1 

### Kelly, Shaheerah

From: Kelly, Shaheerah

Sent: Thursday, September 25, 2014 12:59 PM

To: Kelly, Shaheerah

Subject: FW: MCU Questions

From: Kelly, Shaheerah

Sent: Thursday, September 25, 2014 12:59 PM

To: 'Dwight Mallory'

Subject: FW: MCU Questions

Dwight,

Can you also let me know if the Main Flare uses supplemental gas (e.g., for situations where the vent gas going to the

flare is not high enough)?

************************************

Shaheerah Kelly

Permits Office, Air Division (AIR-3)

U.S. Environmental Protec tion Agency, Region 9

San Francisco, CA 94105

Phone: 415-947-4156

Fax: 415-947-3579

Email: kelly.shaheerah@epa.gov

From: Kelly, Shaheerah

Sent: Thursday, September 25, 2014 12:50 PM

To: 'Dwight Mallory'

Subject: MCU Questions

Hi Dwight,

At this time, we need to verify certain info in the PSD application and that the information we have re the MCU plant.

We just need some additional information listed below. Please verify the correctness of the info or provide the

appropriate information. It would be helpful if you could provide this info to me this week if possible. Feel free to

contact me if you have any questions.

1. Clarify the following about the Main Flare.

 Does the flare use a fixed fan or a variable speed fan to control the air

‐ assist rate? If not, please describe how

the air

‐ assist function works on the main flare.

 Does the flare use perimeter assist or pre

‐ mix assist air?

2. Provide description and number of electric compressors on site.

3. Verify that the following statement is correct, or provide corrections as needed:

Natural gas, water, and solids that are extracted from the producing strata with the crude oil are separated before

the oil is stored. Separated water is re

‐ injected back into the producing strata via the water injection

station. Separated gas is sent to the McElmo Creek gas compression plant and processed as described below. Crude2 oil is sold at the lease automatic custody transfer (LACT) unit at each central tank battery to Giant Refinery through

Running Horse Pipeline, which is owned and operated by the Navajo Nation Indian Reservation.

4. Verify that the info in the following table is correct:



### Equipment in MCU Facility’s 1991 PSD Permit

Operation Status

T4500 Gas Turbine (4390 HP) Shutdown 1997

Waste Heat Recovery Unit (11 MMBtu/hr) Shutdown 1997

Ingersoll Rand IC Engine (491 HP) Shutdown 1993

Fairbanks Morse IC Engine (1712 HP) Shutdown 1997

Fairbanks Morse IC Engine (1712 HP) Shutdown 1997

Fairbanks Morse IC Engine (1848 HP) Shutdown 1997

Fairbanks Morse IC Engine (1848 HP) Shutdown 1997

DPC

‐ 540 IC Engine (470 HP) Shutdown 1998

HC Liquid Reboiler (1 MMBtu/hr) Shutdown 1993

Heat Medium Heater (4 MMBtu/hr) Shutdown 1993

Heat Medium Heater (12.2 MMBtu/hr) Shutdown 1991

TEG Reboiler (0.75 MMBtu/hr) [1] Operational

TEG Reboiler (0.33 MMBtu/hr) Shutdown 1991

TEG Reboiler (0.33 MMBtu/hr) Shutdown 1991

TEG Reboiler (0.1 MMBtu/hr) Shutdown 1991

5. Verify the following highlighted info in lb/MMBtu is correct:

The CO emission rate specified in the Consent Decree is 73 tpy based on a cumulative 365

‐ day rolling total. This is based

on an emission factor of 0.37 lb/MMBtu. This level is within the range of BACT determinations listed in Table 7.2.

************************************

Shaheerah Kelly

Permits Office, Air Division (AIR-3)

U.S. Environmental Protec tion Agency, Region 9

San Francisco, CA 94105

Phone: 415-947-4156

Fax: 415-947-3579

Email: kelly.shaheerah@epa.gov

[1] Unit size increased from 0.33 MMBtu/hr to 0.75 MMBtu/hr. (Verify this w/ Resolute!)