### {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 History: This message has been replied to.

Archive: This message is being viewed in an archive.

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

THIS COMMUNICATION AND ANY ATTACHMENTS ARE CONFIDENTIAL AND PROPRIETARY INFORMATION INTENDED FOR THE ADDRESSED PARTY ONLY, AND MAY BE PRIVILEGED UNDER LAW. IF YOU ARE NOT THE INTENDED RECIPIENT YOU ARE HEREBY NOTIFIED THAT ANY FURTHER REVIEW OR DISSEMINATION OF THIS MESSAGE AND ANY ATTACHMENTS IS PROHIBITED BY LAW . IN SUCH EVENT YOU SHOULD DELETE THIS COMMUNICATION AND ALL ATTACHMENTS AND DESTROY ANY PRINTED COPIES. PLEASE NOTIFY THE SENDER OF ANY ERRONEOUS TRANSMISSION OF THIS EMAIL. THANK YOU.