### EX:xtinMhb;tPWrl/~gtion Company P. O. Box 

### 460'1 Houston, Texas 77210-4697 

# RECEIVED DEC 1 6 2005 Permifs Oftlce Air-3 U.S. EPA, Region 9 Sara N. Ortwein Production Manager U.S. Production 

# EJf<onMobii Production CERTIFIED MAIL, RETURN RECEIPT REQUESTED December 5, 2005 Director, Air Division (AIR-1) U.S. Environmental Protection Agency, Region IX 75 Hawthorne Street San Francisco, California 94105 Attention: John Kim 6 

## UO!6a1::J ''1d3 

# 's'n 9 -J!'1 aOIUO lUaWaoJoJu3

## ~OOl 

# s 1 AON 

# G3Al383H Subject: United States v. Mobil Exploration and Producing U.S. Inc. Civil Action Case NO.2:05-CV-00319PGC DOJ Case No. 90-5-2-1-2237 Entered into on 06/08/2005 Title V Permit Application for Consent Decree Requirements Dear Mr. Kim: In accordance with Paragraph 14.b of the Consent Decree for the referenced Civil Action Case United States v. Mobil Exploration and Producing U.S. Inc., attached is a 40 CFR Part 71 permit application to incorporate the applicable Decree requirements into the Title V permit that is currently being created by EPA Region IX and Navajo Nation EPA for the McElmo Gas Compression Plant. This application is to serve as a supplement to the original Part 71 application dated March 22,2000 and all subsequent information provided verbally, in writing, or via e-mail with respect to this permit. Asrequired,itincludes a reference to the terms and conditions in Paragraphs 9.a, 10, 11, and 25(i) -(ix) of the referenced Decree, with the exception that the quarterly report required by Paragraph 25 may be changed, at the discretion of the permitting authority, to a semiannual report. It is submitted within 180 days of the Effective Date noted above as specified. I certify under penalty of law that I have examined and am familiar with the information submitted in this document and all attachments and that this document and its attachments were prepared either by me personally or under my direction or supervision in a manner designed to ensure that qualified and knowledgeable personnel properly gathered and presented the information contained therein. I further certify, based on my personal knowledge or on my inquiry of those individuals immediately responsible for obtaining the information, that the information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing and willful submission of a materially false statement.

### If you have any questions, please contact Justin Harrison at 281-654-1127. Sincerely, 

# f.**Jfbrttr/~rcoJJ** Sara N. Ortwein

# V U.S. Production Manager SNO/ccs 

### Attachments

# PERMIT APPLICATION FORMS
40 CFRPART 71

.FEDERAL OPERATING PERMITS PROGRAM

US EPA JANUARY, 2001OMB Control No. 2060-0336 U.S. ENVIRONMENTAL PROTECTION AGENCY APPLICATION FOR FEDERAL OPERATING PERMIT, 40 CFR PART 71 APPLICATION FORM GIS - GENERAL INFORMATION AND SUMMARY Instructions: Complete this form once for the part 71 source (facility). 

### A. Mailin Address and Contact Information McEimo Creek Unit Oil Production Facility - Gas Compression Plant Facility name:**_-==='-==O>....>:=o.="-"-===~=:.=~=..=,===~....".,** 

# ...... _ 23429 County Road G Mailing address: Street or P.O. Box**_.....=::::....:.:=..:==~=~'---'-** _ City Cortez State .ZIP '81321-

_ Title' ,i Field Supervisor Arlene M. Lee Contact person:
__**~===..:=** 

# _ Telephone UWLL-.l2!

__**'"..::5.::.2~1O,---** __ Ext. "'-

_ Facsimile**~L-.l~.-..:::5;.::2::::.34-=--**__ 

### B. Facili Location "J l Temporary source? _ Yes 

### .2L No Plant site location . 

# sw1/4 S3 LT40S R24E - 4 miles NNW ofAneth, UT City Aneth State UT" '**Courlty_S~'an~J~u~an~** EPA Region,----"'IX'-"-

_ Is the facility located within: Indian lands? 

