Resolute 

Patrick E. Flynn 

Environmental Health & Safety Manager 

303.534.4600 x 1145 

pflvnn(a)rnrc.net 

June 5, 2009 

Ms. Shirley F. Rivera 

Air Division 

US Environmental Protection Agency 

75 Hawthorne Street, Mail Code AIR-3 

San Francisco, CA 94105 

Re: Additional Information, PSD Permit Application 

McElmo Creek Unit Oil and Gas Production Facility, San Juan County, Utah 

Dear Ms. Rivera: 

As you know, Resolute Natural Resources Company (Resolute) has been communicating 

and working with US EPA Region IX for the past 36 months regarding the McElmo Creek Unit 

Oil and Gas Production Facility's (MCU) Prevention of Significant Deterioration (PSD) Permit 

Application, which is a carryover from the Consent Decree entered into between EPA and Mobil 

Exploration & Producing U.S. Inc. (Consent Decree). 

On May 15, 2009, you and Mr. Chew contacted Resolute regarding the MCU permit 

application and a number of associated technical questions. "I'hat same day you followed up by 

sending an email requesting additional information regarding the MCU oil and gas production 

process. As requested, this letter presents a response to those questions posed by you in your 

May 15, 2009 email. Each of your questions is presented in italics below, followed by our 

response. 

DATA CLARIFICATION - We understand some of these may be less/not applicable. 

1. Detailed process flow diagrams (PFD's) for all upstream equipment and process 

units venting to the flare (identify type and location of all control equipment) 

*** We understand the flares are for emergency purposes, e.g., compressor(s) 

offline, pipeline capacity issues. 

Resolute Natural Resources Company, LLC 

1675 Broadway, Suite 1950, Denver, CO 80202 

Voice: 303.534.4600 Fax: 303.623.3628 
The MCU Main Flare serves as an emergency flare for the Carbon dioxide (CO2) recycle 

compressors and as a control device for a relatively low volume stream associated with 

the still column on the MCU Facility's single dehydration unit. The MCU Main Flare is 

not a process flare. 

CO2 and water are injected into the McElmo Creek Unit oilfield's underground oilproducing reservoir in order to enhance the production of crude oil. The injected CO2 and 

water are then produced along with the hydrocarbons (crude oil with small amount of 

natural gas), brought to the surface, and separated into crude oil, water, and gas streams. 

The crude oil is sold and the CO2-rich gas and water are re-injected back into the oil 

reservoir to begin another cycle of enhanced oil production. Under normal operating 

conditions, all of the CO2 produced is re-injected and recycled back into the subsurface 

reservoir, with the electric-drive compressors located at the MCU Facility providing the 

needed injection pressure. In the event an MCU compressor malfunctions and cannot reinject the CO2-rich gas back underground, the recycle gas stream must be routed to the 

Main Flare, an operational scenario specifically contemplated by the Consent Decree. A 

schematic flow diagram depicting the MCU Main Flare and associated facilities is 

included as Attachment 1. 

2. Descrrption of equipment, process, or procedures installed or implemented within 

the last rive years to reduce flaring 

Improvements Made at Resolute Natural Resources MCU Compressor Facility 

Since Resolute assumed operations of the MCU Facility in June 2006, Resolute has 

undertaken extensive Facility repairs, upgrades and operational changes to respond to 

corrosion issues and prevent the recurrence of similar problems in the future that can 

result in flaring of CO2 rich gas. Repairs/upgrades completed as of June 1, 2009 include: 

➢ Ultrasonically tested all Facility piping to determine metal thickness and pressure 

rating; 

➢ Hydro tested HOSS-4 and HOSS-6 piping and pressure vessels to 1.5 x MAOP; 

➢ Upgraded station piping serving C5, HOSS-4 and HOSS-6 compressors to ASME 

B31.3 pressure standards; 

➢ Replaced all carbon steel suction piping with stainless steel piping; 

➢ Replaced all discharge piping from compressor outlet to injection manifold; 

➢ Replaced carbon steel3` aand 4t ' stage coolers with stainless steel; 

-)-- Cleaned all existing piping and cooler tubes to remove iron sulfide; 

➢ Removed carbon steel return gas line off the closed drain system and replaced 

with 2" stainless steel; 

➢ Redesigned/Rebuilt the Facility drain system to improve fluid handling reliability 

and decrease flaring caused by fluid accumulation, which included the removal of 

obsolete drain system piping from the station and hydro-testing of remaining 

drain system piping; 
➢ Installed corrosion coupons in key areas of the station to improve monitoring of 

corrosion related metal loss; 

➢ Installed improved corrosion inhibition injection system throughout the Facility to 

minimize system corrosion; 

➢ Designed and installed improved scrubber-level control devices to minimize 

compressor failures caused by high scrubber fluid levels; 

➢ Relocated the 4th stage scrubber vessel to minimize water dropout in the gas 

stream; 

➢ Cleaned and serviced all instrument air equipment and tubing for better reliability 

of the station control system; 

➢ Removed and tested all system pressure relief valves; 

➢ Inspected and pressure tested all flare system piping; 

➢ Inspected and calibrated the flare system ultrasonic flow meter; 

➢ Tested and certified reliability of the LEL and H2S gas detection, alarm system, 

and ESD system; 

➢ Automated HOS 4 and HOS 6 with PLC which includes systems control and 

historical failure records; 

➢ Implemented Active Factory SCADA Viewer to identify failure trends providing 

opportunity to do proactive maintenance; and 

➢ Rebuilt headers for CO2 and Recycle Gas distribution with Micro Motion 

metering on all flow streams. 

