The MTBE plant, located on 70 acres of land in Morgan's Point, can produce 
17,000 barrels per day of MTBE. Feedstocks to the plant to produce the MTBE 
are methanol from Enron's methanol plant and normal butane from the Mt. 
Belvieu underground storage facility. The emission sources at this facility 
are authorized under Texas Natural Resource Conservation Commission (TNRCC) 
air permits and authorizations (e.g., Standard Exemptions) and are not 
"grandfathered" emission sources. Grandfathered emissions sources are sources 
installed in Texas before September, 1971 (that predate the Texas Clean Air 
Act) and are often uncontrolled.

The major sources of NOx emissions at this plant are two boilers, an oleflex 
heater, and three hot oil heaters. All are currently controlled with low NOx 
burners, but will require more combustion controls and Selective Catalytic 
Reduction (SCR) to attain the strict limits in the proposed Houston 
non-attainment regulations. The proposed limits are 0.01 pounds of NOx per 
MMbtu for the two  boilers and oleflex heater, and 0.015 pounds of NOx per 
MMbtu for the smaller hot oil heaters. One third of the reductions must be 
attained by the end of 2002, two thirds by the end of 2003, and all 
reductions must be completed (or emission credits purchased) by December 31, 
2004.

Major Volatile Organic Compound (VOC) emission sources at this facility 
include storage tanks (controlled with floating roofs) and loading facilities.

The methanol plant, located on 20 acres in Pasadena, can produce 125,000,000 
gallons of methanol per year. Feedstocks to the plant to produce methanol are 
natural gas and oxygen. Most of the emission sources at this facility are 
authorized under TNRCC air permits and Standard Exemptions, but some predate 
the Texas Clean Air Act and are grandfathered.

The major sources of NOx emissions at this plant are a reformer (heater) and 
three natural gas-fired reciprocating engines. The reformer is currently 
controlled with low NOx burners, but will require more combustion controls 
and Selective Catalytic Reduction (SCR) to attain the strict limit of 0.01 
pounds of NOx per MMbtu in the proposed Houston non-attainment regulations. 
The proposed limit for the engines (currently uncontrolled) is 0.017 grams 
per horsepower-hour. Although combustion controls and SCR are possible 
control methods to attain this strict limit, they are unproven on engines, 
and it is likely that the engines will need to be replaced with electric 
motors. One third of the reductions must be attained by the end of 2002, two 
thirds by the end of 2003, and all reductions must be completed (or credits 
purchased) by December 31, 2004.

Major VOC emissions sources at this facility include storage tanks 
(controlled with scrubbers) and loading facilities.

The Bammel gas storage facility is located on Kuykendahl Road in north 
Houston and is used for the underground storage of natural gas. The 15 
natural gas-fired engines at this facility were replaced with electric motors 
in 1999. The estimated reductions of emissions by the replacements at this 
facility were 1,254 tons/year of NOx and 42 tons per year of VOC. Most of the 
NOx credits have been sold to other companies under TNRCC,s current trading 
program, which is not a cap and trade program. 

The remaining minimal emissions at this site are from the glycol dehydrators 
(NOx and VOC), and storage tanks (VOC). The VOC emissions from the 
dehydrators are already controlled with incinerators under current TNRCC 
regulations.

The 1999 emissions from the chemical plants as indicated in Enron,s EH&S 
Annual Report are 2,822 tons per year of NOx, 823.7 tons per year of VOC, and 
195 tons per year of Carbon Monoxide. Most of the NOx emissions are from the 
uncontrolled engines at the methanol plant.

The Cost Estimate for the installation of combustion controls and SCR, and 
replacement of the engines at the chemical plants is $30 to $40 million.