1 

### Kelly, Shaheerah

From: Dwight Mallory <dmallory@ResoluteEnergy.com>

Sent: Wednesday, April 18, 2012 3:38 PM

Subject: RE: McElmo Main Flare: Pat's 12/06/10 letter

Attachments: RE: McElmo Creek Unit Follow Up (1.18 MB)



### Andrew,

As we discussed in our telephone conversation, I wanted to clarify the facility throughput information provided in my

April 13 email (copy attached). While the replacement of the existing reciprocal compressors with screw compressors

will ultimately give the facility a compression capacity of up to 50 MMCFD, the proposed glycol dehydrator is being

designed with a capacity of 25 MMCFD.

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: Dwight Mallory

Sent: Wednesday, April 18, 2012 4:23 PM

To: 'Andrew Chew'

Cc: Shaheerah Kelly; Cleveland Holladay; Tom Mintz; Patric k Flynn; John Jacus; Dann, Randy (Randy.Dann@dgslaw.com)

Subject: RE: McElmo Main Flare: Pat's 12/06/10 letter



### Andrew,

Thanks for the follow up email and phone call. As we discussed during the call this morning, GHG emissions for the MCU

CO2 recycle facility are attached.

I look forward to your comments on the modeling discussion. In the meantime, I will follow up on the Class I area

impacts and ESA issues with Mr. Notar and Mr. Maddux respectively and will forward copies of any correspondence with

them to you as soon as possible.

Please call or email 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: Andrew Chew [mailto:Chew.Andrew@epamail.epa.gov]

Sent: Wednesday, April 18, 2012 11:56 AM

To: Dwight Mallory2 Cc: Shaheerah Kelly; Cleveland Holladay; Tom Mintz

Subject: McElmo Main Flare: Pat's 12/06/10 letter

Hi Dwight,

To be frank and honest, we wish we can narrow down the list fu rther than what was bulleted in Pat's letter, but we're still a

little ways away. For the Class I area impacts and ESA issues , please get separate confirmations from the federal land

manger and Fish and Wildlife Service that their 2006 assessment statements apply to this day if the PSD Main Flare

permit were to be issued in a few months.

Also, we're reviewing McVehil Monnet's 6/1/11 report on 1-hr SO2 modelling and plan to let you know our findings next

week. While Scott believed that the 1-hr NO2 modelling work was sufficient, he asked that 1-hr SO2 modelling work to be

more specific. However, since Scott is no longer on this project, Cleve Holladay of our agency will be helping me with

reviewing the modelling work.

Finally, we would need GHG CO2e emissions quantification so t hat the record reflects what's found. Shaheerah Kelly, my

peer in our Air Permits office, will be partnering with me to help move the permit process along. She's very

knowledgeable and has been with the agency for more than 7 y ears. I plan to include her in future correspondence and

meetings. Thanks again.

- 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: "Dwight Mallory" < dmallory@ResoluteEnergy.com >

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

Date: 04/17/2012 11:28 AM

Subject: RE: Pat's 12/06/10 letter

Andrew,

Thanks for sending the letter. Based on our conversation in reference to the bullet list of requested information on page 2, it is my

understanding that you are requesting information to address the review of the Class I area impacts and Endangered Species

sections of the PSD application.

We have reviewed the Class I area impacts and Endangered Species sections of the PSD application. Because the previous Class I

area and Endangered Species assessments and findings were based on the maximum facility emissions allowable under the Consent

Decree emission limits and the annual averaged emissions from the SCREEN 3 modeling scenario, and inasmuch as neither the

Consent Decree emission limits nor the modeling inputs have been modified; we believe that the Class I area impacts and

Endangered Species impacts analyses provided in the PSD application are still valid and no update is needed.

It is also my understanding that McVehil Monnet discussed the potential need for additional air quality modeling to address the 1

hour NAAQS standard for SO2 with Scott Bohning at EPA and that they were in agreement that additional modeling, and thus

additional assessment of impacts to Class I areas and Endangered Species, were unnecessary.

Please contact me if you require additional information.

Dwight E. Mallory

Environmental, Health & Safety Coordinator3 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: Andrew Chew [ mailto:Chew.Andrew@epamail.epa.gov ]

Sent: Monday, April 16, 2012 4:52 PM

To: Dwight Mallory

Subject: Pat's 12/06/10 letter

- 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