{In Archive} Draft - Title V response

jennifer.wilder to: Shaheerah Fateen 05/25/2004 12:58 PM

From: jennifer.wilder@exxonmobil.com

To: Shaheerah Fateen/R9/USEPA/US@EPA, 

Archive: This message is being viewed in an archive.

Shaheerah

Here is a copy of the letter that will go out today. 

It does not have any

of the back up information, but I have copied you on 

the letter to Mr.

Rios, so hopefully you will receive that soon.

If you have any questions, please don't hesitate to 

e-mail or call me.

Thank you for your patience with this

(See attached file: Title V EPA response_May 25.doc)

Jennifer Wilder Baird

Compliance Engineer

ExxonMobil Production Company

Office: (281) 654-1135 Fax: (281) 654-1147

jennifer.wilder@exxonmobil.com

Title V EPA response_May 25.doc
May 25, 2004 

Gerardo C. Rios 

Chief, Permits Office 

United States Environmental Protection Agency 

Region IX 

75 Hawthorne Street 

San Francisco, CA 94105 

Subject: Response to Request for Information to Update Part 71 Permit Application No. NN-OP 00-07 

Dear Mr. Rios: 

ExxonMobil submits this letter in response to Region IX's letter dated March 31, 2004. In order to 

respond to the request it is important to review a brief history of ExxonMobil's McElmo Creek Unit 

(MCU) site. The original PSD permit included several pieces of equipment as listed in your Attachment 

A; however, during the middle of the 1990s the NGL facilities were shut down due to economic. With 

the shut down of the NGL process, all gas driven compressors and turbines within the plant were 

converted to electric, sulfur recovery was ceased and gas dehydration was reduced. Today ExxonMobil's 

MCU site contains only the following air emitting sources: emergency/process flare, gasoline tank, TEG 

reboiler, Glycol heater. The line heater (also know as CO2 heater) was removed on March 8, 2004. 

Below are ExxonMobil's responses to each of the items addressed in Region IX's letter: 

1. The gas turbine, T4500 was removed June 1998; therefore, 40 CFR part 60 Subpart GG is not 

applicable. 

2. The McElmo facility no longer processes natural gas liquids. This process was discontinued and 

dismantled in June 1998. Therefore 40 CFR Part 60 Subpart KKK is no longer applicable. 

3. The McElmo facility is not classified as a natural gas processing facility. In addition, the plant does 

not sweeten or recover sulfur. This declassification and removal of sulfur recovery equipment 

occurred in June 1998. Therefore 40 CFR Part 60 Subpart LLL is no longer applicable. 

4. Currently only one TEG reboiler is in operation at the McElmo Creek Unit. The emissions from the 

still vent are routed to the flare to control and reduce emissions. Subpart HH MACT standard does 

not apply because emissions are low enough that they do not trigger the regulation. Attached In are 

current emissions as calculated by GRI-GLYCalc. In addition, last years emission inventory is 

included for your reference. 

5. As describe above, all equipment except one TEG reboiler has been removed from ExxonMobil's 

MCU site. The removal of the equipment was completed in June 1998. Attached for your reference 
is a copy of our historic AFE documentation that lists the project year, the project description and 

gives a break down of the cost. 

6. Benzene is present at the MCU site, however no stream contains or contacts benzene greater than 10 

percent by weight. In 2001 liquid and gas samples were taken and analyzed. Benzene was present in 

the plant closed drain system and in the inlet gas stream. On a volume percent basis, the liquids in the 

closed drain system contained 0.3839 percent benzene while the inlet gas sample contained 0.0279 

percent. For a more recent inlet gas analysis please see the attached GRI-GLYCalc calculation. 

Currently, ExxonMobil is in negotiations with the Department of Justice and the EPA for a consent 

decree at the MCU site. It is important to note that the Consent Decree has several stipulations that must 

be carried over into the Title V and PSD permit. These include permit limits, monitoring, operation and 

maintenance plans and semi annual reporting. Also, as part of the PSD permit, ExxonMobil must conduct 

a BACT analysis and air quality analysis. ExxonMobil would like to discuss these terms and conditions 

with the Permit Office. Jennifer Wilder Baird will contact Shaheerah Fateen within the next several 

weeks to discuss further. 

If you have any further questions, please contact Jennifer Wilder Baird by phone at (281) 654-1135 or via 

e-mail at jennifer.wilder@exxonmobil.com. 

Yours truly, 

Neil J Ryan 

Regulatory Compliance Supervisor 

ExxonMobil Production Company 

Attachments 

 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

CC: Shaheerah Fateen, EPA Region IX 

 75 Hawthorne Street 

 San Francisco, CA 94105 
Bc: Arlene Lee 

Delphine Whitehorse 

 Joel Talavera 

 Neil J Ryan 

Jennifer Wilder Baird 

CORP-MI-PO20D 

 
Emissions from TEG System 

GRI GLYCalc 
AFE Documentation