### {In Archive} Re: Follow-up for McElmo Title V Permit Conversation j ustin. 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

ccchristopher.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 81321970-564-5210 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 thebenzene 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 Frida y , A ugust 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 applicationrequirements.

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"