Loading...
HomeMy WebLinkAboutClover 2-29HZ Pad and Production Facility - Air Monitoring Program/Report - Kerr McGee - 1/10/2024 Chad Schlichtemeier HSE Rockies Subject: Oil and Gas Monitoring Plan Approval For: Oil and Gas Parent Well Code: 11230512399906 Oil and Gas Company Name: Kerr-McGee Oil and Gas Onshore, LP Oil and Gas Site Name: Kerr-McGee: Clover Kerr-McGee Oil and Gas Onshore, LP Letter Sent by Email: Chad Schlichtemeier@oxy.com Dear Mr. Schlichtemeier, The Air Pollution Control Division has received the oil and gas site ambient air monitoring plan for: Parent Well Code: 11230512399906 Date of This Letter: 1/10/2024 The Air Pollution Control Division has received the Regulation 7 oil and gas air monitoring plan for the Kerr-McGee Clover facility. We have the following comments. 1. A local government comment period was held for Weld County, the Town of Firestone, and the ECMC. It ran from December 18, 2023 – January 8, 2024. None of these entities submitted comments or concerns. 2. The API codes for these wells are not yet available. A temporary Parent Well Code of 11230512399906 has been assigned. A permanent code will be assigned in the future. 3. The plan notes that there will be sound walls. It would be very helpful if the monthly monitoring reports could identify whether the walls are in-place, or not, during that reporting period. 4. The plan is now approved. Sincerely, Copies to: Nancy D. Chick Physical Science Researcher Air Pollution Control Division Local Government Agency Name Contact First Name Contact Last Name Contact Email Address Weld County Jason Maxey Jmaxey@weldgov.com Weld County Dan Joseph djoseph@weldgov.com Weld County Lauren Light llight@weldgov.com Weld County Ryan Fernandez rfernandez@weldgov.com Town of Firestone Pam Howard phoward@firestoneco.gov December 14, 2023 Kerr-McGee Oil & Gas Onshore LP 1099 18th Street Denver, CO 80202 720-929-6000 Nancy D. Chick Physical Science Researcher CDPHE 4300 Cherry Creek Drive S. Denver, CO 80246-1530 Marty Ostholthoff - LGD and Planning Manger 151 Grant Avenue P.O. Box 100 Firestone, CO 80520 Mr. Jason Maxey OGED Director and Local Government Designee Oil & Gas Energy Department 1301 N. 17th Ave. Greeley, CO 80631 Re: Air Monitoring Program: Clover 2-29HZ Pad and Production Facility Weld County, Colorado Per CDPHE Regulation 7 VI.C.1.b.(iv), Kerr-McGee is providing the air monitoring plan for this location. The HSE Air Monitoring Program provides the overall monitoring plan guidelines for air monitoring at pre- production operations and production facilities. Specific guidelines for the Pad and Production Facility are addressed in the Air Monitoring Location Details. As outlined in the regulation, CDPHE will consult with Local Governments as part of their review. If you have any questions, please contact Chad Schlichtemeier at Chad_Schlichtemeier@oxy.com. Air Monitoring Location Details CLOVER 2-29HZ PAD Weld County, Colorado December 14, 2023 Chad Schlichtemeier Oxy HSE Kerr-McGee Oil & Gas Onshore LP 1099 18th Street Denver, CO 80202 720-929-6000 Kerr-McGee Air Monitoring Program Page 2 Air Monitoring Location Details Clover 2-29HZ Pad TABLE OF CONTENTS 1. Company contact ................................................................................................................ 3 2. Location .............................................................................................................................. 3 3. Local Government and ECMC Coordination ....................................................................... 3 4. Pre-Production and Production Facility Schedule: .............................................................. 4 5. well api numbers ................................................................................................................. 5 6. Monitoring Objectives ......................................................................................................... 5 7. Monitoring Site Plan ............................................................................................................ 6 8. Attachments ........................................................................................................................ 9 Kerr-McGee Air Monitoring Program Page 3 Air Monitoring Location Details Clover 2-29HZ Pad 1. COMPANY CONTACT  The owner or operator name and the contact information of the owner or operator representative for monitoring purposes (Reg. 7 VI.C.1.b.(i)) o Owner/Operator:  Kerr-McGee Oil &Gas Onshore, LP o Air Monitoring Contact:  Chad Schlichtemeier Oxy USA Inc. 1099 18th Street Denver, CO 80202 (720) 929-6867 Chad_Schlichtemeier@Oxy.com 2. LOCATION  Pad Name(s)  Clover 2-29HZ Pad  Activity type o Production Rig Drilling o Completions Operations o Production Facility Operations  Location Latitude Longitude o Clover 2-29HZ Pad 40.114788 -104.911843 o NW 1/4 NE 1/4 29 2N 67W 6 PM 3. LOCAL GOVERNMENT AND ECMC COORDINATION  Owners or operators must submit an air quality monitoring plan to the Division and the local government with jurisdiction over the location of the operations and any other local government unit, where applicable, within 2,000 feet of the proposed operations at least sixty (60) days prior to beginning air quality monitoring. Upon the request of any of these local government units within 14 days of receiving the plan, the Division will consult with them as part of its review process. (Reg. 7 VI.C.1.b.(iv)) Kerr-McGee Air Monitoring Program Page 4 Air Monitoring Location Details Clover 2-29HZ Pad o As shown on the attached map, local governments with 2,000 feet  Town of Firestone Marty Ostholthoff - LGD and Planning Manger mostholthoff@firestoneCO.gov 151 Grant Avenue P.O. Box 100 Firestone, CO 80520  Weld County Jason Maxey - OGED Director and Local Government Designee jmaxey@weldgov.com Oil & Gas Energy Department 1301 17th Ave. Greeley, CO 80631  Whether the local government with jurisdiction over the location of the operations has air quality monitoring requirements applicable to pre-production and/or early production operations, a description of those requirements, and a local government contact for air quality monitoring purposes. (Reg. 7 VI.C.1.b.(iv)) o Weld County has jurisdiction over the location and do not have specific air quality monitoring requirements in their code.  ECMC Coordination o Indicate if the ECMC permit required coordination with CDPHE. (yes or no) o Indicate if the ECMC permit requires air monitoring (yes or no)  Federal Lands o Indicate if the project will involve federal lands or minerals. (yes or no) 4. PRE-PRODUCTION AND PRODUCTION FACILITY SCHEDULE:  The planned schedule for drilling and completions operations at the monitoring locations. (Reg. 7 VI.C.1.b.(ii))  Tentative Schedule Clover 2-29HZ Pad Production Drilling Completions Production Facility Air Monitoring Start Finish Start Finish Start Start Finish 6/15/24 8/17/24 9/30/24 1/16/25 1/17/25 5/20/2024 7/19/25 o Air monitoring equipment may be removed in between production drilling and completions operations. o Actual dates will be provided in the monthly reports Kerr-McGee Air Monitoring Program Page 5 Air Monitoring Location Details Clover 2-29HZ Pad 5. WELL API NUMBERS  The operations to be monitored including the API number of the well(s), location of the operations including latitude and longitude coordinates, and any associated facility or equipment AIRS number(s). (Reg. 7 VI.C.1.b.(iii)) Well Name API Latitude Longitude CLOVER 29-8HZ Not Available 40.114788 -104.911843 CLOVER 29-9HZ Not Available 40.114771 -104.911794 CLOVER 29-4HZ Not Available 40.114854 -104.912039 CLOVER 29-5HZ Not Available 40.114838 -104.91199 CLOVER 29-6HZ Not Available 40.114821 -104.911941 CLOVER 29-7HZ Not Available 40.114805 -104.911892 CLOVER 29-12HZ Not Available 40.114722 -104.911646 CLOVER 29-1HZ Not Available 40.114904 -104.912186 CLOVER 29-2HZ Not Available 40.114888 -104.912137 CLOVER 29-3HZ Not Available 40.114871 -104.912088 CLOVER 29-10HZ Not Available 40.114755 -104.911745 CLOVER 29-11HZ Not Available 40.114738 -104.911696  Well API numbers are not available. The API numbers will be provided in the monthly reports.  Production Facility AIRS number for the permanent water tanks is not available. The AIRS number will be provided in the monthly reports. 6. MONITORING OBJECTIVES  VI.C.1.b.(ix)(E) An explanation of how the number and placement of monitoring equipment will be adequate to achieve the desired air quality monitoring objectives, considering the monitoring equipment’s detection limit and other limitations. (Reg. 7 VI.C.1.b.(ix)E) o Section 7 in the Kerr-McGee Air Monitoring Program _June 2021 (Program) describes how the program will achieve the air quality monitoring objectives. Attached are site plans (Figures 1 - 3) for the monitoring equipment setup during production drilling, completions operations and after the last well is turned over to production starting the six (6) months of production facility monitoring for this location. The production facility monitoring setup reflects the design of the facility. See Section 5 of the Program for more information on the design of the production facility. Kerr-McGee Air Monitoring Program Page 6 Air Monitoring Location Details Clover 2-29HZ Pad 7. MONITORING SITE PLAN o Monitoring site plan (Reg. 7 VI.C.1.b.(ix))  VI.C.1.b.(ix)(A) The number of monitors and/or sensors to be deployed. (Reg. 7 VI.C.1.b.(ix)A) o Production Drilling (See Figure 1):  PID analyzers: Four (4) analyzers will be sited around the pad and production facility. See Section 9.1 in the Program for details on the analyzers.  Carbon Sorbent Tubes: Eleven (11) will be sited around the pad in addition co-located with PID analyzers. See Section 9.2 in the Program for details on the carbon sorbent tubes.  SUMMA® canisters: Will be deployed as outlined in the Program. See Section 9.3 in the Program for details on the canisters.  Meteorological Station: One station will be co-located with a PID analyzer. See Section 9.4 in the Program for details on the station. o Completions Operations (See Figure 2):  PID analyzers: Four (4) analyzers will be sited around the pad and production facility. See Section 9.1 in the Program for details on the analyzers.  Carbon Sorbent Tubes: Eleven (11) will be sited around the pads and production facility in addition co-located with PID analyzers. See Section 9.2 in the Program for details on the carbon sorbent tubes.  SUMMA® canisters: Will be deployed as outlined in the Program. See Section 9.3 in the Program for details on the canisters.  Meteorological Station: One station will be co-located with a PID analyzer. See Section 9.4 in the Program for details on the station. o Production Facility (See Figure 3):  PID analyzers: Four (4) will be sited around the production facility. See Section 9.1 in the Program for details on the analyzers.  Carbon Sorbent Tubes: Co-located with PID analyzers. See Section 9.2 in the Program for details on the carbon sorbent tubes.  SUMMA® canisters: Will be deployed as outlined in the Program. See Section 9.3 in the Program for details on the canisters.  Meteorological Station: One station will be co-located with a PID analyzer. See Section 9.4 in the Program for details on the station. Kerr-McGee Air Monitoring Program Page 7 Air Monitoring Location Details Clover 2-29HZ Pad  VI.C.1.b.(ix)(B) The location and height of the monitoring equipment, including for each phase of operations if location and height of the equipment will change (e.g., monitoring placement impacted by sound walls). (Reg. 7 VI.C.1.b.(ix)B) o See attached Figures 1 - 3 for the tentative monitoring locations during Production Drilling, Completions and Production Facility operations. Actual locations of the monitoring equipment may vary from the tentative locations in the Figures 1 - 3 due to access and landowner requests, such as crops. Exact locations of the monitoring equipment will be provided in the monthly reports. o All monitoring equipment will be placed on tri-pods 4 to 7 feet off the ground during each phase of operations. o The pad will have sound walls approximately 32 feet tall. Guidance for air modeling recommends being at least twice the height of the structure to eliminate any influence from the structure. The carbon sorbent tubes and the analyzers will be greater than 100 feet from the wall. SUMMA® canisters will be placed at a carbon sorbent tube or analyzer location. There will be no influence from the sound walls.  VI.C.1.b.(ix)(C) A topographic map and plan of the site, showing the expected equipment layout, including air quality and meteorological monitor locations and their distance from preproduction and production. o See Figures 1 - 3 for monitoring equipment locations and Figure 5 for a topographic map of the area.  Analyzers are generally sited 300 feet from the walls around the preproduction equipment and from the production facility boundary, which is typically identified by a security fence. Monitor locations may be greater than 300 feet from the walls in some directions due to construction of the production facility will be ongoing during production drilling operations, crops and land access restrictions.  Carbon sorbent tubes are generally sited 165 feet from the walls around the pre-production equipment and from the production facility boundary, which is typically identified by a security fence. As discussed for the analyzers, the tube locations may be further from the pad walls in some directions.  Exact locations of the monitoring equipment may vary from the tentative locations in the Figures 1 - 3 due to access and landowner requests, such as crops. Monthly reports for this pad will provide the exact locations of the monitoring equipment. o Equipment Layout  Attached are general layouts of the equipment for Production Drilling, Completions operations and a Kerr-McGee Air Monitoring Program Page 8 Air Monitoring Location Details Clover 2-29HZ Pad Production Facility that is representative of this location. Production Drilling and Completions operations will be conducted inside walls approximately 32 feet high. o The location has no terrain to consider in locating the monitoring equipment as shown in Figure 5. The map must indicate any obstructions to air flow to the monitor(s) and also show all roads and access ways within a half-mile of the facility and any contiguous structures, whether or not they are part of the production operations. (Reg. 7 VI.C.1.b.(ix)C) o Attached Figure 4 shows a half-mile radius around the pads and production facility. There are no obstructions around the pad that will influence the monitors.  A description of how the monitoring equipment, pollutant(s) monitored, and siting plan are expected to detect elevated emissions and achieve at least one of the monitoring objectives listed in Reg. 7 VI.C.1.b.(v). (Reg. 7 VI.C.1.b.(xi)) o Section 9 in the Program details the monitoring equipment to be used at this location and Section 7 in the Program describes how the program will achieve the air quality monitoring objectives. Kerr-McGee Air Monitoring Program Page 9 Air Monitoring Location Details Clover 2-29HZ Pad 8. ATTACHMENTS Clover 2-29 HZ Pad Production Drilling Monitoring Map Sampling Locations Sampling locations are labeled by ID on the map below. 500 ft N Drilling Pad Figure 1 Production Facility Clover 2-29 HZ Pad Completions Operations and Production Facility Monitoring Map Sampling Locations Sampling locations are labeled by ID on the map below. 500 ft N Completions Pad Figure 2 Production Facility Clover 2-29 HZ Production Facility Monitoring Map Sampling Locations Sampling locations are labeled by ID on the map below. Location Tag Monitoring Equipment Tentative Locations Analyzers with Carbon Tubes 300 ft N Figure 3 Production Facility 1000 ft N Well Pad Figure 4 Production Facility Clover 2-29 HZ Pad Completions Pad and Production Facility with Half Mile Radius Monitoring Map Area Map The area encompassing a half mile radius around the facilities is highlighted in black on the map below. Clover 2-29 HZ Pad Topographic Map 1200 ft N Figure 5 Local Governments – 2000’ radius from Clover 2-29Hz Pad General Equipment Layout Production Rig General Equipment Layout Completions Operations: Frac Equipment General Equipment Layout Completions Operations: Flowback and Drillout General Equipment Layout Production Facility 1 – Separators 2 – Bulk Separators 3 – Temporary Water Tanks 4 – Permanent Water Tanks 5 – Emissions Control Device (ECD) 2 HSE Air Monitoring Program Chad Schlichtemeier Oxy HSE June 2021 (Updated QAPP) Kerr-McGee Oil & Gas Onshore LP 1099 18th Street Denver, CO 80202 720-929-6000 HSE Air Monitoring Program January 2021 Page 2 TABLE OF CONTENTS 1. Purpose .............................................................................................................................. 3 2. CDPHE Regulation 7 .......................................................................................................... 3 3. Applicability ......................................................................................................................... 3 4. Monitoring Plan Submittal ................................................................................................... 3 5. Bulk Separator Production Facility ...................................................................................... 3 6. Air Monitoring ..................................................................................................................... 4 6.1 Pre-Operations Monitoring ........................................................................................... 4 6.2 Pre-Production and Production Facility Monitoring ....................................................... 5 7. Monitoring Objectives ......................................................................................................... 5 8. Pollutants Monitored ........................................................................................................... 6 9. Monitoring Equipment ......................................................................................................... 6 9.1 Continuous VOC Analyzer ........................................................................................... 6 9.2 Passive Samplers – Carbon Sorbent Tubes................................................................. 