{In Archive} RNRC - McElmo Creek Unit: PSD Permit Application 

Shirley Rivera to: pflynn, Dwight Mallory 02/13/2008 06:04 PM

Cc: Gerardo Rios, Shaheerah Kelly

From: Shirley Rivera/R9/USEPA/US

To: pflynn@rnrc.net, "Dwight Mallory" <dmallory@rnrc.net>, 

Cc: Gerardo Rios/R9/USEPA/US@EPA, Shaheerah Kelly/R9/USEPA/US@EPA

Archive: This message is being viewed in an archive.

Patrick,

This is a follow-up note regarding the next steps resulting from our conference call last week. Below is an 

e-mail thread, which includes:

- RNRC recent information

- Agenda for our meeting last week.

As a result of our meeting, for the purposes of your current PSD permit application, please do submit 

formally the following to EPA Region 9, for the purposes of the PSD permit application - a letter from 

Resolute that provides:

 a) Contact person(s) - State the contact persons and information for our PSD records. Essentially, we'll 

have 

 b) Proposed PSD application revisions - Provide specific description of the proposed revision to the 

permit application. As we discussed, we understand Resolute has a record of the ExxonMobil filings 

associated with the permit application - from original submittal to revised/updated information as a result 

for ExxonMobil's responses to EPA's data requests for completeness. Proposed revisions should include 

a description of the following, including but not limited to - 

- Updates of assumptions associated with emissions,

- Updates in any operating parameters or assumptions,

- Updates to air quality modeling, if applicable, and

- Updates to any other application element, e.g., BACT, additional impacts analyses, etc.

Thank you for your patience in receipt of this information. Feel free to call me or e/m me if you have 

additional questions or clarification. Meanwhile, we will continue to prepare the portions of the PSD permit 

and air quality impact report/technical support document while awaiting your updated information. I'll 

check-in w/you later next week if I do not hear from you all.

- Shirl

-------------------------------------------

Shirley F. Rivera

U.S. EPA, Region 9, Air Permits Office (AIR-3) | 75 Hawthorne St., San Francisco, CA 94105

T: (415) 972-3966 | F: (415) 947-3579 | Rivera.Shirley@epa.gov

Shirley Rivera/R9/USEPA/US

Shirley Rivera/R9/USEPA/US

02/05/2008 10:08 AM To "Patrick Flynn" <pflynn@rnrc.net>, "Dwight Mallory" 

<dmallory@rnrc.net>

cc Shaheerah Kelly/R9/USEPA/US@EPA, Gerardo 

Rios/R9/USEPA/US@EPA

Subject RNRC: 02/07 (Thurs) Telecon @ 9:00010:00 (PACIFIC)
Pat and All,

Let's go with Thursday, February 7, at 9:00-10:00 (PACIFIC) and below is a slightly revised agenda 

(which can be updated, accordingly, as we begin the telecon) ...

PROPOSED/DRAFT AGENDA FOR CALL: 

For this Thursday's, here is strawman agenda - and please do incorporate items you would like to 

discuss.

OBJECTIVE: To discuss "scope/activities" for moving forward with PSD permit issuance .

 1. Introductions (ALL)

- RNRC (Roles and Responsibilities)

- EPA (Roles and Responsibilities)

- Others?

 2. Status of EPA draft PSD permit

- Content

- Potential clarifications

 3. Site visit findings of RNRC's site visit

- Equipment status, e.g., operational, shutdown in place, removed from site, etc.

- Additional info that may be relevant for PSD permit

- Additional info that may be relevant for Title V/Part 71 permit

 4. Recent and Potential Revisions 

- Updates/Corrections to ExxonMobil information (Heat Value)

- Status of future project

- Other?

 5. Next Steps and Milestones

-------------------------------------------

Shirley F. Rivera

U.S. EPA, Region 9, Air Permits Office (AIR-3)

T: (415) 972-3966 | F: (415) 947-3579

 75 Hawthorne St., San Francisco, CA 94105

 Rivera.Shirley@epa.gov

"Patrick Flynn" <pflynn@rnrc.net>

"Patrick Flynn" 

<pflynn@rnrc.net>

02/04/2008 05:16 PM

To Shirley Rivera/R9/USEPA/US@EPA

cc "Dwight Mallory" <dmallory@rnrc.net>, Shaheerah 

Kelly/R9/USEPA/US@EPA

Subject RE: MCU PSD and Title V Permits

Thursday works for us. Let me know when you confirm.
Sent by GoodLink (www.good.com)

 -----Original Message-----

From: Rivera.Shirley@epamail.epa.gov [mailto:Rivera.Shirley@epamail.epa.gov]

Sent: Monday, February 04, 2008 05:03 PM Mountain Standard Time

To: Patrick Flynn

Cc: Dwight Mallory; Kelly.Shaheerah@epamail.epa.gov

Subject: RE: MCU PSD and Title V Permits

Pat - Let's shoot for Thursday morning, Feb 7th ... I still need to firm

up on my end and will let you know tomorrow morning ... so I am thinking

-

 9 AM (pacific)

 and I will see about keeping my morning for RNRC (just in case)

In case Thursday falls through - I will come in on Friday - and in that

case,

 8 AM (pacific)

 and, likewise, will keep my morning for RNRC (just in case)

- S.

