Larry,

I spoke with Darron Blackburn regarding the Burger, Crane, and Sonora
accounts.  Darron has told me that the blue fee return sheets indicate that
EOTT submitted zero fees for these three accounts.  Darron indicated that
these sites had either NSPS sources or an active Title V permit.  Therefore,
fees would be required.  A fee would not be required if there was no
intention of operating the sites in the 2002 fiscal year (September 1, 2001
through August 31, 2002).

1. If a fee is owed but the site did not operate in 2000, then EOTT would
owe the minimum fee - $26.
2. If the Title V was not officially terminated prior to Nov.1, then the fee
is required if the source operates in the fiscal year.

Our database shows Burger and Sonora to be out of service.  Therefore, a
2002 fiscal year fee would not be required.  This needs to be communicated
to Mr. Blackburn in writing.  Our database shows Crane to have all
grandfathered tanks.  Therefore, the only trigger for a fee would be an
active Title V permit.  Do you know if the TNRCC has voided the Title V and
if so when?



Jon E. Fields, REM
Argent Consulting Services, Inc.
Ph: (281) 953-1008
Fx: (291) 759-9656