TECHNICAL REVIEW: STANDARD PERMIT FOR

INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES

Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

GENERAL INFORMATION
Regulated Entity No.:
Customer Reference No.:
Account No.:
City/County:
RN106278799 Project Type: Standard Permit Application
CN603988692 Date Received by TCEQ: March 11, 2013
Date Received by Reviewer: March 19, 2013
From Karnes City go approx 6 mi w on FM
Karnes City, Karnes County Physical Location:
1144 facility entrance on s side of FM 1144

CONTACT INFORMATION
Responsible Official/ Primary Katie Rickle Phone No.: (210) 561-4207 Email: KMRICKLE@MARATH
Contact Name and Title: Hes Supervisor Fax No.: ONOIL.COM
Technical Contact/ Consultant Vijay K Kurki Phone No.: (210) 561-4209 Email: VKKURKI@MARATHO
Name and Title: Senior Hes Professional Fax No.: NOIL.COM

GENERAL RULES CHECK YES NO COMMENTS

Is confidential information included in the application? X
Are there associated NSR or Title V permits at the site? X If YES, list all permit numbers:
Is the application for renewal of an existing standard permit? X If YES, list expiration date:
Do NSPS, NESHAP, or MACT standards apply to this registration? X If YES, list Subparts: NSPS JJJJ, HH benzene <1 tpy, NSPS
60.18
MACT ZZZZ
NSPS Kb N/A -upstream operations
Is the following documentation included with this registration? X If NO, note any requests for additional information and date
1. The General Requirements Checklist demonstrating compliance with 30 received:
TAC §§ 116.110 and 116.601-615
2. Process description
3. Project description
4. Descriptions of any equipment being installed
5. Emissions calculations including the basis of the calculations
6. Emission increases and/or decreases associated with this project
(quantified)
7. Description of efforts to minimize any collateral emissions or collateral
increases
Are any requirements of 116.110 circumvented by: (1) artificially limiting X If YES, are the limits intended to allow the project to move
feed or production rates below the maximum capacity of the project’s forward while waiting for a permit or permit amendment that
equipment; (2) claiming a limited chemical list; or (3) dividing and will allow full-scale operations, particularly when the project
registering a project in separate segments? would not be economically feasible until fully authorized?

STANDARD PERMIT RULES CHECK: YES NO COMMENTS

Does the facility meet the § 116.14(2) definition of an Oil & Gas facility? X
Are there any net increases in emissions associated with this registration? X If YES, list contaminant and associated emission limit in
§§ 106.261(3) or (4) or 106.262(3): See speciated emission
below.
Does the facility vent or flare more than 0.3 long tons of sulfur (other than X
Sulfur Dioxide) per day?
Are all emissions of sulfur compounds (other than SO2 and fugitives) X If NO, list the emission rate (must be £4 lb/hr):
controlled?
Are all vents that emit sulfur compounds (other than SO2 and fugitives) to the X List vent heights: 20’
atmosphere at least 20 feet above ground level (excluding emergency safety
relief valves)?
Are there new or modified internal combustion reciprocating engines or gas X If YES, list equipment specifications and emission rates to
turbines at the facility? satisfy §§ 106.512 and 106.4(a)(1) (e.g. horse power, fuel type,
NOx emission rate, date of manufacture): See below.
Is there a natural gas glycol dehydration unit at the site that emits >10 tpy X If YES, mark the type of control device used.
of VOCs? flash tank
Vapor Recovery Unit
VOC destruction device
X other JATCO BTEX Condenser
Are any combustion units with a design maximum heat input value > 40 X If YES, list NOx emissions in pounds per MBtu.(must be
1
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

MBtu/hr at the site (other than flares, internal combustion engines, or natural < 0.06 lb/MBtu):
gas turbines)?

Are VOC process fugitive emissions uncontrolled? X VOCs (tpy) receptor < 500' receptor ³500'
If YES, mark applicable inspection and repair requirements. X <10 no LDAR no LDAR
[§ 116.620(c)(1) or § 116.620(c)(2)]
10£25 28M [(c)(1)] no LDAR
25£40 28VHP [(c)(2)] 28M [(c)(1)]
>40 28VHP [(c)(2)] 28VHP [(c)(2)]
Are all components in sweet crude oil or gas service (defined in 30 TAC X RECEPTOR APPLICABLE REQUIREMENT
Chapter 101)? X < ¼ mile § 116.620(c)(3)
If NO, mark applicable inspection and monitoring requirements. ³ ¼ mile § 116.620 (c)(3) or (e)(1)
[§§ 116.620(c)(3) and 116.620(e)(1)]
Are there flares at the facility? X If YES, fill in the appropriate data.
Minimum heating value of waste gas: 1247 Btu/cf
Is gas necessary for adequate combustion? No
Maximum tip velocity: 0.3’/sec
Method of pilot flame monitoring: continuous electronic
ignition
Is a flare the only combustion unit at the site? X If NO, mark the fuel type for all combustion units.
sweet natural gas
liquid petroleum gas
fuel gas £10 grains total sulfur/100 dscf
field gas £1.5 grains H2S/100 dcfm
or £30 grains total sulfur/100 dscf
X field gas >1.5 grains H2S/100 dcfm
or >30 grains total sulfur/100 dscf
(recordkeeping requirements of § 116.620(a)(18)
applicable)
Are all storage tanks onsite either (1) pressurized; (2) < 25,000 gallons in X If NO, mark the applicable control.
size; or (3) used for storage of compounds with vapor pressures < 0.5 psia? internal floating roof [§ 116.620(b)(1)(A) & (C)]
external floating roof [§ 116.620(b)(1)(B) & (C)]
X VOC destruction device with 99.8% destruction
efficiency
& degas system before storage
Vapor Recovery System with 95% recovery efficiency
Are there any fixed roof storage tanks onsite that emit > 10 tpy VOCs or X If YES, list the type of control device and its efficiency
sulfur compounds? [§ 116.620(b)(1)(D)]:

DESCRIBE OVERALL PROCESS AT THE SITE

Marathon Oil EF LLC (Marathon) is submitting the standard permit change of registration application for the North Longhorn Central
Facility located in Karnes County, Texas. Under Permit No. 99778, the North Longhorn Central Facility is authorized to operate oil and gas
production equipment for receipt, separation and custody transfer of produced fluids (crude/condensate, formation water, and natural gas)
from wells located in the area, and handles natural gas that may contain more than 24 ppmv H2 S (company is now claiming 400 ppmv H2S)

The North Longhorn Central Facility is authorized under Permit No. 99778 to operate gas and oil production facilities, including
two heater treaters, each equipped with dual burners, six compressor engines, a flash tower, ten oil storage tanks, six produced
water storage tanks, two loading facilities, two glycol dehydration units, a slop tank, two flares and one combustor.