In addition to the noted Facility repairs and upgrades, which cost approximately 

$6.5 MM in capital and contractor service costs, Resolute has implemented a number of 

changes to the Facility operations and maintenance procedures to improve operational 

efficiency and reduce flaring and air emissions, which include: 

➢ Increased the operations staff and supervision dedicated to operation of the 

compression Facility; 

➢ Improved written operating procedures and operator training; 

➢ Expanded the maintenance program to include ultrasonic testing of Facility piping 

and pressure vessels at prescribed intervals; 

➢ Implemented expanded disciplinary measures associated with operator error; and 

➢ Contracted with a 3` d party compressor operator to increase compressor safety and 

reliability. 

3. Any available storage for excess vent gases? 

No. The problem is not storage; it is a temporary lack of adequate compression. As 

noted above, Resolute has gone to great lengths to reduce the likelihood of future 

compressor malfunctions that can result in flaring. 
4. Scrubbing capacity available for vents and any limitations on scrubbing vent 

gases for use as fuel in other combustion unit? 

None. Based on the MCU process and generation of the COZ recycle gas steam only in 

the event of a MCU compressor malfunction, this is neither applicable nor technically 

feasible. 

5. Description and tech specifications for flare and associated knock out pots, surge 

drums, water sea/s, flare gas treatment and recovery systems. 

The MCU Main Flare is an air-assisted flare system with an auto-ignition system and a 

fire eye/flame monitor. Please refer to Attachment 2, which is a correspondence between 

ExxonMobil and the Director, Air Division of the US EPA Region IX dated July 7, 2006 

that certifies the implementation of upgrades made by ExxonMobil during May 2006 to 

bring the Main Flare into compliance with Consent Decree requirements. Attachment 2 

provides information relevant to the flare's design and performance, and also includes the 

flare manufacturer's specification sheets for the flare tip and pilot assembly. 

6. Description and tech specifications for flare's volumetric flow rate meter and/or 

any on /off- indicators. 

The MCU Main Flare utilizes a digital ultrasonic flowmeter and data logger to provide 

daily flare volume measurements. Information pertaining to the flare meter is included as 

Attachment 3. 

7. Description and tech specifications of any total sulfur analyzer or heating value 

analyzer already installed. 

As discussed in question No. 7 above, a gas sample is collected monthly for laboratory 

analysis of various parameters, including heat content expressed in Btu/ideal ft3and 

Btu/real ft3,A copy of the most recent analytical report is contained in Attachment 4. 

WORK PRACTICE DESCRIPTION - We understand some of these may be less/not 

applicable. 

1. Any audits of vent gas recovery capacity? 

No. See responses to Data Clarification questions 3 and 4, above. 

2. Any acoustical or temperature leak survey of pressure relief devices connected 

directly to the flare or any other flare tie-in headers associated with the gas 

streams venting to the flare? 

No. Pressure relief valves at the MCU Facility are tested annually in accordance with 

API RP 510 in August and a written test record is maintained. 
Additionally, all pressure vessels, pipeline and equipment at the MCU Facility designed 

for "Maximum Allowable Working Pressure" (MAWP) greater than 15 psi are equipped 

with an ASME coded pressure relief valve sized and set so the MAWP will not be 

exceeded. The pressure relief valves in use at the MCU Facility are designed in 

accordance with the American Petroleum Institute's standard for design and installation 

of pressure-relieving systems in refineries (API RP 520). Pressure relief valves at the 

MCU Facility are tied into the flare system as shown on the flow diagram contained in 

Attachment 1. 

3. Equipment and methodology currently used by Resolute to measure heating 

value. 

No gas analyzer is present. A gas sample is collected monthly for laboratory analysis of 

various parameters, including hydrogen sulfide, hydrocarbon and other compounds, and 

heat content expressed in Btu/ideal ft3and Btu/real ft3-A copy of the most recent 

analytical report is contained in Attachment 4. 

EMISSIONS RELATED - We understand some of these may be less/not applicable. 

1. Plans to install or implement to eliminate or reduce flaring? 

Compressor reliability is the key to reducing flaring events. See data clarification 

response 1, above. During 2007, 2008 and continuing into 2009 Resolute spent 

significant monies to increase the efficiency and effectiveness of the CO2 recycle 

compression. See data clarification response 2, above. Specifically, Resolute: (1) added 

a new 2500 HP electric drive compressor (described in question 2 below); (2) replaced a 

significant amount of Facility piping; and (3) refurbished two main recycle compressors 

(HOS-6 and HOS-4). 

2. By what mechanism or technology does the new electric-powered compressor 

added in 2007 minimize flaring and reduce flare emissions? 

As stated above, increased compressor runtime and efficiency is the only means of 

reducing flare volumes. The 2500 HP electric drive CO2 Recycle compressor (C-5) at the 

MCU Facility incorporates an advanced electronic control system and a variable 

frequency drive (VFD) to control the speed of the unit and maximize runtime. 

Additionally, electric motor drives have reduced downtime for maintenance compared to 

gas-fired compressor engines, (i. e. less need for flaring), and the associated gas-fired 

engine emissions are also eliminated. 

3. What is a gas refrigeration skid? How will the process impact emissions from the 

flare or minimize the duration or frequency of flaring events? 

This question is no longer relevant because Resolute does not have a gas refrigeration 

skid at the MCU Facility and Resolute has no current plans to install one at the MCU 

Facility. Nonetheless, a gas refrigeration skid is typically used for the extraction of 

natural gas liquids. 
Please call me with any questions or if you require additional information. 

