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Answers to your Questions:
Both Plants 1. What are the short term NOx and CO emissions during startups, and are there limitations during start-ups. See answers provided by Mitch and Pat. In addition, I offer the following: Caledonia - There is no specific exemption in the permit for startup and shutdown. We tried to request one when we modified the permit for peak firing in May. The state told us however, that there is no need to provide a specific exemption in the permit and that we can rely on the exemption provided in the general rules under (APC-S-1, Section 10.2) Brownsville - Again, there is no specific exemption for startup and shutdown. We are relying on the exemption provided in the general rules under regulation 1200-3-20-0.02 which calls for implementation of good management practice to minimize emissions during startup and shutdown. 2. Are industrial stormwater permits required at either site? No. There is no wastewater discharge at either site Caledonia 3. In Caledonia, what is the custom fuel sampling schedule? We are implementing the recommended EPA protocol for natural gas sampling which calls for twice per month the first six months, then once per quarter the first six quarters, then semi-annually thereafter. However, since we are also required under Part 75 to analyze for the natural gas heat content on a monthly basis, I have asked the plant managers to analyze for the sulfur content monthly. Brownsville 4. What is the agency's response to the Enron letter regarding the 2nd stormwater NOV? We have not received any written correspondence from the agency following the second NOV. However, the site was inspected after completion of the corrective measures (around June 15) and the state inspector was satisfied with the progress made to bring the site into compliance with the stormwater construction permit. 5. Has there been any further action by the agency since the 1st stormwater NOV was never responded to? I am not aware of any action 6. One memo stated that the stormwater is channeled to a wetland. Was that during construction only or is it ongoing? I am not aware of anything existing. I believe that this is during construction. Mitchell -- any thoughts on that? 7. Were there any further problems with the B T Readymix concrete dumping issue? Mitchell - Please respond to this question
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