RE:Fw:Class I Area Impact Analysis for PSD Permit Application Class I Area Impact Analysis for PSD Permit Application

Dwight Mallory Dwight Mallory to: Andrew Chew 08/27/2012 01:08 PM

Cc: Mohit LalSolanky, Cleveland Holladay

History: This message has been forwarded.

Andrew,

I’ve asked Tom Hormel at McVehil-Monnett and Associates to contact 

NPS and work with Mr. Shepherd to address their concerns with 

Hovenweep. I will make sure you and your modeling folks get copies of 

any materials that are generated as a result of their conversations. 

Dwight E. Mallory

Environmental, Health & Safety Coordinator

Resolute Energy Corporation

1675 Broadway, Suite 1950

Denver, CO 80202

Direct: 303-573-4886 X 1165

Cell: 970-302-8620

Email: dmallory@ResoluteEnergy.com

From: Andrew Chew [mailto:Chew.Andrew@epamail.epa.gov] 

Sent: Friday, August 24, 2012 6:13 PM

To: Dwight Mallory

Cc: Shirley Rivera; Cleveland Holladay

Subject: RE: Fw: Class I Area Impact Analysis for PSD Permit Application

Hi Dwight,

Please forward me the information that you're providing to the FLM to us 

at Region 9 also. Shirley and Cleve are helping on Modeling Impacts 

and Additional Impacts. Thanks.

- Andrew 

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

Andrew Chew, P.E. 

T: (415) 947-4197 | F: (415) 947-3579 | chew.andrew@epa.gov

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

Francisco, CA 94105

From: Dwight Mallory <Dmallory@resoluteenergy.com>

To: "'Don_Shepherd@nps.gov'" <Don_Shepherd@nps.gov>

Cc: "'john_notar@nps.gov'" <john_notar@nps.gov>, Andrew

Chew/R9/USEPA/US@EPA, Patrick Flynn <Pflynn@resoluteenergy.com>, "

John_Reber@nps.gov" <John_Reber@nps.gov>, "Michael_George@nps.gov" <

Michael_George@nps.gov>
Date: 08/10/2012 02:11 PM

Subject: RE: Fw: Class I Area Impact Analysis for PSD Permit Application

Mr. Shepherd,

Thank you for your reply. The requested hourly 

maximum emission rates and annualized emissions 

derived from the maximum hourly rates for NOx, SO2 

and PM10 are included below and in the attached 

spreadsheet. The flare is not a direct source of 

H2SO4. 

I will speak with Mr. Chew at EPA and our modeler 

about the visibility impact analysis for Hovenweep 

and will follow up with you. 

Requested Emissions

NOx: Hourly maximum rate - 27.1 lb/hr; Annualized 

maximum - 118.5 TPY

SO2: Hourly maximum rate - 72.9 lb/hr; Annualized 

maximum - 319.1 TPY

PM10: Hourly maximum rate - 3.1 lb/hr; Annualized 

maximum - 13.8 TPY

Dwight E. Mallory

Environmental, Health & Safety Coordinator

Resolute Energy Corporation

1675 Broadway, Suite 1950

Denver, CO 80202

Direct: 303-573-4886 X 1165

Cell: 970-302-8620

Email: dmallory@ResoluteEnergy.com

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

From: Don_Shepherd@nps.gov [

mailto:Don_Shepherd@nps.gov] 

Sent: Wednesday, August 08, 2012 9:51 AM

To: Dwight Mallory

Cc: 'john_notar@nps.gov'; Chew.Andrew@epamail.epa.gov

; Patrick Flynn; John_Reber@nps.gov; 

Michael_George@nps.gov

Subject: Re: Fw: Class I Area Impact Analysis for PSD 

Permit Application

Mr. Mallory,

Thank you for the information on the McElmo Creek 

Unit Gas Compression Facility. Our current (FLAG) 

guidance requests that you calculate the annual 

emissions of SO2, H2SO4, NOx, and PM10 (Q) by 

annualizing (multiply by 4.38) the maximum potential 

hourly emission rates of those pollutants.

Please provide those hourly maxima.
I noticed that the site is near Hovenweep National

Monument, yet i saw no mention of Hovenweep in the 

attachments. While Hovenweep is not a Class I area,

we request that the impact of the flare's plume on 

visibility at Hovenweep be evaluated as part of the

"Additional Impacts Analysis" portion of any required 

PSD analysis.

Please feel free to contact me with any questions.

Don Shepherd

National Park Service

Air Resources Division

12795 W. Alameda Pkwy.

Lakewood, CO 80228

Phone: 303-969-2075

Fax: 303-969-2822

E-Mail: don_shepherd@nps.gov

"the man who really counts in the world is the doer, 

not the mere critic"

TR 1891

 

 John 

 Notar/DENVER/NPS 

 

To 

 08/06/2012 04:45 Don 

Shepherd/DENVER/NPS@NPS 

 PM 

cc 

 John 

Notar/DENVER/NPS@NPS 

 

Subject 

 Fw: Class I 

Area Impact Analysis 

 for PSD Permit 

Application 

 

 

 

 

 

 

Don: my opinion is to screen this one out. It is 58 

km west of MEVE &

92 km Southeast from CANY. I screened this one out
back in June 2006. the

SO2 emission estimates from the flare have gone down 

a small amount from

29.2 -> 26.7 TPY.

