### {In Archive} RE: McElmo Creek Unit Patrick Flynn to: Shaheerah Kelly 04/16/2007 01:56 PM Cc: "Dwight Mallory", wilsonlaughter From: "Patrick Flynn" <pflynn@rnrc.net> To: Shaheerah Kelly/R9/USEPA/US@EPA, Cc: "Dwight Mallory" <dmallory@rnrc.net>, <wilsonlaughter@navajo.org> Archive: This message is being viewed in an archive.


### Shaheerah: The gas is produced from the wells, separated from the fluids at the production headers, gathered by the production gathering lines in the field and flows to the recycle compressor, is compressed, and is then re-injected via the field injection lines into the injection wells. There is no gas processing at any point and no gas storage. I hope this helps. Please call me at 303-534-4600 X145 if I can help clarify this further. Thanks - Pat
-----Original Message----- From: Kelly.Shaheerah@epamail.epa.gov [mailto:Kelly.Shaheerah@epamail.epa.gov] Sent: Monday, April 16, 2007 2:48 PM To: Patrick Flynn Cc: Dwight Mallory; wilsonlaughter@navajo.org Subject: RE: McElmo Creek Unit I appreciate the response. But I still need to get clarification on whether the gas at the gas compression plant enters a natural gas processing plant at some point and also whether it is stored. Please let me know. Thanks.

************************************ Shaheerah Kelly U S EPA Region 9 75 Hawthorne Street San Francisco, CA 94105 Phone: 415-947-4156 Fax: 415-947-3579

### "Patrick Flynn" <pflynn@rnrc.net > To Shaheerah Kelly/R9/USEPA/US@EPA, 04/16/2007 12:58 "Dwight Mallory" PM <dmallory@rnrc.net>

cc <wilsonlaughter@navajo.org> Subject RE: McElmo Creek Unit

Shaheerah: 1. The McElmo Creek Unit (MCU)is under an alternating waterflood and CO2 flood (water alternating with gas, WAG) to enhance oil recovery. The natural gas produced at the MCU is therefore tainted with CO2 and cannot be/is not sold. All of the gas produced at MCU (natural has + CO2) is compressed and re-injected into the producing oil formation. 2. There are no natural gas processing plants at MCU. 3. Correct, the Main Flare is only operated during compressor malfunctions, electrical outages, emergency/upset conditions when the recycle/re-injection compressor is down. Note we've ordered and will soon accept delivery of a new compressor that will significantly reduce compressor downtime and therefore flaring. Hope this helps. Please let me know if you need anything else. Thanks - Pat -----Original Message----- From: Kelly.Shaheerah@epamail.epa.gov

### [mailto:Kelly.Shaheerah@epamail

. e pa . g ov ] Sent: Monday, April 16, 2007 1:44 PM To: Dwight Mallory Cc: Patrick Flynn; wilsonlaughter@navajo.org Subject: RE: McElmo Creek Unit Thank you for your responses. I just need to check a few other items. 1. Based on your response to question 3, it sounds like the gas at the gas compression plant is not sent to a natural gas processing plant and the gas is not later sold/sent to an end user or stored. Please let me know if this statement is correct. 2. Are there any natural gas processing plants at the gas compression plant? 3. Is the main flare only used during upsets, malfunctions and emergencies, or is it currently used or will it be used in the future during regular operation at the gas compression plant?

************************************ Shaheerah Kelly U S EPA Region 9 75 Hawthorne Street San Francisco, CA 94105 Phone: 415-947-4156 Fax: 415-947-3579

Dwight Mallory <dmallory@rnrc.n et> To Shaheerah Kelly/R9/USEPA/US@EPA, 04/12/2007 04:16 Patrick Flynn <pflynn@rnrc.net> PM cc wilsonlaughter@navajo.org Subject RE: McElmo Creek Unit

