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Re: None

Thursday, 12/07/2017 12:02:22 PM

Thursday, December 07, 2017 12:02:22 PM

Post# of 122543
MMEX's TCEQ Type O AQP is an administrative permit - which falls under Permit By Rule (PBR).

The PBR system is an offshoot of USEPA's streamlining efforts for minor source emission - in this case administered by TCEQ.

The PBR process allows marginally competent companies, like MMEX to obtain an operating permit by filling out forms, and providing specific documentation that certifies that its emissions, from operations fall below a set of threshold values which are deemed not significant threats to air or water quality.

For a small, insignificant proposed facility like MMEX's rudimentary topping unit, the PBR is easy to obtain - TCEQ even provides apps, and spreadsheet templates that help an inexperienced applicant like MMEX through the process. For $100.00 (one hundred dollars), any applicant that can successfully complete the forms, and submit the required supporting documentation, gets the permit - there is no engineering review - this is an administrative permit.

TCEQ does not care that MMEX was far too incompetent to permit a facility that could produce marketable products - that's not TCEQ's problem - it's MMEX's problem. MMEX lacks even the minimal internal competence and skill to submit the application on its own - they had to hire Trinity to do the work and submit on MMEX's behalf.

Unfortunately for MMEX, the issued permit is one more element of its own undoing, and doom - if MMEX were ever able to get project financing, this is all they would be able to operate - a rudimentary, low capacity topping unit that cannot produce any marketable products.

The TCEQ issued a permit for something that can't be Sold I guess. LOL......

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