Texas Natural Resource Conservation Commission Interoffice Memorandum From: Tammy Villarreal, Section Manager, Chemical To: Chemical Section, Combustion Section, Don Duke, P.E., Stephen E. Anderson Date: January 23, 1996 Subject: Grandfathered Facilities and Standard Permits Recently, a number of you have come to talk to me about the use of the oil and gas standard permit on non-modified grandfathered facilities. There are a number of companies (due to Title V) that wish to register their facilities under the standard permit even though they may not be modifying the facility from it's grandfathered status or standard exempted status. After talking with David Duncan of Legal, it was concluded that they may do this. David said that all the statute speaks to is when a permit is required and does not say anything about voluntary registration. Therefore a company may include non-modified equipment in the standard permit registration as long as they meet all of the requirements of the standard permit. For purposes of the oil and gas standard permit and the standard exemption 106 and 118 test in the applicability section, new and increased emissions would be all emissions, in the case of a previously grandfathered facility and would be the difference between the new level minus the allowable under the standard exemption for a previously standard exempted facility. If you should have any questions please contact me.