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Mr. Stewart, as per you voice mail request to me on Feb. 20, 2001, attached
is the correspondance concerning the reqeust to replace the mixing valves with carbuerators at the Northern Natural Gas, Spraberry Plant. The players in this activity included Jon Fields of Argent Consulting. Due to the fact that the pre testing data for the emissions from the mixing valves and the post testing data for emissions from the carbuerators were received in hard copy only, I am not able to provide this as an attachment. This data was, however, sent to you via fed-x on January 24, 2001. If needed, I can resubmit the results of the data for your review. As expected, the emissions levels did decrease when the carbs were installed. Please reveiw the attached correspondance concerning the request to replace the mixing valves at the Spraberry Plant (TNRCC account No. ML-0022-W) with carbuerators without requiring involvement of a permitting activity. Thank you for your consideration in this issue. -----Original Message----- From: Duncan Stewart [SMTP:DSTEWART@tnrcc.state.tx.us] Sent: Thursday, August 31, 2000 1:09 PM To: jfields@argentinc.com Subject: RE: RE: Engines and GF Status Jon, Here's the latest comment from Jim: don't see why a test before the change and after the change using the same analyzer would not demonstrate no increase in emissions. DFS <<< Jon Fields <jfields@argentinc.com< 08/29/00 08:38AM <<< Duncan, Ok. We'll test an engine. This project involves 5 identical engines. We want to test just one - will you accept that? Will you accept portable analyzer test results? These analyzers have been certified by the state of New Mexico to be plus/minus 3% from full trailer tests. Thanks, Jon -----Original Message----- From: Duncan Stewart [SMTP:DSTEWART@tnrcc.state.tx.us] Sent: Monday, August 28, 2000 2:59 PM To: jfields@argentinc.com Cc: Jim Linville; James Randall Subject: Fwd: RE: Engines and GF Status FYI <<< Jim Linville 08/28/00 02:21PM <<< IF there is no increase in emissions, this is probably not a modification and the Grandfathered status would remain. They would need to demonstrate that there is no change. This could require testing before and after the change. <<< Duncan Stewart 08/28/00 01:43PM <<< What say you all? -----Original Message----- From: Duncan Stewart [SMTP:DSTEWART@tnrcc.state.tx.us] Sent: Tuesday, August 22, 2000 2:27 PM To: jfields@argentinc.com Cc: Jim Linville Subject: Engines and GF Status Hi Jon, This is a joint Duncan - Jim Linville reply. First, for all intents and purposes, expect GF status to go away when the legislature comes back to town. With that in mind, what exactly is happening with this engine. Does the carburetor replace the mixer valves? If so, this must be one ancient engine! And unlikely to get in under VERP or any other program designed to end GF status. Tell us more. Duncan <<< Jon Fields <jfields@argentinc.com< 08/22/00 11:05AM <<< Duncan, I have some grandfathered gas compressor engines in west Texas. We are going to change out the old mixer valves and install carburetors on the units as a maintenance activity. Horsepower and emissions will not increase. I can maintain my grandfathered status, correct? We will of course document this activity and provide copies to the regional office. Thanks, Jon Fields Argent Consulting
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