TRV

TECHNICAL REVIEW: AIR PERMIT BY RULE
Permit No.: 22240 Company Name: EOG Resources, Inc. APD Reviewer: Dr. Roshani Cowmeadow
Project No.: 138744 Unit Name: East White Point Production Facility PBR No(s).: 106.352, 106.492, 106.512
1GENERAL INFORMATION
Regulated Entity No.: RN101976652 Project Type: Permit by Rule Application
Customer Reference No.: CN600564520 Date Received by TCEQ: June 3, 2008
Account No.: SD-0107-R Date Received by Reviewer: June 16, 2008
City/County: Portland, San Patricio County Physical Location: From Portland, go west on Moore Ave/FM 893, go
straight for 6.73 miles, turn right on CR 69, go
north for 1184 feet, turn left into facility.
CONTACT INFORMATION
Responsible Official/ Primary Mr. Danny Huneycutt Phone No.: (713) 651-6446 Email: dhuneycutt@eogresources.com
Contact Name and Title: Environmental Director Fax No.: (713) 651-6447
Technical Contact/ Consultant Ms. Ginny Powers Phone No.: (361) 902-2809 Email: vpowers@eogresources.com
Name and Title: Safety and Environmental Fax No.: (361) 902-2892
Representative
Technical Contact/ Consultant Mr. Kevin Boudreaux Phone No.: (817) 807-5745 Email: kevin_boudreaux@eogresources.co
Name and Title: Contract Emissions Representative Fax No.: m
GENERAL RULES CHECK YES NO COMMENTS

Is confidential information included in the application? X
Are there affected NSR or Title V permits for the project? X There are no current or pending NSR or Title V permits for this site.
Is each PBR > 25/250 tpy? X
Are PBR sitewide emissions > 25/250 tpy? X
Are there permit limits on using PBRs at the site? X
Is PSD or Nonattainment netting required? X 1This facility is not one of the 28 named sources and emissions are below
the federal significance as major source levels. Therefore, PSD is not
required.
This site is not located in a nonattainment county. Therefore, netting is
not required.
Do NSPS, NESHAP, or MACT standards apply to this registration? X None apply.
Does NOx Cap and Trade apply to this registration? X This site is not located in the Houston/Galveston area.
Is the facility in compliance with all other applicable rules and
regulations?
DESCRIBE OVERALL PROCESS AT THE SITE

EOG Resources, Inc. owns and operates the East White Point Production Facility, an existing oil and gas production facility located near Portland in San Patricio
County, Texas.
This site was previously owned by Marathon Oil. It was originally authorized under standard exemption (#22240) in 1997. The last revision to the current
registration (in 1999), authorized 7 oil tanks, 1 water tank, and 3 engines. Emissions were 24 tpy VOC. In 2001 Marathon Oil added a glycol dehydrator and
additional separation equipment and requested authorization under the Oil and Gas Standard Permit (permit #47990). The Standard Permit was not issued because
emissions, particularly from truck loading, were too high and did not meet 261/262 limits. At the time, the Corpus Christi regional office was investigating whether
or not the company should be issued a notice of violation.
On February 4, 2008, the TCEQ received a request from EOG Resources, Inc. to confirm the equipment that is currently located at this site (project # 136409). Some
of the equipment previously at the site has been removed and some equipment will be added, in particular, a flare will be added to control emissions. EOG
Resources, Inc. requested authorization under 30 TAC §106.352, §106.492, and §106.512. However, on March 20, 2008, this project was found deficient because
emissions from the tanks, flare, reboiler, and truck loading could not be verified. The company has now resubmitted the requested information and is again
requesting authorization under 30 TAC §106.352, §106.492, and §106.512.
No planned MSS emissions, and no emissions from produced water, have been reviewed for this registration.
DESCRIBE PROJECT AND INVOLVED PROCESS

