RE:ATTACHMENT ATTACHMENT ATTACHMENT:Additional Info Needed for MCU AAQIR Additional Info Needed for MCU AAQIR 

Andrew Chew Andrew Chew to: Dwight Mallory 12/05/2012 10:54 AM

Cc: Shaheerah Kelly

Dwight,

I'm writing to acknowledge receipt and thank very much again. I was able to open all of the attachments 

without problems. Their contents will help me in the permit write-up. We'll talk 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

Dwight Mallory Andrew, In the attached Word document you will... 12/04/2012 11:38:01 AM

From: Dwight Mallory <Dmallory@resoluteenergy.com>

To: Andrew Chew/R9/USEPA/US@EPA, 

Cc: Shaheerah Kelly/R9/USEPA/US@EPA

Date: 12/04/2012 11:38 AM

Subject: RE: ATTACHMENT: Additional Info Needed for MCU AAQIR

Andrew,

In the attached Word document you will find a list of the questions from your October 30 email, 

followed by a brief response to each one. The attached Xcel file includes a summary worksheet with the 

individual emissions unit and facility-wide actual and PTE emissions estimates. Also attached are pdf 

files with the GLYCalc input and aggregate reports for the dehydrator PTE and 2011 actual emissions, as 

well as pdf prints of the EPA Tanks reports for the gasoline storage tank. 

I apologize for running a few days beyond the one-month response time we discussed. For reasons 

explained in the attachments, I ended up having to revisit the Main Flare tons per year PTE figures 

submitted with the 2008 PSD application and it took a bit longer than I anticipated. 

I spoke with Tom Hormel at McVehil-Monnett yesterday concerning the Level II modeling that Don 

Shepherd at NPS requested. He said he has finished the modeling and should get the final report out to 

Mr. Shepherd and the rest of us in the next week. 

I’ll touch base with you when the modeling report gets here. In the meantime, let me know if you need 

anything else.

Dwight E. Mallory

Environmental, Health & Safety Coordinator

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@epamail.epa.gov [mailto:Chew.Andrew@epamail.epa.gov] 

Sent: Tuesday, October 30, 2012 10:33 AM

To: Dwight Mallory

Cc: Kelly.Shaheerah@epamail.epa.gov

Subject: ATTACHMENT: Additional Info Needed for MCU AAQIR

Hi Dwight,

Shaheerah is peer-reviewing my write-up for the draft flare permit and we need the following information 

available when we are ready to public notice the permit. Hope it works for you if we can get the 

information from you within a month's timeframe. Also, can you let me know how things are going with the 

modeled impacts for Hovenweep that Don Shepherd at the National Park Service asked for? Thanks 

again for your help.

- 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

----- Forwarded by Andrew Chew/R9/USEPA/US on 10/30/2012 09:23 AM -----

From: Shaheerah Kelly/R9/USEPA/US

To: Andrew Chew/R9/USEPA/US@EPA

Date: 10/29/2012 12:14 PM

Subject: Additional Info Needed for MCU AAQIR

Hi Andrew,

Here is the additional info that is needed to fill in some of the gaps for the MCU AAQIR PSD permit 

amendment. It would be very helpful if you could get this info from Resolute and find out if the company 

can provide this info within the next month or so. Thanks.

1) Provide facility-wide actual emissions and PTE estimates for SO2, CO, NOX, VOC, PM, PM10. and 

PM2.5. Section 3 of the 2008 PSD application provides emissions info for the Main Flare only. 

2) Provide actual emissions and PTE estimates for SO2, CO, NOX, VOC, PM, PM10. and PM2.5 for the 

following emission units. Section 3 of the 2008 PSD application provides emissions info for the Main Flare 

only. 

 TEG Reboiler (0.33 MMBtu/hr) - Operational

 Main Flare (618,104 scf/hr) - Operational

 Gasoline Storage Tank (1000 gallons) - Operational

 Glycol Heater (rated size/capacity?) - Operational
3) Verify the accuracy of the rated sizes/capacities of the following emission units, and provide the rated 

sizes/capacities where none is identified.

 TEG Reboiler (0.33 MMBtu/hr) - Operational

 Main Flare (618,104 scf/hr) - Operational

 Gasoline Storage Tank (1000 gallons) - Operational

 Glycol Heater (rated size/capacity?) - Operational

4) Verify the accuracy of the following information regarding the operational status of (i) the emissions 

units listed in the current PSD permit and (ii) the other operations at the MCU facility.

Equipment in current MCU Facility PSD Permit lasted amended in 1991:

 T4500 Gas Turbine (4390 HP) - Shutdown 1997

 Waste Heat Recovery Unit (11 MMBtu/hr) - Shutdown 1997

 Ingersoll Rand IC Engine (491 HP) - Shutdown 1993

 Fairbanks Morse IC Engine (1712 HP) - Shutdown 1997

 Fairbanks Morse IC Engine (1712 HP) - Shutdown 1997

 Fairbanks Morse IC Engine (1848 HP) - Shutdown 1997

 Fairbanks Morse IC Engine (1848 HP) - Shutdown 1997

 DPC-540 IC Engine (470 HP) - Shutdown 1998

 HC Liquid Reboiler (1 MMBtu/hr) - Shutdown 1993

 Heat Medium Heater (4 MMBtu/hr) - Shutdown 1993

 Heat Medium Heater (12.2 MMBtu/hr) -Shutdown 1991

 TEG Reboiler (0.33 MMBtu/hr) - Operational

 TEG Reboiler (0.33 MMBtu/hr) - Shutdown 1991

 TEG Reboiler (0.33 MMBtu/hr) - Shutdown 1991

 TEG Reboiler (0.1 MMBtu/hr) - Shutdown 1991

Other Operations at the MCU Facility:

 Natural Gas Liquids Processing - Shutdown 1998

 Natural Gas Processing Facility - Shutdown 1998

 Main Flare (618,104 scf/hr) - Operational

 Gasoline Storage Tank - Shutdown 1993

 Gasoline Storage Tank - Shutdown 1993

 Gasoline Storage Tank (1000 gallons) - Operational

 Diesel Storage Tank - Shutdown 1993

 CO2 line heater - Shutdown 2004

 Glycol Heater - Operational

5) EPA was provided the attached description of the MCU facility by Mobil in the past. Please verify the 

accuracy of this information and clarify whether it is acceptable to use this description as part of the PSD 

application

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

Shaheerah Kelly, Environmental Engineer

U.S. Environmental Protection Agency, Region 9

Permits Office, Air Division 

San Francisco, CA 94105

Phone: 415-947-4156
Fax: 415-947-3579

Email: kelly.shaheerah@epa.gov[attachment "Response to 10-30-12 Questions.docx" deleted by Andrew

Chew/R9/USEPA/US] [attachment "Revised Facility Emissions.xlsx" deleted by Andrew

Chew/R9/USEPA/US] [attachment "MCU_DEHY_PTE_Input.pdf" deleted by Andrew

Chew/R9/USEPA/US] [attachment "Fuel Tank 2011 Est.pdf" deleted by Andrew Chew/R9/USEPA/US]

[attachment "Fuel Tank PTE.pdf" deleted by Andrew Chew/R9/USEPA/US] [attachment

"MCU_DEHY_2011.pdf" deleted by Andrew Chew/R9/USEPA/US] [attachment

"MCU_DEHY_2011_Input.pdf" deleted by Andrew Chew/R9/USEPA/US] [attachment

"MCU_DEHY_PTE.pdf" deleted by Andrew Chew/R9/USEPA/US]