Subject: Grandfather Legislation: Update
From: [email-masked]
To: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Cc: [email-masked], [email-masked], [email-masked]
Date: Wed, 6 Jun 2001 10:15:00 -0700 (PDT)

I attended a TXOGA pipeline committee meeting yesterday and the Grandfather 
legislation was discussed in detail. The following information is in addition 
to the previous message on this legislation:

Several members could not agree on whether the option being offered by TNRCC 
of using old standard exemptions to "authorize" grandfathered emission 
sources would be pulled off the table on September 1, 2001. The general 
consensus is that companies should complete the process of using the old 
exemptions by September 1 in case TNRCC does not allow this option anymore;

Although the legislation allows 0 to 20% reductions on pipeline engines in 
West Texas, TNRCC has indicated that they will not require reductions in West 
Texas, except for "huge emitters". No one knows what they mean by huge 
emitters;

TNRCC is required to reduce compressor engine NOx emissions by 50% in East 
Texas, but MAY require 50% VOC reductions in East Texas. No one has heard 
whether TNRCC will require VOC reductions. VOC reductions on a 2-cycle 
engine, especially on a Cooper engine with good combustion characteristics, 
could be problematic;

The TXOGA Pipeline committee will take the lead on responding to the 
regulations that are developed due to this legislation. I will certainly 
participate in this process.

Marc