MAO QUESTIONS:

1.  Can we allow the companies to operate at set levels of production or put on baghouses, or must we require baghouses regardless of their production by a date certain?

2.  Can we be silent on the monitoring data that led us to the agreement?

3.  Can we be silent on our authority?

4.  Are both sources on Std. ACDP? If not, then the penalties will be different. You used penalties for Std. ACDP. ($8,000 matrix; $1600 per day per violation)

a.  If we consider these “interim limits” then we use only 20% versus 40% of the base penalty for stipulated penalties. $800 per day per violation.