Wellhead gas flows into the site from nearby natural gas wells. Some hydrocarbons condense from a gaseous phase into a liquid phase within the gathering lines as
the natural gas is transferred to the site from the wellhead. As the gathering lines enter the facility, three phase separators are employed to separate the liquid
hydrocarbons from the gaseous state.
The liquid hydrocarbons are dumped from the separator and into the stock tanks (one 436-bbl, one 500-bbl, and two 400-bbl steel storage tanks). Flash gas is
generated as a result of the liquid dumping under pressure to atmospheric pressure. The flash gas and liquid hydrocarbons enter the stock tanks. The liquid is
collected in the stock tanks and the flash gas is routed to the flare. Water from the separator is routed to a gunbarrel then to three 400-bbl storage tanks.
The gas streams exit the three-phase separators and are commingled into a suction header at the natural gas compressor. The compressor takes the low-pressure gas
and boosts pressure up to pipeline specifications. The gas then exits the compressor and is sent to a triethylene glycol dehydrator for water removal.
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The water-saturated gas enters the bottom of the dehydrator contact tower and makes contact with lean (water free) glycol. Water is preferentially exchanged from
the gas to the glycol solution. The dry gas exits the top of the contact tower and is sent through a sales meter into the transmission pipeline and leaves the site. The
rich (water saturated) glycol collects at the bottom of the contact tower as lean glycol is pumped into the top of the contact tower via a gas driven pump. The rich
glycol is then sent through a closed loop at the top of the regenerator to pre-heat the stream. The rich glycol stream is then sent through a heat exchanger, through
“side A” of the pump and into the flash tank.
The flash tank maintains a constant 40-psi operating state through the use of a backpressure valve. As the rich glycol and pump gas enter the tank, the gas is flashed
and separated from the rich glycol. The flash gas exits the tank and is sent to the process flare for destruction.
Portions of the hydrocarbons maintain a steric affinity for the triethylene glycol matrix and remain within the rich glycol stream. These residual hydrocarbons will be
carried into the regenerator with the rich glycol stream. The stream enters the regenerator, which acts as a distillation column. The burner and heat exchangers
maintain an optimal temperature such that the vapor pressures of the water and residual hydrocarbon components then exit out of the top of the regenerator and into
the BTEX condenser. The glycol remains in a liquid phase, drops to the bottom of the regenerator, and into the reboiler.
The glycol within the reboiler is free of water and hydrocarbons and exists in a lean glycol state. Within the reboiler, a constant temperature of 375 °F is maintained.
When the temperature of the reboiler exceeds 375 °F, the main burner is turned off, when the temperature falls below 375 °F, the burner re-ignites.
Once the lean glycol liquid level within the reboiler is sufficient, the lean glycol is sent to the dehydrator surge tank. The surge tank acts as a recycle block and
completes the glycol regeneration loop by sending lean glycol, through “side B” of the glycol pump and into the top of the contact tower. Here the process repeats.
As the water and liquid hydrocarbons enter into the BTEX condenser, a thermodynamic exchange occurs between the water and hydrocarbons with ambient
atmospheric conditions. The efficiency of the heat exchanger is rated at 20 °F approach above ambient conditions. In this state, the water and the majority of
hydrocarbons no longer possess the internal energy to exist in a gaseous state and therefore condense into a liquid phase. The liquid phase is sent via a pump to the
stock tanks. The non-condensable hydrocarbon gas, consisting mainly of lighter hydrocarbons, is sent through a flame arrestor and into the main burner for
destruction.
Loading of liquid hydrocarbons occurs via the use of tanker trucks. The trucks employ a submerged loading process to periodically empty the stock tanks.
OIL AND GAS FACILITY GENERAL INFORMATION

Natural Gas Throughput (MMSCF/day): 2.8 H2S Content of Inlet Gas: 0.201 gr/100 SCF / 3.2 ppmv / 0.00032 mol%
Oil Throughput (bbl/day): 0 Is the gas sweet or sour? SWEET
Condensate Throughput (bbl/day): 250 Is this an existing site? YES
Produced Water Throughput (bbl/day): not provided Has the site been registered before? YES
EQUIPMENT/PROCESSES AT SITE
Number of each: Compressor Engines: 1 Glycol dehydrators: 1 VRU: 0
Separators: 1 Amine units: 0 Gunbarrel: 1
Storage Tanks: 7 Heater Treaters: 0 Other: -
Truck Loading: 1 Flares: 1 Other: -
STORAGE TANKS
Tank Identifier Capacity of Throughput Working and breathing Loss Flash Loss
(EPN) Tank (bbl/day) Contents of Tank Calculation Method* Calculation Method Other
TANK1 436-bbl 62.5 condensate E&P Tank E&P Tank
water tank 400 bbl - produced water - - The company is not
authorizing
water tank 400 bbl - produced water - -
emissions from
water tank 400 bbl - produced water - - produced water at
this time.
E&P TANKS - ACTUAL ANALYSIS [FOR ESTIMATING WORKING, BREATHING, AND FLASH LOSSES FROM STORAGE TANKS]
Known Separator Stream: Low Pressure Oil Laboratory Analyses Low Pressure Liquid Sample YES, 2/13/2008
Tank and Shell Data included? YES submitted (if yes, High Pressure Liquid Sample no
include date):
Is analysis from Actual site or Representative Representative Low Pressure Gas Sample no
Site? (from Crites A3 site)
If from Representative Site, distance between ~ 4 miles Measured GOR no
sites:
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Emissions Emissions
Separator Production API Uncontrolled after any
Separator Temperature C10+ C10+ Rate Gravity RVP VOC, C3+ controls
Tank Identifier (EPN) Pressure (psig) (°F) MW SG (bbl/day) (°API) (psia) (ton/yr) (tpy)
TANK1 40* 62 98.70* 0.7292 62.5 40.5* 10.50 44.647 0**
*
TANK2 40* 62 98.70* 0.7292 62.5 40.5* 10.50 45.245 0**
*
TANK3 40* 62 98.70* 0.7292 62.5 40.5* 10.50 44.367 0**
*
TANK4 40* 62 98.70* 0.7292 62.5 40.5* 10.50 44.367 0**
*
* Lab analysis lists API gravity of 62.54, separator pressure of 81 psig, C10+ MW of 151.0, C10+ SG of 0.7842. Previous submission of E&P listed an ambient
temperature of 85°F and a bulk liquid temperature of 85°F, whereas this E&P run used an ambient temperature of 70°F and a bulk liquid temperature of 70°F (actual
ambient probably closer to 71.2°F, actual bulk temperature probably closer to 74.2°F). The reviewer re-ran E&P using correct inputs and results were slightly lower
than those calculated by company. Therefore, reviewer accepted company’s results.
** Emissions routed to flare.
TRUCK LOADING [EMISSIONS CALCULATED USING LL=(12.46)(S)(P)(M)/(T) EQUATION FROM AP-42, SECTION 5.2-4]
LL Hourly Loading Annual Hourly Annual
P M T (lb VOC/1000 gallons Rate Loading Rate Emissions Emissions
S (psia) (lb/lb-mole) (°R) loaded) (gallons/hour) (gallons/year) (lb/hr) (tpy)
0.6 8.3 50.822 537 5.87 10,920 3,973,536 64.10 11.65
HEATERS AND BOILERS (INCLUDING GLYCOL DEHYDRATOR REBOILERS)