Changes in this registration application include a proposal to increase production to 30 MMscf/day @ 400 ppmv H2S, 10,500 BCPD, 4,000 BWPD
and other operational and equipment changes as outlined below.

DESCRIBE PROJECT AND INVOLVED PROCESS

Marathon Oil is submitting this change of registration application to authorize the following changes at the North Longhorn Central Facility under 30
TAC §116.620.
• Installation of two 1380-HP Caterpillar Compressor engines (CE-7 & CE-8) to accommodate potential increase in the facility's gas throughput from
current rate of 20 MMscf/day to 30 MMscfd;
• Installation of one additional H2S Scavenger Unit (Ultrafab Skid), which will not be a source of emissions;
• Installation of one 750-bbl gun barrel oil/water separator tank (GBTK-1), with emissions controlled by the low pressure flare;
• Installation of a vapor recovery unit (VRU) to recover emissions from the crude/condensate tanks;
2
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

• Installation of one VRU compressor powered by a 46-hp Gas Jack-Compressco GJ230 Engine (CE-9);
• Installation of two electric-powered VFD engines to supplement vapor recovery;
• Installation of one 210-bbl chemical tank, which will not be a source of emissions;
• Removal of combustor (enclosed-flare), whereby all sources previously controlled by the combustor will be controlled by the low pressure flare,
previously referred to as the "Loading Flare" (FL-2);
• Control of the crude/condensate truck loading emissions with the high pressure flare, previously referred to as the "Emergency Flare" (FL-1),
instead of the low pressure flare.
• Revision of the glycol dehydration still vents' (DHY-1 & DHY-2) emissions to accommodate potential increase in the facility's gas throughput from
current rate of 20 MMscfd to 30 MMscfd;
• Revision of the glycol reboiler (RBL-1 & RBL-2) emissions to reflect that the existing glycol dehydration still vents will be controlled by
the reboiler, in lieu of the combustor;
• Revision of produced water tank (WTK-1 thru WTK-6) emissions to update tank color and to represent control of emissions by the low pressure flare,
in lieu of the combustor;
• Revision of slop tank (SLTK-1) emissions to reflect an increase in throughput, update tank color and to represent control of emissions by the low
pressure flare, in lieu of the combustor;
• Revision of the crude tank (CTK-1 thru CTK-10) emissions calculations to update tank color, and to represent that VOC emissions are routed
to a VRU with 98% capture efficiency during normal operating conditions, or are controlled by the low pressure flare, in lieu of the
combustor, when the VRU is inoperable;
• Revision of emissions to include venting of flash tower emissions to the low pressure flare (FL-2) for periods not to exceed 438 hours annually.
• Revision of emissions calculations for fugitive component equipment (FUG-1), due to installation of additional equipment;
• Addition of small VOC emissions, vented from existing and new compressor b1owdown valves through the blowdown vent. (Note that these emissions
from the compressor blowdown vent are not associated with maintenance, start-up and shutdown activities.)
• Revision of emissions to incorporate site-specific sampling conducted during October 2012.

The North Longhorn Central Facility handles and comingles oil and gas from multiple oil and gas production wells. North Longhorn receives
produced fluids (crude/condensate, formation water and natural gas) from wells located in the area and separates the produced fluids so that the gas and oil
can be sold for customer use. North Longhorn Central Facility is currently authorized to handle a maximum of 20 MMSCF of natural gas, 4,000 barrels of
produced water and 10,500 barrels of crude per day. However, one of the changes requested in this change of registration is for operational flexibility to
increase the maximum gas handling rate to the North Longhorn facility to up to 30 MMSCF per day.

Natural Gas Handling:

A mixture of produced fluids enters the facility through flow lines connected to a suction header and is directed to a three-phase separator to separate the
natural gas, crude/condensate and produced water. After separation, the natural gas is routed first to an H2S Scavenger (Ultrafab Skid), where the H2 S is
removed from the gas, and then to two glycol dehydration units, where water is removed from the gas stream. Compressors (CE-1, CE-2 and CE-3) are used
to increase pipeline pressure of the gas, as needed. After the H2 S and water have been removed from the gas, it is sold via pipeline.

At this time, Marathon requests authorization to install two additional compressors, each powered by a 1380 horsepower Caterpillar engine (CE-7 and CE-8),
to increase gas compression capacity. Marathon also requests installation of an additional H2S Scavenger unit. The existing and new H2 S Scavenger
Units consists of a tower where gas contacts H2S scavenger chemical. Treated gas is routed to the dehydrator. Spent chemical from the H2S Scavenger
Units is pumped to the 400-bbl slop tank (SLTK-1) for disposal. The H2S Scavenger is not a source of emissions.

The above mentioned glycol dehydration units each include a flash tank, a glycol regenerator still and a reboiler (RBL-1 and RBL-2). The vapors from
each dehydrator flash tank are routed to the reboiler, which has an assumed destruction efficiency of 99%, for destruction. The emissions from the glycol
regenerator stills (DHY-1 and DHY-2) are first routed to a condenser (JATCO BTEX Eliminator), and the uncondensed gas is then routed to the reboiler for
destruction. BTEX and other hydrocarbons that are condensed out in the JATCO BTEX eliminator are sent to the slop tank (SLTK-1).

The dehydrator still vent emissions are sent to the firebox 100% of the time during normal operations. When the main burner is on its firing cycle, the exhaust
gases keep an igniter coil red-hot by accumulating heat in the fire tube. After the main burner shuts off, VOCs are routed to the exhaust stack through the
igniter coil that will ignite or flash the vapor until there is free air oxygen dilution.

Crude/Condensate and Produced Water Handling:

Crude/condensate from the three-phase-separator is routed to one of two heater treaters, which are each equipped with duall.5 MMBtu/hr burners (HTR-
1, HTR-2, HTR-3 and HTR-4). The heater treater further separates the produced water and crude/condensate. Gas is released from the heater treater, which is
compressed (CE-4), routed to the H2S Scavenger and dehydrator units, then to the sales pipeline. The crude/condensate from the heater treater is routed
to a flash tower to allow additional gas, the lighter hydrocarbon flash gases released due to system pressure differences, to be captured, compressed and
routed to the sales pipeline using the flash tower compressors (CE-5 and CE-6).

At this time, Marathon requests authorization to install two electric-powered VFD engines to supplement vapor recovery from the flash tower, as well
as one additional flash tower VRU compressor (CE-9), powered by a 46-hp Gas Jack-Compressco GJ230 Engine (CE-9), to compress and route flash
gas to the sales pipeline. Marathon also requests approval for a 750-barrel vessel, referred to as a gun barrel, to provide additional crude/condensate and
produced water separation. Emissions from the gun barrel will be controlled by the low pressure flare (FL-2), with a 98% destruction efficiency.

