RE:McElmo Main Flare McElmo Main Flare McElmo Main Flare :Pat's12/06/10 12/06/10 12/06/10letter

Dwight Mallory Dwight Mallory to: Andrew Chew 04/24/2012 12:04 PM

Andrew, 

Sorry for the delayed reply. I was out sick yesterday and today and just 

got to your email. Figures 2-1, 2-2 and 5-1 from the PSD application. are 

attached as JPEGs. Figure 2-3 is referenced in the table of contents, but 

I didn't see it in the document.

Also attached is a JPEG version of the proposed facility diagram that I 

sent previously.

If there any other pages you're lokking for in JPEG, let me know and I 

can export them from the pdf document.

Thanks, Dwight 

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

Sent: Tue 4/24/2012 12:24 PM

To: Dwight Mallory

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

Hi Dwight,

I want to check-in on this. Do you have the figures in the jpg format 

available? 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

----- Forwarded by Andrew Chew/R9/USEPA/US on 04/24/2012 11:23 AM -----

From: Andrew Chew/R9/USEPA/US

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

Date: 04/20/2012 06:39 PM

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

Dwight,
I'd like to copy some figures that appeared in Resolute's permit

application and paste them onto my report in Microsoft Word, but I'm not 

able to do so because the current file format in pdf doesn't allow it. Can 

you forward me any other formats that would allow it? I appreciate your 

help in getting this done. 

[attachment "McElmo Creek Main Flare PSD App_041108.pdf" deleted 

by Andrew Chew/R9/USEPA/US] 

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

Cc: Shaheerah Kelly/R9/USEPA/US@EPA, Cleveland 

Holladay/R9/USEPA/US@EPA, Tom Mintz/R9/USEPA/US@EPA, "Patrick Flynn" 

<pflynn@ResoluteEnergy.com>, "John Jacus" <John.Jacus@dgslaw.com>, 

<Randy.Dann@dgslaw.com>

Date: 04/18/2012 03:37 PM

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

Andrew,

As we discussed in our telephone conversation, I wanted to clarify the facility 

throughput information provided in my April 13 email (copy attached). While 

the replacement of the existing reciprocal compressors with screw 

compressors will ultimately give the facility a compression capacity of up to 50 

MMCFD, the proposed glycol dehydrator is being designed with a capacity of 

25 MMCFD. 

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: Dwight Mallory 

Sent: Wednesday, April 18, 2012 4:23 PM

To: 'Andrew Chew'

Cc: Shaheerah Kelly; Cleveland Holladay; Tom Mintz; Patrick Flynn; John 

Jacus; Dann, Randy (Randy.Dann@dgslaw.com)

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

 

Andrew,

Thanks for the follow up email and phone call. As we discussed during the call 

this morning, GHG emissions for the MCU CO2 recycle facility are attached. 

I look forward to your comments on the modeling discussion. In the meantime, 

I will follow up on the Class I area impacts and ESA issues with Mr. Notar and 

Mr. Maddux respectively and will forward copies of any correspondence with 

them to you as soon as possible.

Please call or email if you need anything else.

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: Wednesday, April 18, 2012 11:56 AM

To: Dwight Mallory

Cc: Shaheerah Kelly; Cleveland Holladay; Tom Mintz

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

 

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

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 quality modeling 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: Andrew Chew [mailto:Chew.Andrew@epamail.epa.gov] 

Sent: Monday, April 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

----- Message from "Dwight Mallory" <dmallory@ResoluteEnergy.com> 

on Fri, 13 Apr 2012 10:19:12 -0600 -----

To: "Andrew Chew" <Chew.Andrew@epamail.epa.gov> 

cc: "Patrick Flynn" <pflynn@ResoluteEnergy.com>, "John Jacus" <John.Jacus@dgslaw.com> 

Subject

:

RE: McElmo Creek Unit Follow Up

Andrew,

Attached is a process flow diagram for the proposed dehydrator installation at the MCU reinjection facility . 

I also included an as-built drawing for the existing dehydrator. I think you have this information already, 

but it turned up during my document search so I thought I’d send a copy.

