Environmental

Revision: 0
Environmental Implementation Guidelines

Issued: 20-Nov-1999
Review Due: Nov-2000
Volume II
Table of Contents Doc. # TOC-200
• Philosophy
• Management Standards
• Environmental Guidelines
− General – Implementation of Corp. Environmental Policy and Standards
− General – Agency Relations
− General Guidance
− Spills and Releases – Implementation of Emergency Response Guidelines
− Spills and Releases – Spill Prevention
− Spills and Releases – Spill Plans and Training
− Waste Management – General Guidelines
− Waste Management – On-Site Waste Management
− Waste Management – Off-Site Waste Management
− Water Quality Management
− Air Quality Management
− Asbestos Management
− Storage Tank Management
− PCB Management
− Potable Water Management
• Exceptions/Revisions
Global Asset Operations Page 1 of 4

Revision: 0
Issued: 20-Nov-1999
Volume II
Philosophy
Global Asset Operations Philosophy
Management Standards
Environmental, Health and Safety .......................................................................................... MGS-001
Process Safety Management.................................................................................................... MGS-002
Crisis Management.................................................................................................................. MGS-003
International Security .............................................................................................................. MGS-004
Quality Management System (ISO) ........................................................................................ MGS-005
Human Resources.................................................................................................................... MGS-006
Administrative......................................................................................................................... MGS-007
Third-Party Management ........................................................................................................ MGS-008
Maintenance ............................................................................................................................ MGS-009
Operations ............................................................................................................................... MGS-010
“Positive Impact” Program...................................................................................................... MGS-011
Management Standard and Guideline Auditing ...................................................................... MGS-012
Environmental Guidelines
General - Implementation of Corp Environmental Policy and Standards
Statement of Enron Corp Environmental, Health and Safety Principles ...........................ENV-001
Environmental Guideline ...................................................................................................ENV-002
Personnel and Designation of Environmental Responsibilities .........................................ENV-003
Definitions..........................................................................................................................ENV-004
Reserved .............................................................................................................................ENV-005
General - Agency Relations
Facilities Inspections ..........................................................................................................ENV-006
Agency Communications ...................................................................................................ENV-007
Reserved .............................................................................................................................ENV-008
General Guidance
Community Relations and Communications......................................................................ENV-009
Reserved .............................................................................................................................ENV-010
Guideline for Environmental Records................................................................................ENV-011
Monthly Reports.................................................................................................................ENV-012
Annual EHS Report............................................................................................................ENV-013
Reserved .............................................................................................................................ENV-014
Spills and Releases – Implementation of Emergency Response Guidelines
Spill Response Actions.......................................................................................................ENV-015
Spill Cleanup Guidelines....................................................................................................ENV-016
Reserved .............................................................................................................................ENV-017
Spills and Releases - Spill Prevention
General Guidance...............................................................................................................ENV-018
Loading and Unloading......................................................................................................ENV-019
Container Handling and Storage ........................................................................................ENV-020
Aboveground Storage Tank Design and Specifications.....................................................ENV-021
Facility Inspections ............................................................................................................ENV-022
Reserved .............................................................................................................................ENV-023
Spills and Releases - Spill Plans and Training
Spill Plans...........................................................................................................................ENV-024
Personnel Training .............................................................................................................ENV-025
Spill Drills ..........................................................................................................................ENV-026
Reserved .............................................................................................................................ENV-027

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Volume II
Environmental Guidelines (Continued)

Waste Management - General Guidelines
Compliance with Local Laws and Regulations..................................................................ENV-028
Waste Characterization ......................................................................................................ENV-029
Unclassified Materials........................................................................................................ENV-030
Used Aerosol Cans .............................................................................................................ENV-031
Used Drums and Containers...............................................................................................ENV-032
Used Fluorescent Bulbs......................................................................................................ENV-033
Used Glycol and Oil Filters................................................................................................ENV-034
Molecular Sieves and Activated Carbon............................................................................ENV-035
Used Oil..............................................................................................................................ENV-036
Pesticides, Herbicides and Insecticides..............................................................................ENV-037
Sandblasting Materials .......................................................................................................ENV-038
Used Tires and Batteries ....................................................................................................ENV-039
Waste Acids and Caustics ..................................................................................................ENV-040
Waste Paint and Solvents ...................................................................................................ENV-041
New Product Review and Storage Guideline.....................................................................ENV-042
Waste Minimization ...........................................................................................................ENV-043
Personnel Training and Emergency Procedures.................................................................ENV-044
Reserved .............................................................................................................................ENV-045
Reserved .............................................................................................................................ENV-046
Waste Management - On-Site Management
Storage and Inspection .......................................................................................................ENV-047
Treatment Guide.................................................................................................................ENV-048
On-site Waste Management ...............................................................................................ENV-049
Reserved .............................................................................................................................ENV-050
Waste Management - Off-Site Management
Selecting Transportation and Disposal Services ................................................................ENV-051
Documenting Transportation and Disposal Services .........................................................ENV-052
Reserved .............................................................................................................................ENV-053
Water Quality Management
Definition and General Guidance.......................................................................................ENV-054
Containment Area Discharges............................................................................................ENV-055
Discharge Limits and Monitoring Guidelines....................................................................ENV-056
Reserved .............................................................................................................................ENV-057
Domestic Sewage ...............................................................................................................ENV-058
Hydrostatic Test Water Discharges....................................................................................ENV-059
Aquatic Monitoring ............................................................................................................ENV-060
Reserved .............................................................................................................................ENV-061
Air Quality Management
Greenhouse Gas Emissions ................................................................................................ENV-062
Stack Emissions, Controls and Monitoring........................................................................ENV-063
Ambient Air Quality Monitoring Program.........................................................................ENV-064
Reserved .............................................................................................................................ENV-065
Asbestos Management
Policy and Definitions........................................................................................................ENV-066
Notice to Perform Work.....................................................................................................ENV-067
Storage and Disposal..........................................................................................................ENV-068
Reserved .............................................................................................................................ENV-069

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Volume II
Environmental Guidelines (Continued)

Storage Tank Management
Underground Storage Tanks...............................................................................................ENV-070
Aboveground Storage Tanks..............................................................................................ENV-071
Reserved .............................................................................................................................ENV-072
PCB Management
Notification Guideline........................................................................................................ENV-073
Labelling Guideline............................................................................................................ENV-074
Inventory Guideline............................................................................................................ENV-075
Storage and Inspection Guideline ......................................................................................ENV-076
Guideline for Disposal of PCB Wastes ..............................................................................ENV-077
Recordkeeping and Personnel Training .............................................................................ENV-078
Reserved .............................................................................................................................ENV-079
Potable Water Management
Quality Monitoring.............................................................................................................ENV-080
Exceptions/Revisions
Exception Process ....................................................................................................................EXC-001
Revision Process ...................................................................................................................... REV-001

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Environmental, Health and Safety
Doc. # MGS-001
1. Management Standard
Environmental, Health and Safety (EHS) programs shall be developed, implemented and
maintained for all operating assets. The EHS programs shall, at a minimum, address applicable
areas found in Table 1 (Safety) and Table 2 (Environmental), as appropriate.
2. Scope
This management standard applies to all “Company” operated facilities, its employees and its
contractors except where superseded by more stringent local standards.
3. Corporate Resource Commitment

Enron Corp business units shall provide human, physical and financial resources essential to
developing the required EHS programs.
4. References
4.1 Enron Corp Environmental, Health and Safety Management Procedures,

January 1998
4.2 Enron Global Asset Operations Safety and Health Guidelines
4.3 Enron Global Asset Operations Environmental Guidelines

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Doc. # MGS-001
Table 1 - Safety
1. Accident and Injury Reporting and Investigation 28. Flammable and Combustibles-Handling and Storage
2. Abrasive Blasting 29. Fuel Management
3. Animal, Insect and Plant Hazards 30. Gas Testing
4. Asbestos 31. Hazard Communication and MSDS
5. Bloodborne Pathogens Control 32. Hearing Conservation
6. Buried Lines 33. Hot and Cold Work Permits
7. Diving 34. Housekeeping and Office Safety
8. Compressed Gas Cylinders 35. Laboratory Safety and Hygiene
9. Confined Space Entry 36. Ladders
10. Crane Safety 37. Powered Lift Truck Operations
11. Diesel Engine Safety 38. Lock-Out/Tag-Out Safeguards
12. Electrical Safety - Basic 39. Material Handling
13. Electrical Safety – General Substation Rules 40. Naturally Occurring Radioactive Material (NORM)
Safeguards
14. Electrical Safety – Work On or Near Energized 41. Personal Protective Equipment (PPE)
Equipment
15. Electrical Safety – Overhead Lines 42. Process Safety Management
16. Electrical Safety – Underground Installations 43. Respiratory Protection
17. Electrical Safety – Engineering Testing 44. Safety Meetings
18. Electrical Safety – Communications Facilities 45. Safety Teams
19. Emergency Action Plans 46. Scaffolds
20. Equipment and Tool Safety 47. Signs and Tags
21. Excavation 48. Spray Painting
22. Facility Safety Inspection 49. Stairways
23. Fall Protection 50. Walking and Working Surfaces
24. Fire Brigades 51. Working Over Water
25. Fire Extinguishers (Portable) 52. Work Zone Traffic Control and Flagging
26. Fire Extinguishing Systems 53. Employee Orientation
27. First Aid

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Doc. # MGS-001
Table 2 - Environmental
1. General-Statement of Enron Corp EHS Principles 41. Waste-Waste Paint and Solvents
2. General-Environmental Guideline 42. Waste-New Product Review and Storage
3. General-Personnel/Designation of Responsibilities 43. Waste-Waste Minimization
4. General-Definitions 44. Waste-Personnel Training and Emergency Actions
5. General-Reserved 45. Waste-Reserved
6. General-Facilities Inspections 46. Waste-Reserved
7. General-Agency Communications 47. Waste-Storage and Inspection
8. General-Reserved 48. Waste-Treatment Guideline
9. General-Community Relations and Communication 49. Waste-On-Site Waste Management
10. General-Reserved 50. Waste-Reserved
11. General-Guideline for Environmental Records 51. Waste-Selecting T & D Services
12. General-Monthly Reports 52. Waste-Documenting T & D Services
13. General-Annual EHS Report 53. Waste-Reserved
14. General-Reserved 54. Water-Definition and General Guidance
15. Spills & Releases-Spill Response Actions 55. Water-Containment Area Discharges
16. Spills & Releases-Spill Cleanup Guidelines 56. Water-Discharge Limits and Monitoring Guidelines
17. Spills & Releases-Reserved 57. Water-Reserved
18. Spills & Releases-General Guidance 58. Water-Domestic Sewage
19. Spills & Releases-Loading and Unloading 59. Water-Hydrostatic Test Water Discharge
20. Spills & Releases-Container Handling and Storage 60. Water-Aquatic Monitoring
21. Spills & Releases-AST Design and Specifications 61. Water-Reserved
22. Spills & Releases-Facility Inspections 62. Air-Greenhouse Gas Emissions
23. Spills & Releases-Reserved 63. Air-Stack Emissions, Controls, and Monitoring
24. Spills & Releases-Spill Plans 64. Air-Ambient Air Quality Monitoring
25. Spills & Releases-Personnel Training 65. Air-Reserved
26. Spills & Releases-Spill Drills 66. Asbestos-Policy and Definitions
27. Spills & Releases-Reserved 67. Asbestos-Notice to Perform Work
28. Waste-Compliance with Local Laws & Regulations 68. Asbestos-Storage and Disposal
29. Waste-Waste Characterization 69. Asbestos-Reserved
30. Waste-Unclassified Materials 70. Storage Tank-Underground Storage Tanks
31. Waste-Used Aerosol Cans 71. Storage Tank-Aboveground Storage Tanks
32. Waste-Used Drums and Containers 72. Storage Tank-Reserved
33. Waste-Used Fluorescent Bulbs 73. PCB-Notification Guideline
34. Waste-Used Glycol and Oil Filters 74. PCB-Labeling Guideline
35. Waste-Molecular Sieves and Activated Carbon 75. PCB-Inventory Guideline
36. Waste-Used Oil 76. PCB-Storage and Inspection Guideline
37. Waste-Pesticides, Herbicides and Insecticides 77. PCB-Guideline for Disposal of PCB Waste
38. Waste-Sandblasting Materials 78. PCB-Recordkeeping and Personnel Training
39. Waste-Used Tires and Batteries 79. PCB-Reserved
40. Waste-Waste Acids and Caustics 80. Potable Water-Quality Monitoring

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Process Safety Management
Doc. # MGS-002
A Process Safety Management (PSM) program shall be developed, implemented and maintained
for all operating assets that store, transfer, use and/or process hazardous materials (i.e., gas
processing and LNG plants). The PSM program shall, at a minimum, address the following
elements.
• Employee Participation • Mechanical Integrity

• Process Safety Information • Non-routine Work Authorizations
• Process Hazard Analysis • Management of Change
• Operating Procedures and Practices • Incident Investigation
• Training • Emergency Planning and Response
• Contractors Requirements • Compliance Audits
• Pre-Startup Safety Review
U.S. sites shall follow the OSHA PSM program. European sites shall follow the appropriate
European PSM program. Other sites shall follow the OSHA PSM program and/or their
respective country PSM standard whichever is more stringent.
2. Scope
This management standard applies to all “Company” operated facilities, its employees and

Enron Corp business units shall provide the resources needed to set-up and maintain a basic PSM
program. Available resources include PSM training and process hazard analysis facilitation when
required.
4. References
4.1 U.S. OSHA PSM Web Sites
• PSM Resources – www.osha-slc.gov/SLTC/processsafetymanagement/index.html

• PSM Guidelines – www.osha-slc.gov/OshStd_data/1910_0119_APP_C.html
4.2 AICHE/CCPS, Guidelines for Implementing Process Safety Management

Systems, 1994
4.3 Appropriate European Standards

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Crisis Management
Doc. # MGS-003
All operating asset locations and commercial offices shall develop, implement and maintain
Crisis Management and Emergency Action Plans. Maintenance of the above plans shall include,
at a minimum, a desktop training exercise. Crisis Management Simulations should be conducted
every other year. Emergency Action Plan drills should be conducted annually.
2. Scope

Crisis Management and Emergency Action Plans with associated training exercises should
already exist for all operating assets and commercial offices. If not, then regional management
must direct the necessary resources to establish the plans as quickly as possible. These plans
should be reviewed and, if necessary, should be revised annually.
4. References
4.1 Enron Global Asset Operations Crisis Response Planning Manual
4.2 Enron Global Asset Operations Crisis Management Guidelines

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Issued: 20-Nov-1999
International Security
Doc. # MGS-004
All operating assets shall develop a comprehensive Security Program that addresses security for
both the personnel and the assets at each office and facility. The program shall be based on an
accurate threat analysis and on a clear understanding of legal commitments such as:
• The presence and “modus operandi” of terrorist and/or criminal attacks, whether they are
against people or property
• Political factors that could affect the facility such as actual hostility toward the facility and/or
pending relevant legislation
• A summary or extracts of the contractual agreements relevant to security responsibilities
• Information relevant to the project or asset that may influence attitudes toward the company,
facilities or office and personnel
• Potential for acts of god, earthquakes, hurricanes, etc.
The minimum security measures to be provided include:

• Facility perimeter barriers
• Access control (visitor log, ID tags, etc.)
• Security lighting
• Information security
2. Scope

Enron Corp business units shall provide the resources necessary for installation of minimum-
security measures. In addition, resources shall be provided for additional security measures
when identified through audits or when required by other security risk evaluations (refer to
Attachment 1). Corporate Security shall provide assistance in assessing security requirements
through review and/or audit of the security plan. Corporate security also has access to external
resources such as Protection of Assets by Merrit Publishing (see Attachment 1 for the Table of
Contents).
4. References
4.1 Enron Security Guidelines
4.2 Enron Global Asset Operations Crisis Management Guidelines

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International Security
Doc. # MGS-004
Attachment 1
Protection of Assets (Merritt Publishing)
Table of Contents
Vol. Topic Vol. Topic

I 1.0 Introduction III 21.0 Security and Civil Law
2.0 Vulnerability 22.0 Security & Labor Relations
3.0 Barriers 23.0 Organization & Management
4.0 Locking 24.0 Human Relations
5.0 Alarm Sensors 25.0 Ethics
6.0 Sensor Integration IV 26.0 Bombs and Bomb Threats
7.0 Communications 27.0 Alcohol & Drug Abuse Control
8.0 Identification 28.0 Dogs for Protection
9.0 Guard Operation 29.0 Security Aspects of OSHA
10.0 Disaster Control 30.0 Vandalism
II 11.0 Theft & Fraud 31.0 Detection of Deception
12.0 Data Processing 32.0 Personnel Screening with
Psychological Tests
13.0 Strikes & Labor Disturbances 33.0 Training
14.0 Parking & Traffic Control 34.0 Security Awareness
15.0 Proprietary Data 35.0 Accounting and Financial
Controls
16.0 Investigations 36.0 Aviation Facilities
17.0 Insurance 37.0 Consultants
III 18.0 Kidnapping, Extortion, & 38.0 Television in Security
Terrorism
19.0 Physical Security Planning 39.0 Security & the Disabled
20.0 Security and Criminal Law 40.0 Workplace Violence

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Quality Management System (ISO)
Doc. # MGS-005
All operating assets shall develop, implement, certify and maintain the appropriate ISO Quality
Management System (MS). The Quality MS shall address the following elements:
• Management Responsibility • Process Control

• Quality System • Inspection and Test Status
• Contract Review • Control of Nonconforming Products
• Design Control • Corrective and Preventive Action
• Document and Data Control • Inspection and Testing
• Purchasing • Control of Quality Audits
• Control of Customer Supplied Products • Training
• Product Identification and Traceability • Servicing
• Control of Inspection, Measuring and Test • Handling, Storage, Packaging,
Equipment Preservation and Delivery
• Statistical Techniques
2. Scope

Enron Corp business units shall provide the resources required for developing and implementing
an ISO Quality System for each operating asset.
4. References
4.1 Enron Global Asset Operation Quality Management Guidelines
4.2 International Organization for Standardization (ISO)

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Human Resources
Doc. # MGS-006
A human resource (HR) program shall be developed, implemented and maintained for each
country in which the Company has operating assets. The HR program shall, at a minimum,
address the following elements:
• Equal Employment Philosophy • Overtime Pay and Expense Reimbursement

• Fair Treatment • Severance Pay (Related Plan)
• Harassment Prevention • Approved Time Off and Leaves of Absence
• Employee Selection and Job Posting • Smoking
• Employment of Relatives or Household • Relocation
Members
• Performance Management • Workplace Violence Prevention
• Educational Assistance • Probation
• Corrective Discipline • Benefits
• Work Hours, Holidays and Vacations • Termination and Resignation
2. Scope

Enron Corp business units shall provide the resources needed to set-up and maintain a basic
human resource program. Resources that address additional elements will need to be justified
with regional management. The Human Resource Department is prepared to help the operating
asset in developing the HR program through review of new, existing or enhanced plans. HR
personnel are also willing to participate in local and/or corporate audits.
4. References
4.1 Enron Human Resources Guidelines
4.2 Enron Corp Code of Conduct
4.3 United States Foreign Corrupt Practices Act

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Issued: 20-Nov-1999
Administrative
Doc. # MGS-007
1. Management Standards
All operating assets shall develop, implement, and maintain country specific Administrative
Procedures where operating assets are located. The Administrative Procedures shall cover, at
minimum, the following areas:
• Facility Organization Structure and Contact List

• Accounting
• Purchasing
• Inventory Control
Administrative guidelines are available for each of the above areas.
2. Scope

