ADEQ Requirement for Notification of Mechanical Activities

I received a call from a permit engineer with the Arizona Dept. of
Environmental Quality (ADEQ) concerning the issue of notification of
mechanical activities at C/S 2 Flagstaff and a mandatory 7 day wating period
for agency review and approval. Due to the urgency of the C/S 2 work being
performed, I had written a notification to the agency friday evening
requesting approval to initiate the activities detailed in the scope of work
which was included with the letter. On Monday, the engineer called and said
that he had read the letter and had no problems with the activity proceeding
at the C/S. After we had discussed this issue at some length, I posed the
question to him of whether it was necessary to notify the agency of
mechanical and maintenace activities which will not impact or change a
combustion units throughput, fuel use, emissions, horsepower, or cause a
change in design. After some discussions I informed him that Transwestern
will probably inundate the agency with notification letters, he stated that
as long as the engines operating parameters would not change, ( horsepower,
emissions, throughput, fuel use etc), and the burden of responsibility will
rest on Transwestern to ensure that no permit conditions are violated, he
stated that we may proceed with these types of activities in Arizona without
any notification to the agency.

The only hitch being, that when Transwestern does a major mechanical
activity, which would cost more than 25-30% of the cost of replacing a unit,
that we provide them a courtesy notification. I told them we would apprise
them of such an activity.....