“KEAN MILLER Fag ain annie oomee aOR SSO UF LDEQ RECEIPT an sanncn Macon agua GtEnnneLeRCOM 2008 SEP 24 PR 2 20 September 24, 2008 : R E ¢C E I y E D Peggy Hatch, Assistant Secretary Office of Environmental Compliance SEP # 0 7008 Department of Environmental Quality oe Hea eden ete ENVIRONMENTAL Com*PL.ANCE Baton Rouge, LA 70821-4312 ENFORCEMENT DIVISION Murphy Oil USA, Inc. AE-CN-08-0122 Agency Interest No. 1238 File No. 18543-11 Meraux Refine! Dear Ms. Hatch, Our firm has been retained to represent Murphy Oil USA, Inc. (MOUSA”) in thi matter, MOUSA was served with the above-referenced Compliance Order and Notice of Potential Penalty (*CO/NOPP”) on September 9, 2008. The purpose of this letter is to request that the Department amend the order to a) correct certain typographical errors and omissions; b) adjust certain deadlines and c) incorporate additional self-reported matters into the order. The CO/NOPP included an interim limit for a cap on H2S emissions from the North and South Flares of SO TPY. MOUSA believes that this is a typographical error and should be restated as 50 Ib/day. The CO/NOPP included interim limit TPY and average pound per hour limits for $02 from the North and South Flares combined. However, it did not include an interim maximum pound per hour limit for SO2 from the North Flare, MOUSA believes that this is an omission as prior discussions and submissions to LDEQ requested an interim limit maximum pound per hour limit of 94 Ib/hr for the North Flare. In prior self-reports, MOUSA indicated that the emissions of CO, NOx, VOC, and PM for the North Flare exceeded permitted limits, but that the combined emissions of these eters from the North and South flares together did not exceed the combined total in the facility's existing permit. MOUSA' requested an interim cap over both flares in place of the individual limits, until the permit can be modified to create a cap. However, the CO/NOPP did not include the requested interim limits for the caps for emissions of CO, NOx. VOC, and PM emissions for the North/South Flares. MOUSA requests that these be included by amending the CO/NOPP to include a condition such as the following condition WTUFLOOR ONE AMERCANPLACE. POST OFNCE BOK2519 GATON ROUGE LOUSAMA THD) PHONE 252870800 FAX 2282888112 Kesler comPage 2 The TPY and annual average emissions of CO, NOx, VOC and PM10 from the North and South Flares combined shall not exceed the current perinit limits for GRPOO25 and GRP0026 combined for these parameters. These interim limits shall apply in Hew of the the individual TPY and annual average pound per hour limits applicable to these sources umil the permit is modified to incorporate this cap or until the termination of this order, whichever oceurs firs. In addition, interim limits for maximum Ib/hr should be established for the North Flare for these parameters. MOUSA requests that the CO/NOPP be amended to include the following, requirement: ‘The maximum hourly emissions of CO, NOx, VOC and PMIO from the North Flare shall not exceed the following: ‘co 24.9 lb/hr NOx 4.6 lb/hr voc 94 lbvhr PMIO 0.6 Ibihr The CO/NOPP requires rerouting of the MDH Fractionator and Charge Heater Vent . (EQ 0033) to the fuel gas recovery system by December 1, 2008. MOUSA believes that this, is a typographical error as information previously provided to LDEQ indicated that the schedule for rerouting this vent was to complete the project on or before December 1, 2009... The engineering and physical construction work cannot be completed by December 1, 2008. Further, it should be noted that the reason for rerouting this vent is that MOUSA believed that such vent is subject to NSPS Subpart J, which would require such rerouting. However. subsequent clarifications from EPA indicate that this vent may not be subject to NSPS Subpart J and may not require such action. MOUSA intends to reroute the vent to the fuel gas system in aniy"easey"but-il'such is-not required, MOUSA would like-to-be able to includesthis-activity as-a Beneficial Environmental Project. MOUSA will likely appeal this requirement to preserve its rights to further discuss the status of this vent with the agencies. Nevertheless, the deadline for rerouting should be amended to December 1, 2009, in any case. Over the past several years, MOUSA has self-reported a number of other devkitions or potential deviations consisting primarily of releases from the North and South Flares and SRU Incinerators Nos. 2 und 3. MOUSA requests that these matters, as set forth on Exhibit A hereto, be incorporated into any amended CO/NOPP so that they may be appropriately resolved with the agency. MOUSA does not concede that all of these matters are violations as many of them are upset events or startup/shutdown/malfunction emissions that were not contrary to any applicable rules. However. including them in the order will allow such issues to be resolved through either final enforcement action or scttlement of that action.Péggy Hatch, Assistant Secretary September 24, 2008 Page 3 x Ce: ‘Thank you for your consideration of this request. If you have any questions, please call me at 225.382.3412, or Kyle B. Beall at 225.382-3493. Lourdes Iturralde, LDEQ Jane Lacour, LDEQ Alice Fredlund, LDEQ Stanley Carpenter, LDEQ Claudia Rush, LDEQ Kent Veron, MOUSA Very truly yours, « Thue Maureen N, Harbourt fr faite Poarho™