Sincerely, 

REs LUTE NATURAL RESOURCES COMPANY % 

~ J 

Patrick E. Flynn 

Environmental Health & Safety Manager 

Certification Statement 

I certify under penalty of law that I have examined and am familiar with the information 

submitted in this document and all attachments and that this document and its attachments 

were prepared either by me personally or under my direction or supervision in a manner 

designed to ensure that qualified and knowledgeable personnel properly gathered and 

presented the information contained therein. I further certify, based on my personal 

knowledge or on my inquiry of those individuals immediately responsible for obtaining the 

information, that the information is true, accurate, and complete. I am aware that there 

are significant penalties for submitting false information, including the possibility of fines 

and imprisonment for knowing and~willful submission of a materially false statement. 

ignature and Date 

Dale E. Cantwell 

Vice President of Operations 
ATTACHMENTI 

MCU FACILITY FLOW DIAGRAM 
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ATTACHMENT 2 

FLARE SPECIFICATIONS 
ZE~G 

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Flare Tip Specification Sheet 

Client: ExxonMobil IZeeco Ref.: 74P20F I Date: 18-Au -05 

LOcation: McEimo Creek, Utah I Client Ref.: Rev. 1 

General Information: 

Tag No.: F-1 

P.fodel: UF 24/26 Type: Utility 

Lerngth: 

WeEght: 926 tbs 

No. of p+tots: 2 

Oesign Case: 

Govern+ng Case: Case 1 

Molecutar weight: 38.3 

L. H. V. : 401 BTUiSCF 

Temperature: 120 deg. F ~ 

Availabte pressure. 16 psig 

Design flow rate: 75,711 Ibs/lv 0 ~ 

Approximate exit velccihy: 63.7 ft/s 

Apprrox. tip press. drop: 0.06 psig 

.~ ~. 

-~ 

(Typicat drawir.g oniy) 

Construction: 

Jpeer Sec;icn 3l0 ss 4Vindshield: No 

t-ower Sec::cn. Carhon Steel Ftame retention Ring: 310 ss 

Refractory None Re:rac:ory T.k: n/a 

Surface Finish (Carbon. Steel Surfaces): 

Surface Preparatier.; SSPC-SP6 Primec Iror;anic Zi- c 

Paink High Heat Alum.inum 

Connections: 

Qty. Size Type Material 

~11 - Flare Gas Intet: 1 2- " 150>± RFSO Carqon Steet 

ti2 •?'!ot Gas Manifold: FNPT Carbcn Steet 

1`43 - I,rition _ine: 2 b1NPT Carbon Steel 

,yliscellaneous Notes: 

Inc!udes Purr,e Red ;,c:nG In:egral Valcc;ty Seai 

2 Required D::r;e Rate = 515 S;:FH 
z~ tjw 

Pre-Mix Flare Pilot Assembly Speci£'ication Sheet 

Client: ExxonMobi! IZeeco Ref.: T4P20F Date: 18-Aua-05 

Location: McEtmo Creek, Utah IClient Ref.: - IRev. 1 

Genoral Information: 

Tag No.: FP-1 

Modet HSLF ` 

Lergth: 9.135 feet -~ .. ~ 

Weight: 68 Ibs. I r 

Pitot Type: Pre-Mix High Stability 

I nition Type: FFG 

Process Design Data: 

Design Heat Release 85000.00 btu/hr 

Fuel Gas N1W 13.00 

Fuel Gas LHV 1,000 blu/scf 

Fuel Gas Temperature 90.0 F t ~ l 

Fuel Gas Inlet Pressure 15.00 psig [ ~✓'' j^ ~ Fuel Gas Flcwrate 65.0 scfh 

Design V'find Velocit: 150 mph 

Design RainfaH: 10.00 inches/hr 

Mcunting Pcsition: Vertica. ~ 

Thermocouple Type hone 

Construction: 

Pilot Firing T:p HK 

h'indshieid Asse r 51y HK _iIntegraf Ther;nowelt HK 

FFG Ignition Line 310 SS 

,Mounting 8 racicets: uK 

Premix Fuel Lire 310 SS 

'hermocoupip Sne3th V!A 

ThermccouQle Head N/A I 

Fuet titixer Assembly CF-8 / 18-8 

Fue( Strair,er Assembiy CF-8110 

HEI Probe and SuGport: N/A 

=iEl Junct!cn Head 'V!A i 

Connections: oty. Size Type Materiai 

C1 - Fue! Gas Inlet 1 ~ 1/2" FNPT CF81M 

C2 - FFG Ignition Inlet 1 1" SW 310 SS 

C3 - Thermoccuple N/A N/A N/A N/A 

C=t - HEI Ignition NiA N/:, N/A N,'A 

Mrsc. Notes. (see ignition s ystem datasheet for tvoe applicable to this quote) 

lpper rcu^:ir.g cr•scket is reinfor.eo 7ccx type `or p lot raciovai frcm plat!orrn 

2 Paot arar,kPts and thermocoupie ~-or.;r•cinc; cmcvacs 3re ;nve:; ~ rrent csst assemtiies. 

3 !s,nvAstment cast higt• e`riciency cernputer modeied •:er.tur. secucrt. 
E~onMobil 

Production 

CERTIFIED MAIL, RETURN RECEIPT REQUESTED 

July 7, 2006 

Drrector, Air Division (AIR-1) 

U.S. Erivironmental Protection Agency, Region IX 

75 Hawthorne Street 

San Francisco, California 94105 

Attention: John Kim 

Subject: United States v. Mobil Exploration and Producing U.S. Inc. 

