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/~rcoJJSara N. OrtweinV

U.S. Production Manager

SNO/ccs

Attachments
PERMIT APPLICATION FORMS

40 CFRPART 71

.FEDERAL OPERATING PERMITS PROGRAM

US EPA

JANUARY, 2001
OMB 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

Facility name: _-==='-==O>....>:=o.="-"-===~=:.=~=..=,===~...."., McEimo Creek Unit Oil Production Facility - Gas Compression Plant...... _

Mailing address: Street or P.O. Box _.....=::::....:.:=..:==~=~'---'- 23429 County Road G _

City Cortez State .ZIP '81321- _

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

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 of affected 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 supplementary question 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 Nonattainment NSR

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 management plan 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 report required by Paragraph 25 may be changed, at the

discretion ofthe permitting authority, to a semiannual report.

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, if different 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 compressor bypass 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

indicated by 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

NOx 13.4 tons/yr VOC _"""""'~ 95.4 __ tons/yr S02 60.0

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. If different

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 permit issuance will occur by March 22, 2001, unless you are not

required to submit an application until after March 22, 2000, in which case assume issuance will occur no later than 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 of application:

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, including but not 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 of permit 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 of application :

_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 FOR COMPLIANCE PLAN STATEMENT #2

Complete this section if you.answered "YES" to the second statement in 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 of how Source will Achieve Compliance.

E SCHEDULE OF COMPLIANCE

Complete this section if you 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 for noncompliance, 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 of how 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 of any judicial 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 of actions with milestones, leading to

compliance, including a date for final compliance.

Remedial Measure or Action Date to be Achieved
FORM 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 of compliance (by completing section E) or if an applicable requirement

requires you to submit a progress report. For most sources, the time frame for submittal of progress reports will be at least every 6 months. One progress report

may include information on multiple schedules of compliance.

Contents ofProgress Report (describe)

Report for Paragraph 25 (i) - (ix) of Decree

Report Starting.date _-="-",,-,,-,,=-,,,,-,=,,,-_ As ofJune 8, 2005 Submittal Frequency _.;;c","",""-'.l...>:..:..o<=""",,,==~o=-"-,,=--'- Quarterly or Semi-Annually for Title V _

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 the requirement 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 Compliance
OMB 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 of Truth, 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 11din rdocuments are true, accurate and complete.

Name (signed) J ,,~ 16{e V1 M f (oN ) , d' ifV"~ - Name (printed or typed) Sara N. Ortwein Date:-LL-/ ZZ· /~ -

\
OMB Control No. 2060-0336

u.s.ENVIRONMENTAL PROTECTION AGENCY

APPLICATION FOR FEDERAL 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 unit best described as a fuel combusting unit.

A. General Information

Emissions unit ID Main Flare Description Flare used to controldehydration emissions and compressor bypassin the

caseof malfunction, C02 breakthrough, or maintenance

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

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

Serial Number __....::..!.~ 5706 _ Installation date __/__/ 1991

Boiler Type: Industrial boiler -,'

'Process burner _ Electric utility boiler

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

Boiler horsepower rating _ Boiler steam flow (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

Primary fuel type(s) _~=~~_ NaturalGas StandHyfueltype(s) _~=~~'--_ NaturalGas

,... ',' 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 maximum fuel 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 Maximum Usage

, 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 estimation method _

F. Ambient 1m act Assessment

Instructions: This information must be completed by temporary sources or when ambient impact assessment is an

applicable requirement for this emissions unit.

See PSD Permit Application Required by Decree

Stack height (ft) _

Stack tempf'F)

Inside stack diameter (ft)

Design stack flow rate (ACFM) _

Actual stack flow rate (ACFM) _ Velocity (ft/sec) _