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.

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Potential NOV letter from TNRCC to EOTT for Ozona Crude Station