## -X-YES NO 

## Des waters? YES _X_NO Nonattainment area? YES _X_NO Ifyes, for what air pollutants?

_ Within 50 miles ofaffected State? _X

__ YES NO Ifyes, What State(s)? CO, AZ, NM 

### C. 

### Owner**~.** Name Mobil Exploratiorrand Producing U.S. Inc. 396 West Greens Road, CORP-WGR-1260 State 

# tx ZIP 77067 i Houston Street! P.O.**Box,--_...;:..:.=-:.:...:::;",,-,,==~=,,-,=,=** ........!.:.;.::::=.=.,,-,,-

_ City

__**~=~** 

# --,,-- _ Telephone ( 713 ) 431 - 1444 Ext. _ D. 0 

### erator 

### "I Name Same as Owner Street!**P.O.Bol.l·~'** --'---i---,-C---------- City

_ State _ ZIP

_ Telephone ( _

## 2 Form GIS 

### Continued Instructions: Mark only one permit application type and answer the supplementaryquestion appropriate for the type marked. 

# ...x... Initial Permit (Second Application) Permit Renewal Significant Mod.

_ Minor Permit Mod. (MPM) Group Processing, MPM Administrative Amend. For initial permits, when did operations commence?

__ " _ 

### 1

__I 1960s for Field, 1985 for Plant, 1991 for Main Flare For permit renewals, what is the expiration date ofthe existing permit? I I



### ------ Instructions: Mark all applicable requirements that apply. SIP FIP/TIP 

## .x, PSD NonattainmentNSR Minor source NSR Section 111 Phase I acid rain Phase II acid rain

__Early reduction ofHAP

_ Sec. 1120) MACT _ Stratospheric ozone

_ Sec. 112(g) MACT __ OCS regulations NESHAP

_ Sec. 112(d) MACT

_ RMP [Sec.112(r)]

_ Tank vessel reqt., section 183(t)

_ Section 129 Standards/Reqts.



### _ Consumerl commercial prod. reqts., section 183(e)

_ NAAQS, increments or visibility (for temporary sources) Has a risk managementplan been registered?

_ YES 

## --.K..- NO " Regulatory agency --------- Has a phase II acid rain application been submitted?

_ YES 

## --.K..- NO "Permitting authority

_ G; Source-Wide PTE Restrictions and Generic Applicable Rquirements Instructions: Cite and describe (1) any**emissions-limitin~** requirements that apply to the facility as a whole, and (2) "generic" applicable requirements that apply broadly or in an identical fashion to all sources at the facility. In accordance with Paragraph 14.b ofthe Consent Decree for DOJ Case No. 90-5-2-1-2237 entered into on June 8, 2005, Mobil shall submit to EPA's permitting office, no later than 180 days after the Effective Date, an application for a Title V Permit, which includes, among other things, terms and conditions that are at least as stringent as the terms and conditions in Paragraphs 9.a, 10, 11, and 25(i) - (ix) ofthis Consent Decree, with the exception that the quarterly reportrequired by Paragraph 25 may be changed, at the discretion ofthe permitting authority, to a semiannualreport. H Process Description Instructions: List all processes, products, and SIC codes for normal operation, in order ofpriority. Also list any process, "products, and SIC codes associated with any alternative operating scenarios, ifdifferent from those listed for normal operation Process 

## - Products SIC Petroluem Production (Gas Compression and Crude Oil 1311 Dehydration)

## 3 Form 

### GIS Continued 

### I. Emission Unit Identification Instructions: Assign an emissions unit ID and describe each significant emissions unit at the facility. Control equipment and/or alternative operating scenarios associated with emissions units should by listed on a separate line. Applicants may exclude from this list any insignificant emissions units or activities. Emissions Unit ID Description ofUnit Flare used to control dehydration emissions and compressorbypass in the case of Main Flare malfunction, C02 breakthrough, or maintenance

