Texas Tank Truck Carriers Association, Inc.


Circular Letter No. 1249

August 27, 1998


TNRCC DRAFT RULES FOR STAGE I VAPOR RECOVERY

Enclosed is a copy of the draft rules proposed by the Texas Natural Resource Conservation Commission (TNRCC) for control of air pollution from volatile organic compounds. These rules have not been published yet in the Texas Register, but it will happen within 30 days.

Please review these draft rules to see if there is any problems for the tank truck carrier industry. Please pay special attention to Subchapter C, beginning on Page 15.

If you have any comments to make, please fax those to us at TTTCA (512) 479-8726 or mail them to us at P.O. Box 2307, Austin, Texas 78768. Please note that the TNRCC is now giving tickets up to $ 5,000.00 per incident for violations of Stage I Vapor Recovery. For example, a tank truck not utilizing vapor recovery equipment where necessary will have an automatic $ 5,000 fine. We are reviewing this policy in view of the fact that the carrier may have provided all of the equipment and the driver has simply failed to use it.

Thank you for your cooperation.




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