 

 "Patrick Flynn" 

 <pflynn@rnrc.net 

 > To

 Shirley Rivera/R9/USEPA/US@EPA 

 02/04/2008 11:50 cc

 AM "Dwight Mallory" 

 <dmallory@rnrc.net>, Shaheerah 

 Kelly/R9/USEPA/US@EPA 

 Subject

 RE: MCU PSD and Title V Permits 

 

I'm available for a call:

a. Tomorrow morning 10-11AM or afternoon 2-3PM Mountain Time.

b. Wednesday anytime after 10AM Mountain.

c. Thursday anytime after 9AM Mountain.

d. Friday anytime after 9AM Mountain.

-----Original Message-----
From: Rivera.Shirley@epamail.epa.gov

[mailto:Rivera.Shirley@epamail.epa.gov]

Sent: Monday, February 04, 2008 9:39 AM

To: Patrick Flynn

Cc: Dwight Mallory; Patrick Flynn; Kelly.Shaheerah@epamail.epa.gov

Subject: Re: MCU PSD and Title V Permits

Pat,

Wanted to just send you a note confirming receipt. Thanks for outlining

specifics. This is very helpful. The information you provided, needless

to say, will need to be taken into consideration across the board for

our efforts.

Please note that I'll be checking in with Tom Mintz, our Regional

Counsel who has been involved with the Consent Decree, and to Gerardo

Rios, the Chief of our Permits Office.

 Also, will forward you, once again, availability for telecon regarding,

at least, the PSD permit. Let me digest what you all provided so I can

understand our next steps and get the telecon rescheduled.

Thanks much,

- Shirl

-------------------------------------------

Shirley F. Rivera

U.S. EPA, Region 9, Air Permits Office (AIR-3)

T: (415) 972-3966 | F: (415) 947-3579

 75 Hawthorne St., San Francisco, CA 94105

 Rivera.Shirley@epa.gov

 "Patrick Flynn"

 <pflynn@rnrc.net

 > To

 Shirley Rivera/R9/USEPA/US@EPA,

 02/01/2008 02:58 Shaheerah Kelly/R9/USEPA/US@EPA

 PM cc

 "Dwight Mallory"

 <dmallory@rnrc.net>, "Patrick

 Flynn" <pflynn@rnrc.net>

 Subject

 MCU PSD and Title V Permits
Shirley and Shaheerah,

Since we have been unable to connect on the phone over the past few

weeks, and in anticipation of our eventual teleconference, I'd like to

point out a few things regarding the PSD application prepared by

ExxonMobil in August-September 2006 for the MCU facility. Many of these

comments apply to the yet to be issued Title V permit as well.

 1. The PSD permit application still lists ExxonMobil and ExxonMobil

 contacts as the owner/operator. This should be changed throughout

 to Resolute Natural Resources Company.

 2. Resolute added a fifth electric-powered compressor to the MCU

 facility in 2007, at a cost of $9.5M. We did this in order to

 improve compressor reliability and try to minimize flaring. We're

 still in the start-up phase but are optimistic this should help

 reduce flare emissions.

 3. ExxonMobil used an unrealistically low Btu value for the flare gas

 for all of its Main Flare emission calculations and modeling. They

 used a range of 300 to 433 Btu. During 2007, we collected monthly

 flare gas samples that showed Btu ranging from 550 to 664. As a

 result, even through the volume of gas being flared has decreased,

 the resulting NOx and CO emissions have increased. The NOx and CO

 levels contained in the Consent Decree, the PSD application, and

 presumably the Title V application are too low and need to be

 revisited. We are currently running at about 98 percent of the NOx

 and CO limits. We need higher emission limits in both permits.

 4. ExxonMobil's use of incorrect Btu values has some impact on the

 air quality modeling.

 5. As I mentioned several months ago to Shaheerah, our mid-term plan

 is to add a gas refrigeration skid to the facility. Although

 actual emissions associated with the proposed skid will be low

 (primarily fugitives and a few low-Btu heaters) and constriction

 wouldn't start until the end of 2008 or beginning 2009, I wanted

 to give you both a heads-up.

Thanks - Pat

Patrick E. Flynn

Environmental Health & Safety Manager

Resolute Natural Resources Company

1675 Broadway, Suite 1950

Denver, CO 80202

Phone: 303.534.4600 X1145

Fax: 303.623.3628

Cell: 303.941.0389

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