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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
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.


James C. Myers, P.E.
Director, Enforcement Group