They claimed that EPA Region ( made them run refined 

AERMOD to show compliance with the new 1-hour SO2 

NAAQS. AERMOD show they do not cause or contribute

to a 1-hour NAAQS violation. (Why Region 9 & not 

Region 8 is confusing, its in Utah. Dwight Mallory

has left me a voice mail.

As I said I recommend that we screen this out any 

ideas?

My Q/D is :

60 TPY SO2 + 13.4 TPY NOx + 95.4 TPY VOC = 

168.8Q / 58 km D = 2.91

John

----- Forwarded by John Notar/DENVER/NPS on 

08/06/2012 04:27 PM -----

 

 Dwight Mallory 

 <Dmallory@resolut 

 eenergy.com> 

To 

 

"'john_notar@nps.gov'" 

 08/02/2012 01:28 <

john_notar@nps.gov> 

 PM 

cc 

 "

Chew.Andrew@epamail.epa.gov" 

 <

Chew.Andrew@epamail.epa.gov>, 

 Patrick Flynn 

 <

Pflynn@resoluteenergy.com> 

 

Subject 

 Class I Area 

Impact Analysis for 

 PSD Permit 

Application 

 

 

 

 

 
 

Mr. Notar,

In reference to the voice message exchanges we have

had: I am contacting you in reference to a PSD permit 

application, submitted to U.S. EPA Region

9 on December 5. 2005, for the emergency flare at the 

McElmo Creek Unit Gas Compression Facility, located

near Aneth, Utah. Resolute Natural Resources Company 

acquired the MCU facility from Exxon Mobil in 2006 

and we have been working with Region 9’s permitting

staff to obtain issuance of the PSD permit since that 

time.

You provided comments at the time the original PSD 

application and air modeling were submitted that no

additional modeling for Class I impacts was 

necessary. However, since that time, EPA has 

promulgated new 1-hr NAAQS for

NO2 and SO2, and requested that Resolute revise the

modeling to account for the 1-hr NO2 and SO2 NAAQS.

They also requested that Resolute contact you and 

allow the opportunity for you to review your comments 

in light of the

2010 revisions to the air emissions guidance for 

federal land managers.

The emissions limits of 60 TPY S02; 73 TPY CO; 13.4

TPY NOx; and 95.4 TPY VOCs applicable to the flare 

are unchanged since the original PSD application was 

submitted; and the flare’s actual emissions have 

decreased from the 29.2 tons S02; 66 tons CO; 12.1 

tons NOx; and 90.6 tons VOC reported by EOM for 2005 

to 26.7 tons SO2; 45.4 tons CO; 8.4 tons NOx; and

54.9 tons VOC for 2011. The SCREEN 3 model submitted 

with the PSD application estimated near-field impacts 

from the flare operating at 14.83 MMCFD for the 

entire year, or 7 times greater than the average rate 

for 2005.

The results of the model showed that the flare did 

not cause or contribute to a violation of the 

National Ambient Air Quality Standards for NO2 or SO2 

that were effective at the time of the PSD submittal. 

The revised SCREEN 3 model demonstrated that the 

flare did not to cause or contribute to a 1-hour NO2 

NAAQS violation, but showed that the maximum 1-hr SO2 

impact for the flare exceeded the interim SIL of 3 

ppb. At Region 9’s request, Resolute remodeled the 

SO2 emissions using EPA’s refined AEROMOD model and

was able to effectively demonstrate that the flare 

does not cause or contribute to a 1-hour SO2 NAAQS 

violation.

I have attached Appendix D of the original PSD 
application, which includes the original

communication between yourself and Justin Harrison at 

Exxon Mobil concerning impacts to Class I areas. Also 

attached is a map showing the location of the project 

in relation to Class I areas. Please review and let

me know if any additional information or modeling is 

necessary.

If you would like to speak with EPA Region 9 staff,

please contact Andrew Chew at (415) 947-4197.

As requested by Region IX, I have also contacted 

Laura Romin with USFWS to allow an opportunity for 

USFWS to renew their comments regarding T&E species

and critical habitat impacts.

Dwight E. Mallory

Environmental, Health & Safety Coordinator Resolute

Energy Corporation

1675 Broadway, Suite 1950

Denver, CO 80202

Direct: 303-573-4886 X 1165

Cell: 970-302-8620

Email: dmallory@ResoluteEnergy.com

[attachment "APP D from EOM PSD Ap.pdf" deleted by 

Don Shepherd/DENVER/NPS] [attachment "MCU Class I 

Air.pdf" deleted by Don Shepherd/DENVER/NPS]