# 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 theneeded 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` a and 4 t ' 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 

## ft 3 and Btu/real 

## ft 3, 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 

## ft 3 and Btu/real 

## ft 3- 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

## e n = F 4 O ' f

'
~ 

## _ 6 ~ F

~ 

## _ 3
m _ u E

e ~ j
, z

~ 0

~ 

## m 5

c6 ~ ~ rcLL
K ~

~ ~

~

F E ~ ,~



### ~ & E'S 

### ~~ ' 

### ~ Sd 

### sa a'



### , a~

~ z

_ 

### ~;

-prox p P

~ d

~ ovn, 5 -



## ~

~

i i 

### ~''~~

+Q 

## ~ ' u



### ~ ~ , —• s >mxw . °x+°^s

~ s ° t e

- ~ K4

~ f



## Y .- q 

# ~ '

__ r

,~~ - -

~ swc

~ s

~a~m~~ >n+x

~ orma ~~ wu a ~~c~w~'

~ .> mvu m ~ +nswt ~ <w ffi

~ . 'q. <3'

_

~ 

## ri - -

~ ww

~ s<wu ~ ~~ sn,swc

~ x ~ ~ TM, wc

~ s ++

~ isrr:

~ x ~ wr~ x Nns we

~ s ~ 

### - — -- M ,, ~ 

### , ,. a .

_ ~ __ '' - 

### ~ a € i 

### ~

_ r ;

_ 

### ~~ . 6 ~4T~ '~S ~ ~~~xw!~ ^S Wi

~ 'xwnm5 a19^eSwY ~ nS MT

~~ xw`m ~6 ~ g

+~ +5{a[ +Y•' ~S~
~~ xM + ~ SM

~~ xP4 S 

# ~ ~

-~ 

### ° . 4 ! i

. ~ N _ ~~ _ ~~~ 

### ,Mx U ~,.~ 

### _ M

~~ t 

### m ,

~ 

### g <

~~

~



### ¢

~ S 9
~, ~ ~

~ 4 U' 2

2~ < j a ~ ~ z p

~ ~ ~ 3 c e ~ z !~ '~

9 -

~ 

## i " " ^ a :

~~ ~ 8 ~ ~ z



### ~ a ~ ~ ~

## ATTACHMENT 2
FLARE SPECIFICATIONS

### ZE

~ G F 

### < 

## 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~ 

# t j w 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-81 1 0 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 Explo ratio n and P roducin g 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 80202bc: 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 DecreeMcElmo 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 75,711Fl:',".:TTVE t;R S•OYE 1;M;SSIONI

- NST'F:

- - TTO,'JOUTITX%OR LocTtT;IDN -oi, '~ %bservei 

### .
, ipany LoCaL 4 C-n N(EIML I coripail l " , RC*P-. ditic Ill



### y Wind lnduuLry P 

### rc r o p s Un i t
~ 

## M,
SXetch rrocemv iinit: Imlicate ChUCrl,'(.Ir PVU:AlC;1% LQ'laL:.%'e to vot4rt

- Q; 1ndlc-.%ZQ P , :)Lcntidl eirist31-7 7

- --inr6

IV

PA C! r ,r Mv., 'T 57 /gm



### I9L. Iom 

## 1 57" fnn 

## Le , L

- j5 j 4m, 1.
C , m



## S efL Ivl) F-gure



### View or download PDFFxxonMobil 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 f1 2 = 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 sensingbusinesses under a new nameGE Industrial, Sensing 

# GF'x58 

# 0~ 

### E



# 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 

### tt .



# ~ Upstreom t/ E/ Pressure Transducer Transmitter

L I Temperoture

Tronsmrtter

Digitol Anolog 

## ~ ~ .3i 3i ond Alorm 

# ~~ Outputs Preomplifier



## - -- _-_ - 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 Ra 

### ck 

## I

- ~ ~ ~ ~, '~k~ '~ ,4 ~• 

## ~ '` T - — 

## ~- ~..~..~.~.~_.~~ •

Standord transducer mounting configurotions

## ~ 

# E

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 350 0 C); 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/ft 3 ) - 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 , 

### ~ . .

.„ .

~ 1 •. y i ~ . , ~ 

# ' MY

~ 

# A 16 — -- ~ , t 

# ~~ ~

# ►

. , : n

~ s ~

- - - ----

# Sensing

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 REPORTEMS 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 L Data Saved To: RN RC MCU PLANT INL ET-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