Currently, the reinjection facility receives 12 to 24 MMCFD of CO2 rich produced gas from the field. The 

produced gas is compressed for reinjection to the field by 4 existing electric powered reciprocal 

compressors (C5, HOS 6, HOS 4 and AGCB). Only the HOS 6 has the ability to send gas to the existing 

dehydrator. This limits the current dehydrator capacity to ≤ 6 MMCFD. 

The new electric screw compressors (C-101, C-102, C-103) shown on the attached process flow diagram 

will replace the facility’s existing reciprocal compressors and will be configured to send all of the produced 

gas to the proposed dehydrator prior to reinjection. Installation of the new screw compressors and 

proposed dehydrator will handle the current production of 12 to 24 MMCFD, as well as provide capacity 

for additional production up to 50 MMCFD. The ability to dehydrate all of the gas prior to reinjection will 

also eliminate many corrosion and freezing issues with the facility discharge piping that have contributed 

to compressor downtime and flaring of gas. 
Hopefully, this will get you closer to having everything you need .

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

Sent: Wednesday, April 11, 2012 5:11 PM

To: Dwight Mallory

Subject: RE: McElmo Creek Unit Follow Up 

 

Hi Dwight, 

Thanks for the e-mail. Yeah, we need the information to help us move this forward. I'd like to get this 

wrapped up. Let's hope the contracting company or even some other person/source has the information 

(i.e., compressor configuration, and volume flows pre- and post-project) to make this happen. 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: Andrew Chew/R9/USEPA/US@EPA 

Date: 04/11/2012 02:00 PM 

Subject: RE: McElmo Creek Unit Follow Up 

Andrew,

I was going through my list of unfinished projects and it discovered that you’ve been waiting on 

information from me while I thought I was waiting on a phone call from you. 

I haven’t been able to find the process flow diagram you requested for the proposed dehydrator 

installation. The operations engineer who was supervising this project for us has since left the company 

so it’s been difficult tracking the information down. 

I have contacted the contract engineering firm that did the original design and requested the information . I 

have been out of the office quite a bit since we last spoke, but will be able to keep after this more diligently 

until I can get you the information you need. 
In the meantime, please call me at your convenience if you need anything else.

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: Dwight Mallory 

Sent: Friday, March 16, 2012 3:17 PM

To: 'Andrew Chew'

Subject: RE: McElmo Creek Unit Follow Up 

Thanks for the reminder Andrew. I am in the office all next week and can talk at your convenience. I have 

put out feelers with our engineering group looking for the process flow diagrams we discussed and will 

follow up with them in the meantime and see if we have anything.

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, March 16, 2012 2:18 PM

To: Dwight Mallory

Subject: Fw: McElmo Creek Unit Follow Up 

Hi Dwight, 

As I'm writing this friendly reminder, I hope things are going okay. Will you be able to talk next week? 

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

----- Forwarded by Andrew Chew/R9/USEPA/US on 03/16/2012 01:16 PM -----

From: Andrew Chew/R9/USEPA/US 

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

Date: 03/06/2012 11:32 AM 

Subject: Re: McElmo Creek Unit Follow Up 

 
Dwight, 

I'm replying to acknowledge receipt of your e-mail and I'm sorry to hear about your loss. We'll touch base 

later. 

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

Date: 03/06/2012 10:57 AM 

Subject: McElmo Creek Unit Follow Up 

 

Andrew, 

I wanted to let you know that I haven’t forgotten about the process information you requested. I’ve been 

out of the office this week due to a death in the family, but I will be back in on Thursday and will get you 

the requested information as soon as possible. 

Dwight Mallory 

Environmental, Health & Safety Coordinator 

Resolute Natural Resources Company 

 [attachment "ME-PFD-100-Ca.pdf" deleted by Andrew Chew/R9/USEPA/US] [attachment "Stage 2 CO2 

Reinjection Compressor-Glycol Dehydration.pdf" deleted by Andrew Chew/R9/USEPA/US] 

McElmo Creek Main Flare PSD App_041108_Page_018.jpg

McElmo Creek Main Flare PSD App_041108_Page_019.jpg

McElmo Creek Main Flare PSD App_041108_Page_058.jpg ME-PFD-100-C1.jpg