Identifier (EPN) Rating (MMBtu/hr) Operating Hours per year Fuel Heat Value (Btu/SCF) NOx emissions Factor Used
REBL1 / Reboiler 0.5 8760 1007 100 lb/MMSCF
GLYCOL DEHYDRATOR (STILL VENT) EMISSIONS CALCULATED USING GRI-GLYCALC

EPN: DEHY1
Laboratory Gas Sample Analysis Included? YES Was it an extended analysis? YES
(including at least C8+ and BTEX?)
Date of Sample: 7/3/2008 Location at site where gas sample was taken: “inlet gas to dehydrator”
Gas Flow Rate (MMSCF/day): 2.8 Lean Glycol Flow Rate (gpm): 0.261
Contactor Pressure: 600 psig Flash Tank Pressure: 40 psig
Contactor Temperature: 83°F Flash Tank Temperature: 140 °F
How are regenerator emissions controlled and what 84% total (68% for condenser, plus 50% for non-condensables routed to reboiler firebox)
control efficiency is claimed?
How are flash tank (if present) emissions controlled 100% (emissions routed to flare, where 98% control is claimed - see flare calculations)
and what control efficiency is claimed?
VOC HAPS Benzene
lb/hr tpy lb/hr tpy lb/hr tpy
Uncontrolled Regenerator Emissions: 1.3930 6.1014 1.0821 4.7396 0.3727 1.6325
Controlled Regenerator Emissions: 0.2229 0.9762 0.1731 0.7583 0.0596 0.2612
Flash Tank Off Gas (uncontrolled): 1.3942 6.1065 0.1230 0.5389 0.0431 0.1887
Flash Gas Emissions (controlled): 0 0 0 0 0 0
TOTAL EMISSIONS (SUM OF CONTROLLED): 0.2229 0.9762 0.1731 0.7583 0.0596 0.2612
Is MACT HH applicable? YES Why or why not? Applies because dehydrator present. Complies
because controlled benzene emissions < 1 tpy.
FUGITIVES [EMISSIONS CALCULATED USING EMISSION FACTORS FROM EPA DOCUMENT 4531, R-95-017, Table 2-4]
Valves Flanges Connectors Open Pump Seals Other VOC Total Annual
Ended lines content of Emissions
stream (tpy)
(weight %)
Gas Service Component Count 164 170 0 0 1 33 29.02% 3.0739
Water/Oil Component Count 82 85 0 0 1 16 100% 2.2684
If VOC content of gas stream <100%, was inlet YES Date of 12/4/2007 VOC content from 29.04 wt% H2S content from lab 0
3
or other laboratory gas analysis included? Sample: lab analysis (wt %): analysis (wt %):
30 TAC §106.352 RULE CHECK

REQUIREMENTS YES, NO, OTHER / COMMENTS
or n/a
If the site conditions the natural gas (with a glycol dehydrator, amine unit, sulfur recovery unit, YES long tons per day of sulfur compounds < 0.01
etc.), it handles less than two long tons per day of sulfur compounds (1 long ton = 2240
pounds).
(1) All compressors will meet the requirements of 106.512. YES
(1) All flares will meet the requirements of 106.492. n/a There are no turbines at this site
(2) Total emissions, including process fugitives, combustion unit stacks, separator, or other YES
process vents, tank vents, and loading emissions from all such facilities constructed at a site
under this section, will be equal to or below 25 tons per year (tpy) each of sulfur dioxide (SO 2 ),
all other sulfur compounds combined, or all volatile organic compounds (VOC) combined; and
250 tpy each of nitrogen oxide and carbon monoxide.
Emissions of VOC and sulfur compounds other than SO2 must include gas lost by equilibrium
flash as well as gas lost by conventional evaporation.
(3) If the facility handles sour gas, it will be located at least 1/4 mile from any recreational area n/a This site does not handle sour gas.
or residence or other structure not occupied or used solely by the owner or operator of the
facility or the owner of the property upon which the facility is located.
(4) Total emissions of sulfur compounds, excluding sulfur oxides, from all vents will be equal to YES This site does not handle sour gas.
or below 4.0 pounds per hour (lb/hr).
(4) The height of each vent emitting sulfur compounds meets the following requirements, and is n/a This site does not handle sour gas.
in no case less than 20 feet.
(5) If the site handles sour gas, the company will register the site by submitting Form PI-7 or PI- n/a This site does not handle sour gas. However,
7-CERT before operations begin. Form PI-7-CERT was submitted.
FLARE
Process or Emergency flare? Process NOx emission factor used: 0.1380 lb/MMBtu
Steam assisted (yes/no)? NO CO emissions factor used: 0.2755 lb/MMBtu
VOC Destruction Efficiency: 98% H2S Destruction Efficiency: n/a (negligible H2S in gas)
(must justify if over 98%)
Heat Content of Each H2S Emissions From Each VOC Emissions From
Sources of emissions routed to Flow Rate of Each Source Source Source Each Source
flare (SCF/hour) (Btu/SCF) (lb/hr) (lb/hr)
pilot 132 1306.06 0.00 2.2304
TANK1 185.42 1932.25 0.00 10.193
TANK2 186.25 1939.60 0.00 10.330
TANK3 185 1928.53 0.00 10.129
TANK4 185 1928.53 0.00 10.129
Dehydrator Flash Tank 72.10 1318.9 0.00 1.394

