From: <Alicea.Jezebele@epamail.epa.gov> To: "Dick Sturm" <dsturm@wppienergy.org> Date: 7/26/2010 11:57 AM Subject: Re: Plant ID: 02569 - Policy Questions- Possible Extension Request Attachments: pic22758.gif

Greetings,

EPA has reviewed your extension requ est for the steam electric effluent guidelines questionnaire for the Menasha Utilities Steam Plant. The deadline for your plant to submit Version 2 of the completed questionnaire is extended to October 15, 2010. If you need assistance during the completion of the stea m electric questionnaire, please contact the steam electric helpline via e-mail at steamhelp@erg.com or by phone at 1-877-353-7560.

Sincerely,

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From: "Dick Sturm" <dsturm@wppienergy.org>

To: Jezebele Alicea/DC/USEPA/US@EPA

Date: 07/15/2010 12:32 PM

Subject: Plant ID: 02569 - Policy Questions- Possible Extension Request

Dear Jezebele,

Policy Question #1: Part A - Question A1-11: Is the generation of electricity the primary purpose (i.e., the predominant source of revenue and principal reason for operation) of the plant?

In 2004-2005 MU converted the River St reet Electrical Generation Station to a Steam Facility/Co-Generation Facility with the primary purpose being the production of process steam to local paper mills and electrical generation as a by produc t. The issue is further complicated by the fact that the facility went into financial default and ceased operation on October 9, 2009. We are currently passively marketing the facility as a co-generation facility. It is also clear that as the present owner MU is not likely to ever operate the plant again.

Based on the above Menasha Utilities answer to Part A, Question A1-11 would be No, and we would not complete the remainder of the questionnaire. Do you agree with this reasoning? If you agree pleasedisregard the request for an extension to complete the ICR. Please reply that our interpretation is correct.

Policy Question #2: I have been unable to find a definition for the acronym BCI which appears as a preliminary question to each question. Would you please provide the definition for BCI.

Request for an extension - if needed.

Menasha Utilities, Plant ID: 02569 would by this email respectfully request a time extension to complete information collection request (ICR). Initially I intended and felt the 90 day completion could be met, however after beginning the ICR and recognizing the volume of information being requested I now realize that we can not meet that deadline. Menasha Utilities does not have a full time environmental person to devote the time needed to complete the ICR. In addition Menasha Utilities Steam Plant ceased operation on October 9, 2009 due to financial difficulties. The plant is now shuttered and in a moth-balled state with efforts being made to sell the plant. All Steam Plant employees including management have either been transferred or are on layoff status which further complicates the issue of completing the ICR within the 90 day period.

Menasha Utilities respectfully is requesting an additional six months beyond the 90 days to complete the ICR.

Sincerely,

Dick Sturm Co-General Manager / Engineering and Operations Menasha Utilities P.O Box 340 Menasha, WI 54952 Phone (920) 967-3410 Cell (920) 540-1125 Fax (920) 967-3440 NOTE: New E-Mail Address: dsturm@wppienergy.org