9 9.3 Summa Canisters .......................................................................................................10 9.4 Meteorological Station ................................................................................................10 10. Monitoring Location Setup .................................................................................................11 11. Health Guidance Values ....................................................................................................13 12. Monitor Data and Reporting ...............................................................................................14 13. Operations Records ...........................................................................................................16 14. Investigation Levels ...........................................................................................................16 14.1 Continuous Analyzers .................................................................................................16 14.2 Analytical Data ............................................................................................................17 15. Investigation Level Response ............................................................................................17 15.1 Continuous Analyzer ...................................................................................................17 15.2 Analytical Data ............................................................................................................18 16. Figure 1 – Pre-Production Site Typical Monitoring Configuration .......................................20 17. Figure 2 – Production Facility Site Typical Monitoring Configuration ..................................21 18. Figure 3 – Bulk Separator Facility Typical Layout ..............................................................22 19. Attachments .......................................................................................................................23 HSE Air Monitoring Program January 2021 Page 3 1. PURPOSE This document establishes guidelines for conducting air monitoring around pre-production and production facility activities to protect public health, safety, welfare, the environment, and wildlife resources in accordance with CDPHE Regulation 7. The document will be reviewed periodically and revised if necessary to adapt to changes in technology, operational and monitoring data, and regulatory guidelines. The air monitoring program will be operated on behalf of Kerr McGee Onshore Oil & Gas LP (“Kerr-McGee”) by Montrose Air Quality Services, LLC. 2. CDPHE REGULATION 7 This document follows the requirements set forth in CDPHE Regulation 7 VI.C. For each section, the applicable regulation reference is included in parenthesis as applicable. 3. APPLICABILITY This document provides the overall monitoring plan guidelines for air monitoring at pre- production operations and production facilities. Specific guidelines, as outlined in this document, for the monitoring location are addressed in a document titled “Air Monitoring Location Details.” The Monitoring Plan for each location includes the Kerr-McGee HSE Air Monitoring Program and the Air Monitoring Location Details. (Reg. 7 VI.C.1.) 4. MONITORING PLAN SUBMITTAL The Monitoring Plan will be submitted to CDPHE and Local government with jurisdiction over the location of the operations and any other local government unit, where applicable, within 2,000 feet of the proposed operations at least sixty (60) days prior to beginning air quality monitoring. (Reg. 7 VI.C.1.b.)  Air Monitoring Location Details will include whether the local government with jurisdiction over the location of the operations has air quality monitoring requirements applicable to pre-production and/or early production operations, a description of those requirements, and a local government contact for air quality monitoring purposes. (Reg. 7 VI.C.1.b.(iv)) 5. BULK SEPARATOR PRODUCTION FACILITY CDPHE Regulation 7 requires air monitoring at production facilities during early production. The bulk separator production facilities are designed to minimize or eliminate air emissions. Monitoring data collected during early production will be used to further support the design. Below are the design aspects of facilities focusing on minimizing or eliminating air emissions.  Design o No condensate tanks  Condensate flows from the separator to a pressurize bulk separator into a pipeline. Condensate tanks are the largest source of potential volatile organic compound (VOC) and benzene emissions. This source is eliminated in the bulk separator facility design HSE Air Monitoring Program January 2021 Page 4 o Instrument air  All pneumatic controllers at bulk separator production facilities are operated on instrument air. Natural gas-driven pneumatic controllers can be significant source of VOC emissions, which includes benzene due to the number of actuations and potential malfunctions  Supervisory Control and Data Acquisition (SCADA) o Operating parameters on equipment at the bulk separator facilities are monitored continuously through Kerr McGee’s Integrated Operations Center (IOC). Operating ranges or status are set for equipment to ensure safe operations and also minimizes or eliminate potential air emissions. The IOC is staffed 24 hours a day/7 days a week and can automatically send out notifications alerting an Operator of a trending parameter or initiate engineering controls, which may include shutting in a facility. Below are some of the parameters that are monitored continuously, and the engineering controls. Figure 3 in Section 18 of this document shows a typical Bulk Separator Facility layout and location of the equipment. Equipment Parameter Description Engineering Controls Tanks - Temp and permanent Water Tanks, Maintenance Tank Pressure Monitor tank pressures to prevent over pressurizations causing venting High Pressure - Automation will shut-in facility Liquid Level Monitor liquid level on tanks to prevent spills and venting High Level - Automation will shut-in facility Bulk Separator Pressure Monitor vessel pressure to prevent over pressurization causing venting High Pressure - Automation will shut-in facility Separator Temperature Monitor high/low temperature for safe operations and prevent excess emissions High Temperature - Automation will shut-in separator and well Pressure Monitor vessel pressure to prevent over pressurization causing venting High Pressure - Automation will shut-in separator and well Burner Monitor pilot status to prevent raw gas from being vented Loss of pilot - Automation shuts off pilot valve and main valve. Automation will shut-in well if separator reaches high pressure or low temperature Emission Control Device (ECD) Knock-out Pot Liquid Level Monitor liquid level to prevent liquids from carrying over to the ECD potentially causing smoke High liquid level - Automation will shut-in facility Pilot Light Status Monitor pilot light to prevent venting of unburned hydrocarbons Loss of pilot - Automation will shut-in facility Pneumatic Controllers Air Compressor Status All pneumatic controllers are operated on instrument air. Monitor status of the electric air compressor for safe operation. Air Compressor not operating - Automation will shut-in facility Wellhead Pressure Monitor pressures for safe operation and preventing excess emissions High/Low Pressure - Automation will shut-in well 6. AIR MONITORING 6.1 Pre-Operations Monitoring  At least ten (10) days prior to beginning pre-production operations (Reg. 7 VI.C.1.a.) HSE Air Monitoring Program January 2021 Page 5 6.2 Pre-Production and Production Facility Monitoring  Drilling - Air monitoring conducted during drilling through the hydrocarbon bearing zones (i.e. Production rig drilling) (Reg. 7 VI.C.1.a.)  Completions – Air monitoring conducted during hydraulic fracturing or refracturing, drill-out, and flowback of an oil and/or natural gas well. (Reg. 7 VI.C.1.a.)  Production Facility - Air monitoring conducted for at least six (6) months after the last well on the pad is turned over to production (TOTP). (Reg. 7 VI.C.1.a.)  The Air Monitoring Location Details includes: o The owner or operator name and the contact information of the owner or operator representative for monitoring purposes (Reg. 7 VI.C.1.b.(i)) o The planned schedule for drilling and completions operation at the monitoring locations. (Reg. 7 VI.C.1.b.(ii)) o The operations to be monitored including the API number of the well(s), location of the operations including latitude and longitude coordinates, and any associated facility or equipment AIRS number(s). (Reg. 7 VI.C.1.b.(iii)) 7. MONITORING OBJECTIVES  The purpose of the air monitoring around pre-production and production facility activities is to protect public health, safety, welfare, the environment, and wildlife resources. Kerr Mc-Gee has established Investigation Levels for the VOC analyzers and analytical results with an associated investigation response. See Sections 14 and 15 for more details on Investigation Levels and Investigation Level Response. One component of an Investigation Level Response is an on-site investigation into the cause of the elevated reading. If the source is identified further analysis will be conducted into the cause, which could lead to the reduction in air emissions. Gas streams at pre-production operations and production facilities typically contain methane, VOCs, and BTEX (benzene, toluene, ethyl benzene and xylenes). Any emissions reduction would potentially reduce all listed pollutants. Kerr Mc-Gee’s monitoring objectives covers all three (3) objectives listed below. The monitoring program does not directly monitor methane, but methane is part of the gas stream that is being monitored and, thus, indirectly monitored. Any evaluation for VOCs and BTEX to reduce emissions will in most cases have a corresponding reduction in methane emissions. In addition, Kerr-McGee will review the monitoring program periodically and revise if necessary to adapt to changes in technology and operational and monitoring data. (Reg. 7 VI.C.1.b.(v)) o Detect, evaluate, and reduce as necessary hazardous air pollutant emissions. (Reg. 7 VI.C.1.b.(v)(A)) o Detect, evaluate, and reduce as necessary ozone precursor emissions. (Reg. 7 VI.C.1.b.(v)(B)) o Detect, evaluate, and reduce as necessary methane emissions. (Reg. 7 VI.C.1.b.(v)(C))  The continuous monitoring equipment employed in this program uses photoionization detector (PID) technology. A PID sensor contains a lamp that produces photons HSE Air Monitoring Program January 2021 Page 6 which carry enough energy to break molecules into ions. The PID will only respond to molecules that have an ionization energy at or below the energy of the lamp, the PID used in this program contains a 10.6 electron-volt (eV) lamp. Any VOC that has an ionization energy less than 10.6 eV will be ionized as it passes across the lamp. The produced ions then generate an electrical current that is measured as the output of the detector. While methane has an ionization energy above 10.6 eV, hazardous air pollutants and ozone precursors have an ionization energy below 10.6 eV allowing for detection of elevated emissions. Carbon sorbent tubes and SUMMA® canisters will be used to quantify BTEX emissions. Monitoring equipment will be sited as described in Section 10 and actual locations monitoring location will be included in the site plan as part of the Air Monitoring Location Details. Investigation Levels and Response as described in Sections 14 and 15 are established to protect public health and welfare and to evaluate operations and reduce VOC, BTEX and methane emissions as deemed appropriate. The monitoring program is setup to meet all the objectives in section. (Reg. 7 VI.C.1.b.(xi)) 8. POLLUTANTS MONITORED  Air pollutants monitored at pre-production and production facility operations will include VOCs (continuous analyzers), benzene (carbon sorbent tubes) and BTEX (24- hr SUMMA® Canisters). (Reg. 7 VI.C.1.b.(vi)) 9. MONITORING EQUIPMENT  Below are the monitoring equipment that will be used at pre-production and production facility operations. (Reg. 7 VI.C.1.b.(vii)) 9.1 Continuous VOC Analyzer  SENSIT SPOD Ion Science Photo Ionization Detector (PID) HSE Air Monitoring Program January 2021 Page 7  Lunar Output Canary-S Photo Ionization Detector (PID)  Data Collection o 15-minute block averages based on 1 minute readings  Data Acquisition o Dashboard  Airsense is a web-based system used to acquire, manage, and display real-time air quality data. Site personnel can access all data via a password-protected website for viewing recent data, setting up alerts, conducting analyses, downloading data, building automated reports, and maintaining complete oversight of the network.  Real-time display of monitoring data o 1-minute readings and selected averaging periods (e.g. Investigation Levels)  Notifications o E-mails sent when a monitor reading exceeds an Investigation Levels set in Section 14  Equipment selection description (Reg. 7 VI.C.1.b.(vii)) o The PID technology that will be used for continuous monitoring in this program is a tried-and-true VOC monitoring technology that is approved for use in Leak Detection and Repair programs as described in EPA Method 21 Section 6.1 and as a detector for gas chromatography as described in EPA Method 18 Section 2.0. The PIDs ability to respond to hazardous air pollutants and ozone precursors at low concentrations, consume little power, provide data continuously, and scale across a large network are the reasons why the technology was chosen for this program. The specific instrument models that will be used are the Sensit SPOD and Lunar Outpost Canary-S, though other models may be used if these vendors cannot provide instruments in a timely manner, specifics about these monitors can be found in the attached Quality Assurance Project Plan. The only data correction applied to these units is a linear regression between the sensors raw voltage output and known concentration of calibration gas, as described in the Quality Assurance Project Plan. The operating range for the SPOD and Canary-S unit is 0-40 ppm. HSE Air Monitoring Program January 2021 Page 8  Manufacturer’s Specification Sheets - SENSIT SPOD PID and Lunar Outpost Canary- S PID, See Section 19  Quality Assurance Project Plan – SENSIT SPOD PID and Lunar Outpost Canary-S PID, See Section 19 o The standard operating procedures that will be employed, to include at minimum (Reg. 7 VI.C.1.b.(x)):  The continuous monitors used in this program sample every second, and provide 1-minute averaged data to the data platform. The minimum detection limit and precision is calculated as three times the standard deviation, providing a confidence level of 99.7%, of 7 consecutive 1-minute averages with a 1 ppm isobutylene gas. (Reg. 7 VI.C.1.b.(x)A)  The Investigations and Response Levels for each pollutant monitored and/or sampled and the response procedures or actions that will be taken if elevated levels are observed can be found in Sections 14 and 15. (Reg. 7 VI.C.1.b.(x)B)  Quality Assurance Project Plan includes: o The precision and bias are determined during each monthly calibration, and data quality indicators. (Reg. 7 VI.C.1.b.(x)C) o Quality control and quality assurance procedures, including calibration intervals and frequency, which will be used to ensure proper operations of the monitoring equipment. (Reg. 7 VI.C.1.b.(x)D)  PIDs are known to drift with ambient temperature and humidity variation. The PIDs used in this program mitigate the humidity issue by having a hydrophobic filter installed between the lamp and the ambient air. This deters water molecules from entering the ion producing chamber and absorbing radiation. The PIDs are also heated slightly above ambient temperature to improve stability of the detector. The hydrophobic filters are also known to deteriorate over approximately 6-8 weeks of field use, as part of the Quality Assurance Project Plan these filters are replaced during monthly calibrations. If this filter is not replaced, not only will the humidity interference not be mitigated but dust and dirt can enter the ionization chamber dampening the total VOC readings. (Reg. 7 VI.C.1.b.(x)E)  The data system and operating protocol to be used for data collection, including, but not limited to, data logging, data processing, recording, downloading, backup and storage, and reporting is outlined in Section 12. (Reg. 7 VI.C.1.b.(x)G)  The methods used for collecting and analyzing speciated or other samples of chemical constituents identified by the Division when indicated necessary based on site-specific concentration thresholds, if applicable, can be found in the attached Standard Operating Procedures for Carbon Sorbent Tube and Summa Canister Collection and Analysis in Section 19. (Reg. 7 VI.C.1.b.(x)H) HSE Air Monitoring Program January 2021 Page 9 9.2 Passive Samplers – Carbon Sorbent Tubes  14-day deployment schedule  Analyzed for Benzene  Tubes located around the pad sited and analyzed in accordance with EPA Method 325  Equipment description (Reg. 7 VI.C.1.b.(x)H): o The passive sorbent tube sampling portion of this test program, EPA Method 325A/B entitled “Volatile Organic Compounds from Fugitive and Area Sources” will be followed for both sampling and analysis methodology. o The monitoring program will use passive sampling for Benzene utilizing Carbopack X™ tubes. The tube is a stainless-steel net cylinder, with 100 mesh grid opening and 5.8 mm diameter, packed with 530 ± 30 mg of activated charcoal with particle size 35-50 mesh. Volatile organic compounds are trapped by adsorption. The tube is desorbed using a thermal desorber and the extract is analyzed using GC/MS. Benzene concentrations are calculated using the mass of each compound found, the validated Carbopack X™ uptake rates, time sampled, and average field temperature. o Field-ready passive samplers will be provided by Enthalpy Analytical in a background-free cooler. Tubes will be individually packaged in sealed vials to prevent against contamination. The cooler includes ice packs to keep the sampled tubes cool throughout the shipping process back to Enthalpy for analysis. Enthalpy’s typical schedule is to provide analytical results for the carbon sorbent tubes on a 7-business day schedule.  