or n/a
(1)(A) The flare will be equipped with a flare tip designed to provide good mixing with air, YES Actual gas heating value (Btu/SCF) = 1836.87
flame stability, and a tip velocity less than 60 feet per second (ft/sec) for gases having a lower (avg).
heating value less than 1,000 British thermal units per cubic foot (Btu/ft3 ) or a tip velocity less
than 400 ft/sec for gases having a lower heating value greater than 1,000 Btu/ft3.
Actual tip velocity (ft/sec) = 120 .
(1)(B) The flare will be equipped with a continuously burning pilot or other automatic ignition YES Continuous pilot (yes/no)? YES .
system that assures gas ignition and provides immediate notification of appropriate personnel
when the ignition system ceases to function.
Automatic ignition (yes/no)? NO .
A gas flare which emits no more than 4.0 pounds per hour (lb/hr) of reduced sulfur compounds,
excluding sulfur oxides, is exempted from the immediate notification requirement, provided the
emission point height meets the requirements of §106.352(4) of this title (relating to Oil and Gas
Production Facilities).
(1)(C) If the flare burns gases containing more than 24 parts per million by volume (ppmv) of n/a The flare burns gas that contains less than 24 ppmv
sulfur, chlorine, or compounds containing either element, it will be located at least 1/4 mile of sulfur or chlorine.
from any recreational area or residence or other structure not occupied or used solely by the
owner or operator of the flare or the owner of the property upon which the flare is located.
(1)(D) The heat release of a flare (Qflare) which emits sulfur dioxide (SO2 ) or hydrogen chloride n/a The flare does not emit SO2 or HCl.
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(HCl) will be greater than or equal to QSO2 and QHCl.

(2)(A) The flare will burn a combustible mixture of gases containing only carbon, hydrogen, YES
nitrogen, oxygen, sulfur, chlorine, or compounds derived from these elements.
When the gas stream to be burned has a net or lower heating value of more than 200 Btu/ft3
prior to the addition of air, it may be considered combustible.
(2)(B) If the flare will burn gases containing more than 24 ppmv of sulfur, chlorine, or n/a The flare burns gas that contains less than 24 ppmv
compounds containing either element, the company has registered the flare by submitting Form of sulfur or chlorine. However, form PI-7-CERT
PI-7 or PI-7-CERT. was submitted.
(2)(C) Under no circumstances will liquids be burned in the flare. YES
NATURAL GAS FIRED COMPRESSOR ENGINE

Engine Engine Information Pollutant Source of Emission Factor Type of Control Emissions Emissions
Identifier Emission after controls Control efficiency (lb/hr) (tpy)
(EPN / name) factor Device
CAT 399 TA Date of Manufacture 2007 VOC vendor 4.0 g/hp-hr catalytic 50% 0.21 0.93
or Reconstruction: (NMNEHC) converter
Horsepower: 525 NOx vendor 2.0 g/hp-hr catalytic 81% 3.66 16.03
converter
Hours of Operation 8760 CO vendor 3.0 g/hp-hr catalytic 76% 3.66 16.03
per year: converter
Fuel Consumption 9300 PM10 AP-42 0.0194 lb/MMBtu - - 0.13 0.57
(Btu/hp-hr): (filterable +
condensable)
2 or 4 stroke, 4, Rich SO2 AP-42 0.000588 - - <0.01 0.02
Rich or Lean Burn: lb/MMbtu
Vendor Data Sheet Yes CH2O vendor 0.0205 lb/MMbtu catalytic 75% 0.14 0.60
Included? (required if converter
≥ 500-hp )
Does NSPS, Subpart JJJJ apply? NO Why or why not? Not applicable because manufactured before
If yes, how will requirements be met? 7/1/2007.
Does MACT, Subpart ZZZZ apply? NO Why or why not? Not applicable because site is not a major source of
If yes, how will requirements be met? HAPs

or n/a
(1) The engines or turbines have been registered with Form PI-7 or PI-7-CERT within 10 days Yes Form PI-7-CERT was submitted.
of the start of construction.
Engines and turbines rated less than 240 horsepower (hp) need not be registered, but must Horsepower of engine(s) = 525 .
meet paragraphs (5) and (6) of this section, relating to fuel and protection of air quality.
(1) Table 29 has been submitted for each proposed gas or liquid fuel-fired stationary internal Yes
combustion reciprocating engine.
(2) Any engines rated greater than 500-hp will meet the requirements of subparagraphs (A) - Yes
(C) of this paragraph.
(2)(A) Emissions of nitrogen oxides (NO x) will not exceed the following limit: YES Actual NOx Emissions = 2 g/hp-hr.
(2)(A)(i) 2.0 grams per horsepower-hour (g/hp-hr) under all operating conditions for YES
any gas-fired rich-burn engine;
(2)(B) The engine requires an automatic air-fuel ratio (AFR) controller in order to meet the YES
NOx limits in subparagraph (2)(A).
(2)(B) The engine requires an automatic air-fuel ratio (AFR) controller in order to meet the NO
following requirements:
An AFR controller shall be deemed necessary for any engine controlled with a non-
selective catalytic reduction (NSCR) converter and for applications where the fuel
heating value varies more than ± 50 British thermal unit/standard cubic feet from the
design lower heating value of the fuel. If an NSCR converter is used to reduce NOx , the
automatic controller shall operate on exhaust oxygen control.
2)(C) The records specified in (2)(C) of this PBR will be created and maintained by the YES
owner or operator for a period of at least two years, made available, upon request, to the
commission and any local air pollution control agency having jurisdiction.
(3) Any gas turbine rated greater than 500-hp will meet the requirements of subparagraphs (A) n/a There are no turbines at this site.
and (B) of this paragraph.
(4) Any engine or turbine rated less than 500 hp or used for temporary replacement purposes is n/a Horsepower: 830 .
exempt from the emission limitations of paragraphs (2) and (3) above.
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Temporary replacement engines or turbines shall be limited to a maximum of 90 days of Temporary? NO .

