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Microcap & Penny Stocks : Green Oasis Environmental, Inc. (GRNO) -- Ignore unavailable to you. Want to Upgrade?

To: Norman H. Hostetler who wrote (9249)	4/25/1998 10:46:00 AM
From: Charles A. King	Read Replies (2) \| Respond to of 13091

DHEC's position that the permit should be processed per NSPS Subpart NNN means that there should be a 45 day public notice period as there was last summer. To restate Norm's excerpts for emphasis, the following is also from the RS letter to DHEC. Despite the fact that GRNO is proposing an increase in usage and production, some emission rates are lower than those previously applied for on June 6, 1997. In the case of air toxics and volatile organic compounds, previous emission rates were based on sampling analyses of gaseous samples and the density and molecular weight of #2 distillate which is a liquid. Since the vent stream is a gas, this density inflated the emission rates. This is evident from the stack testing on June 4,1997. The emission rates are approximately a scale-up of the stack testing on 6/4/97 based on the increase in raw material usage. I don't know how much clearer it could be that DHEC's position is entirely wrong. RS also uses DHEC's own regulations to bolster its arguments. Furthermore, if the facility is not subject to the requirements of NSPS, Subpart NNN, the 1996 litigation between the Chemical Manufacturers Association vs. EPA indicated that if the control equipment does not meet the definition of "federally enforceable" the fact that the equipment is practically enforceable allows a facility to take credit for its efficiency toward the "major source" applicability as well as the "significant increase" applicability. We believe that since South Carolina's construction permits require the operation of these control devices at all times that the process is in operation, the control device is practically enforceable. We therefore ask that this new construction permit not be public noticed for the reasons of SC regulation 62.5, Standard 7. The RS letter also points out that 'Analysis consistant with the "Air Toxic Modeling Procedures" issued by SCDHEC, Bureau of Air quality on 10/96 indicates that all such regulated pollutants are either de minimus by definition or well below modeled concentrations previously submitted on 6/6/97.' Charles