## 4 Form GIS 

### Continued 

### J. Facili Emissions Summa Instructions: Enter potential to emit (PTE) for the facility as a whole for each air pollutant listed below. Enter the name of the single HAP emitted in the greatest amount and.its PTE. For all pollutants stipulations to major source status may be indicatedby entering "major" in the space for PTE. Indicate the total actual emissions for fee purposes for the facility in the space provided. Applications for permit modifications need not include actual emissions information. Limits for Main Flare Only - Paragraph 9.a ofConsent Decree 60.0 95.4 VOC**_"""""'~** __ tons/yr S02 tons/yr 13.4 NOx PM-IO

_____ tons/yr CO 

### 73.0 tons/yr Lead

_____ tons/yr Total HAP tons/yr . Which single HAP emitted in the greatest amount?**~_** PTE? tons/yr

Total emissions ofregulated pollutants (for fee calculation) from section F, line 5 ofform FEE? 134 tons/yr (2004 - included Flare, Glycol Heater, Gasoline Tank, and Fugitives) Permit number(s)**_..::c8A~T-,-AP-=-** _ Permit type.

__....:oP-"S;.:::D'--

_ Permitting authority EPA Region VIII Permit number(s)**-'-_~** _ Permit type

_ Permitting authority

_ L. Emission unites) subject to general permit.

__ N""',../A ........ _ Check one:

_ Application made _ Coverage granted General permit identifier Expiration Date

__ /

__ /

__ M. Cross-referenced Information Does this application cross-reference information? 

### --.K- YES (Consent Decree) NO (Jfyes, see instructions)OMB Control No. 2060-0336 U.S. ENVIRONMENTAL PROTECTION AGENCY APPLICATION FOR FEDERAL OPERATING PERMIT, 40 CFR PART 71 FORM I-COMP - INITIAL COMPLIANCE PLAN & COMPLIANCE CERTIFICATION INSTRUCTIONS: There are 3 pages to this form. On this page, complete Sections A, B, and C for each applicable requirement. Ifdifferent portions of an applicable requirement or compliance methods vary from unit to unit, prepare a separate form for each unique set of requirements, methods, and units. For compliance plan purposes, assume permitissuance will occurby March 22, 2001, unless you are not required to submit an application until after March 22, 2000, in which case assume issuance will occurno laterthan 18 months after submittal. A. COMPLIANCE STATUS OF EACH APPLICABLE REQUIREMENT (Describe each applicable requirement and determine its compliance status) Cite and Describe the Applicable Requirement Unit ID(s): Compliance status at time ofapplication: All Applicable Requirements detailed in Consent Decree Main Flare _K..In Compliance

, _ Not In Compliance B. METHODS USED TO DETERMINE COMPLIANCE Describe all methods' ou used to determine com Iiance with this re uirement By perfonning and completing all requirements, includingbutnot limited to record-keeping, reporting, monitoring, operating, pennitting, and tlareupgrading, as detailed exactly in the Decree within the specified time frame.

C. COMPLIANCE PLAN STATEMENTS (Respond to one ofthese statements for this applicable requirement)

1- If in compliance at this time, 

## z.; If not in compliance at-this time, Iwill be in 3. For future-effective requirements. I I will continue to comply. compliance by expected date ofpermit issuance. will meet this requirement on a timely basis. 

### --K- Yes


### -- No - Yes - No Expected Date

__I

__ ,_1

__ 

### --K- Yes -- No
A. COMPLIANCE STATUS OF EACH APPLICABLE REQUIREMENT (Describe each applicable requirement and determine its compliance status) Cite and Describe the Applicable Requirement Unit ID(s): Compliance status at time ofapplication : _In Compliance _ Not In Compliance B. METHODS USED TO DETERMINE COMPLIANCE Describe all methods' ouusedto determine co

C. COMPLIANCE PLAN STATEMENTS (Respond'to one ofthese statements for this applicable requirement)

1- If in compliance at this time, 2. Ifnot in compliance at this time, I will be in 3. For future-effective requirements. I I will continue to comply. compliance by expected'date of'permit issuance. will meet this requirement on a timely ExpectedDate

# ,,'0-J-_1_- basis.



### -- Yes


### -- No - Yes - No


### -- Yes -- No 

### '.
,FORM I·COMP (CONTINUED) 

## 2 D. ADDITIONAL INFORMATION FORCOMPLIANCE PLAN STATEMENT#2 Complete this section ifyou.answered "YES" to the second statementin Section C. Complete this section for each such applicable requirement. Identify the applicable requirement and describe the actions you will take prior to permit issuance to come into compliance. 1. Applicable Requirement. Unit(s) _--'

_ Applicable Requirement 2. Narrative Description ofhow Source will Achieve Compliance.