operation after which they shall be removed or rendered physically inoperable.
(5) The gas fuel will be limited to: sweet natural gas or liquid petroleum gas, fuel gas containing YES Type of fuel: field gas.
no more than ten grains total sulfur per 100 dry standard cubic feet, or field gas.
(6) Compliance with National Ambient Air Quality Standard (NAAQS) in the area of the YES Which method was used (A, B, or C)? B .
proposed facility has been demonstrated.
(6)(B) Engine stack height and distance to potential obstructions were used to demonstrate NAAQS:
All existing and proposed engine and turbine exhausts are released to the atmosphere at a height at least twice the height of any surrounding obstructions to
wind flow. Buildings, open-sided roofs, tanks, separators, heaters, covers, and any other type of structure are considered as obstructions to wind flow if the
distance from the nearest point on the obstruction to the nearest exhaust stack is less than five times the lesser of the height, Hb, and the width, Wb, where:
Hb = maximum height of the obstruction
L = length of obstruction, in feet
W = width of obstruction, in feet
Wb = projected width of obstruction, in feet = 2 * SQRT(LW/3.141)
Minimum Is Actual If NO,

Distance Distance enter Is stack
(5X Lesser Actual greater than stack height at
Engine/Turbine Potential Hb L W Wb Lesser of of Hb or Distance to Minimum height least 2X
Identifier, EPN Obstruction (ft) (ft) (ft) (ft) Hb or Wb Wb) Obstruction Distance?* (ft) Hb?
ENG1 storage tanks 20 200 80 142.743 20 ft 100 ft 120 ft YES - -
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* If the answer is YES, then the object is not considered an obstruction, and stack height requirements do not apply.
(7) The engine or turbine will not be used to generate electricity. YES
COMMUNICATION LOG
Date Time Name/Company Subject of Communication
6/24/2008 10:48 AM Ms. Ginny Powers, The reviewer emailed Ms. Powers a list of issues that needed resolving, requesting response by July 1:
EOG Resources,
Safety and Flare emissions resulting from tank vapors will need to be revised:
Environmental
Representative • Total Tank VOC: total tank VOC emissions were stated to be 82.57 tpy. However, the results of the
E&P runs lead to total tank emissions of 178.626 tpy (44.647 + 45.245 + 44.367 + 44.367).
Assuming a 98% destruction efficiency, this would lead to VOC emissions of 3.5725 tpy (not 1.65
tpy).
• Heat Value of Tank Gas Stream: a heat value for the tank emissions of 1301 Btu/SCF was used.
However, this is not consistent with the E&P Tank reports (Tank1: 1932.25 Btu/SCF; Tank 2:
1939.60Btu/SCF; Tanks 3&4: 1928.53 Btu/SCF). The weighted average of these heating values is
1932.24 Btu/SCF. This will change NOx and CO emissions.
• Tank Volume Flared: The total volume of gas from the tanks sent to the flare used in the
calculations was 324 SCF/hr. However, this is not consistent with the E&P Tank reports. The Tank
1 E&P tank report lists total gas volume released from the tank of 4.45 MSCFD (or 185.42
SCF/hr). For Tank 2, the volume released is 4.47 MSCFD (or 186.25 SCF/hr), For Tanks 3&4, the
volume released is 4.44 MSCFD each (or 185 SCF/hr). This leads to a total tank vapor volume sent
to the flare of 873.67 SCF/hr. This will change NOx and CO emissions.
Truck Loading:
• A saturation factor of 0.5 was used. This means that submerged loading of clean cargo tanks is
occurring. However, the previous submission used a saturation factor of 1.0, meaning that
submerged loading with dedicated vapor balance is occurring. Can you please confirm the kind of
truck loading that occurs at this site?
Glycol Dehydrator:
• Please provide details about how the control efficiencies claimed for the regenerator (>99%) and
for the flash tank (95%) will be achieved.
The reviewer also discussed the discrepancies found in the E&P Tanks runs, but said that at this time, no
revision was required since in the end, there wasn’t a significant difference in the resulting emissions.
6/25/2008 2:00 PM Mr. Kevin Boudreaux / Mr. Boudreaux called the reviewer to discuss her questions. He said he should be able to get the answers
EOG Resources to the reviewer by July 1.
6/27/2008 10:32 AM Mr. Kevin Boudreaux / Mr. Boudreaux emailed the reviewer:
EOG Resources “I am sending in the revised numbers on the:
1) Total Tank VOC Emissions sent to the Flare.