Civil Action Case No, 2 05-CV-00319PGC 

DOJ Case No. 90-5-2-1-2237 

Entered into on 06/08/2005 

Certification of Main Flare 

Dear Mr. Kim: 

As required by Paragraph 11.c of the Consent Decree in the referenced Civil Action Case United States 

v. Mobil Exploration and Producinq U.S. Inc. , Mobil hereby certifies that the Main Flare is equipped with 

ari autoniatic air-assrsted flare system and is in compliance with all applicable provisions of 40 C.F.R. 

§60.18(c)(1), (c)(2), (c)(3)(ii), (c)(5), (d), (e), (f)(1) through (f)(4), and (f)(6). The new flare tip was installed 

during the week of May 8-12, 2006, which was within 365 days from the Effective Date of the Decree in 

accordance with Paragraph 11.b. Mobil submits this certification within 395 days from the Effective Date 

as required by the Decree. 

Please see the attached document, which shows the Main Flare's compliance with the provisions listed 

above. 

I certify under penalty of law that I have examined and am familiar with the inforrnation submitted in thrs 

document and all attachments and that this document and its attachments were prepared either by rne 

personally or under my direction or supervision in a manner designed to ensure that qualified and 

knowledgeable personnel properly gathered and presented the information contained therein. I further 

certify, based on my personal knowledge or on my inquiry of those individuals immediateiy responsible for 

obtaining the information, that the information is true, accurate, and coniplete. I am aware that there are 

significant penalties for submitting false information, including the possibility of fines and imprisonment for 

knowing and willful submission of a materially false statement. 

If you have any questions, please contact Justin Harrison at 281-654-1127. 

Sincerely, 

.,. 

RJC/ccs 

xc: Patrick E. Flynn 

Environmental Health & Safety Manager 

Resolute Natural Resoiirces Company 

1675 Broadway, Suite 1950 

Denver, Colorado 80202 
bc: Justin Harrison 

Neil Ryan 

Laura Johnson 

Christopher Armstrong 

Mitch Hosman 

Jim Sandy 

Bryari Wesley 

Sharolyn Gales 

Arlene Lee 

Aaron Pina 

Delphine Whitehorse 

Air File Room (MI-P020D) - Greater Aneth / Air / McElmo Creek Unit / Consent Decree 
McElmo Flare Upgrade 

40 CFR Requirement Comment 

60.18(c)(1) Flare shall be designed for and operated with See commerit for 60.18(f)(1) 

no visible emrssrons as determined by the 

methods specified rn paragraph (f), except for 

periods not to exceed a total of 5 minutes 

during any 2 corisecutive hours 

60.18(c)(2) Flare shall be operated with a flame present at Flare is designed and operated with an 

all times, as determined by the methods automatrc ignitor to ensure a flame is present at 

specified in paragraph (f). all times. See comment for 60.18(f)(2). 

60 1£1(c)(3)(ii) Flare shatl be used only with the net heating Please see the attached gas anaiysrs, which 

value of the gas beirrg conibusted be ng 11.2 stiows a representative sample of the gas being 

MJ/scm (300 Btu/scf) or greater if the flare is conibusted. The net heating value typically 

steam-assisted or air-assisted ... The net ranges from 400 - 500 BTUlscf. 

heating value of the gas being combusted shall 

be determined by the methods specified in 

paragraph (f)(3) of this section. 

60 18(c)(5) Air-assisted flares shall be designed and See cornments for 60.18(f)(4) and (f)(6) Actual 

operated with an exit velocity less than the exit velocity < Vmax. 

velocity, Vmax, as determined by the method 

specified in paragraph (f)(6). 

60.18(d) Owners or operators of flares used to comply Operations has and wilt ensure that this flare is 

with the prov srons of this subpart shall monitor operated iri accordance with rnanufacturing 

these control devices to ensure that they are recommendations consistent with the desrgri 

operated and maintained in conformance with 

their designs. Applicable subparts will provide 

provisions stating how owners or operators of 

flares shalt monitor these control devrces 

60.18(e) Flares used to comply with provisions of this Operations has and will ensure that this flare 

subpart shall be operated at all times when will be operated at all times when emissrons 

emissrons may be vented to them. may be verited to them. 

60.18(f)(1) Method 22 of appencix A to this part shall be Method 22 was used to determrne compliance 

used to determine the compliance of flares with with this requirement as specified Please see 

the visible emission provisions of this subpart. the attached observation form. In a 2 hour, 21 

The observatron period is 2 tiours arid shall be minute observal on period, no visrble erniss oris 

used according to Method 22. (Reference were observed. 

60.18(c)(1)) 

60 18(f)(2) The presence of a ffare pilot flame shall be The flare is equipped with a fiame monitor to 

monitored using a thermocouple or any other detect the presence of a flame Due to some 

equivalent device to detect the presence of a reliability issues with the monitor after lhe new 

ftame. (Reference 60 18(c)(2)) `lare tip was rnstalled, we recently replaced the 

nir,r~ ilrx 

~ ----------- _ _ 
POcElmo Flare Upgrade 

40 CFR Requirement Comment 

60 18(f)(3) The net heating value ot the gas being See comment for 60.18(c)(3)( i). 

combusted in a flare shall be calcufated using 

the equation given in 60.18(f)(3) (Reference 

60.18(c)(3)(6)) 

60 18(f)(4) The actual exit velocity of a flare shall be See attached calculations for actual exit vefocity 

determined by dividing trne volumetric flowrate at maximum possible flaring (63.0 ft/s). 

(in units of standard temperature and 

pressure), as determined by Reference 

Methods 2, 2A, 2C, or 2D as appropriate; by 

the uriobstructed (free) cross sectional area of 

the flare tip. 

