McElmo Main Flare: Pat's 12/06/10 letter

Andrew Chew to: Dwight Mallory 04/18/2012 10:56 AM

Cc: Shaheerah Kelly, Cleveland Holladay, Tom Mintz

Hi Dwight,

To be frank and honest, we wish we can narrow down the list further than what was bulleted in Pat's letter,

but we're still a little ways away. For the Class I area impacts and ESA issues, please get separate

confirmations from the federal land manger and Fish and Wildlife Service that their 2006 assessment

statements apply to this day if the PSD Main Flare permit were to be issued in a few months.

Also, we're reviewing McVehil Monnet's 6/1/11 report on 1-hr SO2 modelling and plan to let you know our

findings next week. While Scott believed that the 1-hr NO2 modelling work was sufficient, he asked that

1-hr SO2 modelling work to be more specific. However, since Scott is no longer on this project, Cleve

Holladay of our agency will be helping me with reviewing the modelling work.

Finally, we would need GHG CO2e emissions quantification so that the record reflects what's found.

Shaheerah Kelly, my peer in our Air Permits office, will be partnering with me to help move the permit

process along. She's very knowledgeable and has been with the agency for more than 7 years. I plan to

include her in future correspondence and meetings. Thanks again.

- 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

"Dwight Mallory" 04/17/2012 11:28:01 AM Andrew,

From: "Dwight Mallory" <dmallory@ResoluteEnergy.com>

To: Andrew Chew/R9/USEPA/US@EPA

Date: 04/17/2012 11:28 AM

Subject: RE: Pat's 12/06/10 letter

Andrew,

Thanks for sending the letter. Based on our conversation in reference to the bullet list of requested

information on page 2, it is my understanding that you are requesting information to address the review

of the Class I area impacts and Endangered Species sections of the PSD application.

We have reviewed the Class I area impacts and Endangered Species sections of the PSD application.

Because the previous Class I area and Endangered Species assessments and findings were based on the

maximum facility emissions allowable under the Consent Decree emission limits and the annual

averaged emissions from the SCREEN 3 modeling scenario, and inasmuch as neither the Consent Decree

emission limits nor the modeling inputs have been modified; we believe that the Class I area impacts and

Endangered Species impacts analyses provided in the PSD application are still valid and no update is

needed.

It is also my understanding that McVehil Monnet discussed the potential need for additional air qualitymodeling to address the 1 hour NAAQS standard for SO2 with Scott Bohning at EPA and that they were

in agreement that additional modeling, and thus additional assessment of impacts to Class I areas and

Endangered Species, were unnecessary.

Please contact me if you require additional information.

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: A ndrew Chew [mailto:Chew. A ndrew@epamail.epa.gov]

Sent: Monday, A pril 16, 2012 4:52 PM

To: Dwight Mallory

Subject: Pat's 12 / 06 /

10 letter

- 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