Potential NOV letter from TNRCC to EOTT for Ozona Crude Station

I received from the TNRCC an NOV letter for the above facility for failure to
submit an emissions inventory for 2000. This notification from the agency
originally came to Rick Loveless by way of Wayne Brunette. I called the
TNRCC and spoke to Kevin Cauble concerning the NOV and he pulled the
emissions inventory submitted in 1999 for the facility. Because VOC's are
the issue, I asked him what the emissions were for VOC's on the 1999
inventory. Kevin stated that the inventory showed VOC emissions of 19.50
tons/yr actuals and 33.56 tons/yr potentials. We discussed why EOTT would
submit an inventory as it is not a major source and not required to. The
only thing we could come up with is that EOTT may have anticipated an
increase in throughput at this site and therefore, wanted to ensure that this
facility was shown as a title V source. According to the phone records from
the TNRCC for this facility, Craig Willoughby of Entrix had requested that
the faciltiy be kept on the list of facilities required to do inventories. I
have a call into EOTT to determine whether increased throughput is proposed
for this facility in the near future.

In speaking with Kevin, he suggested that if a determination is made that if
there is to be an increased throughput that wont exceed the 100 ton/yr limit
on VOC's, or that throughput conditions remain approximately consistent with
previous years, EOTT should provide written notification to the agency that
this facility does not meet the applicability requirements of 101.10
(emissions inventory requirements) and request that this facility be removed
from the TNRCC mailings. Should EOTT confirm the status of operating
throughput to be below the 100 ton/yr VOC emissions limit, I will make make
written notification to the TNRCC requesting removal from the list.