
EGM emissions desk in talking to reporters about environmental regulation's 
role in the California situation. Mary Schoen will be focusing on California 
in the coming weeks, helping to provide intelligence about state/local 
actions to change environmental/emissions regulations and leading efforts to 
develop innovative solutions to acquiring offsets for new generation 
development.  Stacey Bolton's work on renewable energy issues will help Enron 
businesses in looking at additional opportunities to provide capacity to 
California.  The entire ESG will act as a resource for federal and state 
government affairs as they offer policy solutions to the crisis.

Coal/Power Markets - RCRA Coal Ash decision:  On Friday, January 19, a 
Federal Court dismissed a lawsuit by environmental groups against EPA's 2000 
determination that classified most types of fossil fuel waste as 
"non-hazardous" under the RCRA hazardous waste laws.   A decision against EPA 
and industry could have imposed greater disposal costs on generators, having 
significant impacts on power and coal prices and limiting generators ability 
to sell ash for positive uses, such as cement making.   Jeff Keeler advised 
EGM coal, ENA power, and PGE of the decision.

Power Markets -- Environmental Disclosure:   Stacey Bolton updated EES on the 
New York PSC's progress on developing environmental disclosure regulations 
and what Enron's requirements will be.  Stacey also provided the Texas group 
information on the proposed label calculation rule and voluntary certificates 
market.

Advocacy Coordination and Business Support

Clean Air Act -- Federal Multi-pollutant Legislation:   Jeff Keeler continued 
development of strategy on a multi-pollutant cap and trade proposal for 
submission to Congress and the new Administration.   Jeff participated in 
several industry strategy calls and organized visits of an ad hoc "Clean 
Power" group to key staff on Capitol Hill and in EPA.  Jeff interviewed 
several law firms and consultants that the group may retain to assist with 
technical legislative drafting and lobbying on the multi-pollutant bill.   

Climate Change:  Stacey Bolton represented Enron at a Pew Center on Climate 
Change seminar in Portland, OR, speaking on Enron's renewable energy 
products, regulatory hurdles in the retail renewable market, and the benefits 
of renewable energy credit trading.  Stacey made several contacts with 
potential customers (Weyerhaeuser & Toyota - manufacturing) that she has 
passed along to Enron businesses. Mike Terraso presented Enron's Greenhouse 
Gas Inventory methodology.  Jeff Keeler assisted Enron Europe and Government 
Affairs in developing final comments to submit to the UK government regarding 
their proposed greenhouse gas emissions trading pilot program.  Jeff also 
answered inquiries from ENA power developers who are interested in 
potentially selling carbon offsets through the purchase additional 
land/forest resources along with power projects.

Power Quality:   The entire ESG continues to provide a great deal of support 
to the EES Premium Power group as they develop and implement their business 
plan to provide power quality and distributed generation services to 
customers in the high-tech area.  Mary Schoen worked on evolving 
environmental regulations regarding distributed generation in California and 
Texas.   Stacey Bolton provided support on renewable energy technologies and 
incentive monies.  Jeff Keeler coordinated meetings with the US DOE, who is 
interested in lending support to Enron projects.   Enron is helping the DOE 
staff and Bush transition team develop a FY 02 multi-million dollar funding 
mechanism at DOE to support R&D and commercial applications for power quality 
projects in the high-tech sector.  In addition, DOE has committed some 
immediate discretionary funding to existing Enron projects.  Mary Schoen 
organized meetings for EES on environmental regulation and the relation to 
various power technologies.

Pipeline Safety Legislation & Regulation:  Jeff Keeler held meetings in 
Washington, DC to provide ETS and Federal Government Affairs with information 
on activities in the 106th Congress and assist in developing a strategy in 
the 107th Congress.   Jeff organized meetings with policy makers and industry 
organizations to ensure Federal Government Affairs' smooth transition into 
assuming a leadership role on this issue.

Renewable Energy - California Customer Credit:   Stacey Bolton provided 
testimony to California Energy Commission (CEC) regarding the current 
customer credit fund for larger users being prematurely depleted, and ways in 
which the commission can ensure this doesn't happen with the future 
allocation from 2002-2007.  Stacey also submitted formal comments to CEC on 
the allocation of the extended SBF program.

Renewable Energy Credit Trading:  Stacey Bolton talked to New York PSC staff 
regarding their quasi-trading program (conversion transaction) for renewable 
energy.  Enron submitted joint comments last summer, and NYPSC staff 
confirmed that many of our recommendations will be incorporated into the 
final rule, to be released at the end of the month.  Stacey informed EES of 
this win.   Stacey is also working with Texas renewable coalition to fight 
hefty charges for the REC program.  Charges could act as a disincentive to 
renewable generators thinking about building projects & raise the price of 
retail products in TX.  

Renewable Energy Trading/Products:  Mike Terraso and Stacey Bolton met with 
Elliot Mainzer of ENA West structuring for a strategy session regarding his 
development of a wholesale renewable energy desk.  Stacey is assisting Elliot 
with information for inclusion in his business plan.  Stacey also met with 
Elliot and EES to discuss arrangement between an ENA/EMPI renewable wholesale 
desk and EES.  

Environmental Disclosure:   Stacey Bolton is working with a law firm in 
Maryland to submit reply comments arguing against the Commissions' intent to 
go with a PJM tracking system for disclosure.  Stacey is coordinating a joint 
response with several stakeholders (PG&E national energy group, Green 
Mountain, and possibly some utilities/affiliates).

2001 Strategies for Business Support:   ESG met with EES' Heather Mitchell 
and Elizabeth Howley to discuss their 2001 objectives and how we can assist 
them over the next year.  They are interested in promoting the role of energy 
efficiency in reducing emissions and monetizing the benefits that they help 
customers accrue.  They are also interested in assistance with renewable 
energy strategies and EPA Star programs.  Stacey Bolton also participated in 
the EHS meeting with Enron Industrial Markets to inform him of our group's 
capabilities, and followed up with an e-mail.

Presidential Inauguration:   Environmental Strategies participated in several 
inauguration activities.  In addition to participating in the Enron events, 
ESG sponsored the "Environmental Inaugural Ball" which was a smaller event 
with participation by companies, organizations, and policy makers in the 
environmental area.