Enron Corp business units shall provide the resources required for developing and implementing
a country specific administrative program where operating assets are located.
4. References
4.1 Enron Global Asset Operations Administrative Guidelines

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Third-Party Management
Doc. # MGS-008
All operating asset locations shall ensure that all contractors and other third parties engaged in
operations by the Company are held accountable for and have both the resources and information
needed to conduct their activities in accordance with Management Standards and associated
guidelines.
2. Scope

Local operations management will assess third party capability for meeting the Company’s
operating standards and will direct third parties to take actions needed to ensure that they
consistently comply with these standards.
4. References
4.1 Enron Global Asset Operations Management Standards
4.2 Enron Global Asset Operations Operating Guidelines
4.3 Enron Corp Code of Conduct
4.4 United States Foreign Corrupt Practices Act

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Maintenance
Doc. # MGS-009
All operating asset locations shall develop, implement and update maintenance systems and
programs consistent with the asset size, complexity, utilization and workforce capabilities. The
following components will be considered:
• Equipment Criticality Analysis and Ranking
• Work Order System
• Work Prioritization System
• Work Planning & Scheduling Processes
• Predictive Maintenance Program
• Preventive Maintenance Program
• Corrective Maintenance Procedures
• Maintenance History Capture and Review
• Computerized Maintenance Management System
• Spare Parts/Inventory Management System
2. Scope

Local management should periodically review maintenance systems and results to identify
necessary improvements. Audit of these systems will be performed by Global Asset Operations
on a two-year schedule. Enron Corp business units shall provide the resources for developing,
implementing and maintaining maintenance systems commensurate with specific asset
requirements.
4. References
4.1 Enron Global Asset Operations Maintenance Guidelines

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Issued: 20-Nov-1999
Operations
Doc. # MGS-010
All operating assets shall develop, implement and maintain systems and programs to ensure
operations consistent with Enron’s Operating Philosophy and Management Standards, legal and
regulatory requirements and local requirements. At a minimum, the following components must
be addressed:
• Reporting for Safety-Related Conditions
• Reporting for Environmental Conditions
• Reporting for Incidents and Emergencies
• Corrosion Control Systems
• Operating Procedures for Routine Operations
• Operating Procedures for Nonroutine Operations
• Management Reporting
• Incident Investigation (Lessons Learned)
• Record Keeping and Retention
• Procedure Review System
• Material Balance and Measurement Systems
• Operating Monitoring and Control Systems
2. Scope

Local management should periodically review operations systems and performance results to
identify necessary improvements. Audit of these systems shall be performed by Global Asset
Operations on a two-year schedule. Enron Corp business units shall provide the necessary
resources for developing, implementing and maintaining these systems commensurate with
specific asset requirements.
4. References

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Issued: 20-Nov-1999
“Positive Impact” Program
Doc. # MGS-011
Global Asset Operations has developed and implemented and supports a “Positive Impact”
(Continuous Improvement) Program for those assets operated by Enron. The “Positive Impact”
program encompasses knowledge-based management using validated knowledge and experience
from operations and maintenance activities. The program does not grade success or failure but
instead focuses on weaknesses to improve and strengths to sustain. Personnel from all operating
assets actively participate in and sustain the process. Asset Operations with the assistance from
Global Development and Learning, provides training and oversight of the program to ensure the
longevity.
The “Positive Impact” (Continuous Improvement) Program is an internal, “learning from

experience” program that collects, analyzes and disseminates information from experiences into
lessons learned. The process is a self-discovery initiative that in the end state results in shared
knowledge, organizational learning, organizational change, improved performance and profit
improvement. It is designed to allow the operating facility team to evaluate projects using a
“critical path approach” to determine the successfulness of the project and the potential for
improvements. The results will generate “best practices” that will be shared across all assets.
2. Scope

Enron Corp business units shall provide the resource required to build and maintain a “Positive
Impact” (Continuous Improvement) Program. The program will build on existing
programs/information systems, such as the Intranet and the auditing process, to actively
disseminate best practices and achieve continuous improvement.
4. References
4.1 Management Standards and Guideline Auditing (MGS-012)

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Issued: 20-Nov-1999
Management Standards and Guideline Auditing
Doc. # MGS-012
Global Asset Operations shall audit against the following management standards along with
related guidelines for each Company operated asset.
• Environmental, Health and Safety • Administrative

• Process Safety Management • Third-Party Management
• Crisis Management • Maintenance
• International Security • Operations
• Quality Management System • “Positive Impact” Program
• Human Resources
The audit program shall follow a two-year cycle and shall be quantitative as well as qualitative
so that the results can be considered in:
• Identification of improvements and corrective actions

• Assessment of operating risk and asset performance
• Performance management feedback process to operating management
• Identify and disseminate “best practices”
2. Scope

Global Asset Operations is responsible for developing, executing and maintaining the audit
program. Local management is responsible for providing necessary resources and information to
support the audits and for managing corrective actions to completion.
4. References
4.1 Enron Global Asset Operations Audit Protocol
4.3 Enron Global Asset Operations Philosophy

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Issued: 20 Nov-1999
Statement of Enron Corp Environmental Health and
Safety Principles Doc. # ENV-001
It is Enron’s policy to conduct its business worldwide in compliance with all applicable environmental,
health and safety laws and regulations and to apply responsible standards where such laws do not exist.
These laws, regulations and standards are designed to safeguard the environment, human health, wildlife
and natural resources. Our commitment to observe them faithfully is an integral part of our business and
our values.
At Enron, we shall:
• Make environmental, health and safety considerations a priority in our business planning and in the
design and implementation of our projects.
• Participate with concerned agencies and groups in the continued development of appropriately
balanced environmental laws and regulations.
• Manage our business with the objectives of providing a healthful and safe workplace for our
employees, preventing accidents and environmental incidents and controlling emissions and wastes
to below harmful levels.
• Be prepared to respond timely and appropriately to incidents resulting from our operations.
• Encourage the sensible development of the world’s energy resources.
• Encourage respect and concern for the environment and emphasize to our employees each
individual’s responsibility in environmental performance through appropriate communications and
training.
• Strive continuously to enhance our environmental, health and safety performance through
appropriate means and programs.

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Issued: 20-Nov-1999
Environmental Guideline
Doc. # ENV-002
1. Purpose
This guideline establishes the requirements to be followed for providing a general outline for the
cleanup of spills and releases.
2. Scope
This guideline applies to all “Company” operated facilities, its employees and its contractors
except where superseded by more stringent local standards.
3. Guideline
3.1 General
Depending on the nature of the spill, removal (remediation) of contaminated materials
(soils, etc.) may require a detailed plan, environmental monitoring and/or oversight from
an experienced professional. Operating Company Managers are encouraged to consult
with an environmental professional for additional guidance regarding the cleanup of
specific materials.
3.2 Considerations
The development, maintenance and distribution of the Enron EHS Policy and the EHS
Guidelines shall be the responsibility of the GAO EHS Department. The GAO EHS
Department Head shall approve the Company Environmental Guidelines. These
guidelines shall be periodically reviewed to reflect changes in Enron’s EHS Policy, EHS
Management Standards and Best Management Practices. The GAO EHS Department
Head shall approve all revisions.
Copies of the Company Environmental Guidelines will be made available electronically
and by hard copy.
The Company shall conduct audits to determine if Operating Company environmental
management systems, procedures and operational controls meet the expectations
contained in the Environmental Guidelines.
3.3 Expectations/Requirements
Environmental Management System
Operating companies shall develop site-specific environmental management systems,
procedures and operational controls that achieve the expectations stated in these
guidelines. In most instances, the environmental management system will be integrated
with the health and safety management system.
Operating companies shall also consult other international environmental standards such
as the environmental criteria contained in the World Bank Environmental Guidelines,
World Bank Environmental Impact Assessment requirements and local laws and
regulations.
Procedures Manual
Projects shall develop environmental management system requirements in the early
stages of development. In particular, a site-specific Procedures Manual including
environmental requirements and procedures shall be prepared by Operating Company
personnel with assistance from the GAO EHS Department (Houston) no later than two
months prior to commercial operation (and within six months after acquisition or
merger). Further requirements for development of the site-specific Procedures Manual
are as follows:

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Issued: 20-Nov-1999
Environmental Guideline
Doc. # ENV-002
3.3 Expectations/Requirements (Continued)

• The Regional Management and the Operating Company Manager are responsible for
finalizing and approving all operating procedures prior to distribution. The
procedures document shall include a complete distribution list.
• The Operating Company Manager shall be responsible for ensuring that procedures
are implemented for all operations under his or her management.
• The procedures will be subject to internal audits as required by the Company
environmental management system.
• The procedures shall be periodically reviewed to reflect changes in legal
requirements, audit findings and reviews of incidents and drills.
• Revisions shall be promptly distributed to designated copy holders.
3.4 Records
Procedures shall be subject to a simple document control system to ensure that current
copies are always readily accessible and that obsolete copies are not mistakenly used.

Revision: 0
Issued: 20-Nov-1999
Personnel and Designation of Environmental
Responsibilities Doc. # ENV-003
1. Purpose
This guideline establishes the requirements to be followed for environmental management
systems to designate personnel for all management and operational activities that affect
environmental performance.
2. Scope
3. Guideline
3.1 General
Operating Company environmental management systems, programs and procedures shall
provide a list of environmental responsibilities and designate the title of the responsible
individual(s).
3.2 Considerations
The essential items necessary to develop and implement an effective environmental
program are as follows:
• Environmental Management System
• Environmental policy fevelopment and implementation
• Identifyication of environmental issues, risks and impacts
• Tracking and communicating legal requirements
• Preparing permit applications
• Developing environmental plans, programs (including waste minimization) and
budgets
• Designation of environmental responsibilities
• Establishment of training requirements and management of training programs
• Communicating Company requirements to personnel and external groups
• Reporting to regulatory agencies
• Maintaining controlled documents
• Checking operational controls
• Maintaining emergency plans including drills
• Ensuring that monitoring programs are established
• Checking recordkeeping systems
• EMS auditing and review with management
Essential items necessary to effectively develop and implement proper procedures for
each of the following areas of concern are as follows:
Air Quality
• Operation and maintenance of Continuous Emissions Monitoring (CEM) systems
• Coordination and review of relative accuracy test audits of CEM systems
• Operation of combustion equipment in accordance with permit requirements
• Coordination and review of stack tests for compliance purposes

Revision: 0
Issued: 20-Nov-1999
Personnel and Designation of Environmental
Responsibilities Doc. # ENV-003
• Ambient air monitoring program management and interpretation of reports

• Determination of Greenhouse Gas Emissions and entry into database
• Conducting training on air permit and emissions compliance
Drinking (Potable) Water Management

• Procurement of drinking water from supplier
• Sampling and analyzing facility-supplied drinking water
• Determining whether facility water meets drinking water standards
Fuel Management
• Sampling and analysis of fuel
• Determining compliance with fuel specification
• Truck unloading area management
Housekeeping
• Keeping grounds clean and free of trash and debris
Spills and Releases of Toxic Substances

• Procurement of spill response and cleanup materials
• Maintenance of spill equipment inventory list
• Ensuring mechanical integrity and performing maintenance of spill equipment
• Performing weekly AST and secondary containment area inspections
• Conducting Spill Prevention and Response Training
• Maintaining emergency notification contacts (internal and external)
• Authorization of third-party response
• Conducting emergency drills
Waste Management
• Conducting storage area inspections
• Proper labeling and storage of drums
• Arranging for transportation and disposal services
• Conducting audits of third party disposal services
• Approval of third party services
• Sampling and analyzing wastes
• Classifying wastes
• Tracking and data entry of waste generated/disposed/recycled into database
Wastewater Management
• Sampling and analyzing effluent
• Determining compliance with Environmental Guideline ENV-056, Discharge Limits
and Monitoring

Revision: 0
Issued: 20-Nov-1999
Definitions
Doc. # ENV-004
1. Purpose
This guideline establishes the requirement to be followed for establishment of the use of
common definitions and clearly communicated acronyms that enable personnel to communicate
clearly and succinctly.
2. Scope
3. Guideline
3.1 General
Many terms are used as part of environmental management. Clearly understood
definitions are essential for assisting environmental communications. As used in the
following guidelines, certain words shall have limited meanings but shall have the same
meaning wherever they appear.
3.2 Considerations
Definitions
General Procedure is a procedure that is applicable to the entire facility.
May/Might indicates a suggested or permissible action that, if taken, will be acceptable
but which is possibly only one of several acceptable actions available to the line
organization in satisfying a given requirement or recommendation.
Pollutant is any substance or groups of substances whose release to the environment may
create an environmental detriment.
Noncompliance Incident is the actual or suspected release or discharge of a pollutant to
the environment in an amount or concentration that violates one of the discharge
limitations or general protection guidelines contained within the Company’s legal
requirements. This definition also includes the failure to comply with all permit
requirements including procedural requirements.
Procedure Effective Date is the date on which a procedure was implemented.
Must/Will, when used in a procedure, indicate a requirement that is mandatory. These
statements are usually written in terms of the final result to be achieved and are a direct
reflection of either a legal requirement or a specific company policy. Failure to comply
with such a procedural requirement will therefore result in a noncompliance condition.
Shall/Should, when used in a procedure, indicate a recommendation that is to be
followed unless there is an alternative action that will provide the same end result.
Generally, a "shall/should" statement is written in support of a mandatory requirement
(must/will statement) and offers a proven means of satisfying that requirement.
Specific Procedure is a procedure specific to a particular facility but having the same
importance as a general procedure.

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-005
THIS PAGE IS RESERVED FOR A NEW GUIDELINE AT A LATER DATE

Revision: 0
Issued: 20-Nov-1999
Facilities Inspections
Doc. # ENV-006
1. Purpose
This guideline establishes the requirements for the implementation of common procedures
and practices to be followed during the inspection of facilities by governmental and
regulatory agencies and/or financial institutions seeking to lawfully enforce legal
requirements.
2. Scope
3. Guideline
3.1 General
Company facility personnel shall follow Company guidelines for facility inspections
in order to ensure cooperation with governmental agencies and/or financial
institutions seeking to lawfully enforce national or local laws or regulations or
environmental, health and safety requirements that apply to the facility.
3.2 Considerations
The following guideline is provided to facilitate cooperation and communication
between the facility and the agency while ensuring that such visits are carried out
according to the Company’s requirements.
The Operating Company Manager shall be made aware of agency inspections.
Individuals who are notified of a forthcoming agency inspection shall immediately
notify the Operating Company Manager.
The Operating Company Manager shall appoint a representative to coordinate all
activities concerned with the agency visit. The appointed representative is
responsible for handling all aspects of the agency visit from initial coordination to
completion of the facility’s inspection report and response to follow-up items.
Occasionally, the Operating Company Manager may assume that role.
Requirements for Agency Visits

Company requirements for an agency visit shall include the following:
• There shall be no tape recordings of employee conversations.
• Photocopies of documents should be provided only after consultation with
appropriate Company and facility personnel, including legal staff.
• Photographs shall be taken at the discretion of the Operating Company Manager.
• Samples taken should be split and all sampling procedures should be
documented.
NOTE: Operating Company personnel should not disclose any prior studies of
the problem subject to inspection. Operating Company personnel should never
give false or misleading information to an inspector.
• Prior to the visit, the appointed representative shall clarify the purpose of the
inspection visit with the agency, as follows:

Revision: 0
Issued: 20-Nov-1999
Doc. # ENV-006

a. Communicate with the agency and with the actual inspector who is planning
to visit.
b. Request a clear statement of purpose (i.e., alleged non-compliance routine,
etc.).
c. Ask the inspector for a list of questions or problems that he/she will be
reviewing during the inspection.
• Obtain a list of documents the inspector wants to review and/or to photocopy.
• Obtain security clearance and inform reception about the visit. It is important
that the security guard and reception know precisely what to do when an
inspector arrives. Generally, this simply means having the security guard and/or
receptionist know to immediately contact the representative when the inspector
arrives.
Inspections
Inspections shall be conducted as follows:
Opening Conference: The formal part of the inspection begins with an opening
conference. This should be conducted in an office or conference room. This
conference sets the tone for the whole inspection and should be considered very
important. During the opening conference, the following should take place:
• Verify that the inspector is a true agency representative by requesting to see an
official identification card. If needed, confirm authorizations through the
agency’s office. Document all names and agencies present.
• Obtain information about the qualifications and experience of the inspector so
that appropriate information and explanations can be provided during the
inspection.
• Establish and document the purpose of the visit. If the inspection follows a
complaint, ask the inspector to provide a copy of the complaint (with the
complainant’s name concealed).
• Inform the inspector about the Company’s requirements concerning tape
recording, photocopies and the presence of Operating Company personnel during
the inspection.
• Establish an agenda and document who and what the inspector needs to see.
Photographs during the Inspection: The inspector may desire to take photographs.
If so, the representative should follow the following minimum precautions:
• Request duplicates or negatives of any photographs taken.
• Take photographs from a duplicate camera including photographs from both the
same angle and distance as well as from a different angle to demonstrate
differences in perception.
• Discuss the photographed areas or equipment with the inspector in order to
clarify the reason those areas or equipment were being photographed. Make
notes regarding what was photographed and why.
• Obtain acknowledgment from the inspector that notes describing the reasons for
the photos are accurate.
• Make notes about any unusual circumstances or weather conditions that may
negatively impact the visual interpretation of the photographs.

Revision: 0
Issued: 20-Nov-1999
Doc. # ENV-006
Sampling: Inspectors are authorized to take samples; however, the following

guidelines should be observed:
• Document all records concerning the sampling procedures. Record the number
of samples taken and the sampling methodology as well as the location, time and
date they were taken.
• Carefully observe the sampling technique used by the inspector and note any
improper techniques or procedures. Ask the inspector to acknowledge these
records.
• Take split samples with the inspector or take a duplicate sample using sampling
equipment at the same time(s) and place(s) as the inspector. Have the samples
analyzed for the same parameters.
• Provide the test results to the Operating Company Manager.
Remedy Easy Problems: An inspector may point out obvious minor problems that
can be corrected immediately, which may include the following:
• Minor housekeeping problems
• Minor valve adjustments
• Recalibration of monitoring equipment
The representative should show evidence of good faith by immediately responding to
these minor problems. Any responses by the representative to such problems should
be recorded.
Closing Conference: The closing conference provides an opportunity to obtain the

initial conclusions of the inspector and to correct any misunderstanding about the
facility’s operations. The representative should encourage the inspector to provide as
much feedback as possible by requesting a verbal summary of the inspection
including the inspector’s initial conclusions and probable follow-up actions.
3.4 Records
Inspection Report to the Operating Company Manager

The representative should prepare a report to the Operating Company Manager
within three days of the inspection that includes the following information:
• Information regarding the inspector including name, title, agency, address, phone
number,qualifications and experience
• Reasons for the inspection
• A record of the inspection including the opening and closing meetings and
information (including conversations, photocopies, documents, photographs and
samples) taken by the inspector.
• Commentary, conclusions and potential follow-up action indicated by the
inspector with particular emphasis on commentary about potential problems and
alleged violations.
• Any other important points such as the general approach of the inspector and/or
any relevant incidents that occurred during the visit.