60.18(f)(6) The maximum permitted velocity, Vmax, for air- See attached calculations for niaximum 

assisted flares shall be determined by the permitted velocity (63 8 fUs) 

equation given in 60.18(f)(6). (Reference 

60.18(c)(5)) 
Process Conditions -- English Units 

Client: ExxonMobil IZeeco Ref.: 15496 1 Date: 9-Jun-06 

LOCation: McElmo Creek, Utah iClient Ref.: PO# 30-52745-OC I Rev. 1 

Mol % L. H. V. Cp (60 F) Cp (300 F) 

Case I M. W. (BTU/SCF) 

METHANE 17.35 16.043 909.1 0,527 0.624 

ETHANE 5.88 30.07 1611.8 0.410 0.543 

PROPANE 5.40 44.097 2316.1 0.389 0.534 

BUTANE 0.23 58.124 3001.1 0.391 0.532 

PENTANE 0.10 72.151 3698.3 0.410 0.528 

HEXANE 0.13 86.178 4403.7 0.443 0.526 

HEPTANE 0.06 100.205 5100.2 0.474 0.525 

OCTANE 0.05 114.232 5796.7 0.449 0.524 

NONANE 128.259 6493.3 0.382 0.523 

DECANE 142.286 7188.6 0.382 0.522 

DODECANE 170.3374 8623.58 0.381 0.521 

TR]DECANE 184.3642 9333.71 0.381 0.521 

CYCLOPENTAtiI: 70.135 3512 0.282 0.352 

ETHYLENE 28.054 1499 0.362 0.478 

PROPENE 42.081 2182.7 0.354 0.473 

BUTENE 56.108 2879.4 0.370 0.493 

ACETYLENE 26.038 1422.4 0.397 0.469 

BENZENE 78.114 3590.7 0.301 0.360 

TOLUEhE 92.141 4273.3 0.348 0.379 

XYLENE 106.168 4958.3 0.350 0.380 

CARBON'vIONOXIDE 28.01 319.8 0.248 0.252 

CARBON DIOXIDE 69.35 44.01 0 0.201 0.254 

HYDROGEN SL`L.FIDE 34.076 588 0.238 0.251 

SULFIiR DIOXIDE 64.059 0.145 0.195 

AMMONIA 17.031 359 0.506 0.556 

A1R 28.964 0 0.240 0.243 

HYDROGEN 2.016 274 3.409 3.462 

OXYGEN 31.999 0 0.219 0.226 

NITROGEN 1.44 28.013 0 0.249 0.250 

WATER 18.015 0 0.496 0.550 

BUTADIENF 54.092 27g9 0.350 0.505 

ME'1'H.AN()L 32 7096 

Total 100 

Mol. wt. 38.3 

L. H. V. (BTU/SCF): 401 

Temperature (Deg. F): 120.0 

Avail. Staiic Pressure (psig). 16.40 

Flow Rate flbs+hry 75,711 

Smokeiess Ftate (tbs/hr). 1 75,711 
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View or download PDF 
FxxonMobil SO I549(, 

Junc 14, 2006 

EYA Conformance Calculations: 7,eeco Flare 1'ip 

Design Conditions: 

Design Gas Case: Gas Case 1 

Molecular Weight: 38.3 

Temperature: 120 ° F 

Flow Rate: 75,711 b/hr 

Lower Heating Value: 401 BtuISCF 

Note: Design condtions are based on flow measurement data provided by ExxonMobil 

Calculations: 

New Flare Tip will be Air Assisted 

According to Section 60.18 (c) (3) the net (lower) heating value must be greater than 300Btu/SCF. 

Current design conditions satisfy this requirement. 

Maximum Exit Velocity, V m ,, for a air assisted flare is calculated in Section 60.18 (f) (6). 

V, = 8.706 + .7084 (H.) 

H, for this case is 401 Btu/SCF = 15.16 MJ/scm 

So, V,nax = 19.45 mis = 63.81 ftis 

Zeeco flare tip is a modi`ed Utility Ffare tip with an open area of 475 in`(3.30 ft 2 )at the exit. 

The maxlmum flowrate for the ftare is 75.711 Ib/hr = 750,000 SCF/hr 

Flare tip open area: Pipe ID: 25.5in 

Flame tab dimension: 2.5in x 1.75in (8 tabs total) 

Area= (25.5/2)2 x7 - 8(2.5 x 1.75) =475in 2 

Exit Velocity at maximum flaring Is = 208 ft 3/s / 3.30 f12= 63.0 fUs 

Coriclusions: 

Maximum Allowable Exit Velocity Per 40 CFR 60.18 = 63.81 fVs 

Exlt Velocity of Zeeco Flare Tip at Maximum Flow = 63.0 ft:'s 

Zeeco flare tip satisfies EPA 40 CFR requirements for exit velocity. 
ATTACHMENT3 

FLARE METER SPECIFICATIONS 
~=; t 

Sensing 

Applications 

The DigitalFlow GF868 flowmeter is a complete 

ultrasonic flow metering system for: 

