### {In Archive} RNRC (PSD): PSD Permit History for McElmo Creek Shirley Rivera to: pflynn 12/05/2007 05:53 PM Cc: Shaheerah Kelly From: Shirley Rivera/R9/USEPA/US To: pflynn@rnrc.net, Cc: Shaheerah Kelly/R9/USEPA/US@EPA Archive: This message is being viewed in an archive. [Shaheerah - FYI, only. For your records. **No action ** needed on your part. I am just cross-checking with Pat the PSD permits we have and having him check-in on his end what they all have (or don't). - Shirl] ========== Pat, Per our conversation, the following e-mail addresses: PSD Permit information and overview (several attachments)  and Comparison to Permit History described in the ExxonMobil revised PSD permit application (via  McVehil-Monnett) SUMMARY : We currently have an April 1991 PSD Permit as the most recent PSD Permit. The first record of a PSD permit is a Feb 2, 1987 PSD permit, for which afterwards there were two other actions taken prior to the most recent April 1991 PSD permit. In the April 1991 PSD permit, there are 2 tables which list EXISTING equipment and SHUTDOWN equipment. NEXT STEPS / REQUEST , in no special order :

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1) Please confirm your receipt of this information.

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2) Additional info/correction - Let us know any necessary revisions or updates that would be relevant regarding the PSD permit.

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3) Equipment history - Under separate cover (e-mail), let's address and confirm the equipment history ... those existing, those shutdown **and** removed/dismantled, and those shutdown in-place. (See attached .pdf w/filename "April ...")

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4) Your records - If for some reason you have other records, please do

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** PSD Permit information I am confirming, via copying you on the files that EPA has scanned for our project file, the following as our PSD permit history that is readily available; therefore, please keep in mind that this is not intended to be an exhaustive compilation regarding a) PSD Permit issued Feb 2, 1987 - EPA Region VIII issues PSD permit to Mobil; NOx and VOC limits placed on 3- recip engines, each at 1,730 hp.
b) PSD Permit issued Oct 27, 1987 - EPA Region VIII issues PSD permit admin change for replacement of the 3 recips with 2 GTs (3,216 hp, each; Solar Turbine T4500 Centaur units); NOx triggered. (Table 1 included with CO, SO2, and VOC estimated emissions and stack info (i.e., ht, diam, deg F, UTM, exit velocity); pollutants did not trigger significant emission rate.)c) PSD Permit issued Mar 21, 1989 - EPA Region VIII issues PSD permit admin change for stack height revision from 20 ft to ~40 ft. Letter states revision.
d) PSD Permit issued April 19, 1991 - EPA Region VIII issues PSD permit admin change, which, according to the accompanying cover letter to the PSD permit "... replaces the October 22, 1987 permit." This permit outlines that is for the following: 1) replace existing heating equipment with waste heat recovery unit, and 2) temporarily replace existing GT with an identify unit during maintenance overhaul of GT. Also, in this permit cover letter, it is stated that only **ONE** (rather than initially approved **TWO**) GT is installed. The GT rating is noted at 4,390 hp (and NSPS Subpart GG applicable; for which was not noted as part of the Oct. '87 permit because hp was less than Subpart GG trigger).
Features of this permit include: Permit history- Page 3 (or page 5.pdf) does provide a history of the requested revisions/actions for  this site. (So perhaps you all have the detail info as part of your records, as well.) Equipment list - Table 1 has list of INSTALLED equipment. Table 2 has list of SHUTDOWN  equipment. Facilitywide emission limits - Table 1 has 12-month rolling emission limits for SO2, NOx, CO, and  VOC.

** Comparison to Permit History in McVehil - Monnett / ExxonMobil revised PSD permit application As a cross-check, presuming you all also have the Sept 2006 submittal of the August 2006 dated revised PSD application information, the following summarizes a comparison of what I have readily found regarding the PSD Permits. Page 2-2 lists a Summary of the PSD permit history associated with the McElmo facility. a) March 21, 1989 admin change is not noted. b) April 18, 1991 is the noted last PSD permit, which was signed (and effective) on the 18th; however, the PSD permit is dated April 19 (nineteen).

================== Look forward to hearing from you, - Shirl

------------------------------------------- Shirley F. Rivera U.S. EPA, Region 9, Air Permits Office (AIR-3) T: (415) 972-3966 | F: (415) 947-3579 75 Hawthorne St., San Francisco, CA 94105 Rivera.Shirley@epa.gov