I would add only one thing to the response from Gus.

In regards to #2, neither plant meets the definition of "industrial activity" 
under 40 CFR 122.  As a result, neither plant needs an industrial stormwater 
permit.  Both plants were required to obtain construction stormwater permits.

Dave
---------------------- Forwarded by Dave Kellermeyer/HOU/ECT on 12/05/2000 
08:24 AM ---------------------------
From: Gus Eghneim@ENRON on 12/05/2000 08:13 AM
To: Benjamin Rogers/HOU/ECT@ECT, Don Miller/HOU/ECT@ECT
cc: Mitch Robinson/Corp/Enron, Dave Kellermeyer/HOU/ECT@ECT, Ross 
Newlin/HOU/EES@EES, Mitchell Hurt/Corp/Enron, Jon Cathers/Corp/Enron 
Subject: 

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