1 

### Kelly, Shaheerah

From: Kelly, Shaheerah

Sent: Friday, September 26, 2014 1:39 PM

To: 'Dwight Mallory'

Subject: RE: MCU Questions

Dwight,

Thanks for the information.

************************************

Shaheerah Kelly

Permits Office, Air Division (AIR-3)

U.S. Environmental Protec tion Agency, Region 9

San Francisco, CA 94105

Phone: 415-947-4156

Fax: 415-947-3579

Email: kelly.shaheerah@epa.gov

From: Dwight Mallory [mailto:Dmallory@resoluteenergy.com]

Sent: Friday, September 26, 2014 11:19 AM

To: Kelly, Shaheerah

Subject: RE: MCU Questions

Shaheerah,

Please see the answers to your questions below. I addressed your follow up question regarding supplemental gas in

Answer 1.

Answer 1.

The McElmo Creek Unit Main Flare uses a fixed speed fan and a perimeter mixing ring assembly to provide assist air to

the flare tip. The flare is equipped with a flame front generator that controls the supply of assist air, process gas and

supplemental fuel gas to the flare.

Answer 2.

There are currently 5 electrically driven compressors, listed below, at the MCU gas compression facility. Note that the

AGC

‐ A compressor is out of service.

Dresser

‐ Rand HOS 4 compressor

Dresser

‐ Rand HOS 6 compressor

Ariel C5 Compressor

Worthington Cub AGC

‐ A out of service

Worthington Cub AGC

‐ B

Answer 3.

The statement is correct, except that the last sentence should be corrected to read: “Crude oil is sold at the lease

automatic custody transfer (LACT) unit at each central tank battery and transported to Western Refining’s Ciniza

Refinery in Gallup, NM via the Running Horse Pipeline, which is owned and operated by the Navajo Nation Oil and Gas

Company.

Answer 4.2 The information in the table is correct. Only the 0.75 MMBtu/hr dehydrator unit remains operational. The remaining

equipment in the table has been shut down and removed from the site.

Answer 5.

The highlighted text is correct. CO emissions are based on an emission factor of 0.37 lb/MMBtu.

Dwight E. Mallory

Environmental/Regulatory Manager

Resolute Natural Resources Company, LLC

1700 Lincoln Street, Suite 2800

Denver, CO 80203

Direct: 303-573-4886 X 1165

From: Kelly, Shaheerah [ mailto:Kelly.Shaheerah@epa.gov ]

Sent: Thursday, September 25, 2014 1:59 PM

To: Dwight Mallory

Subject: FW: MCU Questions

Dwight,

Can you also let me know if the Main Flare uses supplemental gas (e.g., for situations where the vent gas going to the

flare is not high enough)?

************************************

Shaheerah Kelly

Permits Office, Air Division (AIR-3)

U.S. Environmental Protec tion Agency, Region 9

San Francisco, CA 94105

Phone: 415-947-4156

Fax: 415-947-3579

Email: kelly.shaheerah@epa.gov

From: Kelly, Shaheerah

Sent: Thursday, September 25, 2014 12:50 PM

To: 'Dwight Mallory'

Subject: MCU Questions

Hi Dwight,

At this time, we need to verify certain info in the PSD application and that the information we have re the MCU plant.

We just need some additional information listed below. Please verify the correctness of the info or provide the

appropriate information. It would be helpful if you could provide this info to me this week if possible. Feel free to

contact me if you have any questions.

1. Clarify the following about the Main Flare.

 Does the flare use a fixed fan or a variable speed fan to control the air

‐ assist rate? If not, please describe how

the air

‐ assist function works on the main flare.

 Does the flare use perimeter assist or pre

‐ mix assist air?

2. Provide description and number of electric compressors on site.

3. Verify that the following statement is correct, or provide corrections as needed:3 Natural gas, water, and solids that are extracted from the producing strata with the crude oil are separated before

the oil is stored. Separated water is re

‐ injected back into the producing strata via the water injection

station. Separated gas is sent to the McElmo Creek gas compression plant and processed as described below. Crude

oil is sold at the lease automatic custody transfer (LACT) unit at each central tank battery to Giant Refinery through

Running Horse Pipeline, which is owned and operated by the Navajo Nation Indian Reservation.

4. Verify that the info in the following table is correct:



### Equipment in MCU Facility’s 1991 PSD Permit

Operation Status

T4500 Gas Turbine (4390 HP) Shutdown 1997

Waste Heat Recovery Unit (11 MMBtu/hr) Shutdown 1997

Ingersoll Rand IC Engine (491 HP) Shutdown 1993

Fairbanks Morse IC Engine (1712 HP) Shutdown 1997

Fairbanks Morse IC Engine (1712 HP) Shutdown 1997

Fairbanks Morse IC Engine (1848 HP) Shutdown 1997

Fairbanks Morse IC Engine (1848 HP) Shutdown 1997

DPC

‐ 540 IC Engine (470 HP) Shutdown 1998

HC Liquid Reboiler (1 MMBtu/hr) Shutdown 1993

Heat Medium Heater (4 MMBtu/hr) Shutdown 1993

Heat Medium Heater (12.2 MMBtu/hr) Shutdown 1991

TEG Reboiler (0.75 MMBtu/hr) [1] Operational

TEG Reboiler (0.33 MMBtu/hr) Shutdown 1991

TEG Reboiler (0.33 MMBtu/hr) Shutdown 1991

TEG Reboiler (0.1 MMBtu/hr) Shutdown 1991

5. Verify the following highlighted info in lb/MMBtu is correct:

The CO emission rate specified in the Consent Decree is 73 tpy based on a cumulative 365

‐ day rolling total. This is based

on an emission factor of 0.37 lb/MMBtu. This level is within the range of BACT determinations listed in Table 7.2.

************************************

Shaheerah Kelly

Permits Office, Air Division (AIR-3)

U.S. Environmental Protec tion Agency, Region 9

San Francisco, CA 94105

Phone: 415-947-4156

Fax: 415-947-3579

Email: kelly.shaheerah@epa.gov

[1] Unit size increased from 0.33 MMBtu/hr to 0.75 MMBtu/hr. (Verify this w/ Resolute!)

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