Revision: 0
Issued: 20-Nov-1999
Agency Communications
Doc. # ENV-007
1. Purpose
This guideline establishes the requirements to be followed for communication with governmental
and regulatory agencies and/or financial institutions.
2. Scope
3. Guideline
3.1 General
Following the Company’s environmental guideline ENV-007 “Agency Communications”
should ensure that Operating Company personnel shall communicate clearly with
governmental agencies and/or financial institutions.
3.2 Considerations
The following guideline is provided to facilitate cooperation and communication between
the Operating Company and the agency while ensuring that the Operating Company’s
legal obligations are respected.
The Operating Company Manager should be made aware of all agency communications,
as follows:
• All written correspondence and telephone calls to the plant from environmental
regulatory agencies and/or environmental representatives from financial institutions
should be directed to the Operating Company Manager or his designee.
• All telephone calls to environmental regulatory agencies and/or environmental
representatives from financial institutions from the plant other than for initial
noncompliance notifications should be made only by the Operating Company
Manager or his designee and shall be logged and documented.
• All written correspondence to environmental agencies dealing with COMPLIANCE
ISSUES such as permit applications and written followups on noncompliance
situations must be reviewed and signed by the Operating Company Manager or his
designee prior to submittal.
3.4 Records
Site environmental management procedures should contain specific guidance on copying
and maintaining records of the following types of agency related correspondence:
• Notification of any activity by regulatory officials to initiate enforcement in the
environmental area (notices of noncompliance)
• Inspection summaries
• Reports to regulatory agencies including but not limited to Quarterly Pollution
Reports, Spill Reports, Environmental Monitoring Reports and Permit Applications

Revision: 0
Issued: 20-Nov-1999
Agency Communications
Doc. # ENV-007
4. Reference
4.1 Internal and External Reporting Standards
Refer to the following Administration Guidelines for specific information regarding
internal reporting requirements:
• ADM-001, Incident Reporting Requirements (External)
• ADM-002, Operations and Maintenance Plans
• ADM-003, Investigations of Accidents and Failures
• ADM-004, Reporting of Safety Related Conditions
• ADM-005, Property Damage to Company Facilities
• ADM-006, Property Losses - Fraud and Theft

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-008

Revision: 0
Issued: 20-Nov-1999
Community Relations and Communications
Doc. # ENV-009
1. Purpose
This guideline establishes the expectations for operating plant programs and procedures for
community relations and communications.
2. Scope
3. Guideline
3.1 General
Community relations involve the interaction of the Operating Company Manager or
designated staff with members or representatives of local communities and interest
groups concerning the facility operations environmental risks and impacts.
Community consultations should address both positive environmental issues as well as
adverse situations such as emergencies and citizen complaints.
3.2 Considerations
Direct, regular contact with the local community is encouraged in order to communicate
facility environmental issues and performance including anticipated abnormal operating
conditions that may result in unusual conditions or environmental impacts. Examples of
events that should lead to communication initiatives are increased traffic, intermittent
noise (steam vents), responses to complaints or requests for information, permit renewals
or unplanned activities that may have impacted the local community.
The following should be considered when developing site-specific environmental
procedures for community relations and communications:
Complaints
Complaints shall be referred to the Operating Company Manager and should be
responded to promptly. If a more thorough investigation is required and a delay is
anticipated, inform the party that additional time will be needed and provide updates as
necessary.
Depending on the nature of the complaint, additional assistance such as legal staff, media
relations, etc. may be sought from Asset Management (Houston).
Information Requests
It is common for local citizens and interest groups to occasionally request information
from industrial facilities regarding the environmental issues and risks associated with the
facility including requests for Material Safety Data Sheets, data reports on effluent
quality and emissions and general information regarding the environmental impact of the
facility. The Operating Company Manager or his designee should honor such requests in
a timely manner and provide additional information as appropriate.
Crisis Communication
It is the Company's policy to interact with local, state and national emergency response
agencies; the news media; other key audiences and the general public in a way that
promotes cooperation, efficient coordination of response efforts and effective
communication during a crisis.
The facility's Crisis Response Plan should be consulted for instructions regarding
community communications during or following a crisis.

Revision: 0
Issued: 20-Nov-1999
Community Relations and Communications
Doc. # ENV-009

Media Relations
Regular interaction with the local media is important in maintaining critical relationships
and is an effective communication tool for public relations. The local commercial office
will coordinate media relations for facilities with the assistance of Company's Public
Relations Team (Houston).
3.4 Records
Keep a record of all complaints and responses including the following information:
• Name of the person filing the complaint
• Date the complaint was received
• Nature of the complaint
• Date of followup and response provided
• Names of other Company personnel contacted or copied on correspondence
• Corrective actions taken, if any

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-010

Revision: 0
Issued: 20-Nov-1999
Guideline for Environmental Records
Doc. # ENV-011
1. Purpose
This guideline establishes the requirements for providing a common filing structure for
organizing environmental records that may be required to demonstrate compliance with the
Company’s environmental management expectations and with legal requirements.
2. Scope
3. Guideline
3.1 General
An environmental recordkeeping system is needed to monitor performance and verify
that environmental management system expectations are being met.
3.2 Records
Recordkeeping systems should be established for the following subjects that include the
items listed.
Aboveground Storage Tanks
• Inspections
Air Quality
• Permits, Licenses and Authorizations
• Emissions Tests (by year)
• Emissions Inventory (by year)
• Continuous Emissions Monitoring Data, Certification Gases
• Relative Accuracy Test Audits (by year)
• Excess Emissions Reports (by quarter, year)
• Fuel Sulfur and Nitrogen Monitoring
• Custom Fuel Monitoring Schedule
• Emission Fees
• Ambient Air Quality Monitoring Reports (by year)
• Agency Correspondence
Asbestos Management
• Asbestos Inventory
• Asbestos Notification
• Asbestos Plan
Drinking Water
• Quality Test Reports (by year)
• Operator Certifications (by year)
PCB Management
• PCB (Polychlorinated Byphenelysis) Inventory
• Transportation and Disposal Records (by year)

Revision: 0
Issued: 20-Nov-1999
Guideline for Environmental Records
Doc. # ENV-011
3.2 Records (Continued)
Radioactive Materials
• NORM (Normally Occuring Radioactive Materials) Inventory
Spills and Releases
• Spill Plan
• Spill Report Forms
• Spill Response Contracts or Cooperative Agreements
• Spill Response Training and Drills
• Cleanup and Disposal Records
Training
• Training Records
• Contractor Orientation Forms
• Contractor Orientation Records
Waste Management
• Permits, Licenses and Authorizations
• Waste Generation Inventories (by year)
• Disposal Facility Audits/Information
• Transporter Information
• Analyses (by waste type)
• Weekly Inspections (by year)
• Landfarm Permit, License and Authorizations
• Disposal Records, Manifests, etc
Wastewater Management
• Discharge Permits, Licenses and Authorizations
• Effluent Quality Reports (by source or parameter)
• Hydrostatic Water Permits, Licenses and Authorizations
• Stormwater Pollution Prevention Plan

Revision: 0
Issued: 20-Nov-1999
Monthly Reports
Doc. # ENV-012
1. Purpose
This guideline establishes the requirements for the generation and distribution of Environmental,
Health and Safety (EHS) monthly reports.
2. Scope
3. Guideline
3.1 General
The Managing Director of the Asset Management requires an EHS Monthly Report from
all direct reports having operational oversight of assets owned and managed by Enron
International. The format for the EHS Monthly Report is an electronic Excel Workbook
that is filled out at the facility. The workbook is used to electronically post the data that
creates a file that the facility e-mails to Houston, Texas, where the report will be imported
into a database.

Revision: 0
Issued: 20-Nov-1999
Annual EHS Report
Doc. # ENV-013
1. Purpose
This guideline establishes the requirements to be followed for the issuance of an EHS Annual
Report.
2. Scope
This guideline applies to all Company operated facilities, it employees and its contractors except
where superceded by more stringent local standards.
3. Guideline
3.1 General
Beginning in 1999, Enron will issue an EHS Annual Report. Through the Enron EHS
Council, a task force has been assembled to select performance measures that will be
included in the Annual Report.
3.2 Considerations
Enron’s annual environmental report to the public contains information that operating
plants will need to contribute and the ways in which operating facilities may use this
annual report in communicating with external groups.
Providing Information to Enron
Each Operating Company and Regional Management Team shall report EHS
performance in accordance with Enron's expectations.
Uses of the Annual Report
Proper uses for the “Annual Report” are as follows:
• Reply to EHS Performance Questionnaires from Investor Relations
• Reply to EHS Performance Inquiries from environmental interest groups
• Address Qualification Packages
• Inform the Enron Board of Directors of Enron's EHS performance
• Proper use of referenced Internal and External Standards
NOTE: EHS Performance Measures will be developed in the future and will be provided
as part of these guidelines.

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-014

Revision: 0
Issued: 20-Nov-1999
Implementation of Emergency Response Guidelines
Spill Response Actions Doc. # ENV-015
1. Purpose
This guideline establishes the requirements to be followed to guide Operations personnel in the
implementation of appropriate response and notification procedures in case of a spill. This
guideline shall also establish responsibilities for the effective management of spill and release
emergencies.
2. Scope
3. Guideline
3.1 General
This is not intended to be a stand-alone document. It should supplement local
Emergency Action Plans for spills and releases and local Crisis Response Plans.
In the event of a spill, responsible parties shall take appropriate actions as follows:
Operating Personnel shall evaluate the hazards of the situation before proceeding and
ensure that all responding personnel have received appropriate safety training and
personal protection equipment. The Supervisor shall be contacted if proceeding would
endanger personnel. If not, the following steps shall be followed:
• Stop the source of the spill as soon as possible by turning off valves, pumps or
affected equipment and uprighting containers or plugging holes.
• Confine the spill to the immediate area and prevent it from entering any uncontrolled
drainage system or waterway.
• Restrict access or barricade the area to keep unnecessary personnel isolated from the
contaminated area.
• Initiate spill cleanup per Guideline ENV-016, Spill Cleanup Guideline.
• Notify the shift supervisor.
The Shift Supervisor shall determine the extent of the spill and make appropriate internal
notifications as follows:
• Notify the Operating Company Manager and the GAO EHS Manager (Houston)
immediately of any off-site spill, any spill that enters a waterway or any on-site spill
that may have exposed an employee to a hazardous condition.
• Follow the Notification Guidelines in the Crisis Response Plan for all other spills.
Additional responsibilities of the Shift Supervisor in responding to spills are as follows:
• Refer to company-specific notification guidelines for external notifications. (Refer
to Administration Guideline ADM-001, Incident Reporting Requirements (External).
• Initiate spill containment and cleanup activities utilizing internal or external services,
as needed.
• Request professional spill response contractor services as necessary upon appropriate
management approval. A list of approved contractors may be found in the Emergency
Action Plan, Crisis Response Plan or list of emergency numbers.
• Appoint an individual (or individuals) to track the type, quantity and cost of resources
used to contain and clean up the spill; names of personnel involved in cleanup, hours
worked and an estimate of the quantity of material recovered.

Revision: 0
Issued: 20-Nov-1999
Spill Response Actions Doc. # ENV-015

• Verify the following information on a Spill Report Form:
a. Time of spill
b. Material spilled
c. Cause of the spill
d. Estimated quantity of the spill
e. Location of the spill
f. Personnel injuries (if any)
The Company Manager or Designee shall submit a Spill Report to pertinent
management including environmental management or support services within three (3)
days following the spill event that encompasses the above information. Additional
responsibilities shall include the following:
• Retain a copy of the report and related documentation (i.e., disposal records,
contractor invoices, etc.) on-site in plant environmental files for three (3) years.
• Follow up with appropriate authorities as requested or required as soon as possible.
• Request additional assistance from environmental management or support services as
needed.
• Ensure that leaky or faulty equipment is repaired and replenish spill equipment
supplies as needed.
The Regional EHS Manager or Designee, if warranted, shall conduct a follow-up audit
to develop safeguards to prevent a recurrence. Ensure that Oil Discharge Contingency
Plans, Spill Prevention Containment and Countermeasures Plans, Emergency Response
Plans and Crisis Response Plans are revised as necessary.

Revision: 0
Issued: 20-Nov-1999
Spill Cleanup Guidelines Doc. # ENV-016
1. Purpose
This guideline establishes the requirements to be followed for providing general guidance for the
cleanup of spills and releases.
2. Scope
3. Guideline
3.1 General
The Operating Company is responsible for identifying potential spill events and
preparing plans to mitigate these accordingly. Such plans may include but are not limited
to the following:
• Procurement of containment equipment (booms, pumps, etc.)
• Formation of spill response teams and assignment of specific responsibilities
• Conducting routine mock drills
• Providing routine training for personnel commensurate with their responsibilities in
such an event
3.2 Considerations
Depending on the nature of the spill, removal of contaminated materials (soils, etc.) may
require a detailed plan, environmental monitoring and/or oversight from an experienced
professional. Operating Company Managers are encouraged to consult with an
environmental professional for additional guidance regarding the cleanup of specific
materials.
In the event of a spill, determine the nature and extent of the spill or release using
Guideline ENV-015, Spill Response Actions. Before proceeding, ensure that all response
personnel have received appropriate safety training and are wearing appropriate personal
protection equipment. Stop or reroute operations of the affected equipment. Stop pumps
and close valves.
Notification
Contact with external agencies, the public and senior management should be routed
through the Operating Company Manager. The following entities shall be contacted:
• Notify the appropriate agencies or officials (Coast Guard, environmental agency or
ministry, etc.) and Enron management as outlined in the Emergency Action Plan or
Crisis Response Plan.
• The Manager of Environmental, Health and Safety (GAO Houston) shall be notified
immediately of any spill or release that has the potential to impact the health of the
public or employees (including contractors) off site.
• Local residents and/or members of the community (i.e., mayor, council, etc.) shall be
notified, as necessary.

Revision: 0
Issued: 20-Nov-1999
Spill Cleanup Guidelines Doc. # ENV-016

Spill Containment
Contain the spill as follows:
• Within a secondary containment structure, ensure that secondary containment valves
are in the closed position.
• On land, construct terrace dams or ditches and/or scatter absorbents, sand or hay to
absorb the spill.
• On concrete or metal work surfaces, scatter absorbents, sand or hay to absorb the
spill. If feasible, hydrocarbon spills may be routed to an oily water separator or
sump.
• On water, surround the affected area with containment booms. Sensitive areas
(beaches, estuaries, mangroves, etc.) and/or other structures (rocky tide breakers,
erosion barriers, piers, etc.) may require additional protection.
• In a public or shared ditch or trench, block drainage systems, sewer connections,
and overflow devices with covers if not equipped with mechanical valves.
Spill Cleanup
Conduct spill cleanup as necessary and/or as directed by the Operating Company
Manager or designee. Recover and collect the spilled material as follows:
• From a Secondary Containment Structure: If the secondary containment structure is
connected by a drain or valve to an oily water separator system (for fuel oil) or
neutralization tank (for acids/caustics) or sump, the material may be drained directly
to the separator or neutralization tank. However, consideration should be given to the
type of material and treatment rate (capacity) of the system. If the secondary
containment structure is not connected to a separator system or neutralization tank,
the spilled material may be pumped to approved drums or other storage vessels for
treatment or reuse. Never mix incompatible materials or activate drainage valves if
unfamiliar with drainage systems.
• From Land, Concrete and Metal Work Surfaces, remove soaked dirt, sand, hay or
other sorbents with nonspark shovels and other tools as appropriate. Collect
contaminated materials in approved drums or place materials in an approved
landform.
• From Water, use skimmers, pumps or sorbents to recover the spilled material and
store recovered material in approved drums or other storage vessels such as
temporary holding tanks.
Request the services of a spill response contractor, if necessary. A list of qualified
contractors is available in the Emergency Action Plan or Crisis Response Plan. Contact
the environmental professional in the Emergency Action Plan and/or Crisis Management
Plan for assistance.
Disposal of Contaminated Material
Arrange for disposal or treatment of contaminated material by an approved method
and/or contractor. Seek assistance from an environmental professional as needed. (See
Guideline ENV-051, Selecting Transportation and Disposal Services, for additional
information.)
Seal and label the drum or storage vessel with the name of the contaminated material
(i.e., Oil-Contaminated Sand) and the date.
Transfer storage containers to the designated waste storage area.

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-017

Revision: 0
Issued: 20-Nov-1999
Spill Prevention
General Guidance Doc. # ENV-018
1. Purpose
This guideline establishes the requirements for the use of good work practices to ensure that
reasonable measures are taken to prevent spills of hazardous materials.
2. Scope
3. Guideline
3.1 General
Personnel are responsible for following good work practices to ensure that reasonable
measures are taken to prevent spills of hazardous materials including but not limited to
oils, fuses and hazardous wastes.
The Operating Company Manager or his designee is responsible for implementing the
following spill prevention measures:
• Unloading or loading of regulated and hazardous substances must be monitored for
leaks, spills and proper hose connections or disconnections.
• All fuel lines including hard pipes and flexible hoses must be on a regular
preventative maintenance program for the detection of structural weaknesses and
defects that could cause a leak.
• Routine visible inspections of aboveground piping or the implementation of an
inventory control process for unaccountable fuel shall be considered part of a
preventative maintenance program.
• Required repairs or replacement shall occur in a timely manner and shall be
documented in the preventative maintenance program.
• Container storage buildings and secondary containment systems including the
immediate area around such structures must be kept clean and free of trash, junk and
debris.
• All storage containers must be kept securely closed except when adding or removing
contents.
• Funnels must be removed from containers or covered when not in use.
• The valves for all dike and sump drains must always be closed except during drainage
periods. Before releasing accumulated precipitation, inspect for any visible sheen or
other signs of contamination. If any sheen is detected, it must be removed prior to
discharge.
• Oily water separator effluent, if applicable, should be analyzed for oil and grease
prior to discharge in accordance with Environmental Guideline ENV-056 “Discharge
Limits and Monitoring Guidelines”.
• Equipment leaks shall be repaired as soon as possible.
• Material handling practices should be in accordance with those guidelines identified
in Environmental Guideline ENV-019, “Loading and Unloading”.
3.3 Records
An environmental inspection should be completed weekly in accordance with
Environmental Guideline ENV-011, “Guideline for Environmental Records” for
designated areas and shall be retained on site in environmental files for three (3) years.

Revision: 0
Issued: 20-Nov-1999
Spill Prevention
Loading and Unloading Operations Doc. # ENV-019
1. Purpose
This guideline establishes the requirements for providing guidance in recognizing and preventing
hazardous releases during loading and unloading operations.
2. Scope
3. Guideline and Expectations

3.1 General
Loading and unloading of hazardous substances (lubricating oils, used oil, fuel, etc.) shall
be conducted in a manner that minimizes or eliminates the potential for a spill.
Where applicable, the following guidelines shall be observed:
• The Operating Company Manager or qualified designee shall be responsible for the
loading and unloading of hazardous substances in accordance with company-specific
procedures. (See Appendix.)
• Where appropriate, each loading or unloading installation shall have adequate
containment equipment or systems.
• Containment systems shall have provisions to drain or otherwise remove rainwater.
Drainage valves shall remain closed at all times except when actively draining
accumulated rainwater.
• Designated facility personnel must monitor the loading and unloading of all
hazardous substances from tank trucks and/or barges for leaks, spills and proper hose
connections and/or disconnections.
• All fuel lines including hard pipes and flexible hoses shall be included on a regular
preventive maintenance program for the detection of structural weaknesses and
defects that could cause a leak.
• Routine visible inspections of aboveground piping or the implementation of an
inventory control process for unaccounted fuel shall be considered part of a
preventive maintenance program.
• Required repairs or replacement shall occur in a timely manner and shall be
documented in the preventive maintenance program.
• Where bulk loading or unloading of hazardous materials is being done, facilities shall
develop and implement site-specific loading/unloading procedures that describe the
responsibilities of personnel, actions and emergency shutdown systems.
• Where the loading or unloading of flammable materials occurs, proper grounding is
required.
• Eyewash stations, showers and spill response equipment as well as other appropriate
safety equipment shall be readily accessible to personnel engaged in the loading or
unloading of hazardous materials.
• Containment systems must be kept clean and free of trash, junk and debris.

