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

justin.j.harrison to: Shaheerah Kelly 08/12/2005 02:47 PM

Cc: christopher.w.armstrong, Ann Lyons, Colleen McKaughan, neil.j.ryan, 

Gerardo Rios

Archive: This message is being viewed in an archive.

Shaheerah,

To further clarify our discussion today around 

Subpart V:

From our reading of the rules, it does not seem quite 

as clear cut that

Subpart V is automatically applicable in our 

situation.

In Subpart V, 61.240(b) reads:

"The provisions of this subpart apply to the sources 

listed in paragraph

(a) after the date of promulgation of a specific 

subpart in part 61."

In Subpart J, 61.110(c)(2) reads:

"Any equipment in benzene service that is located at 

a plant site designed

to produce or use less than 1,000 megagrams (1,102 

tons) of benzene per

year is exempt from the requirements of §61.112."

61.112(a) states:

 

 "Each owner or operator subject to the provisions of 

this subpart shall comply with the 

 requirements of subpart V of this part." 

 The inference of Subpart J is that if you don't meet 

the threshold benzene levels of 

 this subpart, you are exempt from the requirements 

of Subpart V. Subpart J treats 

 benzene separately from other VHAPs. 

 

 In researching the issues, if you come across any 

guidance documents that clarify 

 application of this rule, I would certainly 

appreciate receiving a copy or a link to 

 the appropriate web page. 

 

 Thanks - I will call you if I have any questions on 

the Part 71 (Title V) application 

 required under the Decree as we discussed today. 
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"

 

 Kelly.Shaheerah@epama 

 il.epa.gov 

To: justin.j.harrison@exxonmobil.com 

 

cc: Lyons.Ann@epamail.epa.gov, 

christopher.w.armstrong@exxonmobil.com, 

 

Rios.Gerardo@epamail.epa.gov, 

neil.j.ryan@exxonmobil.com, 

 08/12/05 03:03 PM 

Mckaughan.Colleen@epamail.epa.gov 

 

Subject: Re: Follow-up for McElmo Title V Permit 

Conversation 

 

Thanks for the follow-up.

I would like to point out that 40 CFR Part 61 subpart 

V starts at 40 CFR

61.240, so 61.110 and 61.112 would not apply.

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.harriso

 n@exxonmobil.com

 

To

 08/12/2005 11:52 Shaheerah 

Kelly/R9/USEPA/US@EPA

 AM 

cc

 
christopher.w.armstrong@exxonmobi

 l.com, Ann 

Lyons/R9/USEPA/US@EPA,

 

neil.j.ryan@exxonmobil.com,

 Gerardo 

Rios/R9/USEPA/US@EPA

 

Subject

 Re: Follow-up 

for McElmo Title V

 Permit 

Conversation

Shaheerah,

This e-mail is a further follow-up to our 

conversation on Wednesday,

August

10, 2005 concerning the McElmo Title V Permit and PSD 

Application:

 As you pointed out, based on the GlyCalc 

calculations dated July 8,

 2004, our Regenerator Overhead Stream from the 

Dehy Reboiler Still

Vent

 has greater than 10% Benzene by weight. However, 

per 40 CFR 61.110

(2),

 we believe we are exempt from the requirements of 

61.112 and as a

 result, 40 CFR Subpart V, because we are designed 

to produce or use

less

 than 1,102 tons of benzene per year as 

demonstrated by our inlet gas

 analysis.

 We will submit a PSD application in accordance 

with 40 CFR 52.21,

 specifically paragraphs j-r, per the Consent 

Decree. It will include

a

 BACT analysis for the Main Flare and Modeling, 

which has already been

 accepted by Scott Bohning as being insignificant.

 The Plant Contact for the Title V Permit is as 

follows:

 Arlene Lee

 23429 County Road G

 Cortez, CO 81321
 970-564-5210

 The Permit Contact for the Title V Permit is as 

follows:

 Justin Harrison

 P.O. Box 4358

 Houston, TX 77210-4358

 281-654-1127

I look forward to speaking with you today concerning 

the Title V

application required under the Decree, which may have 

already been

fulfilled, and Subpart V applicability.

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"

 Kelly.Shaheerah@epama

 il.epa.gov 

To:

justin.j.harrison@exxonmobil.com

 

cc:

aaron.j.pina@exxonmobil.com, 

Lyons.Ann@epamail.epa.gov,

christopher.w.armstrong@exxonmobil.com, 

Rios.Gerardo@epamail.epa.gov,

 08/09/05 06:08 PM

neil.j.ryan@exxonmobil.com

 

Subject: Re:

Follow-up for McElmo Title V Permit Conversation

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.harriso

 n@exxonmobil.com

 

To

 08/09/2005 02:22 Shaheerah 

Kelly/R9/USEPA/US@EPA

 PM 

cc

 Gerardo 

Rios/R9/USEPA/US@EPA, Ann

 

Lyons/R9/USEPA/US@EPA,

neil.j.ryan@exxonmobil.com,

christopher.w.armstrong@exxonmobi

 l.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"