### {In Archive} Re: Follow-up for McElmo Title V Permit Conversation Shaheerah Kelly to: j ustin.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: j ustin. 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 j ustin.j.harrison @ exxonmobil.com
j ustin.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 stillvent 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

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