### {In Archive} RE: Addition of Gas Refrigeration Skids at AU and MCU Shaheerah Kelly to: Patrick Flynn 08/03/2007 02:51 PM Cc: "Charlene Nelson", "Rachel G. Misra", "Wilson Laughter", Kathleen Stewart From: Shaheerah Kelly/R9/USEPA/US To: "Patrick Flynn" <pflynn@rnrc.net>, Cc: "Charlene Nelson" <charlenenelson@navajo.org>, "Rachel G. Misra" <rachelgmisra@navajo.org>, "Wilson Laughter" <wilsonlaughter@navajo.org>, Kathleen Stewart/R9/USEPA/US@EPA Archive: This message is being viewed in an archive. Pat, you may also need to send an application update to EPA of this change for the MCU PSD permit.

************************************ Shaheerah Kelly U S EPA Region 9 75 Hawthorne Street San Francisco, CA 94105 Phone: 415-947-4156 Fax: 415-947-3579 "Wilson Laughter" <wilsonlaughter@navajo.org> "Wilson Laughter" <wilsonlaughter@navajo.org> 08/03/2007 01:49 PM To "Patrick Flynn" <pflynn@rnrc.net>
cc "Charlene Nelson" <charlenenelson@navajo.org>, "Rachel G. Misra" <rachelgmisra@navajo.org>, Shaheerah Kelly/R9/USEPA/US@EPA Subject RE: Addition of Gas Refrigeration Skids at AU and MCU

Hi Patrick: I have received your email regarding the possible addition of a CO2 Unit at the Aneth and MCU. It would be an application update, as such, you would need to submit to our office an application containing all the necessary information about this equipment in accordance with Part 71 and Navajo Nation Operating Permit Regulations. The application will be reviewed and processed accordingly. It's likely that the equipment couldn't be installed until after the permit is amended. Without an actual application, it's difficult to determine the exact time from beginning to end. Since the initial permit was issued by our Program, all correspondence will be directed to our office concerning this action. I hope this answers your question, otherwise, give me a call. Wilson Laughter Senior Environmental Specialist N avajo Nation Air Quality Control Program (928) 729-4093

-----Original Message----- From: Patrick Flynn [ mailto : pflynn @ rnrc . net ] Sent: Fri 8/3/2007 2:35 PMTo: Kelly.Shaheerah@epamail.epa.gov; Wilson Laughter Cc: Dwight Mallory Subject: Addition of Gas Refrigeration Skids at AU and MCU Shaheerah and Wilson:

We are investigating the feasibility of adding CO2 refrigeration units at both the Aneth and McElmo Creek Unit CO2 recycle facilities. As you know, the Navajo EPA will shortly issue the final Title V permit for the Aneth Unit, and the USEPA is working on the draft Title V permit for the McElmo Creek Unit. The refrigeration skids we're considering will remove natural gas liquids from the CO2 recycle lines before the CO2 is re-injected into the oil reservoir. Air emissions should be negligible, and would include fugitive emissions from the refrigeration unit and the N GL tanks, and possibly some combustion-related emissions from a heater-treater burner. Any added compression would be electric. Dehydration would be done with closed loop systems and there would be no still column emissions.

What is the permitting process for adding such units to the final Aneth Title V permit and incorporating the new equipment into the MCU draft permit? How long would it take to modify the permits? Would we be able to construct and operate such equipment in the meantime, or do we need to wait until the required permitting is done?

We have not added any equipment yet... j ust asking so that we can plan accordingly.

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
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