Revision: 0
Issued: 20-Nov-1999
Spill Prevention
Container Handling and Storage Doc. # ENV-020
1. Purpose
This guideline establishes the requirements for routine handling and proper storage of containers
utilized in various Company operations.
2. Scope
3. Guideline
3.1 General
Containers are used to transport hazardous materials in many Company operations.
Employees shall be familiar with handling and storage of all containers they come in
contact with.
Container Handling Precautions
In order to minimize risks associated with hazardous material in containers, the following
information must be ascertained before attempting to handle the waste or material:
• Identification of the material
• Location, or where the material is to be moved
• The weight of the container
• Access and egress routes
• What personal protective equipment (PPE) is required
• What emergency actions may be needed (i.e., first aid, fire fighting media, etc.)
Container Storage Precautions
Hazardous materials containing liquids must always be stored inside the diked or curbed
portion of the container storage area.
• Incompatible materials must be stored separately in an "isolated" section of the
container storage area, as they will react if mixed. (Refer to D.O.T. Compatibility and
Isolation Tables when applicable.) Examples of incompatible materials are as
follows:
a. Caustics and acids
b. Caustics/acids and petroleum products
c. Caustics/acids and paints
• Containers must be kept tightly closed except when adding or removing contents.
Funnels shall be removed or covered when not in use.
• Each container shall be labeled with its contents. Appropriate hazard markings shall
be clearly visible. Labels and hazard warnings shall face out.
• Containers holding flammable materials shall be grounded during any transfer of
contents.
• Any liquid draining or dripping spills shall be absorbed with pads, sawdust, oil-dry,
etc. for proper disposal.
• Any rinsing or other drum cleaning must be done according to specific instructions
for containers that hold particular materials.

Revision: 0
Issued: 20-Nov-1999
Spill Prevention
Container Handling and Storage Doc. # ENV-020

• Disposal of empty containers shall be carried out according to instructions specific to
what the container once held. (See Environmental Guideline ENV-032 “Used Drums
and Containers”.)
• Containers must be compatible with the material it will store or contain.
• Dike/sump drains from any curbed area must be valved closed except during periods
of drainage, which will be initiated only by supervision after properly identifying
disposal routes for the contained material.
• Containers shall be stacked on pallets, one pallet high, with approximately 18 inches
of aisle space between rows.
• Container storage buildings, areas and containment systems must be kept clean and
free of trash, junk and debris.

Revision: 0
Issued: 20-Nov-1999
Spill Prevention
Aboveground Storage Tank Design and Specifications Doc. # ENV-021
1. Purpose
This guideline establishes the requirements to be followed for the installation of bulk storage
tanks.
2. Scope
3. Guideline
3.1 General
This guideline is intended to ensure the efficient and safe design and installation of bulk
storage tanks used to store petroleum products such as pipeline condensate, fuels, new or
used lube oil and hazardous chemicals such as caustics and acids.
Where applicable, the following guidelines shall be observed:
• The tank material must be compatible with the stored material.
• Tanks with a capacity greater than 660 gallons or any group of tanks with an
aggregate capacity greater than 1,320 gallons must have a secondary containment
system with capacity for the entire contents of the largest tank in the containment
system plus sufficient freeboard to allow for precipitation.
• Tanks with a capacity of 660 gallons or less that are not located within a secondary
containment system for a group of tanks, must have an individual secondary
containment system.
• If a leak or rupture could cause oil to enter a public waterway that is used for
transportation and/or recreation, then a secondary containment system is essential.
• The diked area should be constructed using a sufficiently impervious material such as
concrete, fiberglass or compacted soils with permeability less than 10-5 centimeters
per second.
• If the dike is constructed using local soils, the permeability of the soil shall be tested
prior to construction to ensure that it is capable of achieving the requirements of
compacted permeability.
• Secondary containment systems may include a liner, vault or double-walled tank.

Revision: 0
Issued: 20-Nov-1999
Spill Prevention
Facility Inspections Doc. # ENV-022
1. Purpose
This guideline establishes the requirements for the regular inspection of aboveground tanks and
related facilities.
2. Scope
3. Guideline
3.1 General
Aboveground storage tanks and secondary containment systems shall undergo
documented weekly inspections for condition and need for maintenance.
The scope and frequency of inspections shall be included in the facility’s Spill Prevention
Control and Countermeasures Plan, Spill Contingency Plan or other similar plans.
3.3 Records
Inspection observations shall be documented on an Aboveground Storage
Tank/Secondary Containment Inspection Form. (The form is being developed as of
November 1999).
Corrective actions for potential problems detected during the inspection shall be taken as
necessary and recorded on the inspection forms. This may include the assignment of
work orders, purchase orders, etc. Copies of inspection forms shall be maintained on site
in facility files for three years.
Leak tests, tank assessments and certifications shall be maintained for the life of the tank
or system.

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-023

Revision: 0
Issued: 20-Nov-1999
Spill Plans and Training
Spill Plans Doc. # ENV-024
1. Purpose
This guideline establishes the requirements for providing Operating Companies with steps to
prepare and implement spill plans.
2. Scope
3. Guideline
3.1 General
Operating Companies engaged in drilling, producing, gathering, storing, processing,
refining, transferring or consuming “oil” or other hazardous materials that could be
discharged in harmful quantities shall prepare and implement a Spill Plan as part of its
emergency procedures.
3.2 Considerations
The Spill Plan shall be revised or amended if there is any change in the facility’s design,
operation or maintenance that could affect the facility’s potential for accidental discharge.
Such revisions shall be implemented within 6 months of the change.
The Spill Plan shall be prepared within 6 months of a facility’s date of commercial
operation or acquisition and fully implemented within 1 year.
The Spill Plan shall include the following information:
• Description of the facility’s operation
• Physical location of the facility including latitude and longitude coordinates and
access routes (directions)
• List of equipment, tanks or other structures as well as operational activities such as
fuel unloading that could result in a leak or spill
• Description of potential failures (rupture, failure, overflow, etc.) including a
prediction of flow direction, potentially impacted areas or receiving bodies and
potential spill quantities
• Description of secondary containment systems, diversionary structures or spill
response equipment that could prevent discharge into a public waterway
• Discussion and implementation of fail-safe engineering designs that could prevent
spills from occurring including high-level alarms or emergency shutdown systems.
• Discussion regarding implementation of other spill prevention activities such as
weekly inspections and preventive maintenance programs
• Discussion of development of detailed unloading procedures
• Description of site security measures
• Description of employee training and frequency of such training in the area of spill
prevention, control and response.
• Provisions for a periodic review of the plan and steps for making necessary revisions
• Identification of individual(s) at the facility responsible for preparing, revising and
implementing this plan
• Management approval when developing and implementing procedures for the Spill
Plan

Revision: 0
Issued: 20-Nov-1999
Spill Plans Doc. # ENV-024
3.4 Records
The current Spill Plan shall be maintained on-site as a supplement to an emergency plan
or as a stand-alone document.
Superseded plans should be kept in facility’s files for 3 years.
All documents related to the Spill Plan (inspections, incident reports, training records,
corrective actions, etc.) should be maintained on-site for 3 years.
4. Reference
4.1 Internal Standards
• Health and Safety Guideline SAF-019, Emergency Action Plans
• Environmental Guideline ENV-015, Implementation of Emergency Response
Guidelines - Spill Response Actions
• Environmental Guideline ENV-016, Implementation of Emergency Response
Guidelines - Spill Cleanup Guidelines
• Environmental Guideline ENV-018, Spill Prevention - General Guidance
• Environmental Guideline ENV-019, Spill Prevention - Loading and Unloading
• Environmental Guideline ENV-020, Spill Prevention - Container Handling and
Storage
• Environmental Guideline ENV-021, Spill Prevention - Aboveground Storage Tank
Design and Specifications
• Environmental Guideline ENV-022 Spill Prevention - Facility Inspections
• Environmental Guideline ENV-024 Spill Plans and Training - Spill Plans
• Environmental Guideline ENV-025 Spill Plans and Training - Personnel Training
• Environmental Guideline ENV-026 Spill Plans and Training - Spill Drills

Revision: 0
Issued: 20-Nov-1999
Personnel Training Doc. # ENV-025
1. Purpose
This guideline establishes the requirements for the identification of specific training required of
Operational personnel with assigned responsibilities for identifying and responding to spills or
releases of material at Company facilities.
2. Scope
3. Guideline
3.1 General
Personnel responsible for identifying and responding to spills shall be properly trained in
the prevention of spills as well as the methods and skills necessary for a proper response
in the event of a spill.
Training (General)
• In facilities that are not required to have a Spill Plan, each employee shall be
responsible for recognizing the potential for a spill or leak and bringing it to the
attention of the facility manager.
• Operations and maintenance employees shall be trained in the proper operation and
maintenance of equipment to prevent accidental discharge including emergency
shutdown systems and will also be made familiar with emergency plans.
• Individuals responsible for the overhaul or repair of oil-filled equipment shall be
instructed to observe precautionary measures to ensure that spills do not occur.
• Individuals responsible for the loading or unloading of oil or other hazardous
materials shall be instructed in appropriate procedures to mitigate the potential for
spills.
• Documentation of this training is recommended.
Spill Plan and Spill Prevention Training
• In facilities that are required to have a Spill Plan, briefings shall be conducted at least
annually to ensure that operations and maintenance employees understand the
facility’s Spill Plan. Briefings shall include spill prevention techniques, notification
procedures and discussions of recent spill incidents or equipment malfunctions.
• Each employee shall be encouraged to discuss ways in which spill prevention can be
improved.
• Documentation of this training must be completed.
Spill Response Training
• Operations and maintenance employees shall be trained in basic spill response
techniques (notify, stop the source and seek help) at least annually.
• Appropriate operations and maintenance personnel shall be given instructions at least
annually regarding basic cleanup techniques including appropriate safety precautions
to be exercised.
• Facilities involved in the bulk unloading of fuel oil and/or which have purchased
advanced spill cleanup equipment such as booms and skimmers, shall provide
detailed instructions at least annually to employees who may be involved in such
activities.
• Training shall be documented.

Revision: 0
Issued: 20-Nov-1999
Spill Drills Doc. # ENV-026
1. Purpose
This guideline establishes the requirements to be followed to provide guidance for the regular
conducting of spill drills and exercises.
2. Scope
3. Guideline
Operating Companies shall implement a schedule for conducting practice drills
commensurate with its potential for spills.
TYPE OF EXERCISE FREQUENCY COMMENTS

Emergency Information Monthly Check the accuracy of internal and
Check external contacts and telephone numbers.
Make necessary corrections to ensure that
the contact list is current.
Full Deployment Exercise Quarterly For facilities that own their own response
equipment, response teams or designated
personnel shall practice actual deployment
of response equipment to ensure that
individuals are knowledgeable of response
equipment and that such equipment is in
good operating condition. Drills shall be
critiqued and documented.
Third-Party Assistance Annually For facilities that depend on third-party
Exercise assistance for spill response (external
companies or co-ops.), drills shall be
conducted to actively deploy such
assistance to ensure that the facility can
coordinate an effective response. Advance
notification may be required.
Spill drills may be coordinated with other emergency drills such as evacuation drills,
crisis response drills, fire drills, etc. to best utilize the time and effort involved in
planning such events. Deployment exercises, third-party exercises and joint emergency
drills shall be followed by a discussion of the drill and opportunities for improvement.

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-027

Revision: 0
Issued: 20-Nov-1999
Waste Management – General Guidelines
Compliance with Local Laws and Regulations Doc. # ENV-028
1. Purpose
This guideline establishes the requirements to be followed to supplement waste management
practices required by local environmental laws and regulations to which a facility may be
subject.
2. Scope
3. Guideline
3.1 General
Observance of these guidelines alone does not constitute compliance with local laws. For
a summary of local environmental requirements, consult the Operating Company-specific
environmental procedures.
3.2 Considerations
Definition of Terms
Incineration is the controlled process in which combustible solid, liquid or gaseous
wastes are burned and changed into non-combustible gases.
Medical Waste includes disposable equipment, instruments and utensils such as latex
gloves or other protective clothing and hypodermic needles that may have been exposed
to a communicable disease through contact with blood or other body fluids as well as
pathological specimens. (See SAF-005 “Bloodborne Pathogens Control” for details).
An Open Dump is a land disposal site where solid wastes are disposed of in a manner
that does not protect the environment, are susceptible to open burning and are exposed to
the elements as well as scavengers.
Open Burning is the burning of solid wastes in the open, such as an open dump.
Reclaimed Material is material that is processed or regenerated to recover a usable
product. Examples are recovery of lead from spent lead acid batteries and the
regeneration of resin beds in water treatment systems using reverse osmosis.
Recycled Material is material that is used, reused or reclaimed.
Scrap Metal is bits and pieces of metal parts (i.e., bars, turnings, rods, sheets, wire) or
metal pieces that may be combined with bolts or soldering (i.e., radios, scrap
automobiles, etc.) that, when worn, can be recycled.
Sludge is the accumulated semi-liquid suspension of settled solids deposited from
wastewater or other fluids in tanks or basins. It does not include domestic sewage or
dissolved solids in water resources such as silt and dissolved or suspended solids in
industrial effluents.
Solid Waste is any garbage, refuse, sludges and other discarded materials resulting from
industrial and commercial operations and from community activities. Discarded
materials include but are not limited to materials that are collected for purposes of
recycling.
Spent Material is any material that has been used and as a result of contamination, can no
longer serve the purpose for which it was produced without processing.
Used or Reused Material is material that is either employed as an ingredient in an
industrial process to make a product or in a particular function or application as an
effective substitute for a commercial product.

Revision: 0
Issued: 20-Nov-1999
Waste Characterization Doc. # ENV-029
1. Purpose
This guideline establishes the requirements for determining if a waste is hazardous or
non-hazardous. The process of making such a determination is called waste characterization.
2. Scope
3. Guidelines
3.1 General
The following recommendations for storage, treatment, transportation and disposal
practices are intended to supplement local regulations especially in countries where waste
classification systems are unavailable and transportation and disposal services are
limited. For more detailed information, refer to U.S.-D.O.T. Hazardous Waste
Identification Table 172.101 and the isolation and segregation tables.
3.2 Considerations
In lieu of using the U.S. EPA Hazardous Waste classification system, consideration shall
be given to regionally acceptable waste classification systems. Operating Company
environmental procedures should reflect local regulations and identify waste storage and
disposal alternatives specific to the Operating Company and location. This guideline
outlines terminology and reviews basic principles for the development of procedures to
ensure safety and efficiency.
Classification of Hazardous Wastes
Waste shall be designated as U.S. EPA hazardous if it exhibits any one of the following
characteristics or definitions:
• Ignitability means the waste material has a flashpoint less than 140°F and/or is an
aqueous solution with an alcohol content greater than or equal to 24%. Typical
wastes exhibiting this characteristic are waste solvents and paint.
• Corrosivity means the waste material is a liquid and has a pH less than 2.0 or greater
than 12.5. Typical wastes exhibiting this characteristic are acids and caustics.
• Reactivity means the waste material undergoes rapid or violent chemical reaction
when mixed or exposed to water, shock, heat or pressure. Examples include
perchlorates, peroxides, and cyanides.
• Toxicity means that the waste material contains one or more of the toxic substances
listed in Table 3.1.1-1 in concentrations equal to or greater than the level indicated for
each substance. Concentrations are determined by the Toxicity Characteristic
Leaching Procedure (TCLP).
• Listed: A partial list of materials that have been specifically listed by the U.S. EPA as
“hazardous” is provided in Table 29.1. The complete list is available by request to the
Environmental, Health and Safety Department, Enron Global Asset Operations
(Houston).
Global Asset Operations Page 1of 3

Revision: 0
Issued: 20-Nov-1999

Determining if a Waste is a Hazardous Waste
Following are steps to be followed to determine if a waste is hazardous:
• Determine what, if any, hazardous characteristics are exhibited by performing a
process and/or laboratory analysis.
• A process analysis shall consist of an evaluation of the process from which the waste
is generated and a review of the material’s Material Safety Data Sheet (MSDS).
• This analysis shall be performed whenever the process or feedstock changes.
Non-Hazardous Wastes
A non-hazardous waste is any waste that is not a listed waste or does not possess the
characteristics of a hazardous waste as described in Table 29.1. Following are some
examples of methods of classifying wastes:
• Used oil is considered a non-hazardous waste unless it is mixed with a hazardous
waste.
• PCB-contaminated oil or debris is considered a toxic waste. Consult the section
entitled “PCB Management” for further guidance.
• Friable asbestos is considered a hazardous air pollutant. Consult the section entitled
“Asbestos Management” for further guidance.
TABLE 3.1.1-1 - TOXICITY CONCENTRATIONS
Constituent Concentration Constituent Concentration

(mg/l) (mg/l)
Arsenic 5.0 m-Cresol 200.0
Barium/ 100.0 p-Cresol 200.0
Cadmium 1.0 Cresol 200.0
Chromium 5.0 1,4-Dichlorobenzene 7.5
Lead 5.0 1,2-Dichloroethane 0.5
Mercury 0.2 1,1-Dichloroethylene 0.7
Selenium 1.0 2,4-Dinitrotoluene 0.13
Silver 5.0 Heptachlor 0.008
Endrin 0.02 Heptachlorobenzene 0.013
Lindane 0.4 Hexachloro-1,3-butadiene 0.5
Methoxychlor 10.0 Hexachloroethane 3.0
Toxaphene 0.5 Methy ethyl ketone 200.0
2,4-Dichlorophenoxycetic acid 10.0 Nitrobenzene 2.0
2,4,5-Trichlorophenoxypropionic acid 10.0 Pentachlorophenol 100.0
Benzene 0.5 Pyridine 5.0
Carbon tetrachloride 0.5 Tetrachloroethylene 0.7
Chlordane 0.003 2,4,5-Trichlorophenol 400.0
Chlorobenzene 100.0 2,4,6-Trichlorphenol 2.0
Chloroform 6.0 Vinyl chloride 0.2
o-Cresol 200.0

Revision: 0
Issued: 20-Nov-1999
TABLE 29.1 - LISTED HAZARDOUS WASTES
U.S. EPA Waste

Identification Number Characteristic Waste Description
U002 Ignitability Acetone
P012 Toxicity Arsenic Trioxide (AS2O3)
P011 Toxicity Arsenic Pentoxide (AS2O5)
U019 Ignitability, Benzene
Toxicity
U037 Toxicity Chlorobenzene
U070 Toxicity 1,2 Dichlorobenzene
U144 Toxicity Lead Acetate
U151 Toxicity Mercury
U154 Ignitability Methanol (Methyl Alcohol)
U159 Ignitability, Methyl Ethyl Ketone (MEK)
Toxicity
U161 Ignitability Methyl Isobutyl Ketone (MIBK)
U188 Toxicity Phenol
U196 Toxicity Pyridine
U220 Toxicity Toluene
U239 Ignitability Xylene
F001 Toxicity Before use, all solvents containing 10% or more of any
combination of the following: tetrachloroethylene, 1,1,1-
trichlorethane, carbon tetrachloride and chlorinated
fluorocarbons
F002 Toxicity Before use, all solvents containing, 10% or more of any
combination of the following: tetrachloroethylene, methylene
chloride, trichloroethylene, 1,1,1-trichloroethane, 1,1,2-
trchloro-1,2,2-trifluoroethande, orthodichlorobenzene,
trichlorfluoromethane and 1,1,2-trichloroethane.
F003 Ignitability Before use, all solvents containing, 10% or more of any
combination of the following: xylene, acetone, ethyl acetate,
ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl
alcohol, cyclohexanone and methanol.
F004 Toxicity Before use, all solvents, containing 10% or more of any
combination of the following: cresols and cresylic acid, and
nitrobenzene.
F005 Ignitability, Before use, all solvents containing, 10% or more of any
Toxicity combination of the following: toluene, methyl ethyl ketone,
carbon disulfide, isobutanol, pyridine, benzene, 2-
ethoxyethanol and 2-nitropropane.

