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         Texas Natural Resource Conservation Commission
                     Interoffice Memorandum

From:  Tammy Villarreal, Section Manager, Chemical
To:  Chemical Section, 
     Combustion Section, 
     Don Duke, P.E., 
     Stephen E. Anderson
Date:  January 23, 1996
Subject:  Grandfathered Facilities and Standard Permits

Recently, a number of you have come to talk to me about the use
of the oil and gas standard permit on non-modified grandfathered
facilities.  There are a number of companies (due to Title V)
that wish to register their facilities under the standard permit
even though they may not be modifying the facility from it's
grandfathered status or standard exempted status.

After talking with David Duncan of Legal, it was concluded that
they may do this.  David said that all the statute speaks to is
when a permit is required and does not say anything about
voluntary registration.  Therefore a company may include
non-modified equipment in the standard permit registration as
long as they meet all of the requirements of the standard permit.

For purposes of the oil and gas standard permit and the standard
exemption 106 and 118 test in the applicability section, new and
increased emissions would be all emissions, in the case of a
previously grandfathered facility and would be the difference
between the new level minus the allowable under the standard
exemption for a previously standard exempted facility.

If you should have any questions please contact me.