Standard Operating Procedures for collection and analysis can be found in Section 19 HSE Air Monitoring Program January 2021 Page 10 9.3 Summa Canisters  24-hour time weighted sample  Analyzed according to EPA Method TO-15 o Benzene, Toluene, Ethylbenzene, Xylene (BTEX)  Equipment description (Reg. 7 VI.C.1.b.(x)H): o For the summa canister sampling portion of this test program, EPA Compendium Method TO-15 entitled “Determination of Volatile Organic Compounds (VOCs) in Air Collected in Specially Prepared Canisters and Analyzed by Gas Chromatography/Mass Spectrometry (GC/MS)” will be followed for both sampling and analysis methodology. o Entech Instruments Silonite™ CS1200E Passive Canister Samplers will be used to collect samples over each 24-hour period. The Entech canisters used will be six-liter stainless-steel canisters lined with ultra-inert surface coatings. The canisters will be cleaned and blanked for use according to laboratory standard operating procedures. o The sample inlet height will be approximately one and one half (1.5) meters above ground. o The canister samples will be provided by and shipped to Enthalpy. . Enthalpy’s typical schedule is to provide analytical results for the carbon sorbent tubes on a 7-business day schedule.  Standard Operating Procedures for collection and analysis can be found in Section 19 9.4 Meteorological Station  Co-located with an analyzer  Wind speed, wind direction, temperature, barometric pressure, and relative humidity are monitored at 1-minute frequency (Reg. 7 VI.C.1.b.(viii))  The meteorological equipment installed on the Sensit SPOD units is the Airmar 110WX WeatherStation, and the Lunar Outpost Canary-S uses a RM Young ResponseONE. Both monitors collect wind data via ultrasonic anemometers. The anemometers are installed onsite with the proper side of the anemometer facing North to provide valid HSE Air Monitoring Program January 2021 Page 11 wind direction data. (Reg. 7 VI.C.1.b.(viii))  One meteorological station is co-located and directly tied into a continuous total VOC monitor onsite. The total VOC monitor that is furthest away from any structures that have the potential to interfere with the wind data, and therefore provides the data most representative of site conditions, is chosen to co-locate the meteorological station with. The data from the meteorological station is provided at the same time resolution as the total VOC data and is included in the monitors payload. (Reg. 7 VI.C.1.b.(x)F)  Standard Operating Procedures for the meteorological station can be found in Section 19 10. MONITORING LOCATION SETUP  The monitoring equipment will be placed on tripods and no additional surface disturbance is required for air monitoring, in alignment with the Colorado Oil and Gas Conservation Commission’s site preparation requirements. (Reg. 7 VI.C.1.b.(ix)D)  Drilling and Completions Operations o Monitoring Stations  Continuous VOC analyzers o 4 monitors located roughly in each cardinal direction approximately 300 feet from the pad wall. Depending on locations of building units, occupancy building units or other emission sources, additional monitors may be sited.  Meteorological station (1 per pad) co-located with a monitor o Carbon sorbent tubes  Sited around the Pad approximately 165 feet from wall o Siting is determined based on requirements in EPA Method 325  12 tubes plus duplicate and blank  14-day deployment schedule  Co-located with each monitor o 14-day deployment schedule  Depending on locations of building units, occupancy building units or other emission sources, additional tubes may be sited o SUMMA® canisters  24-hour samples o Monitor readings over Investigation Levels, as needed o SUMMA® canisters will be deployed during different phases based results from the analyzers, carbon tubes and SUMMA® canisters results from previous locations during the same phase. HSE Air Monitoring Program January 2021 Page 12 o Periodic sampling, as needed o Typical site layout in Section 16  Production Facility o Some pads may have more than 1 production facility. The monitoring site plan included in the Air Monitoring Location Details will identify the number and layout of all production facilities associated with the pad. o Monitoring Stations  Continuous hydrocarbon analyzer  Meteorological station (1 per pad)  Monitors in each cardinal direction approximately 300 feet from the facility o 4 total monitors o Carbon sorbent tubes  Co-locate one tube with each monitor  14-day deployment schedule o SUMMA® canisters  24-hour samples  Monitor reading over trigger or action level, as needed  Periodic sampling, as needed o Typical site layout in Section 17  The Air Monitoring Location Details will include: o Monitoring site plan (Reg. 7 VI.C.1.b.(ix))  The number of monitors and/or sensors to be deployed. (Reg. 7 VI.C.1.b.(ix)A)  The location and height of the monitoring equipment, including for each phase of operations if location and height of the equipment will change (e.g., monitoring placement impacted by sound walls). (Reg. 7 VI.C.1.b.(ix)B)  A topographic map and plan of the site, showing the expected equipment layout, including air quality and meteorological monitor locations and their distance from preproduction and production operations. The map must indicate any obstructions to air flow to the monitor(s) and also show all roads and access ways within a half-mile of the facility and any contiguous structures, whether or not they are part of the production operations. (Reg. 7 VI.C.1.b.(ix)C)  An explanation of how the number and placement of monitoring equipment will be adequate to achieve the desired air quality monitoring objectives, considering the monitoring equipment’s detection limit and other limitations. (Reg. 7 VI.C.1.b.(ix)E) HSE Air Monitoring Program January 2021 Page 13 11. HEALTH GUIDANCE VALUES  Health Guidance Values (HGVs): The health-based guidelines are based on Exposures and Health Risks from Volatile Organic Compounds in Communities Located near Oil and Gas Exploration and Production Activities in Colorado published by the Colorado Department of Public Health and Environment (CDPHE) on July 16, 2018, in the International Journal of Environmental Research and Public Health. The CDPHE study identified volatile organic compounds VOCs associated with oil and gas operations through review of previous studies conducted in the state of Colorado.  The HGV for benzene is much lower than other analytes common to the oil and gas industry. Previous air sampling at oil and gas facilities show benzene is the main driver of potential health risk. Focus of the air sampling will be benzene but will include ethylbenzene, Toluene and xylene analysis for some samples. Below are the acute and chronic HGVs for each analyte.  Acute exposure: An acute health exposure is a short-term exposure to a substance that results in biological or physical harm to the person exposed. For example, the 9 ppb acute guideline for benzene is the estimate of the daily human exposure without appreciable risk of adverse, non-cancer health effects over 1 to 14 days of exposure. For comparison to the acute guideline for SUMMA® canisters, 24-hour samples will be taken per recommendation from a Certified Industrial Hygienist. Letter from Kahuna Ventures included in Section 19.  Chronic exposure: A chronic health exposure is a repeated or continuous exposure over a much longer period of time to a substance that results in biological or physical harm to a person exposed. In their study, the CDPHE defined a chronic exposure as a scenario in which a person breathes the outdoor air continuously (24 hours per day, 365 days per year) for a lifetime (average of 70 years) and the measured concentrations of the compounds in the air remain constant over the entire lifetime. Production facilities will be in operation beyond one (1) year. Therefore, the sampling results are compared to the acute and chronic HGVs. The evaluation against the chronic HGVs will be based on the mean of all samples taken.  Pre-production activities (Drilling and Completions operations) will be short in duration (i.e. less than 6 months), the results from each 24-hour SUMMA® canister sample and Analyte Acute Guideline Values Chronic Guideline Values (ppb) (ppb) Benzene 9 9 and 3 Toluene 2,000 1,327 Ethylbenzene 5,000 230 m, p, o -Xylene 2,000 23 HSE Air Monitoring Program January 2021 Page 14 carbon sorbent tube result will be evaluated against the acute HGVs for each compound.  Production facilities will be in operation beyond one (1) year. The sampling results will be compared to the acute and chronic HGVs. The evaluation against the chronic HGVs will be based on the mean of all 24-hour SUMMA® canister samples and carbon sorbent tube results. The evaluation for acute exposure will follow the Pre- production process. 12. MONITOR DATA AND REPORTING  Monitoring Data o The data platform used for this monitoring program, AirSense, does not allow for data to be edited or modified. Users can tag and invalidate data but not directly edit data. In addition, as described in the diagram below, all data sent by instruments are stored in the Raw Database that is only inserted by the API and only can be read by the processor. The Airsense site gives users no direct access to the Raw dDatabase. When calibrating sensors, the data is saved to a new data point leaving both the raw and processed data points. All calibration or scaling adjustments are logged and date-stamped to identify when settings have changed. Even if changes are made, no actual data is modified. These settings allow for scaling and truncating, but the data is never directly modified, they are for viewing and alerting purposes only. All monitors data is delivered to AirSense via cellular communication. The monitors also have local data storage so in the event of a cell tower going down all data collected during that time period can be recovered. All records and documents pertinent to the perimeter monitoring program will be stored indefinitely on back-up computer servers and backed up onto offsite disk storage.  Reporting Monthly reports of monitoring conducted will be submitted to the Division by the last day of the month following the previous month of monitoring (e.g., by June 30 for the previous May 1-31), including (Reg. 7 VI.C.2.b.):  The month and year of the monitoring period. (Reg. 7 VI.C.2.b.(i))  A description of the monitoring equipment and the pollutant(s) monitored. (Reg. 7 VI.C.2.b.(ii)) HSE Air Monitoring Program January 2021 Page 15  A description of the monitored operations including (Reg. 7 VI.C.2.b.(iii)):  The phase of operation (e.g., prior to pre-production, during pre- production operations, early production) and activities occurring during the monitored period. (Reg. 7 VI.C.2.b.(iii)(A))  API number of the well(s). (Reg. 7 VI.C.2.b.(iii)(B))  Location of the operations, including latitude and longitude coordinates. (Reg. 7 VI.C.2.b.(iii)(C))  Any associated facility or equipment AIRS number(s). (Reg. 7 VI.C.2.b.(iii)(D))  The date, time, and duration of any monitoring equipment downtime. Downtime will be considered any 15-minute block average where less than 75%1 of the 1-mintue data points within that block are recorded. (Reg. 7 VI.C.2.b.(iii)(E))  The date, time, and duration of the operations malfunctions and shut-in periods or other events investigated for influence on monitoring. (Reg. 7 VI.C.2.b.(iii)(F))  For the first monthly report after beginning monitoring during preproduction operations, a summary of air quality condition results monitored prior to beginning pre-production operations, including time series of the results at 15- minute block average time resolution and a statistical summary of the air quality results monitored prior to beginning preproduction operations, including number of observations, maximum concentrations or levels, periodic averages, and data distributions including 5th, 25th, median, 75th and 95th percentile values. (Reg. 7 VI.C.2.b.(iv))  A summary of monitored air quality results, including time series plots at 15- minute block average time resolution and a statistical summary including number of observations, maximum concentrations or levels, periodic averages, and date distributions including 5th, 25th, median, 75th and 95 percentile values. (Reg. 7 VI.C.2.b.(v))  A description of responsive action(s) taken as a result of monitoring results, including the date; concentration or level measured; correlations with specific events, activities, and/or monitoring thresholds; and any additional steps taken as a result of the responsive action. (Reg. 7 VI.C.2.b.(vi))  The results of any speciated or other samples of chemical constituents identified by the Division and collected when site-specific concentrations indicate such samples are necessary. (Reg. 7 VI.C.2.b.(vii))  A summary of meteorological data, including in the time intervals identified for concentration readings in this air quality monitoring plan during the time period of responsive action(s). The meteorological data will be assessed in the same intervals as the sampling and/or measurement intervals. (Reg. 7 VI.C.2.b.(viii))  A description of how the only processing and correction that is applied to the raw data is a linear regression that is determined during calibrations. A description of 1 Per EPA’s QA Handbook Volume II, Appendix D, January 2017 common recommendation for data completeness HSE Air Monitoring Program January 2021 Page 16 why any, if any, data is missing and that any data below the detection limit will be reported as the detection limit. (Reg. 7 VI.C.2.b.(ix))  In the last monthly report, a certification by the company representative that supervised the development and submission of the monitoring reports that, based on information and belief formed after reasonable inquiry, the statements and information in the monthly reports are true, accurate, and complete. (Reg. 7 VI.C.2.b.(x))  Recordkeeping The following records will be kept for a minimum of three (3) years, unless otherwise specified, and upon request make records available to the Division. Local governments identified in the Air Monitoring Location Details may request those records from the Division. If the Division has not requested the records and a local government(s) identified in the Air Monitoring Location Details requests the records from the Division, the Division shall request the records from the owner or operator. (Reg. 7 VI.C.2.a.)  The air quality monitoring plan. (Reg. 7 VI.C.2.a.(i))  Monthly reports and the data necessary to inform the monthly reports, as provided in the Reporting Section above. (Reg. 7 VI.C.2.a.(ii))  Activity logs to inform the description of the monitored operations in the monthly report. (Reg. 7 VI.C.2.a.(iii))  At a minimum, for a period of one year after the monthly report, the underlying raw data associated with each monitor. (Reg. 7 VI.C.2.a.(iv))  At a minimum, for a period of one year after the monthly report, the meteorological data in the time intervals as close to the sampling and/or measurement intervals as possible. (Reg. 7 VI.C.2.a.(v)) 13. OPERATIONS RECORDS  During air monitoring operations, daily activity will be recorded at the facility. 14. INVESTIGATION LEVELS 14.1 Continuous Analyzers  At previous pre-production monitoring locations with air monitoring, co-located benzene and VOC data were collected. In comparing the data, the VOC ppm to benzene ppb correlation is approximately 1 ppm VOC = 1 ppb benzene. This correlation will continue to be updated as more data is gathered. Kerr-McGee has established three Investigation Levels that equate to benzene levels well below the 9 ppb guideline value, but at levels previous monitoring indicate a potential change in emissions at the location. o Level 1  15 minute VOC block average (based on 1 minute readings) over 3 ppm VOC o Level 2  2 readings over Level 1 reading in a 2 hour period  15-minute VOC block average (based on 1-minute readings) reading over 5 ppm VOC HSE Air Monitoring Program January 2021 Page 17 o Level 3  12-hour average readings (based 15-minute block averages) over 2 ppm VOC 14.2 Analytical Data  SUMMA® canister o Level 2  24-hour result greater than 9 ppb benzene o Level 3  Subsequent 24-hour results greater than 9 ppb benzene  Carbon sorbent tubes o Level 3  14-day average result greater than 9 ppb benzene o Data and Operations Review  14-day average result greater than 2 ppb benzene 15. INVESTIGATION LEVEL RESPONSE 15.1 Continuous Analyzer  Investigation responses will be coordinated through Kerr McGee’s Integrated Operations Center (IOC). o The air monitoring program will be operated by Montrose Air Quality Services, LLC. Airsense software will be used to manage the data from the monitors. In the event there is a monitor reading above an Investigation Level, an e-mail notification will be sent to the IOC. o Monitor readings greater than the Investigation levels will require an investigation into the potential cause(s) of the high reading(s) including any corrective action, as necessary. o Responsibilities during an investigation response:  IOC: o Notify the monitoring location (Drilling or Completions) of the elevated reading requiring an immediate investigation. o Notification of event sent to internal distribution list including management and HSE o Document event and send out follow-up notifications o Levels 2 and 3 – Dispatch IR team to location for inspection. o Level 3 – Notify HSE  Monitoring location: HSE Air Monitoring Program January 2021 Page 18 o As soon as it is safe conduct an on-site investigation  Report investigation findings and any corrective action to IOC o Formal Incident response from facility within 24 hours  IR team (Levels 2 and 3) o Conduct IR inspection at monitoring location  Contact IOC after completion of inspection to report findings  If abnormal emissions noted contact monitoring location  HSE o Level 1 or 2 - Evaluate the need for 24-hour SUMMA® canister sampling. o Level 3 – Deploy 24-hour SUMMA® canister sampling within 24 hours of receiving the final results.  