The crude/condensate from the flash tank tower will flow to one often 1,000-bbl tanks for storage. Because all flash gases are released and captured in the
flash tank tower under normal operating conditions, only working and breathing emissions result from the operation of crude storage tanks. The produced
water from all separation vessels is stored in one of six 500-barrel tanks, which also emit only breathing and working losses.
3
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

The current permit authorizes the control of emissions from the crude/condensate tanks, the produced water tanks and the slop tank by an enclosed flare
(CMBTR-1). However, at this time, Marathon requests: (1) removal of the enclosed flare; and (2) authorization to install a VRU to capture 98% of the
breathing and working losses from the cmde/condensate tanks, under nonnal operating conditions, or to route the crude/condensate tank emissions to the low
pressure flare when the tank VRU is not operating for a period not to exceed 876 hours annually. With the removal of the enclosed flare, Marathon also
requests to control emissions from the produced water and slop tank with the low pressure flare (FL-2). Thus in summary, with this change of
registration application, Marathon requests to utilize the low pressure flare ( FL-2), which has a destruction efficiency of 98%, to control the working
and breathing losses from the produced water, gun barrel and slop tanks, and from the crude/condensate tanks, when the tank VRU system is out of service.

Marathon will assure that the new tank VRU meets the following parameters 100% of the time in order to continue to claim 98% control efficiency for the
newly installed tank VRU:

• A Properly Designed Bypass System: The VRU system will be equipped with a pressure relief valve (PRV) and flame trap for emergency
situations in the unlikely event that the system encounters an over pressure event. If the VRU is down, the gas will be bypassed to the low
pressure flare (FL-2) to control the collected gases.
• Appropriate Compressor Selection: The VRU compressor is engineered to handle the amount of gas anticipated to come off of the tanks
during production. Electricity is not available from the grid, so the compressor will be driven by natural gas.
• The VRU will have a gas blanket to prevent oxygen from entering the system. Specifically, the VRU compressor will have
recycle/makeup gas to ensure that the minimum flow and suction pressure required to run the compressor are available. In addition, the
compressor will have low suction pressure shutdowns which will shut down the compressor if the suction pressure gets too low. These
controls will prevent a vacuum scenario at the tanks, which would result in the valves on the tank vent system opening to let air into the
tanks and VRU system. In essence, this system provides the same level of control as would a gas blanket system.

The crude/condensate is currently removed from the site via pipeline. However, truck loading of the crude/condensate is authorized under the current permit
in case of temporary interruption to the oil pipeline service. Marathon wishes to maintain its authorization to perform truck loading at the North
Longhorn facility at a limit of 4,000 barrels of crude per day. If crude/condensate truck loading is performed at the North Longhorn facility, it will be
controlled by the high pressure flare (FL-1).

The facility will have one tank to store spent chemicals from the Ultrafab H2S Scavenger Units. The tank is expected to contain triazene and its reacted
compounds: thianes, thiazines, alkylamines, and alkanolamines. It is expected that the contribution to emissions from this source is very small and therefore
the emissions are not quantified, per guidance from the TCEQ.

Alternate Operating Scenario:

Marathon is requesting authorization of an alternate operating scenario for the possible venting of flash-off gas emissions from the existing flash tower.
Please recall that during normal operations, the flash-off gases will not vent via the crude storage tanks. Because the oil is routed through the flash towers
prior to storage, the lighter hydrocarbon flash gases, released due to system pressure differences, are captured, compressed and routed to the sales pipeline.
However, Marathon desires to have authorization to also divert the flash off gases to the low pressure flare for up to 438 hours annually to allow for additional
operational flexibility. The additional emissions from the low pressure flare associated with this alternate operating scenario are included with this
submittal.

TECHNICAL SUMMARY - DESCRIBE HOW THE PROJECT MEETS THE RULES

The company estimated speciated and demonstrated that the emissions meet the limits of PBR 261/262.

4
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

As previously described, gas and oil production facilities are operated at the North Longhorn Central Facility. Currently, two heater treaters with
dual burners, two glycol dehydration units, six compressor engines, two loading facilities, sixteen storage tanks, one emergency and one enclosed flared are
authorized under Permit No. 99778. Marathon submits this change of registration to authorize changes to the following emission sources: (1) installation of
three new compressor engines; (2) installation of one 750-barrel gun barrel; (3) removal of the combustor (enclosed flare); (4) venting of flash tower
emissions to the low pressure flare (FL-2) for periods not to exceed 438 hours annually; (5) designation of the high pressure flare (FL-1) as the control
device for crude/condensate loading performed during temporary interruption to the normal oil pipeline service; (6) venting from existing and new
compressor blowdown valves through the blowdown vent; and (7) updating the emissions to incorporate site-specific sampling conducted during
October 2012. Please note that all sources previously controlled by the enclosed flare will now be controlled by the low pressure flare.

Marathon also seeks authorization for the following non-emitting process equipment: (1) one additional H2S Scavenger Unit (Ultrafab Skid); (2) a vapor
recovery unit (VRU) to recover emissions from the crude/condensate tanks; (3) two electric-powered VFD engines to supplement vapor recovery; and (4)
installation of one 210-bbl chemical tank.

Emissions calculations for the newly installed equipment and revisions to the emissions calculations for existing equipment whose emissions are affected
by the proposed changes are included in this submittal. The following text describes the design specifications and emissions calculations methods for each
proposed and existing emission source to be operated at this facility. The design specifications for each existing and proposed emission source at this facility
are also summarized in Table 1.

Heaters

The North Longhorn Central Facility includes the operation of two heater treaters, each equipped with dual burners (HTR-1, HTR-2, HTR-3 & HTR-4) rated
at 1.5 million British Thermal Units (MMBtu), which are used to provide heat to the phase-separation process facilitated within the heater treaters.
The North Longhorn Central Facility will also include the operation of two 0.5 MMBtu heaters, referred to as the glycol dehydration regenerator
reboilers (RBL-1 & RBL-2), which will provide heat required for the glycol regeneration process. The heater treaters will bum field gas as fuel, and the
glycol dehydration units will bum vapors from the flash tank and the regenerator overhead gas. The separator heater and the glycol dehydrator reboilers
emit combustion gases. The proposed nitrogen dioxide (NOx), carbon monoxide (CO), volatile organic compound (VOC) and particulate matter (PM)
emissions from the heaters were estimated using the emission factors provided in AP-42, Chapter 1.4, Tables 1.4-1 and 1.4-2. Mass balance
methodology was used to estimate the hydrogen sulfide (H2S) and sulfur dioxide (S02) emissions, except that H2S emissions from the glycol dehydration
reboilers were calculated via the GRI-GLYCALC process simulation program.