Revision: 0
Issued: 20-Nov-1999
Unclassified Materials Doc. # ENV-030
1. Purpose
This guideline establishes the requirements to be followed to apply specific steps identified in
this guideline to be observed when handling unknown materials.
2. Scope
3. Guideline
The following precautions are to be observed when handling unknown materials:
• The container shall be properly sealed and labeled “UNCLASSIFIED”.
• If the material is being stored in an unlabeled container, maintenance personnel
should be questioned and recent maintenance activities should be reviewed to
determine if the material is associated with such activities.
• If known, the material shall be identified based on prior knowledge of the material’s
characteristics by consulting the MSDS. Compare these characteristics to those in
Guideline ENV-029, “Waste Characterization”.
• Do not try to identify the material by directly inhaling the fumes, touching or tasting.
• If necessary, collect a sample of the material and send it for toxic analytical testing.
• Guidance for determining toxicity based on analytical testing is given in TABLE 29.1
LISTED HAZARDOUS WASTES of Guideline ENV-029 “Waste Characterization”.
If additional assistance is needed, contact the Regional EHS Manager for advice.

Revision: 0
Issued: 20-Nov-1999
Used Aerosol Cans Doc. # ENV-031
1. Purpose
This guideline establishes the requirements to be followed by Operations personnel when
handling used aerosol cans.
2. Scope
3. Guideline
• When cans are completely empty, carefully puncture a hole in the top or bottom of the
can to release any trapped pressure.
• Place the empty containers with plant trash for discard.
• Consult company-specific procedures to determine local compliance requirements.

Revision: 0
Issued: 20-Nov-1999
Used Drums and Containers Doc. # ENV-032
1. Purpose
handling used drums or other containers.
2. Scope
3. Guideline
3.1 General
Proper handling of drums and containers as outlined in this guideline is essential to
prevent injury or environmental incidents. This guideline outlines terminology and
reviews basic principles for development of procedures to ensure safety and efficiency.
3.2 Considerations
This guideline shall refer to key terms as defined below:
Container: Any portable device in which a material is stored, transported, treated,
disposed of or otherwise handled.
Drum: A portable plastic or metal container with a capacity between 14 and 55 gallons.
A container is “Empty” when all contents have been removed by pouring or pumping and
there is less than one inch of residue remaining on the bottom of the container.
No employee or other individual should be allowed to remove used containers from
facility property unless the facility is transporting authorized donations to a charity. Used
drums may be donated to various charity organizations (schools, public parks,
beautification projects, etc.) only if they have been properly rinsed, rendered non-usable
by punching holes throughout the container and the donation has been authorized by the
Operating Company Manager.
When practical, alternate methods of receiving consumable materials shall be pursued
such as purchasing “concentrated” formulas that must be diluted before use; purchasing
chemicals in “totes” or collapsible containers and arranging an exchange program with
the vendor or supplier to trade empty containers for full ones on a regular basis.
Empty containers shall be stored in accordance with the Environmental Guideline
ENV-047, “Storage and Inspection”. Label the containers “EMPTY” or segregate them
in an area designated for the storage of empty containers only.
Non-returnable containers may be reused on site to store wastes, replace physically
damaged containers or to store non-chemicals (i.e., scrap metal, clean-up rags, paper
trash, etc.).
Prior to reusing containers, the following steps shall be taken for compliance:
• The container must be in good condition, free of leaks or excessive rust and have a
cover or lid.
• Waste, new products or materials with residues (such as oily rags) shall be
compatible with the type of container and its previous contents. For example, a used
gear oil drum (metal) shall not be used to store an acid or caustic material.
• Used containers shall be triple-rinsed in an authorized location where drainage is
directed to specially designed treatment systems.
• No welding or cutting of drums shall be allowed.

Revision: 0
Issued: 20-Nov-1999
Used Fluorescent Bulbs Doc. # ENV-033
1. Purpose
handling used fluorescent light bulbs.
2. Scope
3. Guideline
3.1 General
The proper handling of used fluorescent light bulbs is essential to prevent injury or illness
due to mishandling. This guideline reviews basic principles for the development of
procedures to ensure safety and efficiency.
3.2 Considerations
Several types of lamps (light bulbs) contain mercury in concentrations such that they can
be expected to exceed the U.S. EPA TCLP threshold for mercury.
The following types of lamps contain quantities of mercury that will result in their
normally failing the TCLP mercury test:
• Fluorescent lamps
• High-intensity discharge (HID) lamps, which include the following:
a. Mercury vapor
b. Metal halide
c. Low-pressure sodium
d. High-pressure sodium
Many light bulb manufacturers now offer fluorescent lamps that they will warrant as
having mercury levels that will not exceed the TCLP test threshold.
Enron Global Asset Operations strongly encourages its Operating Companies to pursue
such alternatives as well as he recycle mercury-containing lamps, where feasible.
Otherwise, all mercury-containing lamps shall be disposed in accordance with
appropriate local regulations.

Revision: 0
Issued: 20-Nov-1999
Used Glycol and Oil Filters Doc. # ENV-034
1. Purpose
handling used glycol and oil filters.
2. Scope
3. Guideline
3.1 General
Proper use of used glycol and oil filters is essential to prevent injury, illness, product
contamination and environmental damage. This guideline reviews basic principles for
the development of procedures to ensure safety and efficiency.
Used glycol filters and oil filters shall be handled in the following manner to ensure
safety:
Used Glycol Filters
• Place used glycol filters in a closed container to allow the collection of free fluids.
DO NOT MIX USED GLYCOL FILTERS WITH USED OIL FILTERS.
• If used glycol filters are collected in various areas of the facility, designated drums
shall be centrally-located and labeled “USED GLYCOL FILTERS”.
• Drained filters shall be sent to an approved vendor for recycling, landfilling or
incineration.
• The vendor may require analytical testing prior to acceptance. Testing should be
conducted upon request and a copy of the results provided. The original analytical
report shall remain in facility files for future reference.
Used Oil Filters
• Place used oil filters in a closed container to allow the collection of free fluids.
Punching a hole in the filter may accelerate the draining of filters.
• If used oil filters are collected in various areas of the facility, designated drums shall
be centrally located and labeled “USED OIL FILTERS”.
• Drained filters shall be sent to an approved vendor for recycling, landfilling or
incineration.
• The vendor may require analytical testing prior to acceptance. Testing should be
conducted upon request and a copy of the results provided. The original analytical
report shall remain in facility files for future reference.

Revision: 0
Issued: 20-Nov-1999
Molecular Sieves and Activated Carbon Doc. # ENV-035
1. Purpose
handling used molecular sieve and activated carbon materials.
2. Scope
3. Guideline
3.1 General
Proper handling of used molecular sieve and activated carbon materials is essential to
prevent injury or illness and for compliance with all applicable local and environmental
laws.
3.2 Considerations
Personnel shall become familiar with procedures for handling molecular sieve and
activated carbon material. This guideline reviews basic principles for the development of
If possible, isolate the molecular sieve and/or activated carbon from the process stream
and heat the material prior to removal from its vessel. Emissions generated as a result of
heating should not be released into the atmosphere except through a flare stack.
A representative sample of molecular sieve and/or activated carbon shall be characterized
and disposed in accordance with Table 35.1
NOTE: Do not broadcast this waste on the surface of a road, etc. The vendor may
request additional testing in some circumstances.
Label storage containers “USED MOLECULAR SIEVE” and/or “ACTIVATED
CARBON” and store in accordance with Guideline ENV-047 “Storage and Inspection”.

Revision: 0
Issued: 20-Nov-1999
Molecular Sieves and Activated Carbon Doc. # ENV-035
TABLE 35.1
Constituent Concentration Testing Frequency Disposal Recommendations

(mg/l)
Barium ≤ 90.0 Once every 5 years Approved Landfill
> 90, but ≤ 100.0 Test per batch generated Approved Landfill
> 100.0 Test per batch generated Contact Regional Environmental Manager
Cadmium ≤ 0.9 Once every 5 years Approved Landfill
> 0.9, but ≤ 1.0 Test per batch generated Approved Landfill
Chromium ≤ 4.0 Once every 5 years Approved Landfill
> 5.0 Test per batch generated Contact Regional Environmental Manager.
Lead ≤ 4.0 Once every 5 years Approved Landfill.
> 4.0, but ≤ 5.0 Test per batch generated Approved Landfill.
> 5.0 Test per batch generated Contact Regional Environmental Manager.
Mercury ≤ 0.18 Once every 5 years Approved Landfill
Silver ≤ 4.0 Once every 5 years Approved Landfill
> 4.0 but ≤ 5.0 Test per batch generated Approved Landfill
Benzene ≤ 0.4 Once every 5 years Approved Landfill
>0.4, but ≤ 0.5 Test per batch generated Approved Landfill
Total Petroleum ≤ 90.0 Once every 5 years Approved Landfill
Hydrocarbons
> 90, but ≤ 100.0 Test per batch generated Approved Landfill

Revision: 0
Issued: 20-Nov-1999
Used Oil Doc. # ENV-036
1. Purpose
This guideline establishes the requirements to be followed by Operations personnel for the
characterization, storage and disposal of used oil.
2. Scope
3. Guideline
3.1 General
Operations personnel shall become familiar with procedures for characterizing, storing
and disposing of used oil. This guideline reviews basic principles for the development of
3.2 Considerations
Proper characterization, storage and disposal of used oil is essential to prevent injury or
illness and for compliance with all applicable local and environmental laws.
Procedures for handling used oil are as follows:
• Used oil at the facility shall be analyzed for total halogens every 5 years or any time
there is a change in the process generating the used oil that could affect its makeup.
If total halogens exceed 1000 ppm, contact the Regional EHS Manager for advice.
• The mixing of waste paint, thinners and solvents with used oil shall be avoided.
• Label storage containers “USED OIL” and store in accordance with Environmental
Guideline ENV-047 “Storage and Inspections” or ENV-071 “Aboveground Storage
Tanks”.
• Used oil should be recycled with local vendors for energy recovery. The used oil may
be burned directly by the vendor or the vendor may collect used oil from several
sources, mix it and then market it to used oil burners.
• If the vendor collects used oil by pumping it into a tank truck, confirm that the tank
truck is empty prior to loading. Sampling prior to loading is encouraged so that a
quality analysis can be performed in the event there is a dispute.
• Loading by tank truck should occur under supervision of designated facility personnel
under Guideline ENV-019 “Loading and Unloading”.

Revision: 0
Issued: 20-Nov-1999
Pesticides, Herbicides and Insecticides Doc. # ENV-037
1. Purpose
application, storage and disposal of pesticides, herbicides and insecticides.
2. Scope
3. Guideline
3.1 General
Proper procedures for the application, storage and disposal of pesticides, herbicides and
insecticides are essential to prevent injury or illness and for compliance with applicable
local and environmental laws. This guideline reviews basic principles for the
development of procedures to ensure safety and efficiency.
3.2 Considerations
Operations personnel shall become familiar with procedures for the application, storage
and disposal of pesticides, herbicides and insecticides. The Regional EHS Manager
should review the MSDSs of pesticides, herbicides and insecticides prior to usage by
either plant personnel or a contractor.
Procedures for handling pesticides, herbicides and insecticides are as follows:
WARNING: Arsenic, sodium cacodylate, chlorinated and brominated substances are

to be AVOIDED.
• Define the area of treatment and select an applicator. The applicator should manage
the use of the pesticide, herbicide or insecticide in accordance with its label and/or
MSDS, including the requirements for wearing personal protective equipment and
storage and handling precautions.
• Materials purchased by the plant should be acquired in small quantities to avoid
excess accumulation.
• Any unused product shall be clearly labeled and stored in accordance with the MSDS.
• The removal of excess materials supplied by contractors should be the responsibility
of the contractor.

Revision: 0
Issued: 20-Nov-1999
Sandblasting Materials Doc. # ENV-038
1. Purpose
This guideline establishes the requirements to be followed by Operations and Maintenance
personnel for the characterization, storage and disposal of sandblasting materials.
2. Scope
3. Guideline
3.1 General
Most paint removal projects, particularly abrasive blasting operations, can affect human
health and the environment due to dust emissions that contribute to air or water pollution,
as well as those impacts associated with waste management.
3.2 Considerations
This guideline reviews basic principles for the development of procedures to ensure
safety and efficiency when working with sandblasting materials.
The following precautions shall be observed to reduce health and environmental impacts
before, during and after sandblasting activities:
• Review available paint information or conduct a paint test to determine if coatings on
the surface contains lead or other hazardous substances. If a paint test is needed, take
one sample per 500 square feet or linear feet of surface to be blasted.
• According to the substances identified in the above step, take appropriate personal
protection measures. Consult the Enron International Safety Manual or contact the
Regional EHS Manager for additional guidance.
• Determine local environmental regulatory requirements and develop a procedure for
compliance.
• Take reasonable and appropriate actions to minimize abrasive dust emissions from
entering the atmosphere and water sources.
• Store the used abrasive material in drums or hoppers depending on the quanity
generated.
• Depending on the hazardous materials present and their concentration, the material
may be disposed of in a solid waste landfill. The Operating Company shall consult
with the Regional EHS Manager for disposal advice.
• The Operating Company Manager is responsible for ensuring that human health and
the environment are reasonably protected and the blasting material is handled, stored
and disposed of in accordance with all local regulations.

Revision: 0
Issued: 20-Nov-1999
Used Tires and Batteries Doc. # ENV-039
1. Purpose
This guideline establishes the requirements to be followed by Operations, Maintenance
and Waste Management personnel for the characterization, storage and disposal of used
tires and batteries.
2. Scope
This guideline applies to all “Company” operated facilities, its employees and its
3. Guideline
3.1 General
Enron encourages the recycling and reuse of used tires and batteries including
nickel-cadmium and lead acid batteries.
3.2 Considerations
The Operating Company Manager is responsible for ensuring that human health
and the environment are reasonably protected and all used tires and batteries are
handled, stored and disposed of in accordance with all local regulations.
Ideally, automotive services should be provided by a third-party service provider
who can recycle, resell or otherwise reuse used tires. However, this may not be
feasible for isolated facilities or for Operating Companies that must maintain an
inventory of such usable items for its fleet.
The following steps shall be taken when used tire and/or batteries must be stored
or disposed of by the Operating Company:
• Review available battery information.
• Using the MSDS and any other available information on specific hazards for
tire burning or toxic substances associated with batteries, all necessary and
appropriate personal protection measures shall be taken.
• Consult the Enron International Safety Manual or contact the Regional EHS
Manager for additional guidance.
• Determine the local environmental regulatory requirements and develop a
site-specific procedure for compliance.
• Depending on the hazardous materials present and their concentration, the
material may be disposed of in a solid waste landfill. The company operated
facility should consult with the Regional EHS Manager for disposal advice.
4. References
4.1 Attachment 1 - Appendix
• International Environmental Checklist for Waste Transportation and Disposal
Facilities (TSD Audit Form)

Revision: 0
Issued: 20-Nov-1999
Appendix 1
INTERNATIONAL ENVIRONMENTAL CHECKLIST
FOR WASTE TRANSPORTATION AND DISPOSAL FACILITIES
NAME OF FACILITY:
LOCATION:
AUDIT DATE:
Circle all applicable:
Transportation/Storage Landfarm Landfill Recycle/Recover Incinerate
AUDIT COMMITTEE MEMBERS:
Note: It is recommended that a preliminary investigation be conducted to obtain relevant information prior
to conducting a physical inspection of the facility.
I. PERMITS, CLEARANCES AND INSURANCE
1. Is the facility required to obtain and maintain an environmental permit or license from
a government agency for its operation?
If NO, proceed to question 4.
2. Does the owner/operator have a copy of the permit/license, etc. available for review?
3. Are these currently valid for the location and type of operation?
4. Is the owner/operator in good standing with local officials?
5. Does the facility have liability insurance to cover its operations, including vehicles to
transport waste?
If NO, proceed to Section II
6. Does the Insurance conform to Enron Corp’s Risk Management Guidelines?
If not, has Enron Corp’s Risk Management reviewed the policy?
II. TRANSPORTATION ACTIVITIES
1. Does the owner/operator of the waste disposal facility offer transportation services?
2. Does the owner/operator of the waste disposal facility contract a third party for
transportation services?
3. Are transportation vehicles equipped with placards or warning signs to indicate

hazards?
4. Has the transporter acquired all special permits and/or licenses required by local
laws?

Revision: 0
Issued: 20-Nov-1999
III. TRANSPORTATION ACTIVITIES (Continued)
5. Have drivers undergone any special training to respond to spills or releases that could
occur during transport?
6. Observe the general condition of the transportation vehicles and indicate the
following:
a. Both turning signals work?

b. Both headlights work
c. Brake lights work?
d. Emergency flashers work?
e. Horn works?
f. Tires, including spare, appear in good condition?
IV. OPERATIONS
1. Observe the general level of housekeeping around the facility, especially

loading/unloading and storage areas.
2. Determine the types and amounts of security, emergency and spill control equipment?
a. Are emergency instructions posted?

b. Does the facility have security fencing and restricted access?
c. Is communication equipment easily accessible by personnel?
d. Are there sufficient alarms and communication equipment?
e. Are fire extinguishers easily available?
f. Do storage areas and fuel unloading/loading areas have secondary containment?
g. Does the facility have spill control equipment on site?
3. Are personnel equipped with (PPE) personal protective equipment?
4. Inspect Waste Storage areas and observe the following:
a. Are waste containers labeled with its contents and hazards?

b. Are incompatible materials segregated?
c. Is the aisle space adequate to allow emergency access and egress?
d. Are storage areas equipped with a fire extinguisher?
e. Do personnel regularly inspect storage areas?
5. Observe facility drainage systems for the following:
a. Is precipitation from storage areas controlled?

b. If the outfall is visible, is there any evidence of past contamination (discoloration,
stains, dead or stressed vegetation)
V. GENERAL COMPLIANCE
1. Does the facility have a formal “Safety Program”?
2. Are there any public complaints against the facility?
3. Is the facility considered a “Good Neighbor”?
Obtain a list of other companies that have or are using the facility’s services.

Revision: 0
Issued: 20-Nov-1999
Waste Acids and Caustics Doc. # ENV-040
1. Purpose
handling of waste acids and caustics generated during routine laboratory operations.
2. Scope
3. Guideline
3.1 General
Proper handling of waste acids and caustics is essential to prevent injury or illness and for
compliance with all applicable local and environmental laws. This guideline reviews
basic principles for the development of procedures to ensure safety and efficiency.
3.2 Considerations
Personnel shall become familiar with procedures for safely handling waste acids and
caustics.
The following precautions shall be observed to reduce health and environmental impacts
when handling waste acids and caustics:
• Waste acids and caustics may be generated through routine on-site laboratory
operations and must be neutralized prior to disposal in the laboratory drain(s).
• Proper personal protective equipment (PPE) shall be worn during neutralization
process.
• Neutralization can be accomplished in one of three (3) ways as follows:
a. Adding diluted acid slowly to caustics
b. Adding diluted caustics slowly to acids
c. Slowly adding caustics or acids to water as the diluting agent
WARNING: Never pour strong acids or caustics into water, as there is a great
potential for injury due to a violent reaction causing a blowback that will generate heat
and gases.