4 SUMMA® canisters in each cardinal direction at monitor location or other locations, as deemed appropriate  Sample(s) analyzed EPA Method TO-15 for BTEX o Review monitoring data, meteorological data, distance to nearest downwind receptor o Review investigation findings and make any necessary notifications. o Level 3  Activate Emergency Response Team (ERT). The ERT includes:  President & General Manager  Director Operations  Director HSE  Director Drilling Completions and Well Servicing  Director Regulatory  Director Communications and Public Affairs  Managing Counsel  ERT will evaluate facility operations to ensure protection of public health and welfare o COGCC, CDPHE, and Local Government with jurisdiction over the location of the operations, will be contacted within forty-eight (48) hours of receiving notification of Level 3. (Reg. 7 VI.C.1.b.(ix)B) 15.2 Analytical Data  SUMMA® canisters and carbon sorbent tubes samples will be sent to a lab to be analyzed. If results show a benzene level over an Investigation Level, the Investigation Response process is as follows: HSE Air Monitoring Program January 2021 Page 19 o 24-hour SUMMA® canisters less than 9 ppb benzene, Kerr McGee will follow the Investigation Response for the continuous analyzers in Section 15.1, as appropriate. o 24-hour sample - SUMMA® canister greater than 9 ppb benzene  Level 2 Investigation response for continuous analyzers in Section 15.1  Follow Agency for Toxic Substances and Disease Registry (ATSDR) guidance o The acute inhalation MRL for benzene is 9 ppb. An MRL is a health-based value developed to protect the health of the general population. MRLs are derived for acute (1 to 14 days), intermediate (>14 to 364 days), and chronic (365 days and longer) exposure durations. MRLs are intended to serve as a screening tool to help professionals decide if to conduct additional investigations  Conduct additional 24-hour SUMMA® canister sampling o 4 – SUMMA® canister in each cardinal direction at monitor location or other locations, as deemed appropriate  Sample(s) analyzed EPA Method TO-15 for BTEX  If subsequent 24-hour SUMMA® canister sampling results greater than 9 ppb benzene, Kerr McGee will follow the Level 3 Investigation Response for continuous analyzers in Section 15.1. o 14-day carbon sorbent tube greater than 9 ppb benzene, Kerr McGee will follow the Level 3 Investigation Response for continuous analyzers in Section 15.1. o Carbon sorbent tubes - 14-day average greater than 2.0 ppb benzene  Based on the results from carbon sorbent tube sampling at previous pre- production monitoring locations, a result greater than 2 ppb benzene indicates a potential change in emissions at the location. If there is a tube result greater than 2 ppb, operations during the 14-day period will be reviewed and corrective action employed, as necessary o COGCC, CDPHE, and Local Government with jurisdiction over the location of the operations, will be contacted within forty-eight (48) hours of receiving notification of Level 3. (Reg. 7 VI.C.1.b.(ix)B) HSE Air Monitoring Program January 2021 Page 20 16. FIGURE 1 – PRE-PRODUCTION SITE TYPICAL MONITORING CONFIGURATION HSE Air Monitoring Program January 2021 Page 21 17. FIGURE 2 – PRODUCTION FACILITY SITE TYPICAL MONITORING CONFIGURATION HSE Air Monitoring Program January 2021 Page 22 18. FIGURE 3 – BULK SEPARATOR FACILITY TYPICAL LAYOUT HSE Air Monitoring Program January 2021 Page 23 19. ATTACHMENTS Quality Assurance Project Plan – PID Analyzers QUALITY ASSURANCE PROJECT PLAN OCCIDENTAL PETROLEUM Prepared For: Occidental Petroleum 1099 18th St #1800 Denver, CO 80202 Prepared By: Montrose Air Quality Services, LLC 990 W 43rd Ave Denver, CO 80204 Document Number: 928ET-772315-PP-19R2 Effective Date: May 20, 2021 Occidental Petroleum Quality Assurance Project Plan TABLE OF CONTENTS SECTION PAGE 1.0 OBJECTIVES AND SUMMARY OF TEST PROGRAM 4 1.1 BACKGROUND 4 1.2 GENERAL 4 1.3 PROJECT CONTACTS 4 1.3.1 Personnel 4 1.3.2 Responsibilities 5 2.0 EQUIPMENT DESCRIPTION 5 2.1 SENSORS 5 2.2 DATA PLATFORM 6 3.0 QUALITY ASSURANCE QUALITY CONTROL 8 3.1 DEPLOYMENT PROCEDURES 8 3.1.1 Sensor Deployment/Maintenance Log 8 3.1.2 Gas Calibration 8 3.1.3 Wind Direction Siting 9 3.2 ON GOING QUALITY ASSURANCE QUALITY CONTROL 9 3.2.1 Data Platform Alerts 9 3.2.2 Montrose Quality Assurance Checks 9 3.2.3 Monthly Quality Assurance Procedure 10 3.2.4 Consumables Replacement Schedule 10 4.0 REPORTING 11 APPENDIX A Example Nightly System Report 12 Occidental Petroleum Quality Assurance Project Plan SECTION PAGE LIST OF TABLES TABLE 1-1 MONITORING SENSORS 4 TABLE 1-2 PROJECT PERSONNEL 5 TABLE 1-3 PERSONNEL RESPONSIBILITIES 5 TABLE 3-1 MINIMUM GAS CALIBRATION CRITERIA 8 TABLE 3-2 PLATFORM ALERT CRITERIA 9 TABLE 3-3 MINIMUM FIELD CRITERIA 9 LIST OF FIGURES FIGURE 2.1 SCREEN SHOT OF THE AIRSENSE DASHBOARD 7 Occidental Petroleum Quality Assurance Project Plan 1.0 OBJECTIVES AND SUMMARY OF TEST PROGRAM 1.1 BACKGROUND Occidental Petroleum’s (Oxy) air quality (AQ) monitoring network to be deployed around pre- production well pads will provide real-time AQ data. The network will utilize low-cost cutting-edge air pollution sensor technology, redeveloped with solar, battery storage and data connectivity to make it useful for widescale deployment and replicable in any oil and gas facility. Each participating well pad will receive a minimum of four (4) sensors and data access via a data platform dashboard. The dashboard will display real time data and recent alerts, while the backend data platform will create insights for AQ patterns near each pad, leading to operational improvements, as well as generate automated alerts for stakeholders. 1.2 GENERAL The procedures outlined in this document cover the quality assurance procedures to be utilized in the deployment, operations and maintenance of the sensors. Two different sensor manufactures will be used in the quality assurance program as outlined in Table 1-1: TABLE 1-1 MONITORING SENSORS Manufacturer Model Manufactured State Sensit SPOD Indiana Lunar Outpost Canary-S Colorado The sensors measure volatile organic compounds (VOCs) in the air. A specification sheet on the sensors can be found in Appendix A. As part of this program, an AQ data platform, developed by AirSense, manages, quality controls, and reports the sensor data. 1.3 PROJECT CONTACTS 1.3.1 Personnel A list of project participants is included below in Table 1-2: Occidental Petroleum Quality Assurance Project Plan TABLE 1-2 PROJECT PERSONNEL Occidental Petroleum Project Contact: Chad Schlichtemeier Title: Rockies HSE Manager Address: 1099 18th St #1800 Denver, CO 80202 Telephone: 720-929-6867 Email: chad_schlichtemeier@oxy.com Montrose Air Quality Services, LLC Information Project Contact: Austin Heitmann Patrick Clark, PE, QSTI Title: Project Manager VP Ambient and Emerging Tech. Address: 990 W. 43rd Ave. 990 W. 43rd Ave. Denver, CO 80211 Denver, CO 80211 Telephone: 303-670-0530 303-670-0530 Email: aheitmann@montrose-env.com pclark@montrose-env.com 1.3.2 Responsibilities Table 1-3 below details the roles and responsibilities of the project team. TABLE 1-3 PERSONNEL RESPONSIBILITIES Person/Company Primary Assignment Chad Schlichtemeier (Oxy) Overall Project Coordinator Austin Heitmann (Montrose) Sensor deployment, sensor operations, sensor maintenance and QA/QC, data platform management 2.0 EQUIPMENT DESCRIPTION 2.1 SENSORS The Sensit’s SPOD and Lunar Outpost’s Canary-S are air quality monitoring systems equipped with a single Ion Science photoionization detector (PID), cellular communication, and powered via a solar panel and battery. A multitude of units can be deployed to create a network of real- time, localized data focusing on air quality and meteorological measurements. The sensors can monitor VOCs, wind speed, wind direction, temperature, relative humidity and barometric pressure. A complete datasheet summarizing the specifications of the SPOD and Canary-S can Occidental Petroleum Quality Assurance Project Plan be found in the Appendix of this test plan. Both units communicate via a cellular back haul directly to the data platform. 2.2 DATA PLATFORM The AirSense data management platform handles traditional air monitoring data and next generation air sensor data. The AirSense system is a cloud based system that ingests data, performs quality control, calibrates air sensor data, and distribution of air sensor data. AirSense handles up to 1-second data (fixed or mobile), any pollutant or parameter, and offers intuitive navigation to view and display data for public and technical applications. For Oxy and Montrose personnel AirSense’s dashboard provides a summary of the operational status of network. For each well pad, AirSense provides a display showing 1-minute, 15-minute, and 12-hour average readings, site maps, and meteorological data. Occidental Petroleum Quality Assurance Project Plan FIGURE 2.1 SCREEN SHOT OF THE AIRSENSE DASHBOARD Occidental Petroleum Quality Assurance Project Plan 3.0 QUALITY ASSURANCE QUALITY CONTROL 3.1 DEPLOYMENT PROCEDURES The following procedures will be followed prior to deploying a sensor to a pad. Any sensors not meeting all the requirements outlined below will be returned to the manufacturer. 3.1.1 Sensor Deployment/Maintenance Log Upon completion of the sensor pre-delivery checks, the sensors will be received by Montrose and a sensor deployment/maintenance log initiated. The log will be stored on Montrose’s server which is only accessible by Montrose personnel and will contain the following minimum information: • Sensor serial number • Sensor model number • AirSense key • Results of the initial sensor calibration check out procedures • Deployment location, date and time • Filter replacement schedule • History of notes, issues and maintenance procedures organized by date 3.1.2 Gas Calibration A calibration would be performed on all equipment during the initial deployment effort. Montrose personnel would complete monthly calibration checks on each PID sensor using a Zero Air, 3 ppm, and 5 ppm isobutylene certified cylinder. A gas hood is installed over the top of the PID sensor and gas is flowed at approximately 0.5 L/min across the sensing portion of the PID face. TABLE 3-1 MINIMUM GAS CALIBRATION CRITERIA Parameter Minimum Criteria1 3 ppm Precision |3*SD2|<=50 ppb Zero Air Error (Bias) <10% of span gas bottle value 3 ppm Error (Bias) <25% of bottle value 5 ppm Error (Bias) <20% of bottle value Based on the response of the analyzer to each concentration of gas a linear fit will be applied to the data to produce a slope and intercept that is applied to the raw VOC parameter. Once the units are deployed to the field some minor adjustments are made to the unit’s baseline reading, 1 Based on 1-minute readings 2Standard Deviation Occidental Petroleum Quality Assurance Project Plan this adjustment is considered when evaluating if the calibration met the minimum criteria outlined above. 3.1.3 Wind Direction Siting The sonic anemometers North orientation marker's stated direction is conducted using a Brunton pocket transit. The field personnel sites the monitor during the initial deployment and then confirms this reading during each subsequent monthly calibration checks. An acceptable check will verify that the North siting is within 10 degrees. If the verification check fails the monitor will be adjusted and this will be noted in the monthly report. 3.2 ON GOING QUALITY ASSURANCE QUALITY CONTROL The following procedures will be followed on an on-going basis to assure the quality of collected data. 3.2.1 Data Platform Alerts The AirSense data platform will alert Montrose and Oxy according to the table below. Alerts will be in the form of an immediate e-mail notification. TABLE 3-2 PLATFORM ALERT CRITERIA Parameter Minimum Criteria Range check -1 to 100 ppm Sticking check Constant value for more than 15 1-minute data points No data alerts When no data is received for more than 15 minutes emails alerts will be issued at a frequency of once per 6-hours 3.2.2 Montrose Quality Assurance Checks Montrose will review the nightly reports generated as outlined in section 4.0 to verify that the field criteria in Table 3-3 is met. TABLE 3-3 MINIMUM FIELD CRITERIA Parameter 1-Minute Average Minimum Criteria Data Recovery >90% over 48 hours Occidental Petroleum Quality Assurance Project Plan Baseline Variation Over 24 Hours +/- 0.2 ppm If any of the criteria laid out in Table 3-3 fail the following procedures will be followed depending on the parameter in question and a back-up sensor will be ready to replace a failed sensor at all times: Data Recovery: If the sensor fails to meet the data recovery minimums as laid out in Table 3-3 a technician will inspect the unit. Each day is defined as the 24-hour period beginning when the nightly reports are generated at approximately midnight mountain time. The inspection will consist of checking for any loose connections within the unit that may be causing a power failure and that 12 volts of power is being generated by the solar panel and can be traced back to the barrel jack plugged in the device. If the technician cannot determine the cause of the data recovery the unit will be returned to the manufacturer for a more in-depth review. Baseline Variation Over 24 Hours: It is expected that there will be slight baseline variation over 24 hours due to environmental conditions. If this baseline fluctuates more than 0.2 ppm in either direction from the average baseline over a 24-hour period a field technician will inspect the unit. If the technician cannot determine the cause of the baseline fluctuation the unit will be returned to the manufacturer for a more in-depth review. 3.2.3 Monthly Quality Assurance Procedure Monthly a bump test will be conducted on the PID detector to verify that the data collected during the month prior is quality data. This bump test will consist of a different 3 ppm isobutylene gas, if available, then was used for the initial calibration and to pass the reading must be within +/- 25% of the gas bottle value. If the unit fails a bump test: A full three-point calibration will be done on the unit, as outlined in section 3.1.2, and a full inspection will be performed to determine why the bump test failed. If a reason for the failed bump test cannot be determined the unit will be returned to the shop for maintenance and/or the full three-point calibration will be used to update the slope and intercept described in section 3.1.2. If the unit passes a bump test: The unit will be redeployed to the field without making any adjustments to the calibration factors. Though the calibration factors may be adjusted if the unit nearly failed the bump test. 3.2.4 Consumables Replacement Schedule The hydrophobic particulate filter built into the electrode stack on each Ion Science detector deteriorates after approximately 6-8 weeks due to the UV light produced by the lamp. Once this filter deteriorates dust and other particulate can enter the lamp cavity and cause a diminished signal. An additional filter is installed prior to the PID but not in direct contact with the UV lamp. This additional filter has no impact on the VOC concentrations entering the PID. The lamp used to produce the UV light needs replacing approximately every 12 month. After approximately 6 months of field monitoring the monitor will be swapped out with another unit that has had it’s consumables replaced and has been calibrated as described in Section 3.1.2. Occidental Petroleum Quality Assurance Project Plan 4.0 REPORTING A nightly system report will be issued by the AirSense data platform and e-mailed to the principle party’s at Oxy and Montrose. The system report will have at a minimum, the following 24 hour data summary of each parameters listed below. An example system report can be found in the Appendix B. • Sensor ID • Minimum value • Maximum value • Average value • Percent data capture • Alerts that occurred Occidental Petroleum Quality Assurance Project Plan APPENDIX A Example Nightly System Report Occidental Petroleum Quality Assurance Project Plan Occidental Petroleum Quality Assurance Project Plan THIS IS THE LAST PAGE OF THIS DOCUMENT For questions, please use Table 1-3 to contact the individual that would be most prepared to answer your question. Standard Operating Procedure – Collection and Analysis of Carbon Sorbent Tubes Page 1 of 3 STANDARD OPERATING PROCEDURE SOP Title: Passive Tube Sampling Implementation Date: September 9, 2020 Document Number: 928ET-772315-SP-2 SOP Owner (Department): AQS Revision Number: R0 SOP Approval: Austin Heitmann, CPM Montrose Air Quality Services 990 W 43rd Ave, Denver, CO 80211 T: (303) 670-0530 www.montrose-env.com EPA Method 325 Sample Tube Deployment: 1. Remove ice packs from passive sampler (PS) cooler. Freeze them in a horizontal position in a dedicated, contaminant-free freezer until ready for use in the return shipment. 2. Allow the PS to equilibrate to ambient temperature at the sampling location for 1 hour prior to deployment 3. Inspect sample shelter for damage or indication of insect infestation. Replace if damaged or infested. DO NOT spray sample shelter with any type of insect repellant. 4. Complete data sheet/chain-of -custody with required information: • Name of sample shelter • PS identification number etched on exterior of PS, and whether PS is a primary sample, duplicate sample, or field blank (S,D, or B) • Date and time • Any abnormal conditions in the vicinity (e.g., operation of a portable generator, evidence of tampering with sample shelter) 5. Don powder-free nitrile gloves to prevent contamination with body oils, hand lotions, perfumes, etc. 6. Remove PS cartridge from sample shelter (if applicable) 7. Remove PS from vial. Check that the fittings of the PS are not loose – do not use if loose. 8. Remove brass Swagelok® nut with Teflon® ferrule and brass Swagelok® plug from the grooved end of the PS. The grooved end will be on the origin side of the arrow etched on the tube. This indicates it is the inlet end of an active sample. Do not use tube if media leaks when opened. 