The NOx, CO, VOC and PM emissions remain the same as represented in the current permit, except that this submittal will address particulate matter
of 2.5 microns in diameter or less (PM2.5), which is not addressed in the current permit. However, the hazardous air pollutant (HAPs), S02 and H2S
emissions in this change of registration have been revised to incorporate site-specific sampling data. Refer to Table 1(a) and the emissions calculations in
Appendix B for the updated HAP, S02 and H2S emissions.

Engines
Three (3) 1380 horsepower Caterpillar compressor engines (CE-1, CE-2 & CE-3), one (1) 58 horsepower Ajax DPC 60 compressor engine (CE-4), and
two (2) 46 horsepower GasJack GJ230 compressor engines (CE-5 & CE-6) are currently operated at North Longhorn Central Facility. To address a
potential increase in gas production, Marathon requests the installation of two (2) additional 1380 horsepower Caterpillar compressor engines (CE-7 & CE-8)
and one (1) 46 horsepower GasJack GJ230 compressor engine (CE-9). Upon the installation of the three new compressor engines, the facility will include
nine compressor engines in total.

The five (5) Caterpillar engines are needed to increase the field gas pressure to the pressure required by the gas sales pipeline. The existing Ajax
compressor engine compresses gas recovered by the heater treaters' vapor recovery unit (VRU), and the GasJack engines compress gas recovered by the
flash tower(s) VRUs for reintroduction into the system. The existing and proposed compressor engines will be fueled by field gas. The operation of the
compressor engines results in emission of combustion gases. The proposed Caterpillar engines (CE-7 & CE-8) and the GasJack engine (CE-9) will
be equipped with catalytic converters to control the CO, VOC and formaldehyde emissions, as is the case with the existing Caterpillar and GasJack engines.
The existing Ajax engine is not equipped with any emission controls.

The emission factors provided in the manufacturers' specification data sheets were used to estimate the proposed NOx, CO, VOC and formaldehyde
emissions for the new compressor units. Mass balance methodology was used to estimate the hydrogen sulfide (H2S) and sulfur dioxide (S02) emissions
for the new engines, and the emission factors in AP-42, Chapter 3.2, Table 3.2-2 as well as the site-specific gas analysis were used to estimate other
hazardous air pollutant emissions for the proposed compressors. The NOx, CO, VOC and PM emissions for the existing compressors remain the same as
represented in the current permit, except that this submittal will address particulate matter of 2.5 microns in diameter or less (PM 2.5), which is not
addressed in the current permit. However, the hazardous air pollutant (HAPs), S0 2 and H2 S emissions in this change of registration have been revised
to incorporate site-specific sampling data. Refer to Table l(a) and the emissions calculations in Appendix B for the new compressor engine emissions
and the updated HAP, S02 and H2S emissions for the existing compressor units.

Please note that this change of registration also includes the addition of blowdown valve emissions that are vented through the blowdown vent when the
compressors are in operation. The valve emissions vented from the compressors' blowdown vents are not associated with routine maintenance, start-up and
shutdown (MSS) operations. The source of these very small emissions is technically fugitive emissions that escape from the blowdown valves when the
compressors are running, but are emitted through the blowdown vent. Thus, these emissions are calculated separately as emissions from a point source (the
blowdown vent). In effect, the blowdown valves act as open-ended lines; therefore, these emissions were calculated using the emissions factors for open-

5
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

ended lines in the TCEQ Interoffice Memorandum for oil and gas production operations. These emissions were not represented in the current permit, but
are included in Table l(a) and the emissions calculations in Appendix B in the file for the existing and proposed compressor engines.

MSS emissions are not currently authorized under this permit and are not included in this change of registration. Marathon will ensure that the MSS
emissions not addressed under this permit are authorized by the appropriate agency deadline.

Glycol Dehydration Unit

The North Longhorn Central Facility operates two glycol dehydration units, which each include a flash tank, a glycol regenerator still and a reboiler to
remove water from the gas stream. Currently, the dehydration units are authorized to handle 10 MMSCF per day for each unit. However, Marathon
requests an increase in the gas feed rate to 15 MMSCF per day for each unit, to address a potential increase of gas production to the North Longhorn Central
Facility. The current permit also authorizes vapors resulting from operation of the flash tanks and the glycol regenerator stills to be controlled by
the previously authorized combustor (enclosed-flare). At this time, Marathon requests authorization to route the emissions from the flash tanks and
the glycol regenerator stills to the reboiler instead of the combustor, which will no longer be operated at the North Longhorn Facility. To address the
increased feed rate, the change in controls and to incorporate site-specific sampling results, the VOC emissions from the glycol dehydration units
were re-calculated using the GRI-GLYCalc Version 4.0 program with a VOC destruction efficiency of 99%. Refer to Table l(a) and the emissions
calculations in Appendix B for the updated VOC and HAP emissions from the glycol dehydration units.

The company used GRI-GLYCalc Version 4.0 to estimate the emissions from each dehydration unit. The absorber parameters are 15 MMCFD, 1.25 calculated
absorber stages, 100 oF wet gas temperature, 850 wet gas psig, calculated wet gas water ratio 66.16 lbs H2O/ MMSCF, lean glycol flow rate 1.85 gal/min, flash
gas temperature 220 oF, flash tank pressure 120 psig, 3782 scf/hr flow rate to the reboiler and lean glycol recirculation rate 3.00 gal/lb H2O. Regenerator and flash
tank controlled by the reboiler. Emissions are estimated at 0.96 lbs/hr and 0.858 tpy of VOC, 0.0065 lbs/hr and 0.028 tpy benzene and 0.034 lbs/hr and 0.150 tpy
BTEX emissions.