Revision: 0
Issued: 20-Nov-1999
Waste Paint and Solvents Doc. # ENV-041
1. Purpose
This guideline establishes the requirements to be followed by Operations and Maintenance
personnel for the use, storage and disposal of waste paint and solvents.
2. Scope
3. Guideline
3.1 General
Personnel shall become familiar with procedures for using, storing and disposing of
waste paint and solvents.
3.2 Considerations
Proper handling, storage and disposal of waste paint and solvents is essential to prevent
illness and for compliance with all applicable local and environmental laws. This
guideline reviews basic principles for the development of procedures to ensure safety and
efficiency.
The following procedures shall be followed when handling waste paint and solvents:
• Store and reuse paints, paint thinners and solvents as long as possible.
• Brushes and residual paint in cans should be allowed to completely dry prior to
disposal. Once dry, these materials may be disposed of with regular trash.
• Small amounts of excess thinners and solvents may be allowed to evaporate when
exposed to air if exposure to flame or heat sources can be avoided.
NOTE: If a third-party contractor conducts painting, the contractor shall be

contractually required to transport and dispose of any paint waste. This should be
stipulated as a condition to submitting bids for such work.

Revision: 0
Issued: 20-Nov-1999
New Product Review and Storage Guideline Doc. # ENV-042
1. Purpose
This guideline establishes the requirements be followed by Operations personnel with
responsibility for ordering supplies and other materials utilized in local operations and for
storage of those materials.
2. Scope
3. Guideline
3.1 General
Other than laboratory supplies and household quantity consumer available products, this
guideline is to be followed prior to ordering, using and storing products not currently in
use.
The following procedures shall be followed when reviewing new products and providing
storage:
• Supply the Regional EHS Manager with a description of the new product, its intended
use and MSDS.
• The Regional EHS Manager is responsible for evaluating the material with input from
appropriate safety personnel as needed and providing the intended user with an
approval or rejection.
• If approved, the Regional EHS Manager may advise of any restricted use or
applications of the product.
• If approved, the Operating Company using the product shall keep the MSDS on file
in accordance with the MSDS guidelines available in the Safety Manual.
• Chemical supplies, including but not limited to, boiler treatment chemicals,
lubricating oils, cleaning supplies and water treatment chemicals shall be stored in
accordance with Environmental Guideline ENV-047 “Storage and Inspection” to
better manage environmental and safety risks associated with improper storage.

Revision: 0
Issued: 20-Nov-1999
Waste Minimization Doc. # ENV-043
1. Purpose
This guideline establishes the requirements to be followed for all Operating Companies of Enron
Global Asset Operations to systematically and periodically review their processes, products,
equipment, maintenance, housekeeping and inventory control practices for the purpose of
identifying waste minimization opportunities.
2. Scope
3. Guideline
3.1 General
This guideline is intended to prevent the accumulation of excess waste products. This
efficiency.
3.2 Considerations
Evaluation of waste minimization actions and strategies shall include an analysis of costs
and waste reductions. Operating Companies shall report waste minimization strategies to
the Regional EHS Manager for communication to other interested groups.
Examples of waste minimization strategies include:
• Equipment or technology modifications
• Process or procedure modifications
• Reformation or redesign of products
• Substitution of raw materials
• Improvements in housekeeping, maintenance, training and inventory control
• Recycling and reclamation programs in lieu of treatment and disposal
Examples of waste minimization projects include:
• Exchanging used nickel-cadmium and lead acid batteries with the local supplier when
new ones are purchased
• Using cathodic protection and other methods to reduce unnecessary abrasive blasting
• Ordering and using only the amount of material necessary to complete the job
• Recycling white paper
• Purchasing materials made with recycled products
• Recycling copier ink cartridges with the local supplier
• Ordering materials in bulk containers (totes instead of 5-gallon buckets or 55-gallon
drums)
• Storing new products in a manner that prevents contamination that would render the
product unusable or undesirable
• Replacing paper filament oil filters with wire mesh ones that can be cleaned and
reused indefinitely
• Recycling used oil

Revision: 0
Issued: 20-Nov-1999
Personnel Training and Emergency Procedures Doc. # ENV-044
1. Purpose
This guideline establishes the requirements for conducting personnel training in waste
management and emergency response procedures.
2. Scope
3. Guideline
3.1 General
Proper training of employees is essential to prevent injury from emergencies. This
efficiency.
3.2 Considerations
Operating Companies shall address waste management and emergency response
procedures as part of a formal training program including orientation programs for new
employees. Contractors performing work on site shall also be briefed on essential
elements of these procedures as part of their orientation.
Listed below are areas where training may be needed depending on specific facilities and
hazards involved:
• Using, inspecting, repairing and replacing facility emergency and monitoring
equipment (refer to SAF-002 “Facility Safety Inspections”)
• Key parameters of automatic shutdown systems including shutdown of operations
(refer to EMP-020 “Fire and Gas Detection Systems”)
• Communication or alarm system (refer to SAF-019 “Emergency Action Plans”)
• Evacuation procedures (refer to SAF-021 “Evacuation”)
• Responses to fires or explosions (refer to SAF-024 “Fire Brigades”, SAF-026 “Fire
Extinguishing Systems”, SAF-025 “Fire Extinguishers (Portable)” and FPS-001 “Fire
Protection Systems”)
• Spill response (refer to SAF-019 “Emergency Action Plans”)
• Waste minimization programs (refer to ENV-043 “Waste Minimization”)
• Waste identification guidelines (refer to ENV-029 “Waste Characterization”)
• Container handling and storage requirements (refer to ENV-020 “Container Handling
and Storage”)
• Container and storage tank inspection requirements (refer to ENV-022 “Facility
Inspections”)
• Notification procedures to maintenance for emergency or routine repairs or
replacement of equipment or buildings associated with waste management or
emergency response
3.4 Records
Documentation and recordkeeping procedures for personnel training shall be as follows:
• Document the names of individuals receiving training, the training topic as
specifically as possible and the date of training. Materials used to supplement
training should be listed or filed separately for future reference.
• Training records shall be kept on site in facility environmental files for three years.

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-045

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-046

Revision: 0
Issued: 20-Nov-1999
On-Site Waste Management
Storage and Inspection Doc. # ENV-047
1. Purpose
storage and inspection of operating supplies and other materials utilized in or produced from
local operations.
2. Scope
3. Guideline
3.1 General
Operations personnel shall become familiar with procedures for storing and inspecting
supplies or materials used or procured from local operations.
3.2 Considerations
This guideline outlines and reviews basic principles for the development of procedures to
Storage Guidelines
The following procedures shall be followed when storing supplies or materials:
• Containers shall be stored upright. Only empty containers should be allowed to be
stored on their sides.
• Container contents and hazard warnings (labels) shall be clearly indicated and shall
be facing out so that they can be identified from the aisle.
• Containers shall be tightly closed when not in use.
• Funnels should be removed when not in use.
• Drums showing excessive rust, dents or other damage shall not be used.
• Drums should be elevated on pallets when possible and stored no more than four to a
pallet.
• Pallets of unused products of the same kind may be stacked no more than two high.
• Pallets of drums should be stored in rows in such a way that 36 inches of aisle space
is maintained in order to provide unobstructed movement of both drums and
personnel between aisles.
• Incompatible materials shall be stored separately from one another.
• The storage area should have an impervious surface, secondary containment and
drainage, appropriate warning signs, restricted access, access to emergency
communications (such as an alarm, radio or telephone) and access to emergency
equipment (such as eyewash stations and fire equipment).
Inspection Guidelines
The following procedures shall be followed for the inspection of supplies and materials:
• Drums and containers used to store any material should be inspected weekly for
leaks, malfunctions, deterioration, operator errors and discharges that may lead to a
release into the environment or a threat to human health. The purpose of these
inspections is to identify and correct deficiencies before harm to human health or the
environment can occur.

Revision: 0
Issued: 20-Nov-1999

• The Operating Company Manager or designee is responsible for conducting
inspections and providing appropriate documentation on the inspection form(s)
designated for his specific location.
• If problems are found during the inspection, reasonable attempts shall be made to
immediately correct the problem. The action taken shall be noted on an inspection
report form.
4. References

Attachment 1 “Inspection Form” should be used as guidance in developing site-specific
forms.

Revision: 0
Issued: 20-Nov-1999
Attachment 1
DRUM STORAGE AREA

WEEKLY INSPECTION REPORT
Satisfactory Unsatisfactory
______ _______ 1. Containers are in good condition with no severe rusting, corrosion, dents or
bulges. Seams are intact.
______ _______ 2. Containers are staged properly. All containers are kept closed with bungs
secure or otherwise covered and elevated (on pallets) where possible.
There are no leaking containers (if detected, contents are appropriately
transferred).
_______ ______ 3. Containers are adequately labeled with the contents clearly marked and
visible. The accumulation start dates on hazardous labels are marked and
visible. Empty drums are marked “EMPTY”.
_______ ______ 4. All hazardous waste is shipped off site within 180 days.
______ _______ 5. Containment system is in good condition and free of gaps or cracks that
may cause a leak. Spilled waste and absorbent is removed promptly.
______ _______ 6. Warning signs are clearly visible.
______ _______ 7. Area is free of trash, junk and debris. Aisle space is adequate to allow easy
movement.
S = SATISFACTORY U = UNSATISFACTORY - NOTE CORRECTIVE ACTION
NUMBER CORRECTIVE ACTION/COMMENTS
Inspected by: _________________________________________________ Date: ________________

Revision: 0
Issued: 20-Nov-1099
Treatment Guideline Doc. # ENV-048
1. Purpose
evaluating and implementing in situ treatment methods for waste materials generated during
routine operations.
2. Scope
3. Guideline
3.1 General
In situ treatment of certain waste materials is appropriate and encouraged provided that
they are designed, maintained and monitored in accordance with good environmental
management practices.
3.2 Considerations
The Operating Company Manager is responsible for ensuring that the design,
maintenance and monitoring activities of land farms and other in situ treatment methods
follow good management practice.
Land farms shall consider the following:
• Type of soil • Runoff control
• Depth of groundwater • Fertilization methods and techniques
• Type and amount of contaminants • Maintenance techniques
• Local maximum precipitation • Monitoring techniques and schedule
Applications
Small, superficial hydrocarbon spills and equipment leaks can be treated in situ.
Removing or excavating the contaminated soil may not be necessary and in some cases,
may be cost prohibitive. In these cases, the affected area should be routinely aerated and
fertilized. The soil may be periodically sampled and analyzed to determine the total
petroleum hydrocarbon concentration.
Larger land farms may be constructed on a designated area of land for more long-term
use. In these cases, it should be specifically designed so that its base has an impermeable
liner (either natural clay or geotextile membrane). Runoff shall be controlled, collected
and treated, as necessary, and periodic impact monitoring shall be conducted to ensure
that no groundwater impact has occurred.
These land farms may be used to dispose of routinely generated hydrocarbon sludge and
large volumes of hydrocarbon-contaminated soils for which other acceptable disposal
methods are costly, unavailable or otherwise unacceptable.

Revision: 0
Issued: 20-Nov-1999
Doc. # ENV-049
1. Purpose
This guideline establishes the requirements to be followed by Operations personnel to maintain
documentation for key aspects of waste management programs described in prior guidelines.
2. Scope
3. Guideline
3.1 General
Operations personnel shall maintain documentation for key aspects of waste management
programs.
3.2 Records
Recommended documentation and retention periods for such documentation is as
follows:
Weekly Storage Inspections................................................... ........... 3 years

Land Farm Management
• Monitoring Records............................................................... 3 years
• Design/Location .................................................................... Lifetime
Employee Training ............................................................................ 3 years
Waste Minimization Program............................................................ 3 years
Applied Pesticides, Herbicides and Insecticides ............................... Lifetime

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-050

Revision: 0
Issued: 20-Nov-1999
Off-Site Waste Management
Selecting Transportation and Disposal Services Doc. # ENV-051
1. Purpose
evaluating local transportation and disposal service providers for handling generated wastes.
2. Scope
3. Guideline
3.1 General
Operations personnel shall be aware of procedures for evaluating transportation and
disposal service providers who will handle waste generated during routine operations.
3.2 Considerations
Environmental considerations when evaluating a disposal service provider shall include
the following:
• General housekeeping • Waste storage
• Secondary containment • Odors
• Effluent discharge(s) • Site security
• Emissions • Worker health and safety
• Nearby receptors (residences,
schools, surface waters, etc.)
The following procedures shall be followed when evaluating disposal service providers:
• Local regulations shall be reviewed to determine permitting, licensing and
registration requirements of waste transportation and disposal services. For continued
investigation, select only waste transportation and disposal service companies that
have appropriate permits, licenses and registrations required by local regulations.
• Investigate the reputations of potential service providers by requesting references,
making inquiries to those references and inquiring with local environmental agencies
about the provider.
• Determine the limits of liability of the service company’s insurance.
• Determine the proposed method(s) of disposal and the disposal location(s). Certain
methods of disposal shall be avoided and include the following:
a. Dumping of any kind and abandonment
b. Illegal export
c. Burial of hazardous materials or hazardous waste without stabilization
d. Land application without land farm management techniques
• Visit the potential service provider's area of operation and have an appropriately
qualified internal or external environmental professional conduct an audit of storage
stations and disposal sites to ensure that potential environmental risks are minimized.
Such audits shall be performed and periodically documented to ensure conformance.
4 References
4.1 Internal Standard
A sample Treatment, Storage and Disposal Facility Audit Form is provided in Attachment
Appendix 1 for additional reference.

Revision: 0
Issued: 20-Nov-1999
Appendix 1
INTERNATIONAL ENVIRONMENTAL CHECKLIST
FOR WASTE TRANSPORTATION AND DISPOSAL FACILITIES
NAME OF FACILITY:
LOCATION:
AUDIT DATE:
Circle all applicable:
Transportation/Storage Landfarm Landfill Recycle/Recover Incinerate
AUDIT COMMITTEE MEMBERS:
Note: It is recommended that a preliminary investigation be conducted to obtain relevant information prior to
conducting a physical inspection of the facility.
I. PERMITS, CLEARANCES AND INSURANCE
1. Is the facility required to obtain and maintain an environmental permit or license from a government
agency for its operation?
If NO, proceed to question 4.
2. Does the owner/operator have a copy of the permit/license, etc. available for review?
3. Are these currently valid for the location and type of operation?
4. Is the owner/operator in good standing with local officials?
5. Does the facility have liability insurance to cover its operations, including vehicles to transport
waste?
If NO, proceed to Section II
6. Does the Insurance conform to Enron Corp’s Risk Management Guidelines?
If not, has Enron Corp’s Risk Management reviewed the policy?
II. TRANSPORTATION ACTIVITIES
1. Does the owner/operator of the waste disposal facility offer transportation services?
2. Does the owner/operator of the waste disposal facility contract a third party for transportation
services?
3. Are transportation vehicles equipped with placards or warning signs to indicate hazards?
4. Has the transporter acquired all special permits and/or licenses required by local laws?

Revision: 0
Issued: 20-Nov-1999
II. TRANSPORTATION ACTIVITIES (Continued)
5. Have drivers undergone any special training to respond to spills or releases that could occur during
transport?
6. Observe the general condition of the transportation vehicles and indicate the following:
a. Both turning signals work?

b. Both headlights work
c. Brake lights work?
d. Emergency flashers work?
e. Horn works?
f. Tires, including spare, appear in good condition?
III. OPERATIONS
1. Observe the general level of housekeeping around the facility, especially loading/unloading and
storage areas.
2. Determine the types and amounts of security, emergency and spill control equipment?
a. Are emergency instructions posted?

b. Does the facility have security fencing and restricted access?
c. Is communication equipment easily accessible by personnel?
d. Are there sufficient alarms and communication equipment?
e. Are fire extinguishers easily available?
f. Do storage areas and fuel unloading/loading areas have secondary containment?
g. Does the facility have spill control equipment on site?
3. Are personnel equipped with (PPE) personal protective equipment?
4. Inspect Waste Storage areas and observe the following:
a. Are waste containers labeled with its contents and hazards?

b. Are incompatible materials segregated?
c. Is the aisle space adequate to allow emergency access and egress?
d. Are storage areas equipped with a fire extinguisher?
e. Do personnel regularly inspect storage areas?
5. Observe facility drainage systems for the following:
a. Is precipitation from storage areas controlled?

b. If the outfall is visible, is there any evidence of past contamination (discoloration, stains, dead or
stressed vegetation)
IV. GENERAL COMPLIANCE
1. Does the facility have a formal “Safety Program”?
2. Are there any public complaints against the facility?
3. Is the facility considered a “Good Neighbor”?
Obtain a list of other companies that have or are using the facility’s services

Revision: 0
Issued: 20-Nov-1999
Documenting Transportation and Disposal Services Doc. # ENV-052
1. Purpose
documenting local transportation and disposal service providers for handling general wastes.
2. Scope
3. Guideline
3.1 General
Documenting waste streams that are disposed of off site is critical to managing the
potential for liabilities associated with such disposal.
3.2 Considerations
Operations personnel shall follow this guideline when documenting the actual waste
handling services performed by local transportation and disposal service providers.
Documentation of transportation and disposal services should be implemented to ensure
proper management of such services. Various formats and forms can be utilized for this
purpose and shall include the following information:
• Name and physical location of the disposal facility
• Name and physical location of the transporter including vehicle number, license plate
number, etc.
• Date
• Type and approximate quantity of waste
• Name or initials of the facility personnel directing the shipment
The facility should request and receive confirmation in writing from the disposal service
upon receipt of the waste material. This shall be attached to or cross-referenced to the
information above.
3.4 Records
The following establishes recommended documentation and retention periods for that
documentation associated with off site waste disposal:
Waste Characterization Data
Used oil analyses........................................................................................................ 5 years
Molecular sieves.............................................................................. 5 years or per test batch
Used glycol filters ....................................................................................................Lifetime
Other waste...........................................................................................Until process change
Transportation and Disposal Services
Audit information.......................................................................................................3 years
Transportation and disposal records.........................................................................Lifetime

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-053

Revision: 0
Issued: 20-Nov-1999
Definition and General Guidance Doc. # ENV-054
1. Purpose
This guideline establishes the requirements to be implemented by Operations personnel with
responsibilities for managing process wastewater.
2. Scope
3. Guideline
3.1 General
Process wastewater is defined as any water used in the facility’s operations that comes
into direct contact with a raw material, product or pollutant. Contacted materials include
gas, oil, chemicals, heat, solid wastes, sewage and garbage. . This guideline outlines and
reviews basic principles for the development of procedures to ensure safety and
efficiency.
3.2 Considerations
Examples of process waters are as follows:
• Cooling water
• Filter backwash
• Boiler blowdown
• Cooling tower blowdown
• Wash water
• Oily water separator effluent
• Condensates
• Other gas processing, fresh water and brine used in the injection and withdrawal of
hydrocarbons from underground salt caverns
Identify process wastewaters generated at the facility and the method by which they are
disposed of or managed. At a minimum, all process water shall be discharged in a
manner consistent with the applicable local regulations. Management options may
include:
• On-site deep well injection
• Direct discharge into surface waters
• Discharge to facility-owned land surface
• Discharge directly to a publicly owned treatment works or municipal treatment
system
If an on-site method for managing a process wastewater is not available, the material can
be transported off site to a commercial facility for proper treatment and/or disposal (i.e.,
permitted, commercial injection well or municipal system). Water that is disposed of in
this manner must be disposed of as a solid waste and shall be handled in accordance with
Guidelines ENV-030 “Unclassified Materials” and ENV-029 “Waste Characterization.
Water treatment permits and authorizations may be required prior to discharge to any of
these sources.