9. Insert PS in cartridge, and install a diffusion cap on the open end 10. The diffusion cap has two o-rings that seal against the sample tube. Slide the sample tube until both o-rings have sealed against the tube and the inlet end of the tube is just against the diffusion cap screen. The sampler must ensure that the diffusion cap has been pushed on far enough to seal both o-rings. It may take some force with a twisting action to slide the tube far enough into the diffusion cap to seal properly 11. Place the brass Swagelok® nut with Teflon® ferrule and brass Swagelok® plug into the original glass vial, cap the vial, and return to the sample cooler 12. Install field blank or duplicate PS, as applicable • Note: diffusion caps are not placed on field blanks. Leave brass Swagelok® nut with Teflon® ferrule and brass Swagelok® plug secure. • Per Section 9.3.2 of EPA Method 325A, field blanks must be placed in two separate sampling quadrants respective to the geometric center of the facility • Duplicate samples are installed in a manner identical to primary samples Page 1 of 3 STANDARD OPERATING PROCEDURE SOP Title: Passive Tube Sampling Implementation Date: September 9, 2020 Document Number: 928ET-772315-SP-2 SOP Owner (Department): AQS Revision Number: R0 SOP Approval: Austin Heitmann, CPM Montrose Air Quality Services 990 W 43rd Ave, Denver, CO 80211 T: (303) 670-0530 www.montrose-env.com EPA Method 325 Sample Tube Deployment: 1. Remove ice packs from passive sampler (PS) cooler. Freeze them in a horizontal position in a dedicated, contaminant-free freezer until ready for use in the return shipment. 2. Allow the PS to equilibrate to ambient temperature at the sampling location for 1 hour prior to deployment 3. Inspect sample shelter for damage or indication of insect infestation. Replace if damaged or infested. DO NOT spray sample shelter with any type of insect repellant. 4. Complete data sheet/chain-of -custody with required information: • Name of sample shelter • PS identification number etched on exterior of PS, and whether PS is a primary sample, duplicate sample, or field blank (S,D, or B) • Date and time • Any abnormal conditions in the vicinity (e.g., operation of a portable generator, evidence of tampering with sample shelter) 5. Don powder-free nitrile gloves to prevent contamination with body oils, hand lotions, perfumes, etc. 6. Remove PS cartridge from sample shelter (if applicable) 7. Remove PS from vial. Check that the fittings of the PS are not loose – do not use if loose. 8. Remove brass Swagelok® nut with Teflon® ferrule and brass Swagelok® plug from the grooved end of the PS. The grooved end will be on the origin side of the arrow etched on the tube. This indicates it is the inlet end of an active sample. Do not use tube if media leaks when opened. 9. Insert PS in cartridge, and install a diffusion cap on the open end 10. The diffusion cap has two o-rings that seal against the sample tube. Slide the sample tube until both o-rings have sealed against the tube and the inlet end of the tube is just against the diffusion cap screen. The sampler must ensure that the diffusion cap has been pushed on far enough to seal both o-rings. It may take some force with a twisting action to slide the tube far enough into the diffusion cap to seal properly 11. Place the brass Swagelok® nut with Teflon® ferrule and brass Swagelok® plug into the original glass vial, cap the vial, and return to the sample cooler 12. Install field blank or duplicate PS, as applicable • Note: diffusion caps are not placed on field blanks. Leave brass Swagelok® nut with Teflon® ferrule and brass Swagelok® plug secure. • Per Section 9.3.2 of EPA Method 325A, field blanks must be placed in two separate sampling quadrants respective to the geometric center of the facility • Duplicate samples are installed in a manner identical to primary samples Page 2 of 3 STANDARD OPERATING PROCEDURE SOP Title: Passive Tube Sampling Implementation Date: September 9, 2020 Document Number: 928ET-772315-SP-2 SOP Owner (Department): AQS Revision Number: R0 SOP Approval: Austin Heitmann, CPM Montrose Air Quality Services 990 W 43rd Ave, Denver, CO 80211 T: (303) 670-0530 www.montrose-env.com 13. Install PS shelter cartridge with PS in sample shelter and confirm that the end of the PS with the diffusion cap installed is pointed directly downward 14. Remove powder-free nitrile gloves and discard 15. Repeat this sequence of steps for next PS installation Sample Recovery and Re-deployment: Samples will be recovered after 14 consecutive days of sampling, or at another frequency as dictated by the site specific sampling program. Sample recovery should be conducted in the same location sequence as deployment and ideally at clock times that corresponds to exactly 14-days. 1. Inspect sample shelter for damage or indication of insect infestation. Replace if damaged or infested. DO NOT spray sample shelter with any type of insect repellant. • If sample shelter is replaced, document height of replacement shelter from the ground and confirm new location coordinates 2. Complete data sheet/chain-of -custody with required information: • Name of sample shelter • PS identification number etched on exterior of PS, and whether PS is a primary sample, duplicate sample, or field blank (S, D, or B) • Date and time • Any abnormal conditions in the vicinity (e.g., operation of a portable generator, evidence of tampering with sample shelter) • Don powder-free nitrile gloves to prevent contamination with body oils, hand lotions, perfumes, etc, • Remove PS cartridge from sample shelter 3. Remove diffusion cap from the end of the and slide PS from cartridge, and replace the original brass Swagelok® nut with Teflon® ferrule and brass Swagelok® plug on the open end. 4. Ensure that the brass Swagelok® nut with Teflon® ferrule and brass Swagelok® plug on both ends of the PS are secure using one quarter turn past finger-tight with the 9/16” and ½” wrenches. Do not over tighten the brass fittings as this could damage the Teflon® ferrule inside the fitting and compromise the seal. Note: Loose caps discovered at the analytical laboratory following shipment could invalidate the sample. 5. Place the sealed PS in the original glass vial, cap the vial, and secure in the original sample cooler 6. Inspect diffusion cap and remove from service if dirty 7. Remove powder-free nitrile gloves and discard Page 2 of 3 STANDARD OPERATING PROCEDURE SOP Title: Passive Tube Sampling Implementation Date: September 9, 2020 Document Number: 928ET-772315-SP-2 SOP Owner (Department): AQS Revision Number: R0 SOP Approval: Austin Heitmann, CPM Montrose Air Quality Services 990 W 43rd Ave, Denver, CO 80211 T: (303) 670-0530 www.montrose-env.com 13. Install PS shelter cartridge with PS in sample shelter and confirm that the end of the PS with the diffusion cap installed is pointed directly downward 14. Remove powder-free nitrile gloves and discard 15. Repeat this sequence of steps for next PS installation Sample Recovery and Re-deployment: Samples will be recovered after 14 consecutive days of sampling, or at another frequency as dictated by the site specific sampling program. Sample recovery should be conducted in the same location sequence as deployment and ideally at clock times that corresponds to exactly 14-days. 1. Inspect sample shelter for damage or indication of insect infestation. Replace if damaged or infested. DO NOT spray sample shelter with any type of insect repellant. • If sample shelter is replaced, document height of replacement shelter from the ground and confirm new location coordinates 2. Complete data sheet/chain-of -custody with required information: • Name of sample shelter • PS identification number etched on exterior of PS, and whether PS is a primary sample, duplicate sample, or field blank (S, D, or B) • Date and time • Any abnormal conditions in the vicinity (e.g., operation of a portable generator, evidence of tampering with sample shelter) • Don powder-free nitrile gloves to prevent contamination with body oils, hand lotions, perfumes, etc, • Remove PS cartridge from sample shelter 3. Remove diffusion cap from the end of the and slide PS from cartridge, and replace the original brass Swagelok® nut with Teflon® ferrule and brass Swagelok® plug on the open end. 4. Ensure that the brass Swagelok® nut with Teflon® ferrule and brass Swagelok® plug on both ends of the PS are secure using one quarter turn past finger-tight with the 9/16” and ½” wrenches. Do not over tighten the brass fittings as this could damage the Teflon® ferrule inside the fitting and compromise the seal. Note: Loose caps discovered at the analytical laboratory following shipment could invalidate the sample. 5. Place the sealed PS in the original glass vial, cap the vial, and secure in the original sample cooler 6. Inspect diffusion cap and remove from service if dirty 7. Remove powder-free nitrile gloves and discard Page 3 of 3 STANDARD OPERATING PROCEDURE SOP Title: Passive Tube Sampling Implementation Date: September 9, 2020 Document Number: 928ET-772315-SP-2 SOP Owner (Department): AQS Revision Number: R0 SOP Approval: Austin Heitmann, CPM Montrose Air Quality Services 990 W 43rd Ave, Denver, CO 80211 T: (303) 670-0530 www.montrose-env.com 8. If immediately installing new PS at the sample location, perform the sequence of steps described in Sample Deployment 9. Repeat this sequence of steps for next PS recovery Sample Packaging and Shipping: Once all PS are collected and secured in the original sample cooler, the sample cooler must be shipped priority overnight to the analytical laboratory. Per Section 8.5.4 of EPA Method 325B, PS must be analyzed within 30 calendar days of the end of sample collection. 1. If shipping is not done on the same day as sample recovery, samples may be placed in a contaminant-free refrigerator for storage and the ice packs frozen to be placed in the shipping cooler. Per Section 8.5.4 of EPA Method 325B, PS must be stored below 23°C (73.4°F). 2. Each set of samples will contain their own unique chain-of-custody form that is included in the sample cooler. Relinquish the samples by signing the chain-of-custody in the “Relinquished by” section and indicate the selected shipping agency in the “Received by” section. Place the original chain-of-custody form inside a plastic baggie in the corresponding 3. Ensure that at least one temperature blank glass vial is included in the sample cooler. 4. Place the original two frozen ice packs into the sample cooler when ready for shipping. Note: Do not write, etch, or place labels anywhere on the weatherproof sample shelter, glass vial or PS itself. The lids of the glass vials may be marked with a shelter ID to facilitate sample collection. However, do not use permanent marker, paint, or any other marking tool that contains a high level of VOC to write the sample IDs on the sample label. Note: Sampled sorbent tubes MUST NOT be placed in the same container (e.g., shipping cooler, refrigerator) as clean conditioned, sampling tubes. ORIGINAL If not red, destroV this copy after use. Enthalpy Analytical Standard Operating Procedure I Determination of Volatile Organic Compounds (VOCs) by EPA Method 325B I Enthal SOP # ENT222 Revision # 3.0 Author David Berkowitz Date Authored September 4, 2013 Revised by Glenn Graham Date Revised April 19, 2019 Pages 22 Technical Director/designee Approval: ~,4-----\.IL~___L--¥-_",,--_Approval Date: 6-J.f-(q Quality A"mance Di=tor/d~;"", Review: y~~ Review Date: (g-;) 81 'I Effective Date: g-/f}:/ q 1.0 Scope and Application: This document describes the procedures for thermal desorption -gas chromatography/mass spectrometry (TD-GCIMS) analysis of volatile organic compounds (VOCs) collected on sorbent tubes using passive sampling. Table 1. in Appendix A. contains the list of analytes that may be determined using this SOP. 2.0 Summary of Method: Sorbent tubes are conditioned, blanked, and shipped to the field for deployment. Sorbent tube samples received at the laboratory for analysis are thermally desorbed and analyzed by GCIMS for trace-level VOCs. Critical steps included in the process of thermal desorption of each sample are: Leak testing under stop flow, ambient conditions, internal standard addition, tube purging, thermal desorption of the sample tube, refocusing on a cold trap, secondary desorption of the cold trap with transfer/injection of the sample to the capillary GC column for analysis of the analytes of interest. Measures included for the purposes of water management include: Selection of hydrophobic sorbents for the sample tube and optional dry purging of the sample tube for approximately an hour on a tube purging station prior to analysis. The tube may be optionally dry purged prior to thermal desorption to the cold trap. See also SOP ENT226. 2.1 Exceptions to Method Criteria: 2.1.1 Enthalpy will run a minimum of one initial calibration per year to verify continuing instrument linearity instead of the three month criteria from the method. 2.1.2 Since the rCAL points have already been demonstrated to be valid compared to the rcv run after the rCAL, the CCV5 analyses made daily serves to demonstrate the continuing solution validity. Therefore, rcvs will only be run with rCALS and not every three months as per the method criteria. SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B) Page 1 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. 2.1.3 Enthalpy will accept BFB criteria for the m/z 96 response compared to m/z 95 ion response to be acceptable up to and including 14% due to protonation of the 95 ion from using hydrogen as a carrier gas. 2.1.4 Gas Standards in cylinders will be considered valid for use until the date of expiration listed by the supplier. 2.1.5 Tubes which will not pass leak check due to damage on the very ends of the tube may be analyzed if the damage can be mitigated with micro-mesh or similar material to allow the leak test to pass. 2.1.6 CCVs which fail the method internal standard response criteria but pass the RF criteria and are consistent with the remainder of the CCV s in the sequence may be used without rerunning the associated sample tubes if a recollect injection passes all criteria on rerun prior to performing maintenance or tuning. This would confirm a bad injection on the CCV and not a bad spike of the internal standard. 3.0 Definitions: 3.1 Thermal Desorption (TD) -The use of heat and a flow of inert (carrier) gas to extract volatiles from a solid matrix. 3.2 Blanking The desorption and confirmatory analysis of conditioned sorbent tubes prior to shipping for field sample collection. 3.3 Continuing Calibration Verification (CCV) - A midpoint calibration standard analyzed periodically throughout the sequence to verify the linearity of the multipoint calibration. 3.4 Focusing Trap A cooled secondary sorbent trap integrated into the thermal desorber to refocus analytes desorbed from the sample tube. 3.5 Initial Calibration Verification (lCV) - A second source standard analyzed after the Initial Calibration to verify accuracy of the initial calibration. 3.6 Field Blank (FB) Blank tubes shipped to and from the sampling site. Field blank tubes are handled in the same manner as sample tubes, but are not opened to the atmosphere during sampling. 3.7 Method Blank (MB) Analysis of a laboratory blank conditioned tube preferably from the same batch as the tubes used for the field samples. Not a field blank. The method blank is used to verify the contaminant level ofthe analytical system. 3.8 System Blank (SB) An optional analysis of an empty stainless steel tube (no sorbent packing in tube) used to verify that the instrument is contaminant free. 3.9 Standard Conditions Standard temperature and pressure are defined in EPA Method 325B as 25°C (298.2K) and 760mmHg, respectively. 3.10 LOQ (Limit of Quantitation) -Value equal to the lowest calibration standard level used in generating the instrument calibration SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 2 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. 4.0 Safety: Appropriate personal protective equipment should be worn including a lab coat, gloves and safety glasses as deemed necessary. 5.0 Equipment and Supplies: 5.1 Thermal Desorption system -Perkin Elmer ATD650 or equivalent. 5.2 Thermal Desorber Interface -Uniformly heated transfer line with direct connection to the capillary column. 5.3 Thermal Desorption Tubes -Compatible with Perkin Elmer ATD650. Tubes should be 89 mm long, 6.5 nun o.d. (outer diameter) and 5 nun i.d. (inner diameter) made of stainless steel or inert-coated stainless steel with the central section packed with up to 60 nun of sorbent. The sorbent is typically supported between two 100 mesh stainless steel gauzes. When tubes are used for diffusive sampling, they must have an internal diffusion (air) gap of 1.5 cm between the sorbent retaining gauze at the sampling end of the tube and the gauze in the diffusion cap. 5.4 Long term storage caps -Two piece \14" metal Swagelok type tube caps with PTFE ferrules. 5.5 Short term/analytical caps Caps are made of inert material such as PTFE and compatible with the automated TD system. 5.6 Storage and transportation containers Clean glass jars, metal cans, or non-emitting polymer boxes are used to transport and store tubes. A small packet of activated sorbent material may be included in the shipping container with un-sampled conditioned tubes to safeguard against ambient contamination. 5.7 Tube conditioning apparatus A dedicated tube conditioning unit must be leak-tight, allow precise and reproducible temperature selection (±5°C), offer a temperature range at least as great as the thermal desorber and support inert gas flows of up to 150 mLimin through each tube. A TD system may be used provided it supports a dedicated tube conditioning mode in which the inert gas effluent is directed to vent without passing through the key parts of the sample flow-path. 5.8 Tube Purging Station - A dedicated tube purging station must be leak-tight, and support controlled inert gas flows through each tube at ambient temperature. 5.9 Unheated injection port for loading standards onto blank tubes -The apparatus should have a push-fit or finger-tightening connector for attaching the sampling end of blank sorbent tubes without damaging the tube. It must have a means of controlling the carrier gas flow between 50 and 100cc/min. A low emission septum must be used allowing the introduction of liquid or gas standards via appropriate syringes. 5.10 Mass Spectrometer (MS) Agilent 5973 or 5975 Mass Selective Detector (MSD) or equivalent set in scan mode. This system is capable of scanning from 29 to 300 amu every 1 second or less, using 70 eV. 5.11 Gas Chromatograph (GC) -Agilent 5890 or 6890N series or equivalent. SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 3 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. 5.12 GC/MS interface -Agilent GC/MSD interface or equivalent equipped with a heater sleeve and a heater sensor to monitor and maintain interface temperature. 5.13 GC Column -60 m, 0.52 mm, 1.0 11m film thickness silicon coated, Restek® Rtx-l or equivalent. 