2) Revised CO and NOx emissions from flare as a consequence of:
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a) Weighted average of the "waste gas" BTU content sent to flare for combustion.
b) Corrected volume sent to flare.
3) Revised Loading loss emissions as a result of using appropriate saturation factor from AP-42
Chapter 5. The most accurate description is submerged loading, dedicated normal service.
We are requesting additional time to:

1) Use AP-42 factors for VOC on Caterpillar engine and request new guarantee sheet from Exterran
based on the factor. Since Caterpillar has only provided a THC number of 1.0g/BHP-Hr, the catalyst
guarantee sheet gives a 50% reduction based on this number and labels it a "VOC", resulting in a factor
in 0.50 g/bhp-hr. This is in fact, a 50% reduction on a THC and is much too high. We will ask the vendor
to expedite the process of providing the guarantee sheets.
In this case, AP-42 factors are appropriate since:
a) The manufacturer did not provide a true NMNEHC factor.
b) The Manufacturer's THC number combined with an abatement efficiency of 50% results in a
mass emission of 3.9858 TPY. This is 457% greater than when calculated while using the uncontrolled
AP-42 Emission Factor for 4 stroke rich burn engines.
2) Take a spot gas sample at the contact tower of the dehydrator. We would expedite the results and use
this analysis to more accurately determine emissions off of the dehy.
Once we have all of the required information we will resubmit a revised Table 1A and summary of
emissions. Would you be able to grant our request for additional time to take the above-stated courses
of action?”
6/27/2007 4:22 PM Mr. Kevin Boudreaux / The reviewer emailed Mr. Boudreaux:
EOG Resources Flares:
Thank you for revising the emission calculations.
Glycol Dehydrator:
We always encourage the most accurate information possible, so if you are willing to get an additional
gas sample, we will allow up to two weeks for sampling and submission of revised calculations. Please
be sure to follow the instructions from the GLYCalc program for proper sampling location and
techniques, as well as proper sample analysis methods. Please let me know a time estimate for obtaining
this information.
Truck Loading:
Thank you for confirming the type of loading occurring and revising calculations as necessary. I noticed
several variables besides saturation factor were changed from the last submission. One of the variables
that was changed was the vapor molecular weight (from 66 to 62). However, the E&P Tank reports list a
molecular weight for working and standing losses from the tanks (Tank 1: 50.95, Tank 2: 52.19, Tank
3&4: 50.07), which would probably be very similar to truck loading emissions. You could use a
weighted average of these values in the truck loading calculation if you like (this will lower emission
estimates).
Engine:
The TCEQ order of preference for estimating engine emissions:
1. Direct stack sampling from engine at site in question
2. Site-specific and engine-specific vendor guarantees*
3. Engine model specific (but not necessarily from site in question) vendor guarantees*
4. AP-42 factors
*If a vendor provides a THC or NMHC emission factor, but not a NMNEHC emission factor, we have
generally allowed companies to speciate these emissions based on the THC:NMNEHC or
NMHC:NMNEHC ratio of the fuel gas (fuel gas analysis required to be submitted).
Therefore, since you do have some manufacturer information, and have said that you might be able to
obtain a new guarantee sheet from the vendor, we would rather you not use the AP-42 factor for VOC
emissions at this time. During the additional time we are allowing for gas sampling, please try and obtain
more accurate information about the engine from the vendor.
6/30/2008 12:16 PM Mr. Kevin Boudreaux / Mr. Boudreaux emailed the reviewer:
EOG Resources “The following courses of action will take place:
1. I will take your advice and look at a weighted average on the loading emissions.
1. Concerning the glycol dehydrator, we will select a sample location in accordance with
GLYCalc instructions & 3rd party, professional laboratory staff will collect the sample.
1. We will also solicit the vendor for accurate data on the NMNEHC factor. If the data is
unavailable or takes to long to acquire, we will ratio out the VOC portion of the fuel gas and
apply this to the THC factor. More than likely, we will take a further reduction on this factor
as a result of the VOC abatement of the catalyst. We will also provide a revised catalyst
guarantee from the manufacturer to reflect the new factors.”
7/1/2008 2:18 PM Mr. Kevin Boudreaux / The reviewer emailed Mr. Boudreaux, thanking him for informing her of his plans, and giving him until
EOG Resources July 15 to obtain all requested information.
EOG Resources
7
1. “I have taken a weighted average of the molecular weight of the tank hydrocarbons for use in the
loading calculations.
2. Concerning the dehydrator: We have had a sample collected at the contact tower; the sample has
been analyzed. The results of the analysis were input into the GLYCalc model. As per our
discussion, we have taken a 50% combustion control efficiency on the of the regenerator
hydrocarbons. The condenser efficiency is based on a 20-degree approach to ambient conditions.
The ambient temperature frequencies were calculated by GLYCalc site specific for Corpus Christi.
Though the 50% combustion efficiency is conservative, we will use them in the absence of
operational data to substantiate 98% combustion control efficiency on the regenerator. The flash
tank off gas stream is sent to the process flare. GRI GLYCalc was able to provide temperature,
pressure, flow rate and speciated mol% of each hydrocarbon compound. I then was able to
calculate a gross BTU content of the flash gas with Promax EOS Software. I have re-weighted the
BTU content of the flared gas to include this stream. Consequently, the flare NOx and CO
emissions have changed. I have also combined the total VOC emission from the tanks with the
flash tank off gas VOC emissions. I have taken a 98% flare VOC abatement efficiency on these
combined streams. Provided on the attachment is data from Promax as well as the GLYCalc
model.
3. The vendor was unable to provide a NMNEHC number. Since the testing of VOC is costly and time
consuming, this leaves us with option 3. Since this option is preferential to AP-42 factors, we will
use option 3 and the NMNEHC:THC ratio calculated as a percent and multiplied across the
vendor specified THC factor. We will also take the NSCR reduction of 50% efficiency of HC
conversion provided by the catalyst manufacturer. The calculations and formula derivations are
provided on the attachment.
As per your request, I have also provided a detailed process description of the facility. You will also find
the revised Table 1A and all updated calculations.”
A revised Table 1a, an extended gas analysis, and revised calculations for truck loading, flare, engine,
reboiler, and dehydrator were attached to the email.
7/14/2008 10:18 AM Mr. Kevin Boudreaux / The reviewer emailed Mr. Boudreaux a list of follow-up questions, requesting response by Wednesday,
EOG Resources July 16:
Engine:
• Because additional data from the manufacturer could not be obtained. There are two options for
calculating VOC emissions from the engine (these two options cannot be combined):
o Use the data sheet that lists a THC emission factor of 0.8 g/hp-hr, then use VOC:THC
ratio in fuel gas to calculate a VOC emission factor. This would result in: (0.8 g/hp-hr)
(29.02%) or a VOC emission factor of 0.232 g/ph-hr. This would result in VOC
emissions of 0.4248 lb/hr and 1.8607 tpy (if this option is chosen, NOx and CO
emission factors must also come from this data sheet).
o Or, use the data sheet that lists a post-catalyst VOC emission factor of 0.5 g/hp-hr. This
would result in VOC emissions of 0.9149 lb/hr and 4.0074 tpy (if this option is chosen,
NOx and CO emission factors must also come from this data sheet).
If at any point more accurate data from the manufacturer, or actual site-specific sampling data
is obtained, you can always revise these emission estimates.
Reboiler:
• VOC emissions were calculated using AP-42 TOC emission factor multiplied by the VOC content
of fuel gas. However, there is an AP-42 VOC emission factor available. Therefore, this is the
number that should be used, please revise.
Dehy Still Vent emissions:

