Gerald,

This is the e-mail with Larry's comments regarding dewatering prior to issuance of the operating permit.

Dave

 -----Original Message-----
From: 	"Lawrence J. Hand, Jr." <lhand@lemle.com>@ENRON [mailto:IMCEANOTES-+22Lawrence+20J+2E+20Hand+2C+20Jr+2E+22+20+3Clhand+40lemle+2Ecom+3E+40ENRON@ENRON.com] 
Sent:	Friday, June 22, 2001 11:41 AM
To:	Owen, David
Cc:	Robert. D. Morgan (E-mail)
Subject:	FW: Bridgeline Application Deficiencies

David, enclosed is an electronic copy of a "deficiency" letter pertaining
the storage permit application.  The deficiencies are minor in nature and
should be easy to remedy.

Robert Morgan and I met with Joe Ball yesterday and had a chance to discuss
the permit application.  The meeting was not planned, but it just so
happened that Joe had recently completed his review of the application.

We also discussed the timeline for a final order approving storage in the
cavern.  Assuming we can provide the information requested in the letter on
or before July 6, we can take the application to hearing on July 26.  After
the hearing there will be a 1 week post-hearing comment period (approx. Aug.
3).  Commissioner's proposed order and findings of fact should be complete
on Aug 10.  Within 7 days the commissioner should send proposed findings of
fact to Natural Resources Committee for review and comment (Aug 17).  The
order will likely be signed no later than the 1st week in September.  It is
possible that it could be as early as the last week in August.

I discussed with Joe Ball the issue of dewatering.  He again said that we
can begin dewatering anytime now upon notice the office of conservation.
Joe interprets the regs to allow us to take steps necessary to "convert" the
cavern from Brine to NG, but we cannot store NG without a permit.  Joe
considers dewatering to be part of the conversion process.

I would not recommend dewatering until we have provided Joe with the
information identified in the attached letter and he has set the matter for
public hearing (probably the first or second week in July).  Joe will not
set the matter for hearing until he considers the project to be technically
sound and in compliance with Statewide Order 29-M.  After Joe has "blessed"
this project, it is unlikely that we will have to do further sonar testing
(which I understand is difficult during dewatering).

Please call me at your convenience to discuss our response to the deficiency
letter.  504-584-9122.

-----Original Message-----
From: Joe Ball [mailto:JOEB@dnr.state.la.us]
Sent: Thursday, June 21, 2001 4:55 PM
To: lhand@lemle.com
Subject: Bridgeline Application Deficiencies


Below is the letter concerning the Bridgeline gas storage application that
is being mailed.


	June 21, 2001

Lawrence J. Hand, Jr.
Lemle & Kelleher, L.L.P
601 Poydras St., 21 st Floor
New Orleans, LA  70130-6097

Re:	Storage Well Conversion Application
	Bridgeline Storage Co., L.L.C
	Napoleonville Storage No. 1, Serial No. 972568
	Application No. 20406

Dear Mr. Hand:

An initial review of the referenced natural gas storage conversion
application is complete.  Please address the following items relating to
that application and storage project:

1.	Attachment 8, Page 4 of 5:  Include the additional information on
the well identification sign:

		*	Name of the storage well/cavern Operator,
		*	Section, Township, Range in which the well/cavern is
located.

2.	Using the attached Guidelines: Closure Plan and Cost Estimate,
provide:

		*	a plan for plugging and abandoning the storage well,
and
		*	a cost estimate for plugging and abandoning the
storage well.

3.	Provide a statement of the means by which Bridgeline Storage
Company, L.L.C. proposes to comply with the financial responsibility
requirements to plug and abandon the storage well.  The statement on the
type of financial documentation to be submitted may be a letter of credit,
bond, or other instrument acceptable to the Office of Conservation.  The
funds to be available shall be no less than the amount identified in the
closure plan cost estimate.

4.	Provide a plan to monitor ground subsidence at and in the vicinity
of the storage cavern.  The frequency of subsidence monitoring shall be
scheduled to occur semi-annually during the same period.  The plan shall
include submission of subsidence monitoring reports to the Office of
Conservation.

5.	Provide a discussion on the method proposed for documenting
mechanical integrity of the storage well/cavern.  The frequency of testing
shall be at least once every five years.

6.	Provide a discussion on the method proposed for determining cavern
capacity.  The frequency of cavern capacity determinations shall be at least
once every five years.

Contact Joe Ball at 225-342-5561 if you have questions.

								Yours very
truly,

								Philip N.
Asprodites,
								Commissioner
of Conservation





By:_______________________________

Carroll D. Wascom, Director

Injection & Mining Division


PNA:CDW:JSB