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?
benjamin.rogers@enron.com