Natrual Gas Release Reporting Requirements for Texas

As a reminder, the state of Texas requires releases of natural gas greater
than 119 mscf to the atmosphere (in a 24 hour period), to be reported to the
Regional Offices of the TNRCC. These releases include but may not be limited
to the following: ESD's, startups, shutdowns, pipeline ruptures and
maintenance activities. Should any of the above activities release natural
gas in excess of 119 mscf, a written notification should be faxed to the
Regional Office of the TNRCC within the following timeframes:

Unanticipated Upsets- within 24 hours after the discovery of the upset.

Maintenance, Startup or Shutdowns- 10 day prior to the expected exceedance.

This reminder is being sent to all ET&S teams within Texas because in the
last two Northern Natural Gas compressor station inspections conducted by the
TNRCC, they specifically requested backup data and reporting documentation
of the natural gas releases to the atmosphere which were greater than 119
mscf. The agency's inquiry specifically addressed knowledge of compressor
station venting for ESD, start ups and shutdowns.

It should also be mentioned that there has been inconsistencies in the
TNRCC's position regarding this issue. However, until a position has been
adopted by Enron's GPG, I am recommending that each facility comply and
report as appropriate.

The fax numbers for the following Regional offices are as follows:

Midland (915) 570-4795 Included facilities- Wt-2, Walton, Keystone,
Lone Star Valero, Spraberry, Seminole

Lubbock (806) 796-7107 Included facilities- P-2, Plainview, Brownfield

San Angelo (915) 658-5431 Included facilities- Reagan Co. 2, Irion Co. 1,
Eldorado

Reporting forms for the release can be faxed to your location by request by
contacting me at (505) 625-8022.