5.14 Data system -Agilent Windows ChemStation or equivalent is used for data acquisition and processing. This system is capable of continuous acquisition and storage of mass spectral data obtained throughout the run. The processing software allows for data to be plotted as total ion current abundance or extracted ion current abundance versus time and is equipped with a 129,000 analyte library from the National Institute of Standards and Technology (NIST) for mass spectra identification. 6.0 Reagents and Standards: 6.1 Carrier Gas -UHP Hydrogen or Helium 6.2 Sorbent tubes - A suitable sorbent must be chosen based on the physical properties of the analytes of interest. Carbopack X is the optimal sorbent choice when sampling I, 3-Butadiene. Uptake rates should be verified for the sorbent used when the tubes are used for passive sampling unless they are available in relevant international standards or peer reviewed publications. 6.3 Gas phase standards Static or dynamic atmospheres of certified calibration gases, accurate to ± I 0% or better, may be used to prepare calibration tubes or validate passive sampling uptake rates. Changes in room temperature and atmospheric pressure can change the mass spiked onto the TD tube when spiking with gas phase standards. When calculating the mass spiked onto tubes used for performing an initial calibration, the room temperature and atmospheric pressure must be recorded and included in calculating the mass of each standard. When preparing CCV standard tubes, the analyst must verify that any change in the room temperature and atmospheric pressure do not cause the spiked mass to differ from the initial calibration standard by more than 3%. If the CCV standard concentration changes by more than 3% from the initial calibration standard, the new CCV concentration must be used in any subsequent analyses/calculations. Gas standards should be spiked onto calibration tubes using an appropriate gas-tight syringe for each tag amount. Each sorbent tube should be left connected to the flow of gas for 2 minutes after standard introduction. Alternatively, gas standards may be prepared using a Thermal Desorber with appropriate volume gas loops for each level. 6.4 Liquid Stock Standards -Liquid stock standards may be purchased from approved vendors at specified concentrations or may be prepared from neat materials. Purchased stock standards will have an expiration date assigned by the manufacturer and are stored according to manufacturer recommendations. Prepared liquid stock standards will be assigned a 1 year expiration date and should be stored ::;6°C. Liquid stock standards may be used to prepare working standards which may then be used to spike the calibration standard tubes. 6.5 Liquid working standards prepared for spiking calibration standard tubes must be stored at ::;6°C and discarded after two weeks from preparation. The solvent used SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 4 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. must be pure, 0% of the mInImUm analyte levels, and not interfere chromatographically with the analytes of interest. Prepare the calibration standard tubes as follows: 6.5.1 Precise 0.5 to 21lL aliquots of liquid standard are introduced to the sampling end of blank sorbent tubes in a flow of carrier gas using a capillary syringe and urIheated injector. 6.5.2 Each standard tube is purged with carrier gas for five minutes after spiking. 6.5.3 Each standard tube must be sealed with long term storage caps immediately after being spiked unless they are to be analyzed immediately. Calibration tube standards expire after 30 days and must be stored in the same manner as samples. 6.6 GC/MS Tuning Standard - A certified cylinder containing 4-Bromofluorobenzene (BFB) at a known concentration, such that the loop used to load the standard results in an on-column concentration of 50 ng or less. 6.7 Internal Standards - A certified cylinder containing Benzene-d6, Toluene-dg, and Bromofluorobenzene at known concentrations, such that a 5 mL load results in on­ column masses of approximately 20 to 50 ng. 7.0 Sample Preservation, Storage, and Handling: 7.1 Store samples in clean glass jars, metal cans or rigid, non-emitting polymer boxes with long term storage caps. 7.2 Sample tubes must be inspected for damage, lose or missing storage caps, or any other problem prior to analysis. Any problems must be documented and tubes are not to be analyzed unless directed by the customer. Tubes which will not pass leak check due to damage on the very ends of the tube may be analyzed if the damage can be mitigated with micro-mesh or similar material to allow the leak test to pass. 7.3 Sample tubes must be analyzed within 30 days of the end of sample collection. 7.4 Samples must be stored at or below 23°C. If a refrigerator is used for storage, it must be clean and free of organic solvents. 8.0 Calibration: 8.1 Instrument Performance Check (Tuning): 8.1.1 Prior to the analysis of calibration standards, blanks or samples, analyze the BFB standard to verify acceptable mass spectrometer performance. The injection of BFB begins the 24 hour analytical clock. 8.1.2 Either a blank tube or a continuing calibration tube containing <SOng of BFB is analyzed. Process the BFB analysis by averaging three scans (the scan prior to the peak apex, the peak apex and the scan following the peak apex) then subtracting one scan prior to the elution of the BFB peak. 8.1.3 The criteria listed in Table 2 in Appendix A must be met before analysis of blanks and samples may begin. If any of the ion abundance criteria are not met, retune the mass spectrometer and repeat the BFB analysis. SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 5 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. 8.1.4 If instrument performance criteria are still not met, perform maintenance such as cleaning the ion source or baking the ion source for at least 8 hours using the bakeout program available in the software. 8.1.4.1 The use of hydrogen as a carrier gas is known to cause protonation of the mass 95 BFB product ion which may result in an elevated response for mass 96. 8.1.4.2 If multiple injections ofBFB meet all other tuning criteria and mass 96 response is stable and less than 14%, calibration and sample analysis may begin. The following note should to be added to the narrative. "The BFB tune exhibited high bias for the relative response of mJz 96. The use of hydrogen as a carrier gas is known to cause protonation of the mJz 95 BFB product ion resulting in an elevated response for mJz 96. All other BFB tuning criteria have been met for this analysis." 8.2 Initial Calibration: 8.2.1 A spiked tube multipoint calibration, minimum 5 levels, is performed at least yearly. One of the calibration levels must be the same as the daily continuing calibration. See Table 3 in Appendix B for General GC/MS Operating Conditions. 8.2.2 Discrete tube preparations are performed for each level. Desorbing, splitting, and recollecting to prepare another level is not acceptable. Calibration standards must be analyzed using the same analytical conditions as the field samples. 8.2.3 Enter the mass in ng for each analyte into the calibration table when new standards are prepared. Upon analysis of the initial calibration, update each calibration level with the analyte response. The software then calculates the average response factor (RF) and percent Relative Standard Deviation (%RSD) for each analyte. 8.2.4 The software also calculates the mean Response Factor, RF , the Relative Retention Time (RRT), and the Relative Standard Deviation (RSD) for all target analytes over the range of the initial calibration. The response factor for each target analyte is calculated using the equation in section 11.1. 8.2.5 Tabulate the area response of the primary ion for each internal standard and calculate the mean area response. Calculate the mean Retention Time (RT) for each internal standard over the range of the calibration. 8.2.6 Repeat the initial calibration after major changes are made to the instrument including ion source cleaning or repair, column replacement, anytime the mass spectrometer is vented, or if the continuing calibration acceptance . criteria cannot be met. SOP# ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 6 of22 Last Saved 6/2812019 ORIGINAL If not red, destroy this copy after use. 8.3 Acceptance criteria for initial calibration: 8.3.1 The %RSD of the RF for each analyte must be:::; 30%. If this criterion is not met, maintenance may be required prior to analysis of a new initial calibration. 8.3.2 The results of the analysis of each analyte in each calibration must be within 30% of its tag value. 8.3.3 The RRT for each analyte at each calibration level must be within ±0.06 RRT units of the mean RR T for that analyte. 8.3.4 If these criterions are not met, maintenance may be required prior to analysis of a new initial calibration or a new preparation of the calibration standards may be needed. 8.4 Initial Calibration Verification (ICV): 8.4.1 Analyze an ICV after the acceptable analysis of an initial calibration. The ICV standard should be prepared using a second source of reference materials. 8.4.2 Results of the analysis of the ICV standard must be within 30% of its tag value. If this criterion is not met, prepare and analyze a fresh standard. If reanalysis fails, check the instrument for problems. If necessary, analyze a new initial calibration. 8.5 If sufficient time remains on the 24 hour analytical clock after the acceptable initial calibration and ICV analyses, samples may be analyzed. If not, analyze a CCV/BFB instrument performance standard to start a new 24 hour analytical clock. 8.6 Continuing Calibration Verification (CCV): 8.6.1 Analyze a daily CCV containing a passing BFB injection. The percent difference (%D) between the analyte RFs in the CCV and corresponding average RF from the initial calibration must be :::;30%. The internal standard area responses for the beginning CCV must not differ by more than ± 40% from of the average area responses of the most recent initial calibration. 8.6.2 Analyze a CCV after a maximum of 10 field samples and at the end of the sequence. The percent difference (%D) between the analyte RFs in the CCV and corresponding average RF from the initial calibration must be :::;30%. The internal standard area responses for the CCV must not differ by more than ± 40% from of the area response of the most recent daily CCV. 8.6.3 The CCV for a subsequent set of samples may be used as the final CCV for a previous analytical sequence, provided the same analytical method is used and the subsequent set of samples is analyzed within 4 hours oflast CCV. 8.6.4 For CCVs that fail the method internal standard response criteria, if the RFs are in agreement with the CCVs with normal responses, there was probably a bad injection which would not affect sample results and the data can be reported with appropriate narration if a recollect run of the CCV passes both RF and response criteria. SOP # ENT222 Revision 3.0 Last Printed 6/28/20 I 9 SOP-222_R3 (EPA Method 325B).docx Page 7 of22 Last Saved 6/28/20 I 9 ORIGINAL If not red, destroy this copy after use. 8.6.5 If the criteria in sections 8.6.1 or 8.6.2 are not met, perform maintenance and/or prepare a new calibration standard and reanalyze the continuing calibration. If maintenance and new standards fail to correct the problem, analyze a new initial calibration. 9.0 Procedure: 9.1 Tube conditioning: 9.1.1 Freshly packed or newly purchased Carbopack X tubes need to be conditioned at between 315°C (our instrument desorption temperature) and 400°C (the temperature limit for Carbopack X) under a stream of inert gas, flowing between 50 and 150 mLimin for at least 2 hours prior to field use. All other tubes need to be conditioned for at least 30 minutes prior' to field use. 9.1.2 Unused/spare tubes received with field samples shall not be put into the conditioning queue until the analyst has verified that all field samples for the particular job have been loaded (or are available for analysis). 9.1.3 Tubes may be conditioned using the thermal desorber provided the unit has a tube conditioning mode in which the effluent from contaminated tubes is directed to vent without passing through key parts of the sample flow-path such as the focusing trap. 9.1.4 Tubes may be conditioned using a dedicated conditioning apparatus provided it is leak tight to prevent air ingress, allows precise and reproducible temperature selection (±5°C), offers a temperature range at least as great as that of the tube conditioning temperature, and supports inert gas flows of 50­ 120 mLimin through each tube. 9.1.5 Freshly packed or newly purchased tubes must be analyzed individually to demonstrate they are free of contaminants and interference. All other conditioned tubes must be demonstrated to be free of contaminants and interference by analyzing 10% of the conditioned tubes selected at random from each batch. 9.1.6 Blanked tubes should be processed using the response from the Daily CCV to ensure accurate levels are calculated compared to actual sample tubes. The contribution peaks should be included in the area. 9.1.7 Background contamination must be < 2.5 ng. 9.1.8 If tubes contain unacceptable levels of background contamination, repeat the conditioning and recertification process for that entire box of cleaned tubes (including untested tubes). 9.1.9 Sample tubes in which the catch weight exceeds the calibration limit must be marked after analysis and individually blank checked after reconditioning. 9.1.10 Tubes must be reconditioned if not used within 30 days of conditioning. SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 80f22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. 9.2 Pre-desorption System Checks and Procedures: 9.2.1 Ensure all sample tubes, blanks, and standards are at ambient temperature before removing them from the storage container. 9.1.1 Remove the long-term storage caps from the tubes and replace with analytical caps. 9.2.2 Load the tubes on the tray and enter the analytical sequence using the Turbomatrix software used by the automated tube desorber (ATD). 9.2.3 Create a sequence table in Agilent ChemStation software mirroring that of the ATD. 9.2.4 The ATD performs system integrity checks prior to desorption of each tube. 9.2.4.1 Any tube which fails the tube leak test should not be analyzed by the ATD but resealed and stored intact on the autosampler tray. The ATD will continue to test and analyze subsequent tubes. Note that the GCIMS will acquire the next tube in the ATD sequence as if it were the original tube thus unsynchronizing the A TD sequence from the GC/MS sequence. 9.2.4.2 The sample flow path is leak tested without heat or gas flow applied to the sample tube. If a leak is detected, the analytical sequence should be terminated. 9.3 Sample Dry Purge: 9.3.1 Before loading on the ATD, sample tubes may be dry purged with inert gas at ambient temperature for approximately one hour to remove moisture from the tube. They are purged with the sampling sides down (Arrow pointing down). See SOP -226. 9.3.2 Before analysis after loading on the ATD, tubes are dry purged with 30cc/min of carner gas passing into the tube from the sampling end for 4 minutes to remove any remaining water vapor. 9.4 Sample Analysis: 9.4.1 An analytical sequence should consist of the following elements in order: 9.4.1.1 A Passing BFB/CCV standard see Appendix B -or BFB followed by Initial Calibration and ICV 9.4.1.2 Method Blank (MB) 9.4.1.3 Field Blank (FB) 9.4.1.4 Field Samples -up to ten 9.4.1.5 Field Blank (if available) 9.4.1.6 CCV 9.4.1.7 Additional Field Samples up to ten 9.4.1.8 Closing CCV SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 9 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. Note that BFBs or System Blanks may be injected as needed for diagnostic purposes. 9.4.2 Internal standard addition is performed automatically using the A TD. A fixed volume loop is used to introduce the standard to each tube prior to desorption. Benzene-d6 or Toluene-d8 are used to quantitate target concentrations. 9.4.3 Each tube should be purged to vent with carrier flowing in the direction of sample desorption to remove oxygen prior to heating. 9.4.4 Desorb each tube using the same instrument conditions used to calibrate the system. 9.4.5 The internal standard area responses for each sample analysis must not differ by more than ± 40% from the area responses of the daily beginning CCV. Flag sample results for analyses that do not meet the response criteria. 9.4.6 The internal standard retention times must not vary by more than 20 seconds from the retention times of the internal standard in the daily beginning CCV. 9.4.7 Analyzed tubes must be resealed with long-term storage caps after the completion of the analytical sequence. 9.4.8 Report results in ng, Ilg/m3, and ppbv for each analyte, unless otherwise directed by the client. 'E' Flag any result that exceeds the calibration range of the instrument in the data report and associated narrative. 9.5 Record all information associated with instrument calibration and sample analysis on the instrument log book pages. 9.6 Record any instrument maintenance in the instrument's maintenance logbook. 9.7 Interferences: 9.7.l Contamination may occur in the sampling system if tubes are not properly conditioned before use. 9.7.2 Interferences in tubes samples may result from improper use or from contamination of: (1) the tubes due to poo~ manufacturing practices, (2) the tube conditioning cleaning apparatus, and (3) the sampling, shipping or analytical system. 9.7.3 If benzene-d6 is used as an internal standard, a small amount of benzene contribution from the standard will elute on the front of the native benzene. This contribution will be less than the method MDL. The peaks will only be manually integrated if the native benzene from the sampling is not completely included in the area. The internal standard contribution will be integrated out of the peak at the request of the client if the results will affect the clients sampling frequency and will be noted in the narrative. 9.7.4 Attention to the following details will help to minimize the possibility of contamination of tubes. 