• I noticed that the lean glycol flow rate changed from 1.62 gpm in the initial submission of
GLYCalc, to 0.261 gpm in this submission. Could you please explain why?
• The latest calculations use condenser control efficiencies calculated by GLYCalc based upon
ambient temperatures, giving efficiencies ranging from 88.25% to 98.94%. However, the current
TCEQ policy is to allow no more than 80% control for an air-cooled condenser, without actual site-
specific sampling data. Therefore, (using an 80% control for the condenser and a 50% control for
the reboiler), no more than 90% control should be claimed. Therefore, please either revise emission
calculations, or provide additional site-specific data.
Flare:
• The most recently submitted Table 1a lists VOC emissions from the flare (including pilot) of
3.70 tpy. While the NOx and CO calculations did include the contribution of the pilot, the
VOC calculation did not. However, the previous submission did calculate the contribution of
8
the pilot gas to VOC emissions (an additional 0.19 tpy). Therefore, if you concur, I will add
this value to the total flare VOC emissions, resulting in 3.89 tpy.
7/14/2008 11:00 AM Mr. Kevin Boudreaux / Mr. Boudreaux called the reviewer. They discussed the remaining issues, and Mr. Boudreaux said he
EOG Resources would revise calculations as the reviewer requested, and answer her questions.
EOG Resources “Engine:
I understand that there were discrepancies in the manufacturer's published data and the catalyst
guarantee sheet. In order to meet the requirements of 106.512 and get an accurate emissions factor for
VOC, we need to have both the engine manufacturer's guaranteed outputs and the catalyst
manufacturer's guarantees match exactly. We have requested, through the compressor rental company,
a site-specific guarantee sheet from Miratech on this compressor. The sheet will reflect site-specific
conditions with respect to VOC content of the fuel and state the destruction efficiency. The NOx and CO
destruction efficiencies will also be included. The compressor rental company environmental
representative expects the guarantee to state a VOC destruction efficiency within the range of 50%-65%.
I informed him that I would run the calculations based on a 50% destruction efficiency.
Once the guarantee is provided to me, I will make it immediately available to you. I realize that the
deadline is today. The request to Miratech went in this morning; I am hoping for a 24-hour turnaround
time.
I have provided the updated calculations, VOC site-wide emissions have been adjusted to match.
Reboiler:
AP-42 Emissions factor of 5.5 lb/MMbtu is now reflected in the calculations; site-wide VOC emissions
have been adjusted to match.
Dehy Still Vent Emissions:

