### RE: McElmo Main Flare McElmo Main Flare McElmo Main Flare : Pat

' s 12/06/10 12/06/10 12/06/10 letter Dwight Mallory Dwight Mallory to: Andrew Chew 04/24/2012 12:04 PM

Andrew,

Sorry for the delayed reply. I was out sick yesterd ay and today and just got to your email. Figures 2-1, 2-2 and 5-1 from th e 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 fac ility 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.comFrom: 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 s till 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-h r SO2 modelling and plan to let you know our findings nex t week. While Scott believed that the 1-hr NO2 modelling work was suffi cient, he asked that 1-hr SO2 modelling work to be more specific. Howev er, since Scott is no longer on this project, Cleve Holladay of our agenc y will be helping mewith reviewing the modelling work

.

Finally, we would need GHG CO 2e 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 be en with the agency for more than 7 years. I plan to include her in fut ure 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 areasand 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 UpDwight,

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