From: Romin, Laura

To: Chew, Andrew

Cc: larry_crist@fws.gov

Subject: Re: T&E Species/Critical Habitat Consultation

Date: Friday, January 25, 2013 3:22:09 PM

Hi Andrew, due to staffing shortages, we are no longer providing written

concurrences for "no effect" determinations - you are not required to have written

"no effect" concurrences from our office to meet ESA requirements. You can use my

below email for the admin record.

Laura.

On Fri, Jan 25, 2013 at 4:20 PM, <Chew.Andrew@epamail.epa.gov> wrote:

Hello Laura/Larry,

Can we get a written letter from your agency as verification? We plan on getting the

EPA permit public noticed this quarter and need this for our administrative record.

Many 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

From: <Laura_Romin@fws.gov>

To: Dwight Mallory <Dmallory@resoluteenergy.com>, 

Cc: "'laura_romin@fws.gov'" <laura_romin@fws.gov>, Andrew Chew/R9/USEPA/US@EPA, Patrick Flynn

<Pflynn@resoluteenergy.com>, <larry_crist@fws.gov>

Date: 08/03/2012 12:00 PM

Subject: Re: T&E Species/Critical Habitat Consultation

Hi Dwight,

Thank you for your coordination with our office. The proposed action will not effect

any threatened or endangered species, and we have no other concerns.

Laura.

Laura Romin, Deputy Field Supervisor

U.S. Fish and Wildlife Service
Utah Field Office

2369 West Orton Circle

West Valley, Utah 84119

Office Phone: 801-975-3330, ext. 142

Cell Phone: 801-554-7660

Email: laura_romin@fws.gov

-----Dwight Mallory <Dmallory@resoluteenergy.com> wrote: -----

To: "'laura_romin@fws.gov'" <laura_romin@fws.gov>

From: Dwight Mallory <Dmallory@resoluteenergy.com>

Date: 08/02/2012 12:44PM

cc: "Chew.Andrew@epamail.epa.gov" <Chew.Andrew@epamail.epa.gov>, Patrick

Flynn <Pflynn@resoluteenergy.com>

Subject: T&E Species/Critical Habitat Consultation

Ms. Romin,

As we discussed last week when we spoke last week, I am writing you in reference

to a PSD permit application, submitted to U.S. EPA Region 9 on December 5. 2005,

for the emergency flare at the McElmo Creek Unit Gas Compression Facility,

located near Aneth, Utah. Resolute Natural Resources Company acquired the

MCU facility from Exxon Mobil in 2006 and we have been working with Region 9’s

permitting staff to obtain issuance of the PSD permit since that time.

The emissions limits of 60 TPY S02; 73 TPY CO; 13.4 TPY NOx; and 95.4 TPY

VOCs applicable to the flare are unchanged since the original PSD application was

submitted; and the flare’s actual emissions have decreased from the 29.2 tons S02;

66 tons CO; 12.1 tons NOx; and 90.6 tons VOC reported by EOM for 2005 to 26.7

tons SO2; 45.4 tons CO; 8.4 tons NOx; and 54.9 tons VOC for 2011.

A conservative SCREEN 3 model was submitted with the PSD application to

estimate near-field impacts from the flare operating at 14.83 MMCFD for the entire

year, or 7 times greater than the average rate for 2005. The results of the model

showed that the flare did not cause or contribute to a violation of the National

Ambient Air Quality Standards for NO2 or SO2 that were effective at the time of the

PSD submittal. However, since that time, EPA promulgated new 1-hr NAAQS for

NO2 and SO2, and requested that Resolute revise the modeling to account for the

1-hr NO2 and SO2 NAAQS.

The revised SCREEN 3 model demonstrated that the flare did not to cause or

contribute to a 1-hour NO2 NAAQS violation, but showed that the maximum 1-hr

SO2 impact for the flare exceeded the interim SIL of 3 ppb. At Region 9’s request,

Resolute remodeled the SO2 emissions using EPA’s refined AEROMOD model and

was able to effectively demonstrate that the flare does not cause or contribute to a

1-hour SO2 NAAQS violation.

Region 9 staff also requested that Resolute contact your office to review the T&E

species and critical habitat consultation and allow you to comment on the revised
modeling and potential impacts from the project. I have attached Appendix D of the

original PSD application, which includes the original communication between Exxon

Mobil and Henry Maddux at USFWS. Appendix D also includes communication with

John Notar at NPS concerning impacts to Class I areas. As requested by Region

IX, I have also contacted Mr. Notar to will allow him an opportunity to renew his

comments on behalf of NPS.

Please review this information and respond with any questions or concerns USFWS

may have. In addition to Appendix D of the PSD application, I have attached a map

showing the location of the project. If you need additional information in order to

respond, please let me know.

If you would like to speak with Region 9 staff, please contact Andrew Chew at (415)

947-4197.

Thanks again for your response on this. 

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

[attachment "APP D from EOM PSD Ap.pdf" removed by Laura

Romin/R6/FWS/DOI]

[attachment "MCU Class I Air.pdf" removed by Laura Romin/R6/FWS/DOI]

-- 

Laura Romin, Deputy Field Supervisor

U.S. Fish and Wildlife Service

Utah Ecological Services Field Office

2369 W. Orton Circle

West Valley City, Utah 84119

ph: 801-975-3330, ext. 142

cell: 801-554-7660




Canyonlands NP

Weminuche Wilderness

Mesa Verde NP

Weminuche Wilderness

 ̄

Resolute MCU Facility

50 Mile Buffer

Resolute Natural Resources LLC

MCU Class I Area Map

0 10 20 40 60

Miles

0 15 30 60

Kilometers