From: Rivera, Shirley

To: Chew, Andrew ; Dwight Mallory Subject: RE: McElmo Creek PSD action

Date: Thursday, April 25, 2013 2:44:00 PM

Dwight, Confirming receipt. I’ll let you know if there is anything else needed by early next week with regards to this topic. Am working on the additional impacts narrative. Thanks in advance, - Shirl

Week of April 22: Planned *IN* Mon-Fri; Out of office Thurs (partial morning); Off-site Tues. Week April 29: Planned *IN* Mon-Wed, Fri; Out of office Tues (afternoon), Thurs (all day)

____________________________________________________________ Shirley F. Rivera T: (415) 972-3966 | F: (415) 947-3579 | Rivera.Shirley@epa.gov | Workspace #17112 U.S. EPA, Region 9, Air Permits Office (AIR-3) | 75 Hawthorne St., San Francisco, CA 94105

From: Chew, Andrew Sent: Thursday, April 25, 2013 2:40 PM To: Dwight Mallory Cc: Rivera, Shirley Subject: RE: McElmo Creek PSD action

Hi Dwight,

Thanks very much for your response. I’m acknowledging receipt here, and Shirley will get in touch with you soon.

- Andrew

------------------------------------------- Andrew Chew, P.E. T: (415) 947-4197 | F: (415) 947-3579 | chew.andrew@epa.gov U.S. EPA, Region 9, Air Permits Office (AIR-3) | 75 Hawthorne St., San Francisco, CA 94105

From: Dwight Mallory [ mailto:Dmallory@resoluteenergy.com ] Sent: Wednesday, April 24, 2013 11:47 AM To: Chew, Andrew Cc: Rivera, Shirley Subject: RE: McElmo Creek PSD action

Andrew,

I’ve provided some short answers to your questions below, but I’m not exactly sure what you’re looking for here. Please let me know if these answers don’t address your needs.(1) additional temporary employees (that) have been required since the time the Consent Decree was entered, Since acquiring the McElmo Creek Unit from Exxon Mobil approximately 12 months after the Consent Decree was entered, Resolute has not utilized additional temporary employees. We have increased the number of permanent, full-time staff dedicated to operation of the McElmo Creek Unit by 85 percent. This includes the addition of facility maintenance, electrical and engineering specialists that provide valuable expertise which was not immediately available onsite in the past. We have also continued to utilize contractors to supplement employee manpower and expertise as needed.

(2) any need to increase infrastructure resulting from this permitting action, and Since acquiring the facility, Resolute has spent more than $15 MM on additional compression and facility upgrades designed to increase compressor reliability, thereby minimizing emissions from the flare. Resolute is currently investigating the possibility of further increasing compression reliability by replacing the existing reciprocal compressors with variable speed screw compressors. However, this project is still prospective in nature and no capital expenditures have been committed.

(3) anything additional about how the existing employee base already serves the flare operations and maintenance? Operations and maintenance of the McElmo Creek Unit facility is carried out by an employee base that includes a variety of technical professionals and support staff who ensure that the flare is functioning correctly and who work to minimize flare emissions by maximizing compressor reliability. This includes Plant Technicians and the Plant Supervisor who monitor the day to day operation of the flare; the Maintenance Foreman and Facilities Engineer who oversee maintenance and repair services for the flare; and the Automation Supervisor and Electricians who maintain the monitoring and measurement systems associated with the flare.

Dwight E. Mallory Environmental/Regulatory Manager Resolute Energy Corporation 1675 Broadway, Suite 1950 Denver, CO 80202 Direct: 303-573-4886 X 1165 Cell: 970-302-8620 Email: dmallory@ResoluteEnergy.com

From: Chew, Andrew [ mailto:Chew.Andrew@epa.gov ] Sent: Friday, April 19, 2013 4:47 PM To: Dwight Mallory Cc: Rivera, Shirley Subject: McElmo Creek PSD action

Hi Dwight,

What we have under the growth impacts info is generally okay. However, given that the flare is in existence and the consent decree entered for some time, I've been asked to provide a bit morecontext. Can you please confirm and/or update whether (1) additional temporary employees have been required since the time the Consent Decree was entered, (2) any need to increase infrastructure resulting from this permitting action, and (3) anything additional about how the existing employee base already serves the flare operations and maintenance? Please let me know if you have any questions. I’m including Shirley in the cc because she is managing the growth analysis segment. Thanks.

- Andrew

------------------------------------------- Andrew Chew, P.E. T: (415) 947-4197 | F: (415) 947-3579 | chew.andrew@epa.gov U.S. EPA, Region 9, Air Permits Office (AIR-3) | 75 Hawthorne St., San Francisco, CA 94105