1 

### Kelly, Shaheerah

From: Dwight Mallory <Dmallory@resoluteenergy.com>

Sent: Thursday, October 22, 2015 2:04 PM

To: Kelly, Shaheerah

Subject: RE: Question re MCU Li fecycle Maintenance Plan

Attachments: removed.txt

Shaheerah,

Please see my answers to your questions in red font below.

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the co rrect file and location.

Dwight E. Mallory

Environmental/Regulatory Manager

Resolute Energy Corporation

1700 Lincoln Street, Suite 2800

Denver, CO 80203

Direct: 303-573-4886 X 1165

From: Kelly, Shaheerah [mailto:Kelly.Shaheerah@epa.gov]

Sent: Thursday, October 22, 2015 2:07 PM

To: Dwight Mallory <Dmallory@resoluteenergy.com>

Subject: RE: Question re MCU Lifecycle Maintenance Plan

Dwight,

Thanks for your patience. I have a few more questions below related to the portions highlighted in red below. Thanks.

1. Please let me know if it is OK to remove the portion highlighted in red below.

The compressors do have scrubbers and the liquid level checks are part of the operators’ assigned duties. I would

leave that language in.



## Routine Monitoring & Surveillance

The gas compression plant is manned 24 hours a day by operators who work 12-hour shifts. The

operators make plant rounds each shift, during whic h key operating parameter s of the compressors

and supporting equipment are monitored. The following are examples of t he parameters that are

recorded during a shift:

 Overall gas compression plant inlet and discharge volumes

 CO 2 

### purchased volumes

 Flared volumes

 Discharge pressure

 Compressor run times

From the operator’s daily run time report (see Daily Plant Reading Fo rm in Attachment 2 of this O&M

Plan), a compressor reliability spreadsheet and flare volume report are updated.2 

### The operators monitor key operat ing parameters for the compresso rs to ensure the units are

operating within prescribed operat ing limits based on Resolute Natural Resources Company, LLC

and original equipment manufacturer (OEM) standar ds (e.g., compressor suction and discharge

temperatures and pressures, or scrubber liquid levels [ IS THIS NECESSARY? DOES ANY OF THE

EQUIPMENT USE A SCRBBER?] ).

2. The following paragraph in III.D (Life Cycle Maintenance Model) of the O&M Plan was changed from (A) in the

original consent decree, to (B) in the most recent version you sent me. Please let me know which version I

should use. If version (B) is used please respond to the highlighted portion in red.

Version A would be the correct version.



### (A) Life Cycle Maintenance Model

The section below provides a description of the type of activities planned for each Level. Note

Levels 5 and 6 are subject to the Risk Based Work Selection process prio r to committing to the

work. The Risk Based Work Selection process is based on earlier and ongoing data obtained and

analyzed during the maintenance cycles.

(B) Life Cycle Maintenance Model

The section below provides a description of t he type of activities planned for each level of

predictive maintenance. Note Levels 5 and 6 are subject to the Risk Based Work Selection

process [CAN YOU PROVIDE A BRIEF, 1- OR 2-SENTENCE DESCRIPTION FOR THIS

TERM?] prior to committing to the work. The predi ctive maintenance process is based on earlier

and ongoing data obtained and analyzed during the maintenance cycles.

3. III.D (Life Cycle Maintenance Model) of the O&M Plan identifies Levels 1

‐ 6, but there are 7 levels in the Life Cycle

Maintenance Plan. If this is the case, would you like to send me something that describes Level 7 for the O&M

Plan?

I don’t think it’s necessary to include a separate description. The Level 7 tasks aren’t really O&M tasks, it is really just

a review by the facilities engineering group to make sure our O&M procedures are still adequate for each machine.

4. For V (Reference Documentation) of the O&M Plan, please respond to the following questions highlighted in

red:



###  Original Equipment Manufacturer (O EM) maintenance manuals for each unit. [IS THE

SAME INFORMATION IN THE APPENDIX FOR THE LIFE CYCLE MAINTENANCE

PLAN, OR ISOLATION & OPERAT ING PROCEDURES, OR BOTH?]

The appendix for the Lifecycle Maintenance Plan and the isolation and operating procedures were developed using

the OEM maintenance manuals. However, the OEM manuals include additional information, such as equipment

diagrams, part numbers, etc...



###  Piping and instrument diagrams (P&IDs) for the plant, update, to reflect DESOP review in

May 2003. [WHAT IS DESOP?]3 I am not entirely sure. That was an Exxon Mobil term and should’ve been removed. This bullet point should read

“Piping and instrumentation diagrams (P&IDs) for the plant.”



###  Operating limits tables for each compre ssor, compiled from OEM recommendations and

Resolute Energy practices. [ IS THIS INFORMATION IN THE APPENDIX FOR THE LIFE

CYCLE MAINTENANCE PLAN?]

No. The operating limits for each machine are contained in separate notebooks in the plant control room.



###  All operator log sheets. [IS THIS THE SAME AS TH E APPENDIX FO R THE DAILY

PLANT READING FORM?]

