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### Chew, Andrew

From: Dwight Mallory [Dmallory@resoluteenergy.com]

Sent: Wednesday, February 06, 2013 4:05 PM

To: Chew, Andrew

Subject: RE: McElmo Creek Main Flare PSD Permit App lication: Visibility Impact/Soils and Vegitation

Analyses

Attachments: McElmo Creek Main Flare Level II VISCREEN Modeling_013013.pdf

Categories: McElmo Creek PSD

Andrew,

In consultation with Don Shepherd at NPS, Tom Hormel at McVehil Monnett Associates conducted a Level 1 and Level 2

visibility screening analysis for potential impacts from the McElmo Main Flare at Hovenweep National Monument.

Hovenweep National Monument is the only identified federal Class II area within 50 km of the Main Flare. A copy of the

report from that analysis is attached for inclusion in the additional impact analysis for the Main Flare PSD.

I conducted a map search and a review of websites and literature for the area to determine if there were potentially

sensitive non

‐ federal parks, forests, monuments, or recreational areas within 50 km of the project. Included in the

search were websites of the Utah Division of State Parks; Navajo Nation Parks and Recreation; Colorado Division of Parks

and Wildlife; and New Mexico Division of State Parks.

The only potential Class II areas discovered were 1) The Edge of The Cedars State Park, located 48 km northwest of the

project; and 2) The 4

‐ Corners Monument Navajo Tribal Park, located 32 km southeast of the project. A separate visibility

screening analysis of these units was not conducted because the distance to each of these units is greater than the

distance to the 2 Hovenweep units that are most distant from the project. The modeling conducted for the Hovenweep

analysis showed no perceptible plume impacts would occur at the 2 more distant Hovenweep units during any time of

day. In addition to their distance from the project, neither the Edge of The Cedars State Park nor the 4

‐ Corners

Monument Tribal Park have a high potential for visibility impairment since they consist largely of man

‐ made structures

rather than terrain features.

http://navajonationparks.org/

http://stateparks.utah.gov/

As for the soil and vegetation impact analysis, I have asked Mr. Hormel to take a look at the depositional impacts

analysis that was included in Section 7.4.3. of the PSD permit application and see if he can supplement the write up as

needed. I should have something from Tom by the 20 th of this month.

Let me know if you need anything in the meantime.

Thanks.

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: Chew.Andrew@epamail.epa.gov [mailt o:Chew.Andrew@epamail.epa.gov]

Sent: Wednesday, January 30, 2013 4:01 PM2 To: Dwight Mallory

Subject: McElmo Creek Main Flare PSD Permit Application: Visibility Impact/Soils and Vegitation Analyses

Dwight,

Per our phone conversation, as our office is wrapping things up in preparation for public notic e, here are 2 more topics we

hope Tom can help make our write-up more robust:

 Visibility Impact Analysis

The visibility impact analysis for fulfilling the additional impac ts analysis requirement pertains to visibility impairment (e. g., plume blight) in Class II areas. My understanding from Don S hepard is that Hovenweep is the only Class II federal area

within 50 km of the Main Flare. The a nalysis should include Class II areas described below.

The Class II visibility impacts analysis is independent of the Cl ass I visibility Air Quality Related Values. Please confirm

whether there are other Class II federal and state areas (e.g., potentially se nsitive parks, forests, monuments, and

recreational areas) within 50 km of the project. (If there is not a specifically designated "Class II area(s)", the project

should consider a location(s) where ther e may be some potential for visibility impairm ent. For instance, if there is an area

where there are terrain features that provide a contrast t hat makes changes in visibility perceptible, that area may be

considered.)

Please discuss the potential visual im pacts of the project on these areas. Information presented in the EPA 1992

workbook should be considered -

 U.S. EPA (U.S. Environmental Protection Agency), 1992. “Wor kbook for Plume Visual Impact Screening and Analysis.”

EPA-450/R-92-023. October.

http://tinyurl.com/EPA1992plume

Then based upon the evaluation, conduct a VISCREEN Level 1 analysis (beyond what already was provided for Class I

areas) for any identified areas. If necessary, conduct a Level 2 analysis if the Level 1 impacts are exceeded. If there is a

valid reason not to conduct an analysis, please provide that narrative.

 Soils and Vegetation Analysis

Please characterize the potential impacts to soils and veget ation in consideration of the following suggested additional

references to help make the write-up more robust:

 U.S. EPA (U.S. Environmental Protection Agency), 1980. “A Screening Procedure for the Im pacts of Air Pollution Sources

on Plants, Soils, and Animals. Fina l Report” EPA-450/2-81-078. December.

http://tinyurl.com/EPA1980Soils

Web Soil Survey (WSS) for the National Cooperative Soil Surv ey via the USDA Natural Resources Conservation Service.

http://websoilsurvey.nrcs.usda.gov/app/HomePage.htm

From site:



### Web Soil Survey (WSS) provides soil data and inform ation produced by the Nationa l Cooperative Soil Survey.

It is operated by the USDA Natural Resources Conserva tion Service (NRCS) and provides access to the largest

natural resource information system in the world. NRCS has soil maps and data available online for more than

95 percent of the nation’s counties and anticipates having 100 per cent in the near future. The site is updated and

maintained online as the single authorita tive source of soil su rvey information.

Links to recent EPA Region 9 Fact Sheets that include discussions abo ut soils and vegetation, as examples of what we

have proposed in our permits, are as follows:3  Pio Pico, Item IV.2 - http://www.regulations.g ov/#!documentDetail;D= EPA-R09-OAR-201 1-0978-0005

 Palmdale - http://www.regulations.gov/#!document Detail;D=EPA-R09-OAR-2011-0560-0004

 SPI Anderson - http://www.regulations.gov/#!documen tDetail;D=EPA-R09-OAR-2012-0634-0003

Please let me know if you have further questions. Thank you.

- 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