Lean Glycol Flow Rate Question:
The initial submission GLYCalc report relied data supplied by operations.
The most recent revision relied on data collected in the field and upon a gas analysis obtained at the
contact tower at operational pressures and temperatures.
The lean glycol flow rate in the initial submission (1.62 gpm) was the flow rate required to dry the gas
stream at the specified conditions. This is calculated by the program.
The most recent submission shows a flow rate of 0.261gpm as the rate required to dry the gas stream at
the specified conditions. This is calculated by the program.
The % saturation of water in a natural gas stream are primarily dictated by 2 physical properties:
1) Pressure
2) Temperature
At higher pressures, a saturated gas "holds" less water than a gas of the same composition at a lower
pressure.
At lower temperatures, a saturated gas "holds" less water than a gas of the same composition at a
higher temperature.
The initial submission calculated a wet gas water content of 285.60 lbs H2O/MMSCF.
The most recent submissions with more accurate data shows a calculated a wet gas water content of
51.71 lbs H2O/MMSCF.
The glycol circulation rate is given in gallons glycol/lb water. Since there is less water to remove per
MMSCF, the rate has changed.
Calculation:
As per the latest request, the GRIGlycalc dehy model has been run with no condenser controls. An 80%
condenser efficiency for removal of VOC due to the BTEX condenser and a 50% combustion efficiency
for destruction of VOC within the main dehy burner have been used on the uncontrolled condenser
emissions. I understand that these factors are at the request of APD management within the Office of
Permitting, Remediation and Registration.
The latest total results in 0.9762 TPY from the still vent. The calculation is attached. The uncontrolled
VOC is found on the GLYCalc report under "Uncontrolled Regenerator Emissions" portion of the
report. The calculation you will find on the attached document.
Site-wide VOC emissions have been adjusted to match.
Flare:
I have added the 0.19 TPY of VOCs contributed from the flare pilot to flare VOC total. The result is 3.89
TPY and 0.89 lb/hr.
Site-wide VOC emissions have been adjusted to match.”
Revised glycol dehydrator, glycol reboiler, engine, and flare emissions were attached to the email.
7/17/2008 5:52 PM Mr. Kevin Boudreaux / Mr. Boudreaux emailed the reviewer a data sheet from Miratech, confirming the engine emission factors
EOG Resources used for VOC, NOx, and CO.
ESTIMATED EMISSIONS
EPN / Emission Source VOC NOx CO PM10 SO2 Formaldehyde
lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy
9
ENG 1 / 830-hp CAT 399TA engine 0.2124 0.9303 3.66 16.03 3.66 16.03 0.13 0.57 <0.01 0.02 0.1378 0.6028
FLARE / Production Flare 0.89 3.89 0.23 1.03 0.47 2.05 <0.01 <0.01 <0.01 <0.01
REBL1 / Dehydrator Reboiler* 0.0027 0.0060 0.05 0.1087 0.04 0.0913 0.004 0.0083
DEHY1 / Dehydrator Still Vent 0.2229 0.9762
DEHY1 / Dehydrator Flash Tank** 0 0
TANK1 / Condensate Tank** 0 0
3 Produced Water Tanks*** 0 0
LOAD / Truck Loading 64.10 11.65
FUG / Site Fugitives 1.22 5.3423
TOTAL EMISSIONS (TPY): 22.79 17.17 18.17 0.58 0.02 0.60
MAXIMUM OPERATING SCHEDULE: Hours/Day 24 Days/Week 7 Weeks/Year 52 Hours/Year 8760
* Annual dehydrator reboiler emissions based on 4380 hours per year (50% operation).
** Emissions from condensate tanks and dehydrator flash tank routed to the flare.
*** Emissions from produced water are excluded from this authorization.
SITE REVIEW / DISTANCE LIMIT Yes No Description/Outcome Date Reviewed by

Site Review Required? X not required by rule 6/20/2008 R. Cowmeadow
PBR Distance Limits Met? X more than150 feet to nearest property line, more 6/20/2008 R. Cowmeadow
than 1000 feet to nearest off-property structure
TECHNICAL REVIEWER PEER REVIEWER FINAL REVIEWER

SIGNATURE:
PRINTED NAME: Dr. Roshani Cowmeadow Ms. Donna Wurst

DATE: July 17, 2008 July 18, 2008
BASIS OF PROJECT POINTS POINTS

Base Points: PBR 352 2.0
Project Complexity Description and Points:
Additional PBRs 492 and 512 1.0
Communication 3.0
Technical Reviewer Project Points Assessment: 6.0
Final Reviewer Project Points Confirmation:
10

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TECHNICAL REVIEW: AIR PERMIT BY RULE

GENERAL RULES CHECK YES NO COMMENTS

DESCRIBE OVERALL PROCESS AT THE SITE

DESCRIBE PROJECT AND INVOLVED PROCESS

OIL AND GAS FACILITY GENERAL INFORMATION

HEATERS AND BOILERS (INCLUDING GLYCOL DEHYDRATOR REBOILERS)

GLYCOL DEHYDRATOR (STILL VENT) EMISSIONS CALCULATED USING GRI-GLYCALC

30 TAC §106.352 RULE CHECK

30 TAC §106.492 RULE CHECK

(HCl) will be greater than or equal to QSO2 and QHCl.

NATURAL GAS FIRED COMPRESSOR ENGINE

30 TAC §106.512 RULE CHECK

Temporary replacement engines or turbines shall be limited to a maximum of 90 days of Temporary? NO .

Minimum Is Actual If NO,

1) Total Tank VOC Emissions sent to the Flare.

We are requesting additional time to:

Dehy Still Vent emissions:

Dehy Still Vent Emissions:

SITE REVIEW / DISTANCE LIMIT Yes No Description/Outcome Date Reviewed by

TECHNICAL REVIEWER PEER REVIEWER FINAL REVIEWER

PRINTED NAME: Dr. Roshani Cowmeadow Ms. Donna Wurst

BASIS OF PROJECT POINTS POINTS

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