1

Kelly, Shaheerah

From: Kelly, Shaheerah

Sent: Tuesday, December 22, 2015 1:39 PM

To: Dwight Mallory

Cc: pflynn@ResoluteEnergy.com; Kelly, Shaheerah

Subject: FW: Information Request

Attachments: removed.txt; SC-521-S1R2.pdf

Dwight,

Thank you for your response.

It seems part of the message is cut off in the previous email below. So I am sending the original text below for the

record.

Original message:

Dwight, 

Regarding the following conditions in the draft PSD permit, does the continuous monitoring of volume of gas combusted 

in the Main Flare (required in IX.E.1.c) already include purge gas? Please let me know. 

Permit condition IX.E.1.c: 

The Permittee shall continuously measure and record the volume of gas combusted in the Main Flare. 

Permit condition IX.E.1.d: 

The Permittee shall install, operate and maintain continuous monitoring systems on the Main Flare for the usage of pilot 

gas and purge gas (other than nitrogen or other inert gas) by the Main Flare, in standard cubic feet per minute 

(SCFM). Readings shall be taken at least once every 5 minutes and the average hourly values shall be recorded on an 

hourly and daily basis. 

Thank you.

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

Shaheerah Kelly 

Permits Office, Air Division (AIR-3) 

U.S. Environmental Protection 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: Tuesday, December 22, 2015 9:49 AM

To: Kelly, Shaheerah <Kelly.Shaheerah@epa.gov>

Cc: Patrick Flynn <Pflynn@resoluteenergy.com>

Subject: RE: Information Request

Shaheerah,
2

As Resolute stated in our November 19, 2014 comments to the draft permit, continuous monitoring of the volume of gas 

combusted in the Main Flare, as required by condition IX.E.1.c of the draft permit, already accounts for any purge gas that 

is combusted by the Main Flare. Purge gas is routed to the flare via the same flare gas inlet nozzle (N-1 on the attached 

diagram) as any process gas that is combusted during upset conditions. All of the gas that is sent to the Main Flare via the 

flare gas inlet nozzle is measured by the Main Flare meter. 

Again referencing our November 19, 2014 comments to the draft permit, the volume of pilot gas consumed by the Main 

Flare is not currently metered as required by condition IX.E.1.d of the draft permit. Emissions from pilot gas combustion 

are insignificant (<0.5 TPY for CO and <0.1 TPY for NOx) and do not justify the costs for installation of metering and 

SCADA equipment to measure the small volume of gas combusted by the pilot. 

Let me know if you need anything else. 

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

Dwight E. Mallory

Environmental/Regulatory Manager

Resolute Energy Corporation

1700 Lincoln Street, Suite 2800

Denver, CO 80203

Direct: 303-573-4886 X 1165

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

Sent: Monday, December 21, 2015 2:58 PM

To: Dwight Mallory <Dmallory@resoluteenergy.com>

Subject: Information Request

  

Dwight,

Regarding the following conditions in the draft PSD permit, does Please let me know.

Permit condition IX.E.1.c:

The Permittee shall continuously measure and record the volume of gas combusted in the Main Flare.

Permit condition IX.E.1.d:

The Permittee shall install, operate and maintain continuous monitoring systems on the Main Flare for the usage of pilot 

gas and purge gas (other than nitrogen or other inert gas) by the Main Flare, in standard cubic feet per minute 

(SCFM). Readings shall be taken at least once every 5 minutes and the average hourly values shall be recorded on an 

hourly and daily basis.

Thank you.

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

Shaheerah Kelly

Permits Office, Air Division (AIR-3)

U.S. Environmental Protection Agency, Region 9 

San Francisco, CA 94105 

Phone: 415-947-4156 

Fax: 415-947-3579 

Email: kelly.shaheerah@epa.gov

  

  

This e-mail message and any attachments are for the sole use of the intended recipient(s) and may contain confidential, privileged, and 

proprietary information of Resolute Energy Corporation. Any unauthorized review, use, disclosure or distribution may be prohibited 
3

under law. If you are not the intended recipient, please contact the sender by reply E-mail of any erroneous transmission, and destroy 

the original E-mail, any attachments, and all copies of the original message. Thank you.