E SCHEDULE OF COMPLIANCE Complete this section ifyou answered ''NO'' to any of the statements in Section C. Complete this section for each such applicable requirement. Identify the emission unit and the applicable requirement, the reasons fornoncompliance, and describe how the source will achieve compliance. Ifthere are consent decrees or administrative orders that apply to this requirement, attach a copy ofthem to this form. Finally, all sources required to complete this section must include a detailed schedule of compliance. 1. Applicable Requirement. Unit(s) Applicable Requirement 2. Reason for Noncompliance. Briefly explain why the source will not be in compliance at time of permit issuance or not meet future-effective requirements on a timely basis.) 3. Narrative Description ofhow Source will Achieve Compliance. Briefly explain what you will do to bring the source into compliance with this requirement.
4. Consent Decrees or Administrative Orders. Please attach a copy ofanyjudicial consent decrees or administrative orders for this applicable requirement. Consent Decree for this facility is available as public-record. 5. Schedule ofCompliance. Provide a schedule of remedial measures, including an enforceable sequence ofactions with milestones, leading to compliance, including a date for final compliance. Remedial Measure or Action Date to be AchievedFORM I-COMP (CONTINUED) 

## 3 INSTRUCTIONS: Complete sections E, F, and G once for each facility. F. SCHEDULE FOR SUBMISSION OF PROGRESS REPORTS

This section need only be prepared ifyou are required to submit one or more schedules ofcompliance (by completing section E) or ifan applicable requirement requires you to submit a progress report. For most sources, the time frame for submittal ofprogress reports will be at least every 6 months. One progress report may include information on multiple schedules ofcompliance. Contents ofProgress Report (describe) Report for Paragraph 25 (i) - (ix) ofDecree Quarterly or Semi-Annually for Title V Submittal Frequency**_.;;c","",""-'.l...>:..:..o<=""",,,==~o=-"-,,=--'-** _ As ofJune 8, 2005 Report Starting.date_-="-",,-,,-,,=-,,,,-,=,,,-_ Contents ofProgress Report (describe) Report Starting date

__ '1

__ 1_ Submittal Frequency

__..,...- _ G. SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS This section must be prepared by every source. Indicate how often you are required to submit compliance certifications after your permit is issued and when the first one will be submitted. Compliance certifications are required to be submitted at least once per year during the term ofthe permit. Frequency ofsubmittal See Section F Beginning

__1

__1

__ H. COMPLIANCE STATUS FOR ENHANCED MONITORING AND COMPLIANCE CERTIFICATION REQUIREMENTS This section of the form must be completed for every source. Indicate compliance status for therequirement as a whole (to certify compliance with the requirement as a whole, you must be able to certify compliance with each individual requirement that can be categorized under this designation): Enhanced Monitoring Requirements: 

### ---K.... In Compliance (wi Paragraph 10 ofConsent Decree)

__ Not In Compliance Compliance Certification Requirements: 

### ---K.... In Compliance

__ Not In ComplianceOMB Control No 2060 0336 

## - U.S. ENVIRONMENTAL PROTECTION AGENCY APPLICATION FOR FEDERAL OPERATING PERMIT, 40 CFR PART 71 APPLICATION FORM CTAC - CERTIFICATION OF TRUTH, ACCURACY, AND COMPLETENESS BY RESPONSIBLE OFFICIAL INSTRUCTIONS: One copy ofthis form must be completed, signed, and sent with each submission ofdocuments (i.e., application forms, including any updates to applications), and for every document required by a part 71 permit (e.g., annual compliance certification, 6-month monitoring reports, progress reports, and notices required by the terms ofa part 71 permit), Responsible Official. Identify the responsible official and provide contact information. Name: (Last) Ortwein (First) Sara (Middle) N Title U.S. Production Manager Street or Post Office Box 396 West Greens Road, CORP-WGR-1260 