Flash Tower(s) and Storage Tanks

The current permit authorizes all existing storage tanks to emit only breathing and working losses that are reduced by the onsite combustor (enclosed-
flare). The flash gases which are normally captured via the flash tower(s) a r e authorized to vent to the combustor (enclosed-flare) during periods that
the flash tower(s) are not in operation. At this time, Marathon requests the following equipment changes to the flash tower(s) and storage tank
operations:

• Installation of a vapor recovery unit (VRU) to capture the working and breathing losses from the crude/condensate storage
tanks at a capture efficiency of 98%. The tank VRU will recover the working and breathing loss emissions and reintroduce them into
the sales pipeline. However, Marathon requests authorization to route the breathing and working losses to the low pressure flare
(FL-2) when the tank VRU(s) are down for periods not to exceed 876 hours annually (10% of normal operations);
• Venting of flash gases, which are normally captured via the flash tower VRU(s), to the low pressure flare (FL-2), rather than the
previously authorized combustor, during periods not to exceed 438 hours annually of flash tower down time (5% of normal
operations). The combustor will no longer be in operation at this facility.·
• Venting of the tank emissions from the produced water and slop tanks to the low pressure flare (FL-2), rather than the previously
authorized combustor. Again, the combustor will no longer be in operation at this facility; and
• Installation of one 750-bbl gun barrel oil/water separator tank (GBTK-1), with emissions controlled by the low pressure flare (FL-2).

Marathon will assure that the tank VRU meets the following parameters 100% of the time in order to continue to claim 98% control efficiency
for the newly installed tank VRU:

• A Properly Designed Bypass System: The VRU system will be equipped with a pressure relief valve (PRV) and flame trap for
emergency situations in the unlikely event that the system encounters an over pressure event. If the VRU is down, the gas will be
bypassed to the low pressure flare (FL-2) that will control the collected gases.
• Appropriate Compressor Selection: The VRU compressor is engineered to handle the amount of gas anticipated to come off of the
tanks during production. Electricity is not available from the grid, so the compressor will be driven by natural gas.
• The tank VRU will use a gas blanket to prevent oxygen from entering the system. Specifically, the VRU compressor will have
recycle/makeup gas to ensure that the minimum flow and suction pressure required to run the compressor are available. In
addition, the compressor will have low suction pressure shutdowns which will shut down the compressor if the suction pressure gets
too low. These controls will prevent a vacuum scenario at the tanks, which would result in the valves on the tank vent system
opening to let air into the tanks and VRU system. In essence, this system provides the same level of control as would a gas blanket
system.

The uncontrolled working and breathing loss emissions from all the storage tanks were calculated using EPA's TANKS 4.09d program. The uncontrolled
flash emissions for the facility were calculated using E&P Tanks v2.0. The uncontrolled tank emissions have been updated to incorporate site-specific data
and to address the fact that the tanks are either green or black in color. (Refer to the North Longhom Flash Tower Hydrocarbon Liquid SPL Analysis No.
2012100181-006A for the tank liquid hydrocarbon composition and chemical property data.). Please note that the solar absorbance factor for the color "red
primer" was used to model the uncontrolled working and breathing losses because it is the closest in value to the solar absorbance factor for a tank
color of black or green.
6
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

The uncontrolled short-term breathing and working losses for all tanks are estimated using the highest monthly emission data from the TANKS program
output. A portion or all of the 2% of un-captured emissions from the crude/condensate tanks will vent via the Enardo depressurization valves; thus,
these emissions have been included as part of the fugitive emissions. Uncontrolled emissions from the water tank are based upon the presence of 1% by
volume of oil; and the uncontrolled emissions from the new gun barrel tank are based upon the presence of 3% by volume of oil. To address all of
the above described changes, the following calculations are presented in Appendix B of this submittal:

• Breathing and working losses from the new 750-bbl gun barrel tank, which vent to the low pressure flare (FL-2);
• Breathing and working losses from the existing slop tank, which vent to the low pressure flare (FL-2);
• Breathing and working losses from the six existing produced water tanks, which vent to the low pressure flare (FL-2);
• The 2% of uncaptured emissions from the crude/condensate tanks will vent via the Enardo depressurization valves;
• The breathing and working losses from the ten existing crude/condensate tanks, which will vent to the low pressure flare (FL-2) during
periods that the tank VRU is not in operation for no more than 876 hours annually (10% of normal operations);
• The flash-off gases that will vent to the low pressure flare (FL-2) when the flash tower VRU system is not in operation for periods not to
exceed 438 hours annually (5% of normal operations); and
• Copies of the TANKS 4.09d and the E&P Tanks v2.0 outputs associated with the above described emissions calculations.

Loading
A pipeline has been connected to this facility to transport the sales oil off-site. However, for additional operational flexibility, Marathon wishes to
maintain authorization to truckload crude/condensate from the facility. If crude/condensate is loaded at this facility, it will be controlled by the high pressure
flare (FL-1). The maximum truck loading rates for truck loading of both crude/condensate and produced water remain as represented in the current permit.
However the VOCs and the HAPs have been revised to incorporate site specific sampling data. Refer to Table l(a) and the emissions calculations in
Appendix B i n t h e f i l e for the updated HAP emissions.

The North Longhorn Central Facility will continue to operate two, air assist flares with 98% control efficiencies to reduce the hydrocarbons emitted at
the facility. In general, the high pressure flare (FL-1) will be used to control VOCs emitted from the facility during upset conditions at the station. However,
the high pressure flare will also be used to control VOC emissions resulting from crude/condensate truck loading operations during temporary interruption
to the normal oil sales pipeline service. The low pressure flare (FL-2) will be used to control emissions of VOC from the gun barrel, produced water, and
slop tanks and occasionally from the flash tower(s) or crude/condensate tanks, if the VRUs that normally capture gas from these units are temporarily out of
service. Both flares will continue to emit NOx, CO, VOCs, SO2 and H2S. The NOx and CO emissions are based upon the emission factors
provided in the TCEQ's Technical Guidance for Flares and Vapor Oxidizers. The VOC, S02 and H2S emissions were calculated using mass
balance methodology, with a VOC reduction rate of 98% and a H2S to S02 conversion rate of 98%. However, please note that a destruction
rate of 99% was used for propane for the flash-gas stream that will vent to the flare when the flash tower(s) are not in operation.

Fugitive Equipment Components

The fugitive emissions have been revised to reflect the change in fugitive component counts associated with the equipment changes represented in
this change of registration. The emission factors for fugitive equipment components were taken from the TCEQ Interoffice Memorandum for
oil and gas production operations. The calculations for the fugitive emissions are based upon gas, light liquid and oily water stream emission
factors. However, please note for purposes of conservatism, the emissions for several of the compressor seals were estimated using composition data for
the gas stream captured by the heater treater VRU compressors. Additionally, the compressor seals for the electric VRU units are included in the
equipment component counts. Lastly, a separate calculation is performed for the Enardo depressurization valves on the storage tank, and these
emissions are included in the total fugitive emissions for the site.

