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Friday, October 15, 2010 1:18:12 PM
Aren't you overlooking the different treatment of major and minor projects, and instead clumping them all together?
The only argument I see, and what tracks with what the DEC e-mail states, is if a threshold of regulated pollutant tpy is not met. I think the pivotal number is 2.5 tpy (based on data contained in the DEC website) and their NOx (at minimum) would breach that especially if they are trying to permit more than 1 processor.
(And yes there is a difference between the 2.5 tpy threshold and the 50 tpy limit to emissions that will most likely be the conditions included in the permit approval.)
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