106cc.txt
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Texas Natural Resource Conservation Commission Interoffice Memorandum To: The Public Record From: Duncan Stewart Date: December 7, 1993 Subject: Interpretation of Standard Exemption (SE) No. 106(c) The question has arisen about whether SE No. 106(c) limits of six pounds per hour and ten tons per year are per compound or cumulative. Examination of old correspondence (attached) concerning the exemption indicates the intent of the limits is per compound. Overall limits for the project are set by the exemption rule, 116.211(a)(1). April 9, 1985 Mr. Larry B. Feldcamp BAKER & BOTTS One Shell Plaza Houston, TX 77002 Re: Standard Exemption No. 106 Dear Mr. Feldcamp: This is in response to your letter of February 22, 1985 concerning Standard Exemption No. 106 and the intent of paragraph 2 of this exemption. The paragraph reads: (2) Total emissions including fugitive emissions will not exceed 10 tons per year, 100 pounds per day or 6 pounds per hour of any air contaminant subject to the restrictions of (1) of above. The intent of this paragraph is to limit emission increases resulting from a new facility or from physical or operational changes to an existing facility not addressed elsewhere by the standard exemption list. The terms "total emissions" refer to emissions from the new facility or the emission increases resulting from the other changes for which the exemption is claimed. This exemption does not include replacement of facilities which are included in SE No. 111. I believe this will confirm our previous discussion concerning this exemption. If I may be of further help in this matter, please call me. Sincerely, James C. Myers, P.E. Director, Enforcement Group