Fugitive emissions were estimated based on EPA 453/R-95-017 Protocal for Equipment Leak Emission Estimates, Table 2-4. Individual emission sources include
valves, flanges, connectors, and pumps. All fugitive emissions are assumed to be uncontrolled to be conservative. The fugitive component counts are 306 gas
valves, 949 gas connectors, 25 gas compressor seals, 14 gas relief valves, 0 gas flanges, 25 gas other, 304 light oil valves, 483 light oil connectors, 523 light oil
flanges, 19 light oil relief valves, 6 light oil pumps, 6 light oil other, 68 water/light oil valves, 108 water/light oil connectors, 125 water/light oil flanges, 0 heavy oil
valves, 0 heavy oil flanges, 0 heavy oil connectors, 0 heavy oil pumps, and 0 heavy oil other. The VOC content in the gas was 25.78 wt.%, 0.06 wt % H2S and the
light oil and water/light oil VOC content was 100 wt.%. The company also included 11 pneumatic controllers (0.2 scf/hr each) in the fugitive emission estimates.

7
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

NAAQS Compliance- Impacts are less than NO2 hourly and annual NAAQS

8
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

The company provided the emissions estimates and speciation for both options in the file. The speciation for normal emissions is below. Both speciations for the
normal operations and the alternate operations were compared below. Both total speciated scenarios numerical values compared favorable to the MAERT values.

No MSS emissions were submitted or reviewed.

NATURAL GAS FIRED COMPRESSOR ENGINE

Engine Engine Information Pollutant Source Emission Type Control Emission Emissio Emissio
Identifier of Factor of efficien Factor ns ns (tpy)
(EPN / name) Emissio before Contro cy after (lb/hr)
n factor controls l controls
Device Lbs/MMBt
u
CE-7, CE_8-Cat Horsepower: 1380 NMNEHC 0.69 g/hp-hr Oxid 50% 0.187 2.10 9.20
G3516B-1380 hp catalyst
Fuel 8163 NOx 0.5 g/hp-hr 0.136 1.52 6.66
Consumption
(Btu/hp-hr):
2 or 4 stroke, 4SLB CO 0.22 g/hp-hr Oxid 93% 0.0589 0.66 2.89
Rich or Lean catalyst
Burn:
Hours of 8760 PM10 0.0000771 0.11 0.49
Operation per
year:
Vendor Data Yes SO2 0.00333 0.04 0.16
Sheet Included?
(required if ≥
500-hp )
Date of New. CH2O 0.1056 Oxid 76% 0.029 0.32 1.41
Manufacture or >3/1/13 catalyst
Reconstruction:
Does NSPS, Subpart JJJJ apply? Yes Why or why not? New RICE at Area Source.
If yes, how will requirements be
met?
Does MACT, Subpart ZZZZ Yes Why or why not? New RICE. Meet JJJJ.
apply? If yes, how will requirements be
met?
Fuel 1308 Btu/scf -- assume 24 ppmv H2S

NATURAL GAS FIRED COMPRESSOR ENGINE

Engine Engine Information Pollutant Source Emission Type Control Emission Emissio Emissio
Identifier of Factor of efficien Factor ns ns (tpy)
(EPN / name) Emissio before Contro cy after (lb/hr)
n factor controls l controls
Device
CE-9 / Engine Horsepower: 46 NMNEHC 0.54 Oxid 0.05 0.24
GasJack GJ230 catalyst
Fuel 10,777 NOx Oxid 2.0 1.67 7.32
Consumption catalyst
(Btu/hp-hr):
2 or 4 stroke, 4SRB CO 18.62 1.89 8.27
1308 Btu/SCF
Rich or Lean
gas energy
Burn:
No controls
Hours of 8760 PM2.5 0.00991 lbs 0.00 0.00
Operation per PM2.5/MMBt 0.00 0.00
PM10
year: u
0.01941 lbs
PM10/MMBt
u
Vendor Data Yes SO2 0.000588lbs 0.00 0.00
Sheet Included? /MMBtu
(required if ≥
500-hp )
Date of >3/1/13 CH2O 0.0205 0.00 0.00
Manufacture or lbs/MMBtu
Reconstruction:

9
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

Does NSPS, Subpart JJJJ apply? Yes Why or why not? Manu after 7/1/2008 trigger.
If yes, how will requirements be
met?
Does MACT, Subpart ZZZZ Yes Why or why not? New Rice. Meet JJJJ.
apply? If yes, how will requirements be
met?

COMMUNICATION LOG
Date Time Name/Company Subject of Communication
3/13/2013 1345 VKKURKI@MARATHONOIL.COM Email-Please respond:
1. To confirm if the company agrees to receive the response letter
electronically and that no hard copy will need to be sent. All completed
projects can be viewed at:
2. If the company has implemented the project.
3. If the company is waiting on a response from the TCEQ before starting
construction.
4. If you have any updates to the project listed above, please send them in
now.
3/29/2013 1150 Ms. Terri May, 832-251-5184 Email--Revised calculations in four areas, glycol dehydration units, low pressure
flare, summary pages and VOC speciation.
3/29/2013 1226 Ms. Terri May, 832-251-5184 Email--Hello again. Please also replace pages 16 and 21 of the report text. I’ve
attached two PDF files. I am sending you one file to show you the changes
made. (See the file with “DO NOT PRINT” in the file name.) The changes are
highlighted in yellow and are very minor. Basically, the original text made
references to section 2.2, which does not exist. The correct section number that
should have been referenced in this part of the text is “6.2”. The other PDF is
the one you should print and replace the previous pages 13 and 21.
4/4/2013 1655 Tara Capobianco Hi, John. I see that you just got an application for Marathon Oil (formerly North
Longhorn Central Tank Battery). The region is requesting mobile monitoring be
conducted downwind of this site. I was wondering what the pending permit
action entails and if there is anything we should let the group know about.
4/4/2013 1715 Tara Capobianco This is the current SP permit requirements issued June 15, 2012 for this high
production site.
We further understand that you that you will operate with the following:
flash tank towers (degassing units) which will remove all flash gas before tank
storage or as an alternate operating scenario, all degassing units are inoperative
and all flash gas will be routed to the combustor below
a 99.8% efficient combustor (enclosed flare) for storage tank control
a flare (EPN FL-2) as the condensate loading control
20 MMCFD limit of natural gas through two dehydration units with JATCO
BTEX Eliminator on each still vent
10,000 barrels of condensate per day (BCPD) production limit
4000 BWPD & 4000 BCPD loading limit
We further understand that for both bases, pressure tested trucks will be used for
all controlled condensate loading and only produced water loading will be
uncontrolled. We also understand that you will obtain a pressurized condensate
sample prior to the storage tanks for analysis and verification that all flash gas
has been removed and the results submitted within 120 days of the start of
operations. Also within this time frame, you will verify the site emissions based
upon actual site sampling analysis and resubmit a revision to the standard permit
if necessary.
They have applied for a revised SP with 30 MMSCFD throughput, 4,000
BWPD, and 10,500 BCPD which is on my desk. The review should start next
week and barring no problems should be finished by the end of the week or
early the following week.
4/5/2013 1100 Mr. David Reyna Advise Mr. Reyna of the concern from Ms. Capobiance. He wanted to stay
advised.
4/11/2013 1500 Ms. Tara Capobianco Office visit- Had not heard from region and need to issue permit soon but
would not if region had a concern. She stated she would get in touch with
region and have them call me.
4/16/2013 1300 Ms. Tara Capobianco Office visit- Who in region contacted you so I can call them? George Ortiz.
4/17/2013 0830 Mr. Vijay Kurki Called to discuss the project. I told him that I had completed approximately

