{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

Navajo Nation Air Quality Control Program

(928) 729-4093

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

From: Patrick Flynn [mailto:pflynn@rnrc.net]

Sent: Fri 8/3/2007 2:35 PM
To: 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

NGL 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...just 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

Fax: 303.623.3628

Cell: 303.941.0389
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