Hi Larry,

Finally got the documentation you sent in.  Jim Linville and I reviewed it.  
Neither of us believe you need any authorization to do what you did/are 
doing.  In our opinion, there is no change to your grandfathered status, nor 
a need to update your Title V permit.

Having said that, by now you probably know that the Texas legislature seems 
intent on closing out grandfathered status as of September 1st.  Our view is 
that your reworked engines have a clear shot at coming in under the VERP  
entry to permitting.  I would also suggest you check the 1972 Standard 
Exemption No. 7.  One way of the other, you should plan to end the 
grandfather status of these engines soon.

On the Title V permit, if you have a General Operating Permit (most likely), 
it will be due for renewal in the short term (next year marks the 5th 
anniversary for most GOPs).  We suggest you incorporate any changes due to 
the engine reworks at that time.  If you have an issued SOP, do the same.  If 
your SOP is still pending, contact your Permit reviewer here at TNRCC for 
guidance.
So, will this e-mail answer your needs?

Regards,
Duncan Stewart