10
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

90% of the paperwork but I could not issue the permit until I talked to region.
They possibly had some monitoring concerns.
4/17/2013 1530 Mr. Vijay Kurki Stated that they were sending in an update to the project today. Ms. May would
submit electronically in a little while.
4/17/2013 1728 Terri.May@Tetratech.com Email- Per your previous discussions with Mr. Vijay Kurki of Marathon Oil,
please accept and review the attached updates to the pending standard permit
change of registration for the North Longhorn Central Facility (Permit No.
99778). The summary of changes is included in the attachment. Please note
that the submittal includes calculation changes only for the heaters, the oil tanks,
the low pressure flare and the fugitive emissions from the tank’s Enardo valves.
-- 78pages
4/18/2013 0750 Mr. David Reyna, RR Team Leader Reviewed the revised submittal. The submittal is not an update. They are
increasing production to 15,000BCPD, adding one heater treater with dual 0.5
MMBtu/hr burners, adding five 1,000 bbl condensate storage tanks, and adding
one flash tower. Will discuss the issue with management.
4/18/2013 0930 Mr. David Reyna, RR Team Leader Discuss the issue with region and their issues but since we have done the work
for this project (not the 15,000 BCPD production increase, etc) try to issue this
project. Tell the company AND REGION that we are making a separate project
of their 4/18/2013 15,000 bcpd, etc.submittal.
4/18/2013 1100 Ms. Tara Capobianco Discussed the issue with Ms. Capobianco. Was there anybody else involved in
your conversations with region. Yes but do not remember their name except for
the Region13 Air Boss, Mr. George Ortiz.
4/18/2013 1330 Mr.George Ortiz, Region 13 210-403-4030 Discuss the site which they have authorized. Mr. Ortiz stated that they viewed
the site with an IR camera and heavy “smoke” appeared from all areas of the
site. All the tops of tanks appeared to be emitting heavy “smoke”. I stated that I
have no way of knowing if relief valve are stuck open, sanpling ports are left
open or they built the site not pressure tight. I had attempted to make them live
up to their submittal by taking a pressurized sample to confirm that all flash gas
had been removed from the condensate by the stabilizers(flash towers). But I
had not seen any sample results yet. I discussed with him the plan (4/18/2013-
0930) above. He had no objection. He asked my advise on the situation. I
stated that based upon his IR camera visit, he should discuss the issue with Mr.
Kurki and ask how in view of the camera results were they meeting the permit
requirements (i.e. good operations and no leaks). Maybe he could push for a
leak or pressure check of the facilities to demonstrate that they had no leaks for
the present or push for it for the 15,000 BCPD, production increase, etc project.
He stated that somebody from the site wanted to have a meeting. I stated that I
would keep him advised of any new developments.
4/19/2013 1500 Mr. Vijay Kurki Voice message -The submitted project 4/17/2013 increasing production to
15,000 BCPD and other changes is not going to be accepted in this project.
Please call me and I’ll discuss the situation and what is going to happen.
4/19/2013 1507 Ms. Terri May, 832-251-5194 Called and not in office after two phone calls (office number on email not
correct)
4/22/2013 0823 VKKURKI@MARATHONOIL.COM Draft SP 99778. I plan to turn this draft in later this morning for management’s
Terri.May@tetratech.com signature.
As my voice message states which I left last week, management decided that the
amendment (production increase to 15,000 BCPD, etc) submitted April 17, 2013
would require another separate project.
4/22/2013 1000 Mr. Vijay Kurki , Ms. Terri May Discussed the project. I stated that I was turning in the project for signature
about noon. I explained that they would get a request for a permit fee when
APIRT process the 4/17/2013 production increase, etc. submittal.
4/22/2013 1337 VKKURKI@MARATHONOIL.COM Everything looks good. Here is one minor correction:
PM emissions for CE-4 (58-HP Ajax DPC 60 Compressor Engine No.4) needs
to show 0.03 instead of 0.02 lb/hr. Reviewer will make change.

261/262 Emission Limits Demonstration

D=_______625’________ and K = ___62.25____________

11
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

Total 12.827 20.863

The above normal operation total speciated new project emission totals (12.83 lbs/hr and 20.86 tpy of VOC) compares very favorable with the MAERT below. The
MAERT below totals (26.57 lbs/hr & 73.32 tpy of VOC) minus engine emissions of 8.78 lbs/hr and 38.53 tpy results in 17.79 lbs/hr and 34.79 tpy of VOC minus the
previously authorized non engine emissions (5.43 lbs/hr and 16.41 tpy) results in non-engine new project emissions of 12.06 lbs/hr and 18.38 tpy of VOC . These
numbers are very close together.

MAXIMUM ALLOWABLE EMISSION RATES TABLE (MAERT) Normal Operating Scenario

EPN / Emission Source Specific VOC or VOC NOx CO PM10 PM 2.5 SO2 H 2S
Other Pollutants lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy
HTR-1 / 1.5 MMBtu/hr
0.01 0.04 0.15 0.64 0.12 0.54 0.01 0.05 0.01 0.05 0.05 0.22 0.0006 0.002
Heater Treater Burner No.l
HTR-2 / 1.5 MMBtu/hr
0.01 0.04 0.15 0.64 0.12 0.54 0.01 0.05 0.01 0.05 0.05 0.22 0.0006 0.002
Heater Treater Burner No.2
HTR- 3 / 1.5 MMBtu/hr
0.01 0.04 0.15 0.64 0.12 0.54 0.01 0.05 0.01 0.05 0.05 0.22 0.0006 0.002
Heater Treater Burner No.3
HTR-4 / 1.5 MMBtu/hr
0.01 0.04 0.15 0.64 0.12 0.54 0.01 0.05 0.01 0.05 0.05 0.22 0.0006 0.002
Heater Treater Burner No.4
RBL-1 / 0.5 MMBtu/hr
Glycol Dehydration 0.006 0.02 0.10 0.45 0.09 0.38 0.008 0.03 0.008 0.03 0.23 0.99 0.0023 0.0099
Regenerator Reboiler No.1
RLB-1 / Glycol Dehydration
Regenerator Still & Flash 0.1958 0.8577 - - - - - - - - - - - -
Tank No. l
RBL-2 / 0.5 MMBtu/hr
Glycol Dehydration 0.006 0.02 0.10 0.45 0.09 0.38 0.008 0.03 0.008 0.03 0.23 0.99 0.0023 0.0099
Regenerator Reboiler No.2
CMBTR-1 / Glycol
Dehydration Regenerator 0.1958 0.8577 - - - - - - - - - - - -
Still & Flash Tank No. 2