Revision: 0
Issued: 20-Nov-1999
Definition and General Guidance Doc. # ENV-054

Some other considerations when managing process wastewater are as follows:
• Determine the quality and quantity of process wastewater discharges based on actual
analytical testing or the processes from which they are generated. This may be
facilitated by flow diagrams and water use descriptions.
• Ensure that the facility is properly authorized to manage and dispose of the
wastewater. Apply and obtain necessary permits, registrations, etc.
• Determine the monitoring requirements, parameters, limitations and recordkeeping
requirements.
• Develop and implement facility-specific wastewater management procedures that
address effluent sources, permits/registration(s), monitoring program(s) and
recordkeeping.
• Establish an effluent monitoring and recordkeeping program based on the fact that
sampling and analyses should follow standard methods including quality assurance
and quality control.
• Some environmental agencies require that analytical testing be performed by only
authorized laboratories.
• Ensure that personnel are appropriately trained in the operation and maintenance of
water treatment systems, monitoring programs and reporting requirements.
• If facility modifications result in a change in the quantity or quality of process
wastewater, the effluent must be reevaluated to determine its characteristics,
treatment/disposal options, monitoring and permitting requirements.

Revision: 0
Issued: 20-Nov-1999
Containment Area Discharges Doc. # ENV-055
1. Purpose
This guideline establishes the requirements to be followed by Operations personnel with
responsibility for draining or discharging accumulated water from containment areas.
2. Scope
3. Guideline
3.1 General
Operations personnel shall use the correct procedures for drafting or discharging water
that accumulates in containment areas. This guideline outlines responsibilities and
reviews basic principles for the development of procedures to ensure the safe and
efficient operation of containment draining.
Containment areas shall be visually inspected in accordance with Company guidelines.
Accumulated precipitation should be discharged in accordance with the following
guidelines:
• If the precipitation does not have a hydrocarbon sheen and there is no reason to
suspect other contamination that cannot be visually detected, the water can be drained
directly to the ground, routed to an oily water separator or pumped for use in the plant
as noncontact cooling water, etc.
• If a hydrocarbon sheen is present, the water shall be pumped to an oily water
separator or otherwise recovered.
• If there is reason to suspect other contamination besides hydrocarbon, consult with
the Regional EHS Manager for disposal alternatives.
• The drainage valve to the containment area shall remain in the closed position except
when actively draining the containment area.
• Drainage activity shall be monitored by personnel and the valve closed upon
completion.

Revision: 0
Issued: 20-Nov-1999
Discharge Limits and Monitoring Guidelines Doc. # ENV-056
1. Purpose
This guideline establishes the requirements to be followed to ensure compliance with discharge
water limits and proper monitoring for verifying water quantity and quality returning to surface
waterways.
2. Scope
3 Guideline
3.1 General
Presently under development as of 11-4-1999.

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-057

Revision: 0
Issued: 20-Nov-1999
Domestic Sewage Doc. # ENV-058
1. Purpose
responsibility for the handling of sewage generated at facility locations.
2. Scope
3. Guideline
3.1 General
Sewage generated at a facility shall be collected and treated in a properly designed septic
tank system or other on-site treatment system (i.e., sewage treatment plant) or discharged
directly into a municipal system.
3.2 Considerations
Proper handling of sewage is essential to prevent illness in personnel or the community
through exposure to raw sewage or contamination of waterways or the environment. This
efficiency. Local regulations and, where applicable, World Bank Guidelines shall be
consulted to determine any permitting or registration requirements as well as monitoring
requirements.
Under no circumstances should raw sewage be discharged into public or private waters or
land.
Sewage systems, including discharges into a municipal system, shall only be used for
their intended purposes and should not be used to dispose of oil, grease, paints, solvents,
chemical residues or other solid wastes.
If the system requires the periodic removal of accumulated wastes, arrangements shall be
made with a local vacuum service or similar contracted service for its removal and
disposal. These materials should not be broadcast onto the land.
Contact the Regional EHS Manager for assistance in locating removal and disposal
services, as needed.

Revision: 0
Issued: 20-Nov-1999
Hydrostatic Test Water Discharges Doc. # ENV-059
1. Purpose
responsibity for discharges of hydrostatic test water.
2. Scope
3. Guideline
3.1 General
Local regulations may require special permits or authorizations for the discharge of
hydrostatic test water. Refer to Operating Company site-specific procedures to determine
such requirements.
The following minimum guidelines shall be observed:
• Refer to local regulations to determine if special permits or authorizations are
required. Obtain necessary permits or authorizations from the local environmental
agency.
• Determine if the hydrostatic test water is likely to be contaminated. For new pipe and
installations, it may be assumed that no contamination exists. If the water is used to
flush an in-service pipe or system prior to cleaning or maintenance, this determination
should be made based on the type of materials in the system. In some cases, it may
be necessary to store the hydrostatic water in a holding tank to allow proper analysis.
• Unless otherwise specified, hydrostatic test water from new piping and installations
may be discharged directly to the ground, sewer or other on-site treatment systems.
Hydrostatic test waters from other piping and installations that may be contaminated
shall be discharged to appropriate treatment systems. However, if tested and
determined to be “clean”, they may be discharged to the ground or sewer. In some
cases, hydrostatic test water may be reused depending on its water quality
characteristics.
• If discharging to adjacent property or if there is a potential that the discharge will
drain onto adjacent property, seek written approval from the landowner.
3.3 Records
Document the hydrostatic discharge event including the source of the hydrostatic water,
analytical reports, permits, landowner approvals, etc.

Revision: 0
Issued: 20-Nov-1999
Aquatic Monitoring Doc. # ENV-060
1. Purpose
This guideline establishes the requirements to be followed by Operating personnel with
responsibility for ensuring that aquatic monitoring requirements for projects and operations are
implemented.
2. Scope
3. Guideline
3.1 General
Potential impacts to aquatic flora and fauna are site and source specific. Therefore, the
Operating Company’s site-specific environmental procedures shall address any
requirements for monitoring such impacts. These monitoring requirements are usually
described in the project’s Environmental Impact Assessment or similar document.

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-061

Revision: 0
Issued: 20-Nov-1999
Greenhouse Gas Emissions Doc. # ENV-062
1. Purpose
The guideline establishes the requirements to be followed for the inventory and proper control of
Greenhouse Gas (carbon-based) emissions in compliance with Air Quality Management
requirements.
2. Scope
3. Guideline
3.1 General
Air Quality Management requirements are generally source specific or facility site
specific. The type of industry or source, fuel, ambient conditions and local regulations
determines emission limits.
3.2 Considerations
Monitoring of emissions including in-line emissions monitors, stack or source testing and
ambient monitoring programs is determined by the environmental regulations to which a
facility is subject. It is Enron’s policy to conduct its business in compliance with all
applicable regulations.
New construction, facility modifications, expansions and the acquisition of existing assets
may be subject to stringent air quality regulations including those for permitting,
allowable emissions, monitoring and testing.
“Greenhouse gas” is a term that is sometimes used to refer to atmospheric emissions of
carbon gases (CH4, CO2, halocarbons or CFCs,) and N2O. It is believed that carbon
emissions contribute to global climatic change, sometimes referred to as “global
warming”. As a result of this belief, many nations have committed to reducing their
annual production of carbon emissions.
Enron believes that such reductions, whether voluntary or mandatory, can be achieved
through market-based solutions and plans to offer the sale and trading of carbon
emissions in its portfolio of services. In order to undertake this business opportunity,
Enron must maintain an accurate inventory of its own carbon-based emissions including
methane (CH4) and must systematically apply and obtain credit for any realized carbon
emission reductions. The management of such an inventory program requires
cooperation and communication between all levels of management. This inventory will
reside in the Enron Environmental Database.
All facilities shall make reasonable attempts to ascertain its carbon-based emissions.
Tracking of emissions can be achieved through the implementation of the Enron
Environmental database.
Report any current or planned activity that affects the quantity of greenhouse gas
emission to Enron’s Global Affairs Group (Houston) for appropriate documentation and
reporting.

Revision: 0
Issued: 20-Nov-1999
Stack Emissions, Controls and Monitoring Doc. # ENV-063
1. Purpose
This guideline establishes the requirements to be followed for the control and monitoring of
stack emissions at Company facilities.
2. Scope
3. Guideline
3.1 General
Each Operating Company’s environmental procedures shall address local environmental
regulatory requirements and, as applicable, World Bank Environmental Guidelines
concerning emission limits, control of emissions and the monitoring of emissions. This
guideline outlines and reviews basic principles for the development of procedures to
3.2 Considerations
Air Quality Management requirements are generally source-facility site specific and are
determined by the type of industry or source, fuel, ambient conditions and local
regulations. The monitoring of emissions including in-line emissions monitors, stack or
source testing and ambient monitoring programs are determined by the environmental
regulations to which a facility is subject. It is Enron’s policy to conduct its business in
compliance with all applicable regulations.
• New construction, facility modifications and expansions and the acquisition of
existing assets may be subject to stringent air quality regulations including those for
permitting, allowable emissions, monitoring and testing.
• It is recommended that site-specific procedures describe combustion equipment
including source identification, fuel specification, emission limits by pollutant,
emission controls (i.e., water or steam injection or combustion technology),
monitoring requirements (i.e., continuous emission monitoring requirements or stack
testing) and excess emission reporting requirements as mandated by local permits.
• An inventory of emissions shall be maintained in the Enron Environmental Database.
• Each Operating Company is responsible for ensuring compliance with emission
limits, operating limits and source monitoring requirements specified in local permits
or licenses and the Environmental Impact Assessment.
• Emissions from Enron facilities may include the following constituents:
a. CH4 == Methane
b. CO == Carbon monoxide
c. CO2 == Carbon dioxide
d. NOx == Nitrogen oxides
e. PM2.5 == Particulate matter less than 2.5 microns in size
f. PM10 == Particulate matter less than 10 microns in size
g. SO2 == Sulfur dioxide
h. TSP == Total suspended particulates
i. TUH == Total unburned hydrocarbons
j. UH == Unburned hydrocarbons
k. Greenhouse Gases == Carbon emissions (CO, CO2, halocarbons), methane and
NOx

Revision: 0
Issued: 20-Nov-1999
Ambient Air Quality Monitoring Program Doc. # ENV-064
1. Purpose
This guideline establishes the requirements to be followed for ensuring compliance with an
ambient air quality monitoring program.
2. Scope
3. Guideline
3.1 General
Air Quality Management requirements are generally source-facility site specific. The
type of industry or source, fuel, ambient conditions and local regulations determines
emission limits. This guideline outlines basic principles for the development of
procedures to ensure compliance and efficiency.
3.2 Considerations
The monitoring of emissions including in-line emissions monitors, stack or source
testing. Ambient monitoring programs are determined by the environmental regulations
to which a facility is subject. It is Enron’s policy to conduct its business in compliance
with all applicable regulations.
• New construction, facility modifications and expansions and the acquisition of

existing assets may be subject to stringent air quality regulations including those for
permitting, allowable emissions, monitoring and testing.
• Each Operating Company’s Environmental Procedures shall address local ambient air
monitoring programs that may be required by local environmental regulations and
World Bank Environmental Guidelines, as applicable.
• The details for such monitoring requirements including appropriate sampling
methodology and protocols are usually described in the Environmental Impact
Assessment.
• Each Operating Company is responsible for ensuring compliance with all
requirements of an ambient air monitoring program.

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-065

Revision: 0
Issued: 20-Nov-1999
Asbestos Management
Policy and Definitions Doc. # ENV-066
1. Purpose
This guideline establishes the requirements to be followed for the storage and disposal of
asbestos-containing materials at all Enron facilities.
2. Scope
3. Guideline
3.1 General
Each Operating Company shall utilize appropriately qualified and trained contractors or
employees for the encapsulation and/or removal of friable asbestos-containing material.
This guideline outlines terminology and reviews basic principles for the development of
3.2 Considerations
Detailed qualification and training requirements are available in the Enron Global Asset
Operations Safety Guidelines or by contacting the Regional EHS Manager. Local
regulations shall be thoroughly reviewed to determine additional requirements. Each
Operating Company is responsible for ensuring compliance with local regulations
regarding the removal, storage and disposal of asbestos.
Definitions:
The following terms shall be used to for characterization of asbestos related projects:
Friable Asbestos is any material containing more than 1% asbestos which, when dry, can
be crumbled, pulverized or reduced to powder by hand pressure.
Non-Friable Asbestos is any material containing more than 1% asbestos which, when
dry, cannot be crumbled, pulverized or reduced to powder by hand pressure. Under U.S.
EPA regulations, these are subdivided into Category I and Category II materials.
Category I materials originate from gaskets, resilient floor covering (floor tiles) packing,
and asphalt roofing products. Category II materials originate from all other sources not
specified in Category I.
Demolition is the wrecking or removal of any load-supporting structural member of a

building together with any related handling operations or the intentional burning of a
building for destruction purposes.
Renovation is the altering of a building or one or more building components in any way.
Enron Global Asset Operations discourages the use of asbestos-containing materials in
new construction or maintenance activities. If a construction or maintenance activity
requires the use of an asbestos-containing material, the Regional EHS Manager shall be
contacted for approval.

Revision: 0
Issued: 20-Nov-1999
Asbestos Management
Notice to Perform Work Doc. # ENV-067
1. Purpose
This guideline establishes the requirements to be followed by Operations personnel to notify the
proper authorities when working on projects that involve the removal of asbestos-containing
materials.
2. Scope
3. Guideline
3.1 General
Operations personnel shall be appropriately qualified and trained when working on
projects that require the removal of asbestos-containing materials from Company
facilities. This guideline outlines and reviews basic principles for the development of
3.2 Considerations
Operations Safety Guidelines Manual or can be obtained by contacting the Regional EHS
Manager. Local regulations shall be thoroughly reviewed to determine additional
requirements. Each Operating Company is responsible for ensuring compliance with
local regulations regarding the removal, storage and disposal of asbestos.
The Operating Company shall notify the Regional EHS Manager at least 30 days prior to
commencing any project in which asbestos-containing materials will be removed. This
notification should include the following:
• Source and description of activity generating the material
• An estimated quantity to be generated (in linear feet, square feet or cubic feet)
• The date work is to begin
• The name and number of personnel performing the removal
The Operating Company shall contact the Regional EHS Manager for assistance in
obtaining the appropriate permits, where required, and arranging for transportation and
disposal services.

Revision: 0
Issued: 20-Nov-1999
Asbestos Management
Storage And Disposal Doc. # ENV-068
1. Purpose
This guideline establishes the requirements to be followed by Operations personnel with the
responsibility for the storage and disposal of asbestos-containing material that has been removed
from Company facilities.
2. Scope
3. Guideline
3.1 General
Operations personnel shall be appropriately qualified and trained when working on
projects that require the removal of asbestos-containing materials from Company
facilities. This guideline outlines and reviews basic principles for the development of
3.2 Considerations
Operations Safety Guidelines or can be obtained by contacting the Regional EHS
Manager. Local regulations shall be thoroughly reviewed to determine additional
requirements. Each Operating Company is responsible for ensuring compliance with
local regulations regarding the removal, storage and disposal of asbestos.
Storage
Asbestos-containing material shall be stored wet until it is collected for disposal. After
wetting, double bag and seal all asbestos-containing material in a leak-proof plastic bag.
The plastic bag should be 40–60 millimeters thick. It is considered “collected” when it
has been double-bagged, sealed and labeled. Label each bag as follows:
DANGER:
CONTAINS ASBESTOS FIBERS -- AVOID CREATING DUST -- CANCER
AND LUNG DISEASE HAZARD
Disposal
Asbestos-containing material shall be disposed of as soon as practical. Each Operating
Company is responsible for the proper disposal of asbestos-containing material. This
responsibility shall not be delegated to a contractor, transporter or other environmental
service agent. The Regional EHS Manager should be contacted for advice or assistance
regarding the selection and arrangement of proper disposal.
The following guidelines shall be followed:
• All necessary precautions shall be undertaken to avoid accidental damage to
containers holding asbestos-containing materials.
• If transporting in an open vehicle, bagged material shall be covered with a tarp or
other cover.
• Asbestos-containing material should be deposited in an authorized landfill. If the
landfill is not properly authorized by the local environmental agency or does not have
a dedicated area and site-security for asbestos-containing materials, it should be
avoided.
• The Regional EHS Manager should review and approve of the disposal location.

Revision: 0
Issued: 20-Nov-1999
Asbestos Management
Storage And Disposal Doc. # ENV-068
3.4 Records
If the asbestos-containing material is to be disposed in an on-site landfill (within facility
boundaries), its exact burial location should be appropriately documented and such
records shall be made available to any potential buyers. These records shall remain with
the facility for the life of the facility.
Documentation of off-site transportation and disposal should be retained in facility
records for 3 years.

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-069

Revision: 0
Issued: 20-Nov-1999
Underground Storage Tanks Doc. # ENV-070
1. Purpose
handling underground storage tanks in order to ensure personnel safety and minimize potential
risks.
2. Scope
3. Guideline
3.1 General
Underground storage tanks (USTs) are commonly used to store crude oil, lubricating oils,
condensates and motor vehicle gasoline and diesel for vehicle or equipment refueling. .
3.2 Considerations
This guideline is intended to address Best Management Practices related to the
management of such tanks. This guideline outlines and reviews basic principles for the
Enron Global Asset Operations discourages the installation of USTs; however, existing
USTs should be carefully managed and monitored by the Operating Company to
minimize risks associated with faulty tanks. Experience has shown that over time,
underground storage tanks will leak. Therefore, the following shall apply:
• Ensure that USTs are equipped with appropriate cathodic protection.

• Implement an Inventory Control System to detect product losses.
• Reconciliations should be performed monthly or in accordance with delivery and use
schedules.
• A procedure to investigate the cause of product losses should be developed and
implemented including documentation procedures.
• Install a slotted pipe near the tank to a depth equal to the bottom of the UST. Monitor
this open-ended pipe for vapors that may indicate potential leaks.
• Perform regular pressure tests to determine the tank’s ability to maintain pressure.
• If the USTs are utilized for company vehicle refueling, evaluate the savings by
eliminating their use and obtaining fuel from off-site third party filling stations.

Revision: 0
Issued: 20-Nov-1999
Aboveground Storage Tanks Doc. # ENV-071
1. Purpose
This guideline establishes the requirements to be followed by Operations personnel handling
aboveground storage tanks in order to ensure personnel safety and minimize potential risks.
2. Scope
3. Guideline
3.1 General
Operations personnel shall be trained in the correct procedures of handling aboveground
storage tanks (ASTs).
3.2 Considerations
This guideline outlines and reviews basic principles for the development of more detailed
The following procedures shall be followed when handling ASTs:
• Ensure that ASTs are equipped with appropriate cathodic protection.
• Avoid using riveted tanks to store hydrocarbons or other hazardous materials.
• It is strongly recommended that tanks storage materials listed below have a “pad” and
“adequate” secondary containment such that the capacity of the containment system
is large enough to hold the entire contents of the single largest tank in the contained
area plus sufficient freeboard for average precipitation (during 100 year flood).
a. Glycol
b. Methanol
c. Produced water (salt water)
d. Amines (sweetening agents)
e. MTBE
f. Sulfuric acid
g. Sodium hydroxide
h. Mercaptans (odorants)
i. Ammonia
j. Hydrochloric acid
• Ensure that the floor and walls are constructed of an impermeable material and
sealed, where necessary.
• Visually inspect weekly for leaks and signs of deterioration.
• Implement an inventory control system to detect potential leaks.
• Mark all ASTs to identify contents and hazards with letters and symbols large enough
to be read from a distance of 10 feet.