### Please see the numbered responses below. Also, we would like to change the Facility Name on the application to remove the term "gas plant" if possible. I've revised the appropriate page of the Application Form and it is attached. Sorry I didn't catch it on the last update. If we need to submit another certification of truth and accuracy with the change, let me know. I'm out of the office tomorrow and next week, but I can get one signed and to you if need be. Let me know if there's anything else. 1. No. There are no crude oil storage tanks located at the MCU gas compression facility. 2. Yes. There are five small aboveground storage tanks at the MCU gas compression facility. There is one 500 gallon tank, one 400 gallon tank and one 250 gallon tank all of which contain lube oil for the compressors. There is also a 1,000 gallon tank that previously contained diesel fuel, but it has been removed from service. 3. No to both questions. There are no NGLs extracted at the MCU gas compression facility and none of the gas is sold. All of the gas that is processed by the facility is field gas that is re-injected to the producing reservoir. Produced water and crude oil that are removed by free water knockouts or "scrubbers" installed upstream of the facility's compressors and are sent back to the tank batteries via a closed drain system. Dwight Mallory Environmental, Health & Safety Coordinator Resolute Natural Resources Company 1675 Broadway, Suite 1950 Denver, CO 80202 Phone (303) 534-4600 X 165 Fax (303) 623-3628
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-----Original Message----- From: Kelly.Shaheerah@epamail.epa.gov [mailto:Kelly.Shaheerah@epamail.epa.gov] Sent: Wednesday, April 11, 2007 1:11 PM To: Dwight Mallory; Patrick Flynn Cc: wilsonlaughter@navajo.org Subject: McElmo Creek Unit Hi. Please answer the following questions regarding the McElmo Creek Unit Gas Plant. This would help in writing the permit. Let me know if you have any questions. Thanks. 1. Are there tank batteries where oil is stored at the Gas Plant? If so, how many? 2. Are there other storage tanks at the Gas Plant? If so, how many and what materials are stored in the tanks? 3. Besides injecting field gas into the reservoir, is the gas diverted to be sold at times? Is the field gas processed in a manner in which natural gas liquids are extracted from the field gas?

************************************ Shaheerah Kelly U S EPA Region 9 75 Hawthorne Street San Francisco, CA 94105 Phone: 415-947-4156 Fax: 415-947-3579
(See attached file: MCU_Contact_info.pdf)O M B C ontr o l N o . 2060- 0336
U. S

. ENV I RONM ENT A LP R OT ECT I ON A G E NCY A P P L ICA T ION FOR FEDERA LOP ERA T ING P E RMIT , 4 0 CFR P A RT7 1 APPLICATION FORM GIS - GENERAL INFORM ATION AND S U M M ARY

Instruc tions: Com p le te this f o rm onc e f o r the part 71 sourc e (f a c ility ).
A. M a ilin g Ad d r e ss a n d Co n t a c t In fo r m a t io n Fa c ilityna m e
______________________________________________________________________ Ma iling a ddre s s : Stre e tor P

. O

. Box

_______________________________________________________________ C ity

__________________________________________ Sta t e
_______ ZI P ___________ - ________ Conta c tpe rs on:
_________________________________________ T itle

____________________________________ T e le phone ( ______ ) ________ - ___________ Ex t. _________ Fa c s imile ( _______ ) ________ - ___________

B . Fa c ility Lo c a tio n

T e m p o r aryso u r ce? ___ Y e s ___ N o P l a n t s ite loc a tion __________________________________________________
C ity

__________________________________ Sta t e
_______ C ounty

____________ EP AR e g i on ________ Is the f a c ilityloc a t e d w ithin:
I ndia n la nds ? ___Y ES ___ N O O C S w a te r s ? ___Y ES ___ N O
No n a t t a i n m e n tarea? ___ Y E S ___ N O I f y e s , f o rw h a ta i r polluta nts ?

__________ W ithin 50 mile s of a f

f e c t e d Sta t e ? ___ Y E S ___ N O I f y e s , W h a tSta t e ( s ) ?

_____________

C. Ow n e r
N a m e
_______________________________________________ Str e e t/ P

. O

. B o x
________________________________ C ity

_________________________________________ Sta t e
_______ ZI P ____________ - ________ T e le phone ( _______ ) ________ - ____________ Ex t. _________

D. Op erator

N a m e
_______________________________________________ Str e e t/ P

. O

. B o x
________________________________ C ity

_________________________________________ Sta t e
_______ ZI P ____________ - ________ T e le phone ( _______ ) ________ - ____________ Ex t. _________