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Enron Mail |
The answer to your question is that all emissions reported on the emissions
inventory should be included in the calculation of emissions fees. This leads to another question-what emissions should be reported on the emissions inventory? I discussed this issue with a TNRCC emissions inventory team leader. He informed me that that is no written guidance on how to report upset, maintenance, start-up, and shutdown emissions on the emissions inventory, and as a result be included in emission fees. He did indicate that at previous emissions inventory workshops, attendees were verbally told to only include "reportable" (emissions that exceed RQ) on their inventories, and not "recordable" (non-reportable) emissions. He also mentioned that one ton/year would also be an acceptable threshold for including emissions in the inventory. He is aware that upset, maintenance, start-up, and shutdown emissions are an important issue, now that they are included in fees. He indicated that TNRCC will be putting out definitive information on this issue in future emissions inventory workshops and guidance, in preparation for submittal of calendar year 2001 inventories that will be due in 2002. -----Original Message----- From: Loveless, Rick Sent: Monday, September 24, 2001 9:36 AM To: Phillips, Marc Cc: Purvis, Kyle; Campbell, Larry; June, Marilyn; Nichols, Leo; Riedel, Mike; Melton, Richard ; Jensen, Ruth; Kendrick, William Subject: Re: TNRCC Emission Fees Are emission fees paid only on reportable emissions; or are they also payable on recordable? From: Marc Phillips/ENRON@enronXgate on 09/21/2001 10:53 AM To: Kyle Purvis, Larry Campbell/ET&S/Enron@ENRON, Rick Loveless/ET&S/Enron@ENRON, Marilyn June/ECF/Enron@Enron cc: Leo Nichols/ET&S/Enron@ENRON, Mike Riedel/ET&S/Enron@ENRON, Richard Melton/ENRON@enronXgate, Ruth Jensen/ENRON@enronXgate, William Kendrick/ENRON@enronXgate Subject: TNRCC Emission Fees In the last session, legislation was passed in Texas that requires the payment of emission fees for upset, maintenance, start-up, and shutdown emissions. Previously these emissions were required to be included in emission inventories, but not when calculating the fees. Funds generated by the inclusion of these emissions are to be used by TNRCC for enforcement and monitoring activities for air quality permitting, air quality assessment and planning, and enforcement and compliance support. TNRCC is requiring that the additional fees for upset, maintenance, start-up, and shutdown emissions be included in the fees that are due this Fall for calendar year 2000 emissions. Industry groups are questioning the legality of TNRCC requiring the added fees for 2000 emissions since the effective date of the legislation was September, 2001. TNRCC is being requested to change this and legal action is being considered. I will keep you updated as this issue develops. Marc N. Phillips Director, Regulatory Technical Analysis 713-646-7646 (cell 713-594-6919) marc.phillips@enron.com
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