12
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

CE-1 / l380-HP Caterpillar

G3516B Compressor Engine 1.67 7.33 1.52 6.66 0.66 2.88 0.102 0.45 0.102 0.45 0.02 0.091 0.0002 0.001
No.1
CE-2 / 1380-HP Caterpillar
G3516B Compressor Engine 1.67 7.33 1.52 6.66 0.66 2.88 0.102 0.45 0.102 0.45 0.02 0.091 0.0002 0.001
No.2
CE-3 / 1380-HP Caterpillar
G3516B Compressor Engine 1.67 7.33 1.52 6.66 0.66 2.88 0.102 0.45 0.102 0.45 0.02 0.091 0.0002 0.001
No.3
CE-4 / 58-HP Ajax DPC 60 0.0000
Compressor Engine No.4 0.13 0.56 0.56 2.46 0.22 0.95 0.03 0.11 0.03 0.11 0.0011 0.005 0.0001
1
CE-5 / 46-HP Gas Jack
0.0000 0.0000
GJ230 Compressor Engine 0.10 0.44 0.20 0.89 0.41 1.78 0.010 0.042 0.010 0.042 0.001 0.004
1 5
No.5
CE-6 / 46-HP Gas Jack
0.0000 0.0000
GJ230 Compressor Engine 0.10 0.44 0.20 0.89 0.41 1.78 0.010 0.042 0.010 0.042 0.001 0.004
1 5
No.6
CE-7 / 1380-HP Caterpillar ***
G3516B Compressor Engine 1.67 7.33 1.52 6.66 0.66 2.88 0.102 0.45 0.102 0.45 0.02 0.091 0.0002 0.001
No.7
CE-8 / 1380-HP Caterpillar ***
G3516B Compressor Engine 1.67 7.33 1.52 6.66 0.66 2.88 0.102 0.45 0.102 0.45 0.02 0.091 0.0002 0.001
No.8
CE-9 / 46-HP Gas Jack *** 0.0000 0.0000
GJ230 Compressor Engine 0.10 0.44 0.20 0.89 0.41 1.78 0.010 0.042 0.010 0.042 0.001 0.004
1 5
No.9
COMP-BDV / Compressor ***
Blowdown Valve (vented to 0.03 0.11 - - - - - - - - - - 0.0001 0.0003
compressor blowdown vent)
FL-2 / 10 x l000-BBL Crude
Storage Tanks (vents to FL-2 (1) (1) - - - - - - - - - - - -
when VRU down)
FL-2 / 6 x 500-BBL
Produced Water Storage
(1) (1) - - - - - - - - - - - -
Tanks (vents to FL-2 when
VRU down)
FL-2 / one 750 BBL *** (1) (1) - - - - - - - - - - - -
Gunbarrel Tank-GBTK-1
FL-2 / one 400-BBL Slop Oil
(1) (1) - - - - - - - - - - - -
Storage Tanks(vents to FL-2)
FL-1 , CL-1 / Crude Loading
Facility- vents to FL-1 & 1.51 2.55
- - - - - - - - - - - -
1.3%truck loss for NSPS (2) (2)
Subpart XX tested trucks
WL-1 / Produced Water
0.51 1.96
Loading Facility
FL-1 / High Pressure Flare 2.35 4.14 0.47 0.89 0.94 1.78 - - - -- 0.009 0.04 0.0001 0.0004
FL-2 / Low Pressure Flare 7.67 2.20 1.84 0.60 3.67 1.20 - - - -- 0.01 0.04 0.0001 0.0004
F-1 / Equipment Fugitive 5.27 21.92
- - - -- - - - -- - - 0.0029 0.013
Components (3) (3)

Previous Authorized
13.70 51.87 11.17 48.19 13.48 57.54 0.40 1.75 0.40 1.75 0.43 1.88 0.003 0.01
Emissions
Difference 12.87 21.45 0.71 -4.78 -3.47 -30.94 0.2 0.99 0.23 0.99 0.36 1.55 0.008 0.04
TOTAL EMISSIONS : 26.57 73.32 11.88 43.41 10.01 26.60 0.6 2.74 0.63 2.74 0.79 3.43 0.011 0.05
MAXIMUM OPERATING SCHEDULE: Hours/Day 24 Days/Week 7 Weeks/Year 52 Hours/Year 8760
***-New.
(1) The tank emissions are controlled by VRU. The alternate operating scenario when VRU down (5% of year or 438 hrs/yr) is venting of tank emissions to the Low
Pressure Flare, FL-2 and are included in FL-2 emissions.
(2) 1.3% of loading emissions uncollected (NSPS Subpart XX). 98.7% of the loading emissions are collected and controlled by the FL-1 flare and are included in the
emissions.
(3) The equipment fugitive components include emissions from pneumatic controllers.

13
 TECHNICAL REVIEW: STANDARD PERMIT FOR
INSTALLATION AND/OR MODIFICATION OF OIL AND GAS FACILITIES
Permit No.: 99778 Company Name: Marathon Oil EF LLC APD Reviewer: Mr. John Gott, P.E.
6002 - 116.620 (effective
Project No.: 190228 Site/Area Name: North Longhorn Central Tank Battery SP No.:
9/4/2000)

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

Site Review Required? X
PBR Distance Limits Met? X The company claims that 200' exists to the January 30, 2012 John C. Gott, P.E.
property line and 385’ to the nearest receptor.

TECHNICAL REVIEWER PEER REVIEWER FINAL REVIEWER

SIGNATURE:

See Hard Copy.

PRINTED NAME: Mr. John Gott, P.E. Ms. Anne Inman, P.E., Manager
DATE: April 22, 2013 April 22, 2013

BASIS OF PROJECT POINTS POINTS

Base Points: 2.5
Project Complexity Description and Points: 4.25
Communication(several phone calls not 5.0
logged), 27 EPNs & 7 cmpds,,and one revised 1.0
submittal

Technical Reviewer Project Points Assessment: 12.75

Final Reviewer Project Points Confirmation:

14