9.7.4.1 Tubes should be manufactured using high quality stainless steel, preferably deactivated, and new tubes should be conditioned at the lab regardless if they were conditioned by the manufacturer. The sop # ENT222 Revision 3.0 Last Printed 6/2812019 SOP-222_R3 (EPA Method 325B).docx Page 10 of22 Last Saved 6/2812019 ORIGINAL If not red, destroy this copy after use. conditioning apparatus, sampling system, and analytical system should be assembled of clean, high quality components. 9.7.4.2 Tubes should be stored in a contaminant-free location and should be capped tightly during shipment. 9.7.5 Significant contamination of the analytical equipment can occur whenever samples containing high VOC concentrations are analyzed. This in tum can result in carryover contamination in subsequent analyses. Closely examine the sample analysis following the high concentration sample for the presence of carryover. If carryover is suspected, data should be qualified in the report narrative. 10.0 Quality Control: 10.1 Method Blank: 10. LIThe Method Blank is a conditioned blank tube analyzed daily prior to sample analysis but after an acceptable initial or continuing calibration. One Method Blank should be analyzed for a batch of up to 20 field samples or at least once per 24 hour analytical sequence. 10.1.2 The Method Blank must not contain target analytes at concentrations greater than 2.5 ng. . 10.1.3 The internal standard response and retention time criteria in sections 9.4.5 and 9.4.6 must be met. If not, perform clean-up procedures on the analytical system and analyze another method blank. If the samples were already run prior to discovering method blank. 10.2 Field Samples should be flagged with a "P" or "Pc" if Field Duplicates results are not within 30% of the concentration oftheir respective collocated samples. 10.3 Desorption efficiency and compound recovery for the TD method must be demonstrated at instrument setup and after the analytical system is recalibrated. Compound recovery must be greater than 95% for replicate analyses of the same sample tube. Following an initial calibration and ICV acquisition, analyze the high CCV point at 3-1 no-Recollect with internal standard. Immediately rerun the same tube 2-1 using no-Recollect with internal standard. Quantitate the amount of each target, if any, from the second run. This must be less than 5% of the amount originally spiked on tube for the initial run. 11.0 Data Analysis and Calculations: 11.1 Calculate the response factor (RF) for each analyte in the calibration using the following equation: RF = Areac x Amt[S Area!s Amtc Where: Areac = Area of analyte SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 11 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. Amtc = Amount of analyte in ng Amtls = Amount of Internal Standard in ng Areals Area of Internal Standard (IS) 11.2 The instrument software is capable of tabulating each calibrated analyte's response factor at each standard concentration. The software then calculates the average RF and percent RSD. The following equation is used to calculate the % RSD: %RSD = IOO(~~) Where: SD Standard deviation RF average response factor 11.3 Calculate the %D between the average RF from the initial calibration and the corresponding RF from the continuing calibration using the following calculation: _.. I § RF' RF'",,,,,,,..... u:... i'1-... · 'I'iX 100%D= RF ! ~' Where: RF = Average RF from initial calibration RFconcal RF from continuing calibration 11.4 Calculate sample results in ng for each analyte of interest usmg the following equation: . AAxISConcentratlOn (ng) = c AfsxRF Where: AA = Area of quantitation ion of target analyte ISc = Internal Standard mass in ng Als Area of quantitation ion of Internal Standard RF = Response factor from the daily CCV 11.5 Concentrations for detected target analytes are calculated usmg the following equation: SOP #ENT222 Revision 3.0 Last Printed 6/28/20] 9 SOP-222_R3 (EPA Method 325B}.docx Page ]2 of22 Last Saved 6/28/20] 9 ORIGINAL If not red, destroy this copy after use. Where: C = concentration of target compound at normal ambient temperature and . / 3pressure In ug m mmeas = Measured mass of target analyte in Ilg t = Exposure time in minutes Untp = Diffusive uptake rate (sampling rate) in mLimin unadjusted. Tss = Average field temperature (K) over sampling period ex 24.45Conc. (ppbv) = MW Where: C = Concentration of target analyte in Ilg/m3 MW = Molecular weight of target analyte 24.45 = Specific molar volume of and ideal gas at 25°C and 760 mmHg 11.6 Calculate Analytical Precision for Duplicate Field Samples using the following equation: ([F1 -F2]) Field Precision (%) = F x 100 Where: F1 = A measurement value (mass) taken from one of the two field replicate tubes used in sampling. F2 = A measurement value (mass) taken from the second of two field replicate tubes used in sampling. F = The average of F1 and F2. 12.0 Method Performance: Method performance is demonstrated through MDL studies and demonstrations of capability performed by the analyst. Follow procedures detailed in SOP ENT027, for determining MDLs. Follow the procedures detailed in SOP ENT005, for performing demonstrations of capability. 13.0 Pollution Prevention and Waste Management: Expired liquid stock standards and any waste generated during standard preparation must be disposed of in the appropriate waste container using the guidance in SOP ENT 023. SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 13 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. 14.0 References: 14.1 Method 325B, Volatile Organic Compounds from Fugitive and Area Sources: Sampler Preparation and Analysis. Federal Register, Vol. 80, No. 230, Tuesday, December 1,2015. 14.2 McClenny et aI., 24h diffusive sampling of toxic VOCs in air onto Carbopack X solid adsorbent followed by thermal desorption/GCIMS analysis -laboratory studies. J. Environ. Monit., 2005, 7, 248-256. 15.0 Tables, Diagrams, and Flow Charts: 15.1 Appendix A: Table 1: Target Analyte List 15.2 Appendix A: Table 2: Instrument Performance Check criteria 15.3 Appendix B: Table 3: GCIMS Operating Conditions 15.4 Appendix C: Table 4: 325B Data Flags 15.5 Appendix D: Table 5: Acceptance Criteria and Requirements for All Runs Revision History: Revision# Date: Author: Comments: 3.0 04/19/2019 Glenn Graham Updated to reflect new Internal Standard and to clarifY requirements and remedial actions for requirement failures. Listed Enthalpy exceptions to the method requirements. 2.0 6/20118 Glenn Graham Updated to reflect EPA ALT-122 concentration calculations. Removed System Blank and separate BFB requirements. 1.0 12/1115 C. Thrasher; A. Pope Updated per published method 0.0 09/04/13 David Berkowitz SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 14 of22 Last Saved 6/28/2019 ORIGINAL If not red l destroy this copy after use. Appendix A TABLE 1: Target Analyte List: ! !Analyte Name Quantitation Ion CAS Number 1,3-Butadiene 54 106-99-0 Benzene (Cyc1ohexatriene) 78 71-43-2 Toluene (Methyl benzene) 91 108-88-3 Ethylbenzene 91 100-41-4 m-/p-Xylene (1,3& 1, 4-Dimethylbenzene) 91 108-38-3 106-42-3 o-Xylene (1, 2-Dimethylbenzene) 91 95-47-6 Internal Standards Benzene-d6 84 1076-43-3 Toluene-d8 98 2037-26-5 i 4-Bromofluorobenzene 95 460-00-4 TABLE 2-Tune Acceptance Criteria MASS TO-IS Ion Abundance Criteria 8 to 40% of mass 95 75 50 30 to 66% of mass 95 95 Base Peak:, 100% Relative Abundance All ion abundances must be normalized to the 95 mass 96 5 to 14% of mass 95 (if using hydrogen as the carrier gas) 173 <2% of mass 174 174 o of mass 95 175 "mass 174 176 ~to 101% of mass 174 177 5 to 9% of mass 176 SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 15 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. Appendix B , hold for 0.0 min; TABLE 3. GENERAL GCIMS OPERATING CONDITIONS Rtx-l (60m x O. 52-mm x 1.0 !-lm film Chromatography Column Carrier Gas thickness) UHP grade Hydrogen (1.8 mLimin set by ATD6SO) Initial Column Temperature GC Temperature Initial Hold Time S.O minutes Program Program Final Hold Time Mass Range Scan Time Mass Spectrometer EI Condition Mass Scan Valve Temp: 250°C Transfer Line Temp: 22SoC IS Loop Volume: Scc Dry Purge: 30cc/min for 4.0min Column flow: 1.8cc/min UHP Hydrogen Outlet split: 8.0cc/min ATD650 Conditions Percent Sam Ie Inj: 18.4% ~~------~~~---+----~--------~----------------~Tube Desorb: 50cc/min for 8 min 325°C Rate of Heating: Trap: -10°C Desorb: 330°C for 8 min Focusing Trap: Rate: 40°C/sec. Flow during desorb: 1.8cc/min Note: The GC/MS operating conditions presented in the Table 3 are an example. Actual instruments conditions may vary as the instrument is optimized. SOP # ENT222 Revision 3.0 Last Printed 6/28/20] 9 SOP-222_R3 (EPA Method 325B).docx Page ]6 of22 Last Saved 6/28/20] 9 -- I ORIGINAL If not red, destroy this copy after use. Appendix C . TABLE 4. 325B Data Flags Definition/ExplanationCODE The analyte was not present above the Method Detection Limit. J ND Estimated Value -The analyte was detected between the Method Detection Limit and Reporting Limit. IB E S P Pc PI I M H L D Fe Te X Compound present in field blank(s) greater than 1/3 the compliance limit or measured target analyte Concentration exceeds calibration range Saturated peak Field duplicate(s) exceed 30%RPD - Field duplicate(s) exceed 30%RPD, concentrations of both sample and duplicate are near reporting limit. Field duplicate(s) exceed 30%RPD, lab injection error noted Internal Standard recovery outside acceptance limits rix interference present for primary ion, alternative quantitation procedure used. Sample was analyzed outside of method hold time ...... --.~ Recovery of bracketing CCV(s)exceeded acceptance limits (Apply to sample results) I Sample duration outside 14 + 1 days Field Error (missing diffusion screen cap, other documented issue on COC) Tube Error (Sample tube received with leaky sorbent, bent, or missing or loose storage caps) Case Narrative SOP # ENT222 Revision 3.0 Last Printed 6/2812019 SOP-222_R3 (EPA Method 325B).docx Page 17 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. Appendix D TABLE 5. Acceptance Criteria and Remedial Actions Initial 1) Calibration standard tubes may be I Recondition and re-spike any tubes Calibration stored for no longer than 30 days and past the 30-day mark. should be refrigerated if there is any I risk of chemical interaction or degradation. 2) Each TD/GC/MS system must be calibrated using at least five concentrations that span the monitoring range of interest. 3) 4) 5) Each GC/MS system must be recalibrated with a full calibration curve following corrective action that involves venting the MS or performing maintenance that will make the response factor criteria unachievable. Recalibration Yearly or when CCV criteria cannot be met. The %RSD of the RF for each analyte must be s; 30%. 6) The results of the analysis of each analyte in each calibration level must be within 30% of its tag value. 7) r------­ RRT for target peaks ±0.06 units from mean RRT ~.. ICV 1) 2) An ICV should be run with each ICAL Results of the analysis of the ICV standard must be within 30% of its tag value. 3) ICV must be from a second source. a) Remake failing level if obvious, instrument or prep issue. b) Otherwise perform maintenance/tuning and run newly prepared initial calibration curves tubes. a) Remake failing level if obvious instrument or prep issue. b) Otherwise perform maintenance/ tuning and run re-prepared initial calibration curves tubes. Perform maintenance and rerun initial calibration. a) Remake ICV tube and re-inject. b) Perform maintenance and re-ICAL the instrument. SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 18 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. BFB Tune Check 1) Must meet the performance criteria listed in Table 2 of Appendix A of the 325B SOP with the exception of m/z 96. M/z 96 percentage of m/z 95 may be excepted up to 14% of m/z 95 due to protonation from the use of hydrogen. 2) i If a BFB tube and a CCV are both run , the BFB tune must be reported from the tube run closest in time to the samples. I 3) Required at the start of sequence and valid for 24 hour from time of injection. i 4) BFB tune check percentages may not be rounded to the nearest whole digit for the purpose of passing BFB. 5) Ending CCVs do not need to be injected within the BFB clock provided no maintenance or tuning is performed between the last sample and the CCV injection and there is no more than a four hour time lapse. a) Retune and or perform ~:l maintenance and rerun BFB tune. b) Document any exceptions for protonation in the job narrative. I CCV 1) 2) 3) The Internal Standard response of a) Perform maintenance / tuning and the Daily CCV must be at or within ± rerun the Daily CCV. 40% of the average of the ICAl b) b) If the Daily CCV will not pass, Internal Standard responses. -run a new ICAL. The Internal Standard response of the remaining CCVs must be at or within ± 40% of the Daily CCV Internal Standard response. a) Perform maintenance/tuning and rerun the CCV and affected sequence/sequences starting with a new Daily CCV. b) If the RFs are in agreement with the CCVs with normal responses, there was probably a bad injection which would not affect sample results and the data can be reported with appropriate narration. The percent difference (%D) between Perform maintenance/tuning and the analyte RFs in the CCVs and rerun the CCV and affected sequence / corresponding average RF from the sequences starting with a new Daily initial calibration must be $;30%. CCV. i SOP# ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 19 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use, 4) 5) An additional CCV must be run at the end of every ten field samples (not including field blanks) and to close out the sequence. This analysis may be outside of the 24hr BFB clock if all samples are within the clock. The CCV for a subsequent set of samples may be used as the final CCV for a previous analytical sequence, provided the same analytical method is used and the subsequent set of samples is analyzed within 4 hours of last CCV. a) Perform maintenance/tuning and rerun the CCV and affected sequence / sequences starting with a new Daily CCV. b) If samples must be reported using a failing bracketing CCV, flag samples for possible invalidation. • Method Blank Field Blank 1) 2) 3} 1) Internal Standard (IS) area response ±40% and IS Retention Time (RT) ±O.33 min. of most recent daily calibration check. <2.5 ng per VOC targeted compound or 3 times the LOD, whichever is greater. One Method Blank run per each twenty field samples. Internal Standard (IS) area response ±40% and IS Retention Time (RT) ±O.33 min. of most recent daily calibration check. 2) <2.5 ng per VOC targeted compound or < 1/3 of the field sample level. a) Repeat analysis with a new blank tube. b) Check system for leaks, contamination. c) Analyze an additional blank. a) Inspect chromatogram for signs of possible moisture issues and perform an additional nitrogen purge if needed before running recollect. b) If moisture is not the issue, proceed with a recollect analysis after performing maintenance as deemed necessary. c) If responses still are not met, flag field blank for possible invalidation. If criteria are not met, flag samples less than three times the field blank level. SOP# ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 20 of22 Last Saved 6/2812019 ORIGINAL If not red, destroy this copy after use. Duplicate samples must agree within 30%. Duplicate 1) If Duplicates do not match according to method criteria, samples from the associated job should be flagged with a P or Pc flag. 2) Sample 1) 2) 3) Blank Checked Tubes 1) 2) a) Duplicates that exhibit signs of moisture should be re-analyzed after additional nitrogen purging if deemed necessary. b) A poor injection leading to failure for a duplicate and/or its corresponding sample should result in a recollect analysis ofthe affected tube. Pc flag data sets for which the duplicate samples do not agree within 30 percent and the concentrations of both tubes are near reporting limit. Internal Standard (IS) area response ±40% and IS Retention Time (RT) ±0.33 min. of most recent daily calibration check. a) Inspect chromatogram for signs of possible moisture issues and perform an additional nitrogen purge if needed before running recollect. b) If moisture is not the issue, proceed with a recollect analysis after performing maintenance, if deemed necessary. c) If responses still are not met, flag sample for possible invalidation. Sampling time for tubes must be 14.0 ± 1.49 days Flag samples that are outside the criteria. Target peaks that have saturated the detector should have their results "5" flagged. The saturation should be documented in the narrative for the job. Internal Standard (IS) area response ±40% and IS Retention Time (RT) ±0.33 min. of most recent daily calibration check. a) Rerun the failing tube to verify it is blank. b) Run another tube from the same batch in place of the tube with failing IS response to verify the batch is good. One tube analyzed for each batch of tubes cleaned or 10 percent of tubes whichever is greater. Tubes must be verified to be < 2.5 ng of benzene before use of the box of tubes for sampling is permitted. Failure of a tube triggers the reconditioning of all non-verified clean tubes from that tube's oven batch. SOP # ENT222 Revision 3.0 Last Printed 6/28/2019 SOP-222_R3 (EPA Method 325B).docx Page 21 of22 Last Saved 6/28/2019 ORIGINAL If not red, destroy this copy after use. 3) • 100% of new tubes must be verified to be < 2.5 ng of benzene after initial conditioning and before use. Failure of a tube triggers the recleaning and reanalysis of that tube I until the tube passes the 2.5 ng limit. 4) Blanked tubes should be processed using the Daily CCV response factors and the response for benzene should include the contribution from the benzene-d6. I j SOP # ENT222 Revision 3.0 Last Printed 6/2&12019 SOP-222_R3 (EPA Method 325B}.docx Page 22 of22 Last Saved 6/2&/2019 Standard Operating Procedure – Collection and Analysis of Summa Canister Page 1 of 1 STANDARD OPERATING PROCEDURE SOP Title: Summa Canister Sampling Implementation Date: September 9, 2020 Document Number: 928ET-772315-SP-1 SOP Owner (Department): AQS Revision Number: R1 SOP Approval: Austin Heitmann, CPM Montrose Air Quality Services 990 W 43rd Ave, Denver, CO 80211 T: (303) 670-0530 www.montrose-env.com Summa Canister Sampling Standard Operating Procedure: 1. Remove canister from box. 2. Check plug on canister is on tight 3. Confirm the valve on the canister is closed 4. Remove the plug from the inlet of the canister and reserve for after sample collection. If there is an additional fitting attached to the valve, make sure to hold the hex below the plug still with a ½” wrench to remove the plug. Failure to do this may cause the canister to lose vacuum. 