{In Archive} Re: MCU PSD and Title V Permits 

Shirley Rivera to: Patrick Flynn 02/04/2008 08:39 AM

Cc: "Dwight Mallory", "Patrick Flynn", Shaheerah Kelly

From: Shirley Rivera/R9/USEPA/US

To: "Patrick Flynn" <pflynn@rnrc.net>, 

Cc: "Dwight Mallory" <dmallory@rnrc.net>, "Patrick Flynn" <pflynn@rnrc.net>, Shaheerah 

Kelly/R9/USEPA/US@EPA

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Pat,

Wanted to just send you a note confirming receipt. Thanks for outlining specifics. This is very helpful. The 

information you provided, needless to say, will need to be taken into consideration across the board for 

our efforts.

Please note that I'll be checking in with Tom Mintz, our Regional Counsel who has been involved with the 

Consent Decree, and to Gerardo Rios, the Chief of our Permits Office.

 Also, will forward you, once again, availability for telecon regarding, at least, the PSD permit. Let me 

digest what you all provided so I can understand our next steps and get the telecon rescheduled.

Thanks much,

- Shirl

-------------------------------------------

Shirley F. Rivera

U.S. EPA, Region 9, Air Permits Office (AIR-3)

T: (415) 972-3966 | F: (415) 947-3579

 75 Hawthorne St., San Francisco, CA 94105

 Rivera.Shirley@epa.gov

"Patrick Flynn" <pflynn@rnrc.net>

"Patrick Flynn" 

<pflynn@rnrc.net>

02/01/2008 02:58 PM

To Shirley Rivera/R9/USEPA/US@EPA, Shaheerah 

Kelly/R9/USEPA/US@EPA

cc "Dwight Mallory" <dmallory@rnrc.net>, "Patrick Flynn" 

<pflynn@rnrc.net>

Subject MCU PSD and Title V Permits

Shirley and Shaheerah,

Since we have been unable to connect on the phone over the past few weeks, and in anticipation of our 

eventual teleconference, I’d like to point out a few things regarding the PSD application prepared by 

ExxonMobil in August-September 2006 for the MCU facility. Many of these comments apply to the yet to 

be issued Title V permit as well.
1. The PSD permit application still lists ExxonMobil and ExxonMobil contacts as the owner/operator. 

This should be changed throughout to Resolute Natural Resources Company.

2. Resolute added a fifth electric-powered compressor to the MCU facility in 2007, at a cost of 

$9.5M. We did this in order to improve compressor reliability and try to minimize flaring. We’re still 

in the start-up phase but are optimistic this should help reduce flare emissions.

3. ExxonMobil used an unrealistically low Btu value for the flare gas for all of its Main Flare emission 

calculations and modeling. They used a range of 300 to 433 Btu. During 2007, we collected 

monthly flare gas samples that showed Btu ranging from 550 to 664. As a result, even through 

the volume of gas being flared has decreased, the resulting NOx and CO emissions have 

increased. The NOx and CO levels contained in the Consent Decree, the PSD application, and 

presumably the Title V application are too low and need to be revisited. We are currently running 

at about 98 percent of the NOx and CO limits. We need higher emission limits in both permits.

4. ExxonMobil’s use of incorrect Btu values has some impact on the air quality modeling. 

5. As I mentioned several months ago to Shaheerah, our mid-term plan is to add a gas refrigeration 

skid to the facility. Although actual emissions associated with the proposed skid will be low 

(primarily fugitives and a few low-Btu heaters) and constriction wouldn’t start until the end of 2008 

or beginning 2009, I wanted to give you both a heads-up.

Thanks - Pat

Patrick E. Flynn

Environmental Health & Safety Manager

Resolute Natural Resources Company

1675 Broadway, Suite 1950

Denver, CO 80202

Phone: 303.534.4600 X1145

Fax: 303.623.3628

Cell: 303.941.0389

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