### {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 ( j ust 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 ( j ust 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 PermitsShirley 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
THIS COMMUNICATION AND ANY ATTACHMENTS ARE CONFIDENTIAL AND PROPRIETARY INFORMATION INTENDED FOR THE ADDRESSED PARTY ONLY, AND MAY BE PRIVILEGED UNDER LAW. IF YOU ARE NOT THE INTENDED RECIPIENT YOU ARE HEREBY NOTIFIED THAT ANY FURTHER REVIEW OR DISSEMINATION OF THIS MESSAGE AND ANY ATTACHMENTS IS PROHIBITED BY LAW . IN SUCH EVENT YOU SHOULD DELETE THIS COMMUNICATION AND ALL ATTACHMENTS AND DESTROY ANY PRINTEDCOPIES. PLEASE NOTIFY THE SENDER OF ANY ERRONEOUS TRANSMISSION OF THIS EMAIL. THANK YOU.