Yes.

************************************

Shaheerah Kelly

Permits Office, Air Division (AIR-3)

U.S. Environmental Protec tion Agency, Region 9

San Francisco, CA 94105

Phone: 415-947-4156

Fax: 415-947-3579

Email: kelly.shaheerah@epa.gov

From: Dwight Mallory [ mailto:Dmallory@resoluteenergy.com ]

Sent: Wednesday, October 21, 2015 2:19 PM

To: Kelly, Shaheerah < Kelly.Shaheerah@epa.gov >

Subject: RE: Question re MCU Lifecycle Maintenance Plan

Shaheerah,

The “SEE NOTE” language on this line is a vestige of a past version of the O&M manual and refers to a procedural

requirement that no longer exists. You may find a similar notation on L4

‐ T1 for the HOS

‐ 4 compressor as well. It is also

obsolete.

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the co rrect file and location.

Dwight E. Mallory

Environmental/Regulatory Manager

Resolute Energy Corporation

1700 Lincoln Street, Suite 2800

Denver, CO 80203

Direct: 303-573-4886 X 1165

From: Kelly, Shaheerah [ mailto:Kelly.Shaheerah@epa.gov ]

Sent: Wednesday, October 21, 2015 11:24 AM

To: Dwight Mallory < Dmallory@resoluteenergy.com >

Subject: RE: Question re MCU Lifecycle Maintenance Plan

Dwight,

Thanks again for your previous response.4 I have another question. The Aerial C

‐ 5 Level 4 Intermediate Intervention contains a statement that says “SEE NOTE”.

What does “SEE NOTE” refer to? Please clarify what “SEE NOTE” is referring to so I can include the appropriate

reference.



### LEVEL 4 - ARIEL C-5 INTE RMEDIATE INTERVENTION

TASK TASK DESCRIPTION ACTIVITY FREQUENCY SKILL

L4

‐ T1 ENGINE / COMPRESSOR CRITICAL SAFETY DEVICES (SEE NOTE) FUNCTION TEST MONTHLY INSTRUMENT

************************************

Shaheerah Kelly

Permits Office, Air Division (AIR-3)

U.S. Environmental Protec tion Agency, Region 9

San Francisco, CA 94105

Phone: 415-947-4156

Fax: 415-947-3579

Email: kelly.shaheerah@epa.gov

From: Dwight Mallory [ mailto:Dmallory@resoluteenergy.com ]

Sent: Tuesday, October 20, 2015 10:36 AM

To: Kelly, Shaheerah < Kelly.Shaheerah@epa.gov >

Subject: RE: Question re MCU Lifecycle Maintenance Plan



### This information is descriptive only and is not necessary for operational purposes.

Sent via the Samsung GALAXY S®4, an AT&T 4G LTE smartphone



### -------- Original message --------

From: "Kelly, Shaheerah" < Kelly.Shaheerah@epa.gov >

Date: 10/20/2015 10:26 AM (GMT-07:00)

To: Dwight Mallory < Dmallory@resoluteenergy.com >

Subject: Question re MCU Lifecycle Maintenance Plan

Dwight,

The following information was contained in the Lifecycle Maintenance Plan (attachment #1 of Appendix A) for

compressors HOS

‐ 6, HOS

‐ 4, and Aerial C

‐ 5. However, it was removed from the most recent revised version you sent me.

Is this information needed from the proper operation of the compressors? Please verify whether or not it is still

applicable and needs to be in the Lifecycle Maintenance Plan. Thanks.



### LIFE CYCLE MAINTENANCE PLAN

The following pages describe the Level 1 tasks perf ormed by the plant oper ators during each shift.

Critical monitoring devices for pressure, temperature, level, and vibration are equipped with High and HighHigh alarms.

High alarms warn operators of a process malfunction allowing operators to tr oubleshoot the process for

operational or mechanical malfunctions. Operational pr oblems are corrected by an operator allowing equipment5 

### to continue operating. Mechani cal problems that can be easily repaired by the operator are

repaired. Mechanical problems that cannot be repaired by the operator are communicated to the supervisor on

duty and a decision is made to either shut down that piece of equipment or to continue running, depending on

the criticality of the equi pment and/or the severity of the malfunc tion, until repairs can be made. Monitoring

frequency of the equipment will be increased, again depend ing on the criticality of the equipment or the severity

of the malfunction until repairs can be made.

High-High alarms will automatically shut down equipment ensuring the safety of personnel, preventing damage

to equipment, and minimizing impact on the environment. The supervisor on duty is notified of a shutdown and

a decision is made whether to repa ir immediately, depending on day (weeke nd, weekday), time of day (night

tour or day tour) availability of parts and personnel nece ssary to perform repairs, in order to minimize impact on

the environment.

************************************

Shaheerah Kelly

Permits Office, Air Division (AIR-3)

U.S. Environmental Protec tion Agency, Region 9

San Francisco, CA 94105

Phone: 415-947-4156

Fax: 415-947-3579

Email: kelly.shaheerah@epa.gov

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