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jmjjw

01/29/19 2:52 PM

#115991 RE: Turbozen #115987

MMEX-scam will find that a new application is required - there is no process to amend a PBR grant, other than a petition to TCEQ, which has no guarantee of being granted.

MMEX-scam would almost certainly find that new PBR application to fail - the most likely reason critical process components were "forgotten" in the first place is that they'd bust the PBR limits.

Addition of the process equipment, including a desalter, steam unit, pre-flash, pump-around, and parallel/redundant heat exchange, to name a few "missing" pieces would cause the proposed system to exceed the PBR emissions thresholds, requiring full NSR.

Thanks for clarifying, apparently they have everything they need.

Why would they have to amend or apply for a new permit when they already have what they need?