• Flare gas 

- Track down or prevent losses from leakage with 

positive material identification 

- Account for total plant throughput of material 

- Reduce cost of steam usage with proportional 

control 

- Conserve energy by eliminating unnecessary flaring 

- Comply with government regulations for pollution 

control 

• Vent gas 

Features 

• Measures velocity, volumetric and mass flow 

• Measures instantaneous average molecular weight 

• Measures hydrocarbon gases 

• Minimal maintenance due to no moving ports, no holes 

or tubes, and tolerance to dirty or wet conditions 

• Delivers accurate flow rate, independent of gas 

composition 

• Measures very low to very high velocity 

• Field-proven installation techniques 

• Built-in totalizers 

• Built-in power supply for pressure and temperature 

transmitters 

• 2750 to 1 turndown ratio 

DigitalFl OWTm GF868 

Panametrics Flare Gas Mass 

Ultrasonic Flowmeter 

DigitalFlow GF868 is a Panametrics 

product. Panametrics hasjoined 

other GE high-technology sensing 

businesses under a new nameGE Industrial, Sensing 

GF'x58 

0 
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Sensing 

Flare Gas Mass Flowmeter 

The DigitalFlow GF868 ultrasonic flowmeter uses the 

patented Correlation Transit-TimeT"' technique, digital 

signal processing, and an accurate method of 

calculating molecular weight. Add to these features the 

inherent advantages of ultrasonic flow measurement— 

reliability with no routine maintenance, high accuracy, 

fast response, wide rangeability—and the DigitalFlow 

GF868 flowmeter is the clear choice for flare gas 

applications. 

Patented Molecular Weight 

Measurement Method 

The DigitalFlow GF868 uses a patented method for 

calculating the average molecular weight of 

hydrocarbon mixtures. This proprietary algorithm extends 

the range for measuring average molecular weight, while 

improving accuracy and compensating for 

nonhydrocarbon gases better than ever before possible. 

Higher accuracy mass flow data and more precise 

knowledge of flare gas composition can improve the 

efficiency of plant operation, enabling correct metering 

of steam injection at the flare tip, rapid trouble-shooting 

of leaks into the flare stream, early detection of process 

control problems, and accurate plant balance. 

Best Technology for Flare Gas 

Ultrasonic flow measurement, the ideal technology for 

flare gas applications, is independent of gas properties, 

and does not interfere with the flow in any way. AII-metal 

ultrasonic transducers installed in the pipe send sound 

pulses upstream and downstream through the gas. From 

the difference in these transit times between the 

transducers, with and against the flow, the DigitalFlow 

GF868's onboard computer uses advanced signal 

processing and correlation detection to calculate 

velocity, and volumetric and mass flow rate. 

Temperature and pressure inputs enable the meter to 

calculate standard volumetric flow. For maximum 

accuracy, use the two-channel version and measure along 

~ ••• • 

n Downstreom 

Transducer 

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Transducer Transmitter 

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Tronsmrtter 

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Outputs Preomplifier 

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Typical meter set-up for standard volumetric or steam mass flow. 

two different paths at the same location. The 

two-channel meter can also measure the flow in two 

separate pipes or at two different places on the same 

pipe. 

One Meter, Wide Range of Flow 

Conditions 

The DigitalFlow GF868 meter achieves rangeability of 

2750 to 1. It measures velocities from 0.1 to 275 ft/s 

(0.03 to 85 m/s) in both directions, in steady or rapidly 

changing flow, in pipes from 2 in to 120 in 

(76 mm to 3 m) in diameter. With this range of operation, 

one DigitalFlow GF868 flowmeter performs 

measurements under most of the conditions that may 

occur in a flare line. 

Simple Installation 

The flowmeter system consists of a pair of transducers 

for each channel, preamplifiers, and an electronics 

console. The transducers can be installed as part of a 

flowcell, or directly into the pipe with a hot- or 

cold-tapping procedure. The electronics console of the 

DigitalFlow GF868 meter can be located up to 1,000 ft 

(300 m) from the transducers. 

91 Diagonal MidradiusBias 91 91 :1 Diagonal Pipe Rack 

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Standord transducer mounting configurotions 
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Sensing 

Identify Leak Sources, Reduce Steam 

Usage and Improve Plant Material 

Balance 

Leaks and excess steam delivery are two major causes of 

loss of product and energy. Reducing them immediately 

improves the overall efficiency in refinery and chemical 

plant operation. Payback for the entire DigitalFlow GF868 

installation usually occurs within a matter of months. In 

the long term, the DigitalFlow GF868 can help save 

millions of dollars in reduced losses. 

Once the sound speed of the gas has been determined 

by the DigitalFlow GF868, its on-board computer uses 

temperature and pressure inputs in conjunction with the 

sound speed to calculate instantaneous average 

molecular weight and mass flow rate of the gas. These 

parameters are used to help identify sources of leaks 

into the flare system. Detection of even a small increase 

in flow rate into the flare system may indicate a leak 

source such as partially unseated relief valve. An 

accompanying change in the average molecular weight 

of the flare gas may be used to help locate the leak 

source. Quick identification and elimination of leak 

sources into the flare system saves significant amounts 

of potentially lost energy and product. 

Mass flow rate may be used to perform a mass balance 

calculation and to control flare tip steam injection. By 

knowing the exact amount of gas flow and average 

molecular weight in the flare stack, delivery of the 

correct amount of steam required at the flare tip can be 

accurately controlled. Steam usage can be reduced 

while maintaining compliance with pollution control 

regulations. 

Correlation Transit-Time 

Technology Is Ideal for Flare Gas Flow 

Measurement 

The DigitalFlow GF868 uses the patented Correlation 

Transit-Time technique that has distinct advantages over 

other methods of flare gas flow measurement, and it is 

used to solve a variety of difficult problems. Typically, 

gas in flare stacks, headers or laterals, is a mixture of 

components from different sources. Flow rate in flare 

systems may be unsteady or even bidirectional. Pulsating 

pressure, varying composition and temperature, harsh 

environment, and wide flow range further complicate the 

measurement. The GF868 is designed for superior 

performance under these conditions. 