### , City Houston State TX ZIP 77067 

# - Telephone ( 713 ) 43J 

## - 1444 Ext. Facsimile ( 713 ) 431 

## - 1050 Certification ofTruth, Accuracy and Completeness. The Responsible Official must sign this statement. I certify under penalty oflaw that, based on information and belieffonned after reasonable inquiry, the statements and information 11d in

# r documents are true, accurate and complete. Name (signed) J

# ,,~ 

# 16{ eV1 M 

# f (oN ) , d'

### ifV"~ 

# - Name (printed or typed) SaraN. Ortwein Date:

# -LL-/ ZZ·**/~** -

\

### OMB Control No. 2060-0336 

# u.s.ENVIRONMENTAL PROTECTION AGENCY APPLICATION FORFEDERAL OPERATJNG PERMIT, 40 CFR PART 

### 71 APPLICATION FORM EUD-l - EMISSIONS UNIT DESCRIPTION FOR FUEL COMBUSTION SOURCES INSTRUCTIONS: 

### Complete this form for each significant emissions unitbest described as a fuel 

### combusting unit. 

### A. General Information Emissions unit ID Main Flare Description Flare used to controldehydration emissions andcompressorbypassin the caseofmalfunction, C02 breakthrough, ormaintenance 

# sec Code

---- 

### 1311 SIC Code (4-digit)**_-=::..~** 

### B. Emissions Unit Descri tion AirPollutionControlDevice Temporary source Yes .lLNo Manufacturer American Steel and Iron Works; Zeeco, Inc. will perfonnreguired upgrade Model No. N/A Installation date

__ /

__ / 

### 1991 5706 Serial Number

__**....::..!.~** _ 

### BoilerType: Industrial boiler 'Process burner -,' 

### _ Electric utilityboiler

_ Other (describe)**'_~_-,-** 

### _ Boilerhorsepowerrating

_ Boiler steamflow (lblhr)

_ Type ofFuel-Burning Equipment (coal burning only): Hand fired _ Spreader stoker Underfeed stoker Overfeed stoker

_ Traveling grate _ Shaking grate

_ Pulverized, wet bed _ Pulverized, dry bed Actual (average) Heat Input BTUIhr 1.5 MM 

### C. FuelData NaturalGas StandHyfueltype(s)**_~=~~'--_** 

### NaturalGas Primary fuel type(s)**_~=~~_** ,...',' i .' 

### Instructions: Describe each fuel expected to be usedduring the term ofthe permit, Fuel Type Max; Sulfur Max. Ash BTU Value Coi#ent(%) Content (%) (per cf, gal., or lb.)

-;', 

### Natural Gas 

# 0.07% 1071 Produced Gas 0:07% ',; 

### 443 :' , , 

### , '':''. ;
.

### Form 

### EUD-l Continued 

### D. Fuel Usa e Rates 2 

### Emission Unit ID



### ------ 

### Instructions: For each fuel described above, enter actual and maximumfuel usage rates on a worst-case hourly and annual basis. Indicate the dimension for the fuel usage rate (e.g., gallons, cords, cubic feet). Fuel Type Annual Actual Usage MaximumUsage , 

### Hourly Annual Natural Gas 365,000 cubic feet 50 cubic feet 365,000 cubic feet Produced Gas Varies N/A N/A


### E. Associated Air Pollution Control E ui ment Emissions unit ill Device type


## -------------------- Air pollutant(s) Controlled Manufacturer

_ Model No. Serial No.

_ Installation date

__1

__1_-

_ 

### Control efficiency (%) _ Efficiency estimationmethod

_ 

### F. Ambient 1m act Assessment Instructions: This information must be completedby temporary sources or when ambient impact assessment is an applicable requirement for this emissions unit. See PSD PermitApplication Requiredby Decree Stack height (ft)

_ Stack 

### tempf'F) Inside stack diameter (ft) Design stack flow rate (ACFM) _ Actual stack flow rate (ACFM)

_ Velocity (ft/sec)

_