{In Archive} RE: Addition of Gas Refrigeration Skids at AU and MCU

Wilson Laughter to: Patrick Flynn 08/03/2007 01:53 PM

Cc: "Charlene Nelson", "Rachel G. Misra", Shaheerah Kelly

From: "Wilson Laughter" <wilsonlaughter@navajo.org>

To: "Patrick Flynn" <pflynn@rnrc.net>, 

Cc: "Charlene Nelson" <charlenenelson@navajo.org>, "Rachel G. Misra" 

<rachelgmisra@navajo.org>, Shaheerah Kelly/R9/USEPA/US@EPA

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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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