Designed for Flare Gas Environment 

The DigitalFlow GF868 flowmeter has no moving parts to 

clog or wear out. Its patented ultrasonic transducers are 

constructed of titanium or other metals that withstand 

the corrosive environment usually found in flare gas 

applications. The transducers are designed for use in 

hazardous locations. Wide rangeability allows 

measurement of flow rate from 0.1 up to 275 ft/s 

10.03 to 85 m/sl. In contrast to thermal flowmeters, the 

ultrasonic transit-time technique does not depend on the 

heat transfer coefficient of the flare gas and does not 

require regular maintenance. These and other features 

make the DigitalFlow GF868 unique among flare gas 

flowmeters. 
~ E 

Sensing 

G F868 

Specif ications 

Operation and Performance 

Fluid Types 

Flare and vent gases 

Pipe Sizes 

2 in to 120 in NB (50 mm to 3,000 mm) and larger 

Pipe Materials 

AII metals. Consult GE for other materials. 

Flow Accuracy (Velocity) 

• One-path measurement: ±2% to 5% of reading at 

±1 to 275 ft/s (±0.3 to 85 m/s) 

• Two-path measurement: ±1.4% to 3.5% of reading at 

±1 to 275 ft/s (±0.3 to 85 m/s) 

Molecular Weight Accuracy (Hydrocarbon Mixtures) 

MW 2 to 120 gr/gr mole/±1.8%, optimizable for other gas 

compositions 

Mass Flow Accuracy (Hydrocarbon Mixtures) 

• One-path: 3% to 7% 

• Two-path: 2.4% to 5% 

Dependent on accuracy of temperature and pressure 

inputs. 

Accuracy depends on pipe size and whether 

measurement is one-path or two-path. Accuracy to ±0.5% 

of reoding may be achievable with process calibration. 

Repeatability 

±1% at 0.5 to 100 ft/s (15 cm/s to 30 m/s) 

Range (Bidirectional) 

-275 to 275 ft/s 1-85 to 85 m/s) 

Rangeability (Overall) 

2750:1 

Specifications assume a fully developed flow profile 

(typically 20 diameters upstream and 10 diameters 

downstream of straight pipe runl and flow velocity 

greater than 1 ft/s f0.3 m/sl. 

Measurement Parameters 

Mass flow, standard and actual volumetric flow, totalized 

flow, and flow velocity 

Electronics 

Flow Measurement 

Patented Correlation Transit-Time mode 

Enclosures 

• Standard: Epoxy-coated aluminum weatherproof 

Type 4X/IP66 Class I, Division 2, Groups A,B,C&D 

FM and CSA 

• Optional: Stainless steel, fiberglass, explosion-proof, 

flameproof 

Dimensions 

• Weight 11 Ib (5 kg) 

• Size(hxwxd)14.24inx11.4inx5.12in 

(362 mm x 290 mm x 130 mm) 

DigitofFlow GF868 fiefd installation on o typicaf flare system. lnsert 

shows tronsducers instaBed on the flore header that leads to the flare 

stack. 
Sensin g 

G F868 

Specif ications 

Channels 

• Standard: One channel 

• Optional: Two channels (for two pipes or two-path 

averaging) 

Display 

Two independent software-configurable 64 x 128 pixel 

backlit LCD graphic displays 

Keypad 

39-key tactile-feedback membrane 

Power Supplies 

• Standard: 100 to 130 VAC, 50/60 Hz or 200 to 265 VAC, 

50/60 Hz 

• Optional: 12 to 28 VDC, ±5% 

Power Consumption 

20W maximum 

Operating Temperature 

-4°F to 131°F (-20°C to 55°C) 

Storage Temperature 

-67°F to 167°F (-55°C to 75°C) 

Standard Inputs 

Two isolated 0/4 to 20 mA inputs (121 S2) with integral 

24 VDC power supply 

For required temperature and pressure inputs 

Standard Outputs 

• Six 4 to 20 mA outputs, software assignable two 

outputs for 550 0 maximum load 

• Four outputs for 1000 0 maximum load. 

- Analog input board with two isolated 4 to 20 mA 

inputs and 24V loop power 

- RTD input board with two isolated, 

three-wire, RTD inputs; span -148°F to 662°F 

(-100°C to 3500C); 100 0 Pt 

• Totalizer/frequency outputs: Select up to three 

totalizer/frequency output boards, each with four 

outputs per board, 10-kHz maximum. AII boards allow 

software-selectable functioning in two modes: 

- Totalizer mode: Pulse per defined unit of parameter 

(e.g., 1 pulse/ft3 ) 

- Frequency mode: Pulse frequency proportional to 

magnitude of parameter (e.g., 10 Hz = 1 ft 3/h) 

• Alarm relays: Select up to two boards of one of the 

following types: 

General purpose: Relay board with three Form C 

relays; 120 VAC, 28 VDC maximum, 5A maximum; 

DC 30W maximum, AC 60 VA 

Hermetically sealed: Relay board with three 

hermetically sealed Form C relays; 120 VAC, 28 VDC 

maximum, 2A maximum; DC 56W maximum, 

AC 60 VA 

Digital Interfaces 

• Standard: RS232 

• Optional: RS485 (multiuser) 

• Optional: HART' protocol 

• Optional: Modbus'• RS485 or TCP protocol 

• Optional: Ethernet TCP/IP 

• Optional: OPC server 

• Optional: Foundation fieldbus 

Site Parameter Programming 

Menu-driven operator interface using keypad and "soft" 

function keys 

Data Logging 

Memory capacity (linear and/or circular type) to log more 

than 43,000 flow data points 

Display Functions 

Optional Inputs/Outputs • Graphic display shows flow in numerical or graphic 

There are four additional slots available for any format 

combination of the following 1/0 boards: • Displays logged data and diagnostics 

• Analog outputs: Select up to three additional output European Compliance 

boards, each with four isolated 0/4 to 20 mA outputs, Complies with EMC Directive 89/336/ 

