Re: Question 2

---------------------- Forwarded by Don Miller/HOU/ECT on 12/06/2000 01:38 PM
---------------------------

Enron North America Corp.

From: Mitchell Hurt @ ENRON 12/06/2000 01:23 PM

To: Mitch Robinson/Corp/Enron@Enron
cc: Ross Newlin/HOU/EES@EES, Don Miller/HOU/ECT@ECT, Gus
Eghneim/Corp/Enron@Enron, Dean Frederick/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT,
Don Miller/HOU/ECT@ECT
Subject: Re: Question 2

Mitch,

Following your lead my responses are in red.

Respectfully Mitchell

Enron North America Corp.

From: Mitch Robinson 12/04/2000 05:13 PM

To: Benjamin Rogers/HOU/ECT@ECT
cc: Ross Newlin/HOU/EES@EES@ECT, Dave Kellermeyer/HOU/ECT@ECT, Gus
Eghneim/Corp/Enron@Enron, Mitchell Hurt/Corp/Enron@Enron, Don
Miller/HOU/ECT@ECT

Subject: Re: Question 2

Ben -

My recommended response to #1 is in Blue. To all, please review and verify
you concur. Gus, can you answer the others?

Mitch

Benjamin Rogers@ECT
12/04/2000 10:20 AM
To: Ross Newlin/HOU/EES@EES, Mitch Robinson/Corp/Enron@Enron, Dave
Kellermeyer/HOU/ECT@ECT, Gus Eghneim/Corp/Enron@Enron, Mitchell
Hurt/Corp/Enron@Enron
cc:

Subject: Question 2

Guys:
Here are some more questions regarding the Caledonia and Brownsville plants.
Your assistance with these questions would be greatly appreciated. Please
send your answers back to me when completed. Again, thank you for your help.
Regards,
Ben
3-7998
---------------------- Forwarded by Benjamin Rogers/HOU/ECT on 12/04/2000
10:16 AM ---------------------------

Don Miller
12/04/2000 10:11 AM
To: Benjamin Rogers/HOU/ECT@ECT
cc:
Subject: Question 2

---------------------- Forwarded by Don Miller/HOU/ECT on 12/04/2000 10:10 AM
---------------------------

"Tang, David" <dtang@Cinergy.com< on 11/30/2000 07:45:51 PM
To: "'don.miller@enron.com'" <don.miller@enron.com<
cc: "Whitehead, Robert" <rwhitehead@Cinergy.com<, "Hoyos, Sergio"
<sergio.hoyos@cinergy.com<, "Chaney, Tom" <tchaney@Cinergy.com<, "Vivar, Art"
<avivar@Cinergy.com<
Subject: Question 2

More Questions:

Both Plants

1. What are the short term NOx and CO emissions during startups, and are
there limitations during start-ups.

Start-up emissions vary and can not accurately be measured due to the
inherent delay time in the CEMS system. Additionally, start-up emissions are
not required to be and in fact were not measured during the stack testing.
There are no limitations on emissions during start-up evolutions, since the
permits at both plants allow exceptions to exceedences during start-ups and
shutdowns.

Short term NOx emissions due to start ups are as follows:

Unit #1 = 78.95 ppmc
Unit #2 = 79.49 ppmc
Unit #3 = 87.58 ppmc
Unit #4 = 89.48 ppmc

TDEC Operating Permit #950748F special condition #5 requires that Brownsville
Power 1 L.L.C. (BPI) operate at 0.057 #/MMBtu and 0.090 #/MMBtu for units
#1-2 and #3-4 respectively, with a total NOx emission limit of 249 Total Tons
per Year. The TDEC Division of Air Pollution Control regulation chapter
1200-3-20-.02 (1) regulates the reasonable measures required to keep emission
to a minimum during startups, shutdowns and malfuntions. There is no Special
Condition outling rolling averages or compliance with a certain time limit
for NOx emissions otherthan "Reasonable Measures Required."

2. Are industrial stormwater permits required at either site?

Brownsville Power was issued a Tennesse Multi-Sector General Permit (TMGP)
#TNR05XXX for Storm Water Discharges associated with Industrial Activity. Mr.
Jacke Wade, TDEC Division of Water Pollution stated that if the NOV's were
not satisfied after July 1, 2000 a new TDEC rule was being promulgated to
convert the TMGP back into a Storm Water permit during construction. I
believe the NOV's have been satisified and can therefore request TDEC to
terminate the TMGP. Due to BPI's sic code of 4911, it is my understanding
that we are not required to maintain an Industrial storm water permit or
SPDES permit.

Caledonia

3. In Caledonia, what is the custom fuel sampling schedule?

The fuel monitoring schedule has been monthly from Comercial Operation 6-7-00
through 4-00. Then in accordance with the TDEC letter dated 9-10-99
Brownsville Power was granted a custom fuel monitoring schedule. The
schedule consists of sulfur monitoring conducted twice monthly for six
months; then sulfur monitoring conducted once per quarter for six quarters;if
fuel analyses show little variability the samples will be conducted twice
annually during the first and third quarters of each calendar year.

Brownsville

4. What is the agency's response to the Enron letter regarding the 2nd
stormwater NOV?

I spoke with Mr. Jacke Wade on 6-14-00 and requested he visit the site to
inspect the work completed. His response was " I will inspect the facility
as time permits and if I do not show up on your door step your o.k." I have
not heard from him to date.

5. Has there been any further action by the agency since the 1st stormwater
NOV was never responded to?

Not to my knowledge other than issuance of the 2nd NOV dated 5-1-00.

6. One memo stated that the stormwater is channeled to a wetland. Was that
during construction only or is it ongoing?

I do not recall specifically wetland being mentioned, but the TDEC letter
dated 2-22-99 and 5-1-00 refers to the "sediment retention basin". In my
internal memo to Mitch Robinson dated 9-14-00 I outlined the corrective
measures which included the excavation of the holding pond (sediment
retention pond) and build a spillway for sediment retention.

7. Were there any further problems with the B T Readymix concrete dumping
issue?