{In Archive} Re: Follow-up for McElmo Title V Permit Conversation 

Shaheerah Kelly to: justin.j.harrison 08/09/2005 04:08 PM

Cc: aaron.j.pina, Ann Lyons, christopher.w.armstrong, Gerardo Rios, 

neil.j.ryan

From: Shaheerah Kelly/R9/USEPA/US

To: justin.j.harrison@exxonmobil.com, 

Cc: aaron.j.pina@exxonmobil.com, Ann Lyons/R9/USEPA/US@EPA, 

christopher.w.armstrong@exxonmobil.com, Gerardo Rios/R9/USEPA/US@EPA, 

neil.j.ryan@exxonmobil.com

Archive: This message is being viewed in an archive.

Justin, thanks for the follow-up.

I'll take a look at the fax and get back to you. I would like to point out that item 6 of the May 27, 2004 letter 

gives the benzene percentages on a volume basis not on a weight basis.

Also, you mentioned the still vent exhaust from the dehydration unit might be recirulated back to the inlet 

of the gas plant. Thanks for clarifying that the dehydration unit exhaust only vents to the flare and is not 

recirculated back to the plant's inlet. 

Shaheerah Kelly

Environmental Engineer

Air Division, Permits Office

U S EPA Region IX

75 Hawthorne Street

San Francisco, CA 94105

Phone: 415-947-4156

Fax: 415-947-3579

justin.j.harrison@exxonmobil.com

justin.j.harrison@exxonmobil.

com

08/09/2005 02:22 PM

To Shaheerah Kelly/R9/USEPA/US@EPA

cc Gerardo Rios/R9/USEPA/US@EPA, Ann 

Lyons/R9/USEPA/US@EPA, neil.j.ryan@exxonmobil.com, 

christopher.w.armstrong@exxonmobil.com, 

aaron.j.pina@exxonmobil.com

Subject Follow-up for McElmo Title V Permit Conversation

Shaheerah,

As a follow-up to our conversation on Friday, August 5, 2005 concerning the

Pending McElmo Title V Permit, here is the information you requested:

 I will fax (to 415-947-3579), when this e-mail is sent, the MCU Plant

 Inlet Gas Analysis and the Liquid Sample Analysis that is referenced in

 item No. 6 of our May 27, 2004 letter. These will show that we do not

 have any streams containing or contacting benzene greater than 10

 percent by weight. Please let me know if you do not receive this fax.

 I confirmed with operations that the dehydration unit reboiler still
 vent is ducted to the flare rather than the plant inlet. Please

 reference Item No. 4 of our May 27, 2004 letter. Since Paragraph III.3

 of PSD permit 8AT-AP prohibits the operation of any "pollutant-emitting

 equipment at the McElmo Creek Unit other than that listed in Tables 1

 and 2 of this permit." The TEG Reboiler is listed in Table 1 but this

 is for the firebox and not for the reboiler still vent. Since the still

 vent is not listed, it has always been ducted to the flare instead of

 vented to the atmosphere.

 The information for McElmo's Responsible Official is as follows:

 Sara N. Ortwein

 Vice President

 Mobil Exploration and Producing U.S. Inc.

 CORP-WGR-1260

 396 West Greens Road

 Houston, TX 77067

 713-431-1444

If you have any other questions, especially regarding our process or past

submittals, please let me know.

I look forward to speaking with you again on Wednesday concerning

incorporation of Consent Decree requirements in addition to PSD application

requirements.

Thanks.

Justin J. Harrison

ExxonMobil U.S. Production

Regulatory Air Compliance

CORP-MI-3038

P.O. Box 4358

Houston, TX 77210-4358

Office: 281-654-1127

Fax: 281-654-1147

 "Nobody Gets Hurt"