From: Shepherd, Don

To: Chew, Andrew

Subject: Re: Fw: Class I Area Impact Analysis for PSD Permit Application

Date: Wednesday, January 30, 2013 10:02:24 AM



### Andrew,

Hovenweep is our only Class II area within 50 km of the project.

On Fri, Jan 25, 2013 at 4:21 PM, < Chew.Andrew@epamail.epa.gov > wrote:

Hello Don,

Please let me know what other Class II areas are in the vicinity of the McElmo

Creek Unit Gas Compression Facility. 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: Don_Shepherd@nps.gov

To: Dmallory@resoluteenergy.com

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

< Pflynn@resoluteenergy.com >, John_Reber@nps.gov

, Michael_George@nps.gov

Date: 08/08/2012 08:50 AM

Subject: Re: Fw: Class I Area Impact Analysis for PSD Permit Application

Mr. Mallory,

Thank you for the information on the McElmo Creek Unit Gas Compression

Facility. Our current (FLAG) guidance requests that you calculate the

annual emissions of SO2, H2SO4, NOx, and PM10 (Q) by annualizing (multiply

by 4.38) the maximum potential hourly emission rates of those pollutants.

Please provide those hourly maxima.

I noticed that the site is near Hovenweep National Monument, yet i saw no

mention of Hovenweep in the attachments. While Hovenweep is not a Class I

area, we request that the impact of the flare's plume on visibility at

Hovenweep be evaluated as part of the "Additional Impacts Analysis" portion

of any required PSD analysis.

Please feel free to contact me with any questions.

Don Shepherd

National Park Service

Air Resources Division

12795 W. Alameda Pkwy.

Lakewood, CO 80228

Phone: 303-969-2075Fax: 303-969-2822

E-Mail: don_shepherd@nps.gov

"the man who really counts in the world is the doer, not the mere critic"

TR 1891

John

Notar/DENVER/NPS

To

08/06/2012 04:45 Don Shepherd/DENVER/NPS@NPS

PM cc

John Notar/DENVER/NPS@NPS

Subject

Fw: Class I Area Impact Analysis

for PSD Permit Application

Don: my opinion is to screen this one out. It is 58 km west of MEVE &

92 km Southeast from CANY. I screened this one out back in June 2006.

the

SO2 emission estimates from the flare have gone down a small amount from

29.2 -> 26.7 TPY.

They claimed that EPA Region ( made them run refined AERMOD to show

compliance with the new 1-hour SO2 NAAQS. AERMOD show they do not cause

or contribute to a 1-hour NAAQS violation. (Why Region 9 & not Region 8 is

confusing, its in Utah. Dwight Mallory has left me a voice mail.

As I said I recommend that we screen this out any ideas?

My Q/D is :

60 TPY SO2 + 13.4 TPY NOx + 95.4 TPY VOC = 168.8Q / 58 km D

=

2.91

John

----- Forwarded by John Notar/DENVER/NPS on 08/06/2012 04:27 PM -----

Dwight Mallory

<Dmallory@resolut

eenergy.com > To

"' john_notar@nps.gov '"

08/02/2012 01:28 < john_notar@nps.gov >

PM cc

" Chew.Andrew@epamail.epa.gov "

< Chew.Andrew@epamail.epa.gov >, Patrick Flynn

< Pflynn@resoluteenergy.com > Subject

Class I Area Impact Analysis for

PSD Permit Application

Mr. Notar,

In reference to the voice message exchanges we have had: I am contacting

you in reference to a PSD permit application, submitted to U.S. EPA Region9 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.

You provided comments at the time the original PSD application and air

modeling were submitted that no additional modeling for Class I impacts

was necessary. However, since that time, EPA has 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. They also requested that Resolute contact you

and allow the opportunity for you to review your comments in light of the

2010 revisions to the air emissions guidance for federal land managers.

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. The SCREEN 3 model submitted with the PSD

application estimated 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. 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.

I have attached Appendix D of the original PSD application, which includes

the original communication between yourself and Justin Harrison at Exxon

Mobil concerning impacts to Class I areas. Also attached is a map showing

the location of the project in relation to Class I areas. Please review and

let me know if any additional information or modeling is necessary.

If you would like to speak with EPA Region 9 staff, please contact Andrew

Chew at (415) 947-4197.

As requested by Region IX, I have also contacted Laura Romin with USFWS to

allow an opportunity for USFWS to renew their comments regarding T&E

species and critical habitat impacts.

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" deleted by Don

Shepherd/DENVER/NPS] [attachment "MCU Class I Air.pdf" deleted by Don

Shepherd/DENVER/NPS]



### -- Don Shepherd

National Park Service

### Air Resources Division

12795 W. Alameda Pkwy.

Lakewood, CO 80228

Phone: 303-969-2075

Fax: 303-969-2822

E-Mail: don_shepherd@nps.gov

"the man who really counts in the world is the doer, not the mere critic" TR 1891