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-072

Revision: 0
Issued: 20-Nov-1999
PCB Management
Notification Guideline Doc. # ENV-073
1. Purpose
This guideline establishes the requirements to be followed by Operations personnel in notifying
the Regional EHS Manager of the existence of polychlorinated biphenyls (PCBs) at Company
facilities.
2. Scope
3. Guideline
3.1 General
Polychlorinated biphenyl’s (PCBs) belong to a broad family of organic chemicals known
as chlorinated hydrocarbons. The commercial production of PCBs began in 1929. They
were widely used as ingredients in the manufacture of heat transfer fluids, hydraulic
fluids and dyes as well as for cooling and dielectric fluids in electrical transformers, light
ballast and electrical capacitors.
In the 1970s, research concluded that PCBs pose a significant threat to human health and
the environment. Consequently, the U.S. Environmental Protection Agency issued a ban
in 1979 against the further production of PCBs in the United States. Because of the
tendency of PCBs to migrate to other environmental media and progressively
bio-accumulate, the storage and disposal of PCBs and PCB-contaminated materials was
also strictly regulated.
Many countries around the world have since enacted similar regulations to restrict the
use, storage and disposal of PCBs. In a number of these countries, affected facilities
must inventory and quantify PCBs and implement a phase-out schedule for replacement.
Generally, materials are declared “PCB-free” if the concentration of PCBs is less than
50 ppm (<50 ppm). However, local regulations should be consulted to determine
compliance requirements.
Because PCBs were used extensively throughout the world, Operating Companies may
occasionally generate PCB waste. These may include compressor lubricating oils,
turbines and starting air compressors, cold weather valve grease (Rockwell valve grease)
and electrical equipment (light ballast).
3.2 Considerations
This guideline outlines terminology, responsibilities and reviews basic principles for the
Definitions:
Unless otherwise defined in local regulations, the following definitions shall be applied:
PCB Article - Any manufactured article other than a PCB container (as defined below)
that contains PCBs (50 ppm or greater) and whose surface has been in direct contact with
PCBs. This includes capacitors, transformers, electric motors, pumps, valves and pipes.
PCB Article Container - Any package, can, bottle, rag, barrel, drum, tank or other device
used to contain PCB articles or PCB equipment and whose surface has not been in direct
contact with PCBs.
PCB Bulk Product Waste - Fluorescent light bulb ballasts that contain PCB in the potting
material if the PCB content is ≥50 ppm at the time of designation for disposal.

Revision: 0
Issued: 20-Nov-1999
PCB Management
Notification Guideline Doc. # ENV-073
3.2 Considerations (Continued)
PCB Container - Any package, can, bottle, bag, barrel, drum, tank or other device that
contains PCBs or PCB articles and whose surface has been in direct contact with PCBs.
An example of a PCB container is a drum that held leaking light ballast.
PCB Contaminated - Any electrical equipment including transformers, capacitors and
circuit breakers whose dielectric fluids contain PCBs in concentrations of 50 ppm or
greater but less than 500 ppm.
PCB Equipment - Any manufactured item (other than PCB container or PCB article
container) which contains a PCB article or other PCB equipment including microwave
ovens, electronic equipment and fluorescent light ballast and fixtures.
PCB Item - Any PCB article, PCB article container, PCB container or PCB equipment
that contains PCBs.
PCB Transformer - Any transformer containing PCBs in concentrations equal to or
greater than 500 ppm.
PCB Waste - Any PCB liquid (e.g. dielectric fluid) or solid (e.g. rags or soil) with PCBs
in concentrations greater than or equal to 50 ppm.
PCB-Free (No PCBs) - Items that contain less than 50 ppm PCBs.
The Regional EHS Manager shall be notified of the type, quantity and concentration of
PCBs found as well as provide a schedule for planned maintenance to remove PCBs from
service.
The Operating Company Manager shall be responsible for ensuring that the facility has
obtained necessary local permits and shall seek assistance from the Regional EHS
Manager, as needed, to locate third-party transportation and disposal services.
Notification of such removal should be provided as far in advance as possible in order to
ensure the issuance of appropriate permits and conduct personnel training.

Revision: 0
Issued: 20-Nov-1999
PCB Management
Labeling Guideline Doc. # ENV-074
1. Purpose
This guideline establishes the requirements to be followed by Operations personnel who are
responsible for labeling containers and equipment that contains polychlorinated biphenyls
(PCBs) at Company facilities.
2. Scope
3. Guideline
3.1 General
Operations personnel shall be aware of the proper procedures for labeling containers or
equipment that contain PCBs.
3.2 Considerations
This guideline outlines responsibilities and reviews basic principles for the development
of procedures to ensure safety and efficiency when handling PCBs at Company facilities.
PCBs should be clearly labeled. In the absence of local regulations requiring specific
markings and labels, these markings shall be made as described below:
• Lettering shall be black on a white or yellow background.
• Stickers shall be durable enough to last the life of the PCB item.
• Sticker size shall be selected from the following ranges and shall be sized
proportionately to the item on which it has been placed:
a. 6 inches x 6 inches
b. 2 inches x 2 inches
c. 1 inch x 2 inches
d. 0.4 inches x 0.8 inches
The following items shall be labeled:
• PCB containers
• PCB transformers
• PCB high-voltage capacitors (in-service)
• Equipment containing a PCB transformer or a PCB large high-voltage capacitor (in-
service)
• PCB low-voltage capacitors when removed from service
• Electric motors using PCB coolants
• Hydraulic systems using PCB hydraulic fluid
• Heat transfer systems using PCBs (other than PCB transformers)
• PCB storage areas
• Vehicles used to transport liquid PCB containers and PCB transformers
• Accesses to a PCB transformer (so that firefighters can see it)

Revision: 0
Issued: 20-Nov-1999
PCB Management
Inventory Guideline Doc. # ENV-075
1. Purpose
This guideline establishes the requirements to be followed by Operations personnel to track the
handling of PCB equipment used within their operations.
2. Scope
3. Guideline
3.1 General
Operating Companies shall inventory their PCB items annually in order to track removal
and replacement progress.
3.2 Considerations
of procedures to ensure safety and efficiency.
Information included in the annual inventory includes the following:
• Name and address of the facility
• Facility environmental contact
• For bulk PCBs (tank truck or trailer), an estimate of the weight and date of removal
• The serial number or other means of identifying each PCB article (transformer,
capacitor, etc.) and date of removal
• For PCB containers, a description of their contents, an assigned inventory number
unique to each container, total weight of each container and date of removal
• Total number of PCB articles (distinguishing transformers from capacitors)
• Total number of PCB containers
• Total number of PCB transformers still in service at the end of the calendar year
including the serial number
• Total number of PCB capacitors still in service at the end of the calendar year
including the serial number
• Total weight of PCB items and any PCBs still in service at the end of the calendar
year (specify)
• Identification of the transportation and disposal dates, name of the transporter and
name of the disposal company for each PCB item disposed of during the calendar
year (should correspond to the appropriate serial and inventory numbers previously
assigned)
3.4 Records
Copies of inventories shall be provided to the Regional EHS Manager upon request and
stored on-site in facility environmental records for reference.

Revision: 0
Issued: 01-Oct-99
Review Due: mm/yy
PCB Management
Storage and Inspection Guideline Doc. # ENV-076
1. Purpose
This guideline establishes the requirements to be followed by Operations personnel who are
responsible responsibility for the handling and inspection of PCBs stored on site.
2. Scope
3. Guideline
3.1 General
Operations personnel shall be trained in the proper handling inspection of PCBs stored at
the Company facility. This reviews basic principles for the development of procedures to
3.2 Considerations
Storage Area Design Considerations
Storage areas for PCBs shall be designed with the following considerations:
• PCBs should be not stored at a facility that is in the 100-year flood plain.
• The roof and walls of the storage area should be sufficient to prevent container
contact with rainwater.
• The entrance to the storage area should have a warning sign in lettering large enough
to be read at a distance of 25 feet that reads as follows:
WARNING
PCB STORAGE AREA
• The floor and curbing of the container area should meet the following criteria:
a. Floors should have a continuous 6-inch curb large enough to contain 25% of the
total volume stored or twice the volume of the largest container stored, whichever
is greater.
b. The containment area should not have any openings in the floor or curb (including
valved openings).
c. Floor and curbing should be constructed of a smooth, impervious material such as
Portland cement, concrete or steel.
Storage Container Guidelines
Containers and drums used to store PCBs shall be U.S. Department of Transportation
(DOT) approved. When ordering, the supplier will need to know the following
specification descriptions:
• Material Description: Polychlorinated Biphenyl
• Hazard Class of Division: 9
• UN Identification Number: UN2315
• Packing Group: II
PCB liquids shall be stored in close-headed drums and PCB solids in open-headed drums.
3.4 Records
Containers shall be inspected weekly for leaks and spills. Inspection forms should clearly
identify that the storage area is dedicated to PCB storage. The inspection form in
Guideline ENV-006, Facilities Inspections, should be used. The completed form should
be stored in facility files for 3 years.

Revision: 0
Issued: 20-Nov-1999
PCB Management
Guideline for Disposal of PCB Wastes Doc. # ENV-077
1. Purpose
responsibility for disposing of PCB waste and articles generated or used at Company facilities.
2. Scope
3. Guideline
3.1 General
of procedures to ensure safety and efficiency when disposing of PCB waste.
3.2 Considerations
Some countries require the use of certain documents (i.e. manifests) in order to transport
and dispose of PCB materials. Consult the Operating Company Procedures Manual or
contact the Regional EHS Manager for local requirements.
PCBs should be disposed at an approved facility within one year from the date they were
first generated, where possible. If PCBs require on-site storage in excess of one year,
notify the Regional EHS Manager.
In most cases, all PCB waste and articles must either be incinerated at an incinerator
approved to accept PCBs or disposed of at a chemical waste landfill approved to accept
PCBs.
PCB waste exceeding 500 ppm and ignitable PCB waste should not be disposed of at a
chemical waste landfill.
For information regarding approved disposal facilities in specific countries, refer to the
local Operating Company Procedures Manual or contact the Regional EHS Manager for
additional information.
3.4 Records
The Annual Report should reflect transportation and disposal information on PCBs (refer
to Guideline ENV-013 “Annual EHS Report”). Ensure that the information is
coordinated and that all documents reflect true and accurate information.
The following information regarding transportation and disposal services for PCBs
should be recorded:
• Disposal facility name and location
• Transporter name and location including vehicle number, license plate number, etc.
• Date
• Type of PCB waste including a description of container contents
• Weight of each item and total weight
• Name and signature of facility representative directing the shipment

Revision: 0
Issued: 01-Oct-99
Review Due: mm/yy
PCB Management
Guideline for Recordkeeping and Personnel Training Doc. # ENV-078
1. Purpose
responsibility for handling PCBs or PCB equipment as well as by personnel with administrative
responsibilities for documenting the use, storage and disposal of PCBs.
2. Scope
3. Guideline
3.1 General
Personnel responsible for maintenance activities in which they may be exposed to PCBs
should undergo training to warn them of the hazards and specify the use of protective
equipment. Consult the Enron Safety Guidelines or the Regional EHS Manager for
specific guidance.
3.2 Records
Administrative personnel shall be responsible for recordkeeping to document the use,
storage and disposal of PCBs. The requirements for this recordkeeping is as follows:
• The Annual PCB Inventory (see Guideline ENV-075 “Inventory Guideline”) should
be maintained on-site in facility records for at least 3 years after the facility ceases to
store PCBs.
• Transportation and disposal records (see Guideline ENV-077 “Guideline for Disposal
of PCB Wastes”) should be maintained on-site in facility records for 3 years.
• Analytical test results should be maintained on-site in facility records for 3 years.
• Personnel training records should be maintained on-site in individual personnel
records indefinitely.

Revision: 0
Issued: 20-Nov-1999
Reserved
Doc. # ENV-079

Revision: 0
Issued: 20-Nov-1999
Potable Water Management
Quality Monitoring Guideline Doc. # ENV-080
1. Purpose
responsibility for administering programs to provide potable water to facility personnel,
contractors or to the public.
2. Scope
3. Guideline
3.1 General
Potable water, commonly referred to as drinking water, can be supplied from several
sources including on-site wells, vendor-supplied bottled water and municipality or
community water supplies.
of procedures to ensure safety and efficiency.
3.2 Considerations
Drinking water quality standards are generally established on a national level with
implementation and enforcement on a local level. In the absence of such national
standards, the guidelines for drinking water quality shall be determined by the World
Health Organization (WHO) in concert with local factors including the region, human
activity, type of treatment system, etc.
The Regional EHS Manager should be contacted to develop a monitoring program for
drinking water supplies intended for consumption by the general public or on-site
employees and contractors.
Facilities supplying drinking water shall meet appropriate safe drinking water standards:
• Vendor-supplied bottled water does not require additional facility testing.
• Drinking water from public water supplies does not require additional facility testing
if the source is regulated by the government.
• Well water and process water that is not intended for human consumption but is
available at faucets and sinks shall be labeled “Do Not Drink”.
• Well water and desalinization water that is used for human consumption shall be
tested in accordance with a safe drinking water monitoring program that should be
implemented if it is used to supply drinking water to more than 25 employees or if it
is sold, traded or donated to a public water supply.
• The Operating Company shall be responsible for developing and implementing
site-specific programs.

Exceptions to defer implementation of specific standards and
guidelines may be granted on a case-by-case basis with approval by
regional Human Resources.
Human Resources
Standards/Guidelines Exception Process
Develop Approved by Review at Next

Need for Document and
Justification and Regional Yes Corporate
Exception Distribute
Submit Exception Human Audit
Identified
Request Resources
No • Requesting Management
• Management • Management Business Unit
• CEO / COO (if applicable)
• HR files
Communicate Develop
Denial Compliance Plan
and Implement
• Requesting • Management
Management
Business Unit
• CEO / COO (if
applicable
Exceptions to defer implementation of specific standards and
guidelines may be granted on an asset basis with approval by regional
management and Asset Operations.
Standards/Guidelines Exception Process
Management Standards / Guidelines Management Standards / Guidelines
Exception Request Exception Request
Global Operations Date: Global Operations
Submission Asset: Region: Request

Information Asset President: Extension: For Plant Manager
Approval Name Signature Date
Plant Manager: Extension:
Prepared by: Extension:
Exception Asset President

Management Standard Number:
Requested Name Signature Date
From Guideline Manual:
Title:
Page Number: Commercial Manager
Name Signature Date
Description
Of
Exception Regional This exception is approved at the regional level.
Approval
CEO
Name Signature Date
COO
Name Signature Date
Exception requested until:

Date This exception is denied.
Justification
CEO
Name Signature Date
COO
Name Signature Date
Global This exception is approved by Asset Operations.

Asset
Impact Yes No
Operations
Assessment
Approval
• Will this exception pose any safety hazards?
• Will this exception pose any safety hazards to personnel health?
Name Signature Date
• Does this exception create any environmental impacts?
• Is there a significant financial impact if this exception is granted?
• Does this exception create any operations impacts?
• Does this exception create any maintenance impacts?
This exception is denied by Asset Operations.
• Are there other significant impacts associated with this exception?
If the answer to any of the above questions is yes, describe plans to mitigate the impacts.
Name Signature Date
Page 1 Page 2
A six-step process for submitting, evaluating, and issuing revisions
to the Management Standards and Guidelines will be followed.
Submission Revision Distribution
Document Submit Evaluate Make Revision Issue Revision Communicate

Recommended Recommended Change Revision
Change Change
• Obtain revision • Submit revision • Suggested change is • Standard or • Revised standard • Send e-mail
form. form to Global evaluated versus guideline is or guideline is notification to
• Fill out revision Asset criteria. updated to issued per affected
form completely. Operations. • Recommendation is reflect revision. schedule. management.
• Global Asset developed: • Revision date is • Previous version • Site
Operations sends – Accept or reject? updated. is archived. management
– Basis for decision • Audit questions communicates to
acknowledgeme – Recommended
nt with probable are revised (if own personnel.
wording/ change
timeframe for • Recommendation is necessary). • Revision noted
evaluation. reviewed by field on website.
reviewers and/or
appropriate mgrs.
(incl. submitter).
• Recommendation is
approved or rejected.
A six-step process for submitting, evaluating, and issuing revisions
to the Management Standards and Guidelines will be followed.
Management Standards/Guidelines
Revision Request
Global Operations Date:
Submitter Name: Phone #:

Information
Location: E-Mail Address:
Revision Management Standard Standard/Guideline Name:

Information
Guideline Standard/Guideline #:
Section/Page (if pertinent):
Suggested
Revision
Justification/
Benefits
Basis Attach pertinent documents/edits/etc

or
References
Application Does revision apply to other asset types?
Gas Pipeline Electric LDC Gas Processing
Liquid Pipeline LNG Power
Gas LDC LPG All Asset Types
Comments
Submission Submit to: Don Hawkins E-mail: dhawkin@ei.enron.com FAX:

Information
Phone: (713) 646-7XXX

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Environmental Implementation Guidelines

Global Asset Operations Page 1 of 4

Global Asset Operations Page 2 of 4

Environmental Guidelines (Continued)

Global Asset Operations Page 3 of 4

Environmental Guidelines (Continued)

Global Asset Operations Page 4 of 4

3. Corporate Resource Commitment

4.1 Enron Corp Environmental, Health and Safety Management Procedures,

4.2 Enron Global Asset Operations Safety and Health Guidelines

4.3 Enron Global Asset Operations Environmental Guidelines

Global Asset Operations Page 1 of 3

Global Asset Operations Page 2 of 3

Global Asset Operations Page 3 of 3

• Employee Participation • Mechanical Integrity

3. Corporate Resource Commitment

4.1 U.S. OSHA PSM Web Sites

• PSM Resources – www.osha-slc.gov/SLTC/processsafetymanagement/index.html

4.2 AICHE/CCPS, Guidelines for Implementing Process Safety Management

4.3 Appropriate European Standards

Global Asset Operations Page 1 of 1

3. Corporate Resource Commitment

4.1 Enron Global Asset Operations Crisis Response Planning Manual

4.2 Enron Global Asset Operations Crisis Management Guidelines

Global Asset Operations Page 1 of 1

The minimum security measures to be provided include:

3. Corporate Resource Commitment

4.1 Enron Security Guidelines

4.2 Enron Global Asset Operations Crisis Management Guidelines

Global Asset Operations Page 1 of 2

Protection of Assets (Merritt Publishing)

Vol. Topic Vol. Topic

Global Asset Operations Page 2 of 2

• Management Responsibility • Process Control

3. Corporate Resource Commitment

4.1 Enron Global Asset Operation Quality Management Guidelines

4.2 International Organization for Standardization (ISO)

Global Asset Operations Page 1 of 1

• Equal Employment Philosophy • Overtime Pay and Expense Reimbursement

3. Corporate Resource Commitment

4.1 Enron Human Resources Guidelines

4.2 Enron Corp Code of Conduct

4.3 United States Foreign Corrupt Practices Act

Global Asset Operations Page 1 of 1

• Facility Organization Structure and Contact List

Administrative guidelines are available for each of the above areas.

3. Corporate Resource Commitment

4.1 Enron Global Asset Operations Administrative Guidelines

Global Asset Operations Page 1 of 1

3. Corporate Resource Commitment

4.1 Enron Global Asset Operations Management Standards

4.2 Enron Global Asset Operations Operating Guidelines

4.3 Enron Corp Code of Conduct

4.4 United States Foreign Corrupt Practices Act

Global Asset Operations Page 1 of 1

3. Corporate Resource Commitment

4.1 Enron Global Asset Operations Maintenance Guidelines

Global Asset Operations Page 1 of 1

3. Corporate Resource Commitment

4.1 Enron Global Asset Operations Operating Guidelines

Global Asset Operations Page 1 of 1

The “Positive Impact” (Continuous Improvement) Program is an internal, “learning from