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Enron Mail |
UPDATE--DEP recently issued a Notice of Change of Agency Position
(Notice of Change) in the Pompano Beach proceeding in which DEP advised all of the parties and the administrative law judge that it was intending to modify the previously issued intent to issue relative to six issues. The primary two conditions that DEP is modifying its position concern the NOx emission limits during distillate fuel use and a reduction in the number of hours that the facility can operate on distillate fuel use. Specifically on the first issue, DEP intends to limit the facility to 36 ppmvd for NOx rather than the previously issued limitation of 42 ppmvd. On the second issue, DEP proposes to reduce the number of hours of diesel fuel use from 1000 hours to 500 hours per year after 2004. The other issues raised in the Notice of Change include : startup and shutdown conditions; emergency equipment; other minor sources; and the VOC emission limit. I have discussed the Notice of Change with Dave Kellermeyer and he, in turn, is going to discuss the Notice in detail with Scott Osbourn. We have some questions on certain of the issues raised in the Notice of Change, which we will need to clarify with DEP. I will circulate the Notice of Change to you in the next few minutes if you have not already seen it. In addition, we intend to respond to the Notice with a pleading that sets forth : i) our intention to object and present evidence in opposition to certain of the permit changes proposed by DEP, and ii) our desire for expedited discovery with respect to the textual permit language now proposed by DEP. Kay, we will be sending you that draft pleading today for your review and comment. We would like to file the pleading by tomorrow if possible. Debbie and Steve, if you have any questions on this matter prior to your meeting tomorrow, please contact me. I will be here in the office all day. Thanks--Kerri _______________________________________________________________ The information contained in this transmission may contain privileged and confidential information. It is intended only for the use of the person(s) named above. If you are not the intended recipient, you are hereby notified that any review, dissemination, distribution or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. To reply to our email administrator directly, please send an email to postmaster@gtlaw.com.
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