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### 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 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: 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 th e 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 g as is routed to the flare via the same fl are gas inlet nozzle (N-1 on the attached

diagram) as any process gas that is combusted during upset conditi ons. 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 draf t 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 co rrect 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 th e 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 Protec tion Agency, Region 9

San Francisco, CA 94105

Phone: 415-947-4156

Fax: 415-947-3579

Email: kelly.shaheerah@epa.gov

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