1 kS2 maximum load EEC, 73/23/EEC LVD (Installation Category II, Pollution 

Degree 2) and PED 97/23/EC for DN<25 

• Analog inputs: Select up to three boards of one of the 

following types: 
Sensing 

G F868 

Specif ications 

Wetted Flow Ultrasonic Transducers 

TransducerType 

• Standard: T5 

• Optional: Other types available upon request 

Temperature Ranges 

• Standard: -94°F to 300°F (-70°C to 150°C) 

• Optional 

- High temperature: -94°F to 536°F (-70°C to 280°C) 

- Low temperature: -364°F to 248°F (-220°C to 120°C) 

Pressure Range 

0 to 1500 psig (1 to 105 bar) 

Transducer Materials 

• Standard: Titanium 

• Optional: Monel° or Hastelloy® alloys 

Process Connections 

Flanged and compression fittings 

Mountings 

Flanged flowcell, hot tap or cold tap 

Area Classifications 

• Standard: General purpose 

• Optional: Weatherproof Type 4X/IP65 

• Optional: Explosion-proof Class I, Division 1, 

Groups C&D 

• Optional: Flameproof 

1 112 G EEx d IIC T6 

Transducers and flowcells for specific applications are 

available. Consult GE for details. 

Inside view of o Bios 90 flare gos instollotion 

Transducer Cables 

Standard: One pair of coaxial cables, type RG62 AU, or 

as specified for transducer type 

Optional: Lengths to 1000 ft(330 m) maximum 

Pressure and Temperature 

Transducers 

Available upon request. 

Additional Options 

PanaVieWTM PC-Interface Software 

The DigitalFlow GF868 communicates with a PC through 

a serial interface and Windowsm operating systems. 

Consult the manual for details on sites, logs and other 

operations with a PC. 
Sensing 

Spoolpiece 

• Best/preferred solution 

• New build 

• Planned shutdown 

Hot/Cold Tap 

• Large lines 

• New build-shutdown/turn around 

• Retrofit 

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Hybrid Clamped "Tee" 

• Retrof it 

• No welding 

• Special requirements 

0 W271 C E 

02008 GE. AII rights reserved. 

920-009C 

AII specifications ore subject to chonge for product improvement without notice. 

, DigitalFlow'" Correlation Transit-Time*" are trademarks of GE. GE® is o registered 

trademark of Generol Electric Co. Other compony or product names mentioned in 

this document may be trademarks or registered trodemorks of their respective 

companies, which ore not affiliated with GE. 

www.gesensing.com 
ATTACHMENT 4 

EXAMPLE MON1'I ILY GAS ANALYSIS REPORT 
EMS USA 

Diablo Analytical BTU Report 

GPA 2145-03 Analysis 

Sample Information 

--- 

; Sample Information 

Sample Name *Reprocessed: RNRC MCU PLANT INLET 

Meter Number 

Method Name BTEX 

Injection Date 5/6/2009 1:53:02 PM 

Report Date 05/06/2009 02:09:03 PM 

BTU Settings File GPA 2145-03_BTEX.cfg 

Data Source Cerity data system connection 

' Instrument G2801AGC - CN10752004 

LData Saved To: RN RC MCU PLANT INLET-20090506-140903.btu 

Component Results 

Component Normalized Heating Value Molar Mass GPM (Gal. / 

Name Ret Time . Peak Area Mole% (Btu / cu. ft.) Ratio (G) 1000 Cu. Ft.), 

Nitrogen 0.818 1547 0.163 0.000 0.0016 ~ 

Methane 0.401 127675 20.365 205.689 0.1128 

~ Carbon Dioxide 0.501 617441 63.384 0.000 0.9632 

I Ethane 0.606 68503 6.719 118.905 0.0698 1.7916 

Hydrogen Sulfide 0.946 613 0.064 0.407 0.0008 

' Propane 1.653 56199 4.797 120.709 0.0730 1.3178 

n-Butane 0.368 85684 1.932 63.019 0.0388 0.6076 

i-Butane 0.349 22308 0.605 19.686 0.0121 0.1975 

n-Pentane 0.452 31924 0.541 21.702 0.0135 0.1956 

i-Pentane 0.428 23962 0.442 17.671 0.0110 0.1613 

Hexanes Plus 1.908 51885 0.814 41.759 0.0262 0.3524 

Benzene 0.766 3394 0.064 2.410 0.0017 0.0180 

Ethyl Benzene 1.727 191 0.003 0.150 0.0001 0.0011 

o-Xylene 1.925 590 0.010 0.503 0.0004 0.0037 

m,p-Xylene 0.000 0 0.000 0.000 0.0000 0.0000 

Toluene i 1.182 2749 0.049 2.203 0.0016 0.0164 

Oxygen 0.000 0 0.000 0.000 0.0000 

Helium 0.618 495 0.047 0.000 0.0001 

Total: 100.000 614.812 1.3266 4.6629 

Results Summary 

Result Dry 

Total Unnormalized Mole%o 97.505 

Pressure Base (psia) 14.696 

Gross Heating Value (Btu / Ideal cu. ft.) 614.812 

Gross Heating Value (Btu / Real cu. ft.) 618.663 

Real Relative Density 1.33442 

Gas Comqressibilitv (Z) Factor 0.99377 

05/06/2009 Our Success Starts and Ends with Safety Page 1