5. Remove the cap from the bottom of a sample regulator. (Note: There is a removable graphite/vespel ferrule on this fitting – take care to make sure it is not lost when removing.) 6. If the ferrule falls out, place the ferrule on the tubing stub of the regulator with the taped end facing the connection to be made. 7. Connect the regulator to the sample canister. Tighten the nut on the regulator ¼ turn past finger-tight. Make sure to hold the hex of the additional fitting still (if present) with a ½” wrench to ensure that it’s snug. 8. Check and note if the needle is not on zero on the vacuum gauge. 9. Ensure the inlet nut on the inlet filter to the regulator is on and tight. 10. Mount the canister on a tripod (same tripod as a continuous monitor, if applicable) approximately 4-7 feet off the ground. 11. Open the valve on the canister and note the vacuum in the canister. The canister has acceptable vacuum if the gauge reads between 23-28 InHg – please add or subtract any zero offset noted. 12. Allow the regulator to equilibrate for 30 seconds then close the valve on the regulator. 13. To check for leaks, observe the vacuum gauge for 30 seconds to make sure the needle does not move toward zero. 14. If leaking repeat steps above after tighten the fittings an additional 1/8 of a turn. Do this systematically one at a time starting at the canister and moving toward the inlet of the regulator. 15. When ready to sample remove the nut from the inlet of the regulator and open canister. Record sampling information on the COC – Sample ID, Can #, Regulator #. 16. When finished sampling each canister, make sure 2 to 10 InHg of vacuum remains in canister. Note this value on the COC. 17. Close the canister valve 18. Remove regulator from canister 19. Replace nut on top of canister and tighten ¼ turn past finger-tight 20. Replace cap on the bottom of the regulator and plug at inlet. Tighten both ¼ turn past finger- tight. Manufacturer’s Specification Sheets – PID Analyzers and Meteorological Sensor WX Series WX Ultrasonic WeatherStation® Instruments for Land Applications Delivering a Compact, Affordable Instrument for Informed Decision-Making WX Series LAND APPLICATIONS FEATURES • Model 110WX – Measures apparent wind speed and angle, barometric pressure, air temperature, relative humidity, calculated dew point, heat index and wind chill temperature • Models 150WX and 200WX – Includes all 110WX functionality plus internal compass and GPS (for true wind speed and direction), GPS position, speed over ground, course over ground • Model 200WX – Best-in-class dynamic stabilization via three-axis compass and three-axis rate gyro • UV stabilized, compact housing is fully waterproof and resistant to chemicals and sunlight Actual Size Available Models: 110WX, 150WX, 200WX Whether you are harvesting crops, operating equipment, preparing for bad weather or responding to a hazardous event; understanding the weather is important. The WX Series allows users to make informed decisions based on site specific information, resulting in improved efficiency, reduced risks and overall cost savings. Various model options are available depending on the application and requirements. The WX Series WeatherStation Instruments offer a truly best-in-class solution at a better price point compared to any other weather monitoring system on the market today! Product Models to Satisfy Multiple Weather Needs 110WX 150WX 200WX Apparent Wind Model Apparent & True Wind Models Recommended for Stationary Applications Recommended for Moving Vehicle Applications Recommended for Dynamic Moving Vehicle Applications Apparent wind speed and angle ✓✓✓ True wind speed and direction ✓✓ Barometric Pressure ✓✓✓ Ultrasonic wind readings up to 90 mph (78 knots, 40 m/s)✓✓✓ Air temperature plus calculated wind chill ✓✓✓ ✓✓ 10 Hz GPS (Position, COG, SOG) ✓✓ Two-axis solid state compass ✓ Three-axis accelerometer for pitch and roll ✓✓ Three-axis solid-state compass with dynamic stabilization: Better than 1° static compass accuracy Best-in-class 2° dynamic compass accuracy ✓ Three-axis rate gyros provide rate-of-turn data ✓ Best-in-class pitch and roll accuracy ✓ Optional field-serviceable relative humidity Calculated dew point Calculated heat index ✓✓✓ Output options include: NMEA 0183 (RS422) and NMEA2000® (CAN Bus) NMEA 0183 (RS232) and NMEA2000® (CAN Bus) ✓✓✓ Developer Assistance • Enable/disable functionality • Optimize communications bandwidth NMEA 0183 (RS232, RS422) • Change sampling rate (output interval) Field Installation Assistance • Enable/disable functionality • Sensor orientation • Compass calibration • Temperature offset • Select specific device on a NMEA2000® network • Alarms for wind speed and barometric pressure • Altitude offset • More accurate GPS position in 2D mode • More accurate BP reading WeatherCaster™ Software Now available on iTunes — OnSiteWX The innovative App for real-time weather data! Achieving Best-in-Class Product Specifications SPECIFICATIONS Wind Speed Range: — 0 knots to 78 knots (0 MPH to 90 MPH, 0 m/s to 40 m/s) Wind Speed Resolution: — 0.1 knot (0.1 MPH, 0.1 m/s) Wind Speed Accuracy @ 0°C to 55°C (32°F to 131°F), no precipitation*: — Low Wind Speeds: 0-10 knots; 1 knot RMS +10% of reading (0 MPH to 11.5 MPH; 1.1 MPH + 10% of reading) (0 m/s to 5 m/s; 0.5 m/s + 10% of reading) — High Wind Speeds: 10-78 knots; 2 knots RMS or 5%, whichever is greater (11.5 MPH to 90 MPH; 2.3 MPH or 5%, whichever is greater) (5 m/s to 40 m/s; 1 m/s or 5%, whichever is greater) Wind Speed Accuracy in wet conditions**: — 5 knots RMS (5.7 MPH RMS, 2.5 m/s RMS) Wind Direction Range: 0° to 360° Wind Direction Resolution: 0.1° Wind Direction Accuracy @ 0°C to 55°C (32°F to 131°F), no precipitation*: — Low Wind Speeds (5° RMS typical): 4-10 knots (4.6 MPH to 11.5 MPH, 2 m/s to 5 m/s) — High Wind Speeds (2° RMS typical): >10 knots (>11 .5 MPH, >5 m/s) Wind Direction Accuracy in wet conditions** (8° RMS Typical): >8 knots (>9.2 MPH, >4 m/s) Compass Accuracy: — 1° RMS when level—(150WX only) — 1° static heading accuracy; 2° dynamic heading accuracy—200WX only Pitch and Roll Range / Accuracy: ±50° / <1°—150WX & 200WX Air Temperature Range: -40°C to 55°C (-40°F to 131°F) Air Temperature Resolution: 0.1°C (0.1°F) Air Temperature Accuracy: ±1.1°C (±2°F)* @ >4 knots wind (>4.6 MPH wind) (>2 m/s wind) Barometric Pressure Range: 300 mbar to 1100 mbar (24 inHg to 33 inHg, 800 hPa to 1100 hPa) Barometric Pressure Resolution: 0.1 mbar (0.029 inHg, 0.1 hPa) Barometric Pressure Accuracy: ±1 mbar (±0.029 inHg, ±1 hPa) when altitude correction is available Relative Humidity Range: 10% to 95% RH Relative Humidity Accuracy*: ±5% units RH GPS Position Accuracy: 3 m (10’) with WAAS/EGNOS (95% of the time)—150WX & 200WX Operating Temperature Range: -25°C to 55°C (-13°F to 131°F) Supply Voltage: 9 VDC to 40 VDC Supply Current (@ 12 VDC): — (<50 mA) <0.6W —110WX — (<85 mA) <1.0W —150WX — (<105 mA) <1.25W —200WX Weight: 300 grams (0.8 lb) Communication Interface: NMEA 0183 (RS422 or RS232) and NMEA2000® (CAN bus)*** Mounting Thread Size on Base: 1”-14 UNS or 3/4” NPT Certifications and Standards: CE, IPX6 (Relative Humidity/IPX4), RoHS, IEC61000-4-2, IEC60945 IEC60950_1C, IEC60950_22A, EN55022, EN55024, EN15014982 RMS—Root Mean Square *When the wind speed is less than 2 m/s (4.6 MPH) and/or air temperature is below 0°C (32°F), wind, temperature, and relative humidity readings will be less accurate. **Wet conditions include moisture, rain, frost, dew, snow, ice and/or sea spray in the wind channel. ***Airmar has made the address claiming modifications to enable compatibility with the ISO 11783 communication protocol for the agriculture industry – that is based on the SAE J1939 protocol. DIMENSIONS ø 75 mm (2.96”) WX With Heated Cap WX Series ø 72 mm (2.83”)90 mm (3.54”)131 mm (5.16”)90 mm (3.54”)131 mm (5.16”)ø 45 mm (1.77”) ø 45 mm (1.77”) DATA OUTPUT PROTOCOL NMEA 0183 Sentence Structure $GPDTM ...........GPS Datum Reference $GPGGA ...........GPS Fix Data $GPGLL ............Geographic Position—Latitude and Longitude $GPGSA ...........GNSS DOP and Active Satellite $GPGSV ............Satellites in View $GPRMC ...........Recommended Minimum GNSS $GPVTG. ...........COG and SOG $GPZDA ...........Time and Date $HCHDG ..........Heading, Deviation, and Variation $HCHDT ...........True Heading $HCTHS ............True Heading and Status $TIROT ..............Rate of Turn $WIMDA ..........Meteorological Composite $WIMWD .........Wind Direction and Speed $WIMWV. .........Wind Speed and Angle $WIMWR ..........Relative Wind Direction and Speed $WIMWT ..........True Wind Direction and Speed $YXXDR ............Transducer Measurements NMEA2000® Output Message Structure 59392 ...............ISO Acknowledgement 060928 .............ISO Address Claim 126208 .............Acknowledge Group Function 126464 .............PGN List 126992 .............System Time 126996 .............Product Information 126998 .............Configuration Information 127250 .............Vessel Heading 127251 .............Rate of Turn 127257 .............Attitude 127258 .............Magnetic Variation 129025 .............Position and Rapid Update 129026 .............COG and SOG, Rapid Update 129029 .............GNSS Position Data 129033 .............Time and Date 129044 .............Datum 129538 .............GNSS Control Status 129539 .............GNSS DOPs 129540 .............GNSS Sats in View 130306 .............Wind Data 130310 .............Environmental Parameters 130311 .............Environmental Parameters 130312 .............Temperature 130313 .............Humidity 130314 .............Actual Pressure 130323 .............Meteorological Station Data PART NUMBERS 110WX: 44-820-1-01, RH, NMEA 0183 (RS422) and NMEA2000® (CAN Bus) 110WX: 44-823-1-01, NMEA 0183 (RS422) and NMEA2000® (CAN Bus) 110WX: 44-843-1-01, RH, NMEA 0183 (RS232) and AG (CAN Bus) 150WX: 44-832-1-01, RH, NMEA 0183 (RS422) and NMEA2000® (CAN Bus) 150WX: 44-833-1-01, NMEA 0183 (RS422) and NMEA2000® (CAN Bus) 150WX: 44-834-1-01, RH, NMEA 0183 (RS232) and AG (CAN Bus) 200WX: 44-835-1-01, NMEA 0183 (RS422) and NMEA2000® (CAN Bus) 200WX: 44-837-1-01, RH, NMEA 0183 (RS422) and NMEA2000® (CAN Bus) 200WX: 44-847-1-01, NMEA 0183 (RS232) and NMEA2000® (CAN Bus) * Cables sold separately RH— Relative Humidity www.airmar.com @2015 Airmar Technology Corporation WX_Series_LAND_APP_rA 09/21/15 As Airmar constantly improves its products, all specifications are subject to change without notice. All Airmar products are designed to provide high levels of accuracy and reliability, however they should only be used as aids to navigation and not as a replacement for traditional navigation aids and techniques. WeatherStation® and WeatherCasterTM are registered trademarks and trademarks of Airmar Technology Corporation. Other company or product names mentioned in this document may be trademarks or registered trademarks of their respective companies, which are not affiliated with Airmar. Performing Above and Beyond Competitive Products on the Market Wind Angle Error Comparison 50 knots Wind Angle Error (°)10 8 6 4 2 0 -2 -4 -6 -8 -10 0 45 90 135 180 225 270 315 360 ◆ WX Series ▲ Gill Windsonic™ • FT Tech Wind Angle (°) Wind Speed Error Comparison 50 knots Wind Speed Error (knots)10 8 6 4 2 0 -2 -4 -6 -8 -10 0 45 90 135 180 225 270 315 360 ◆ WX Series ▲ Gill Windsonic™ • FT Tech Wind Angle (*) Virtually all mechanical and ultrasonic anemometers report apparent wind speed and direction. The Airmar WX Series is unique because it calculates both true and apparent wind speed and direction. These wind readings are the same if the unit is mounted in a fixed location. However, if the WX  Series is mounted on a moving vehicle, the apparent wind is the wind you would feel on your hand if you held it out the window while going down the highway. Since the WX Series has a built in GPS and compass, it calculates the true wind based upon the apparent wind, speed of the vehicle, and compass heading. True wind information is significant for numerous appli- cations on hazardous response vehicles. True wind speed and direction is also mission-critical. When en route to an emergency situation, first responders can use the true wind readings to predict wind conditions at the disaster site before they even arrive, giving vital information for planning  operations and staging apparatus. Each WeatherStation Instrument is factory calibrated in a wind tunnel at our state-of-the-art facility located in Milford, New Hampshire, USA. Airmar’s WX Series products are the only all-in-one unit to offer true and apparent wind speeds without additional sensors. Vehicle traveling North @ 60 MPH Apparent Wind = 60 MPH True Wind = 5 MPH East (Actual wind speed and direction if the vehicle is not moving Understanding True and Apparent Wind wind Model 91000 Response ONE ™ Ultrasonic Anemometer Model 91000 Response ONE ™ Ultrasonic AnemometerYOUNG Copyright © 2017 R.M. Young Company. Specifications subject to change without notice. Printed in USA. 2/17 ResponseONE™ is a trademark of the R.M. Young CompanyR.M. YOUNG COMPANY 2801 Aero Park Drive Traverse City, Michigan 49686 USA TEL: (231) 946-3980 FAX: (231) 946-4772 E-mail: met.sales@youngusa.com Web Site: www.youngusa.com Complies with applicable CE directives. Wind Speed Range: 0 – 70 m/s (156 mph) Resolution: 0.01 m/s Starting Threshold: <0.01 m/s Accuracy: ±2% or 0.3 m/s (0 – 30 m/s) ±3% (30 – 70 m/s) Response Time: <0.25 seconds Wind Direction Azimuth Range: 0 - 360 degrees Resolution: 0.1 degree Starting Threshold: <0.01 m/s Accuracy: ±2 degrees Response Time: <0.25 seconds Electronic Compass Range: 0 – 360 degrees Resolution: 1 degree Accuracy: ± 2.0 degrees Serial Output (selectable) Interface: RS-232, RS-485/422, SDI-12 Formats: NMEA, SDI-12, ASCII (polled or continuous) Baud Rates: 1200, 4800, 9600, 19200 and 38400 Wind Units: m/s, knots, mph, kmph Output Update Rate: 0.1 to 10 HZ Power Voltage: 10 – 30 VDC Current: 7 mA @ 12 VDC typical, 80 mA max General Protection Class: IP66 EMC Compliance: FCC Class A digital device, IEC Standard 61326-1 Dimensions: 22.0 cm high x 13.5 cm wide Weight: 0.5 kg (1.1 lb) Shipping Weight: 1.4 kg (3.1 lb) Operating Temperature: -40 to +60 °C Removable Bird Spikes: Included The YOUNG Response ONE ™ Ultrasonic Anemo meter is designed to reliably measure wind speed and direction. The Response ONE ™ is wind tunnel calibrated and will accurately measure wind speeds up to 70 m/s (156 mph). The high sampling rate of the Model 91000 provides for fast response to changing wind conditions and wind data may be updated as fast as 10 times per second. An easy-to-use Windows setup program is provided with each sensor. The program allows the user to customize device settings such as sampling rates and communication parameters. The compact IP-66 rated design features durable, corrosion-resistant construction. A variety of useful standard serial output formats are provided including SDI-12, NMEA, and ASCII text. The sensor installs on readily available 1 inch (IPS) pipe and wiring connections are made in a convenient weather-proof junction box. Special connectors and cables are not required. The Model 91000 is available in black or white. Response ONE ™ Ultrasonic Anemometer – White .............91000 Response ONE ™ Ultrasonic Anemometer – Black ..............91000B Ordering Information MODEL Specifications The Response ONE ™ is compatible with a broad range of data loggers and displays, including the YOUNG Model 06206 Marine Wind Tracker. www.gasleaksensors.com Innovative Detection Solutions SENSIT® SPOD VOC EMISSIONS AND AIR POLLUTANT MONITORING SYSTEM SENSIT® SPOD sensors help detect, locate and continuously monitor air pollutant sources. MADE IN THE USA WITH GLOBALLY SOURCED COMPONENTS A remote air quality monitoring platform and pollution data management system SENSIT® SPOD Standard Features • Real-time Continuous Monitoring • Modular Data Transmission • Cellular (4G IoT default) • Local RF (Optional) • Total VOC Output: (Variable range) • Auxiliary Port for Automated Sampling • Solar Compatible with Integrated Battery Backup Applications • Fenceline emissions monitoring • Large-scale outdoor air monitoring • Community stations The SENSIT® SPOD is a low-cost, solar-powered sensor system that combines wind and air pollutant concentration measurements to detect VOC emission plumes and help locate the source of emissions. With a small footprint, the user-friendly SENSIT® SPOD is designed for near-fenceline applications where localized emissions may be present. This Next Generation Air Measurement (NGAM) sensor offers real-time continuous monitoring and direct-reading, without laboratory analysis at a lower cost than traditional methods. The SENSIT® SPOD features solar charging and global cellular integration for remote operation. Accessories • 4 Port Canister Valve Controller • Canister Pressure Monitors • 4 Port Sorption Tube Sampler SENSIT® SPOD includes an Ultrasonic weather station for wind speed, direction, temperature, humidity, and pressure. PRODUCT SPECIFICATIONS Weight Base unit: Dimensions 6x8x16” (Fully assembled with anemometer and antenna) Mounting Attached mounting flanges Voltage Requirements 18-24 DC Charging (wired adapter or solar panel) Current Requirements 2A max current draw when charging Operating Runtime 2-3 days battery backup Operating Temp -20°C to 50°C Data Outputs Digital wired output (3.3V TTL - USB) 4G NB-IoT or Cat M1 Wireless SD card data backup Periodic Maintenance Periodic cleaning of sensor openings of dust, zero point calibration, and single point span calibration. User replacement of sensors is easily performed as needed. Data Page Sampler Page Settings Page Distributed by: © SENSIT TECHNOLOGIES REV: 2-1-2020 851 Transport Drive Valparaiso, IN 46383-8432 Phone: 888 4SENSIT 888 473 6748 219 465 2700 Fax: 219 465 2701 www.gasleaksensors.com SENSIT Technologies is an ISO 9001:2015 certified company. MADE IN THE USA WITH GLOBALLY SOURCED COMPONENTS Canary-S Datasheet Lunar Outpost 2019 I. Introduction The Canary-S is a continuous solar powered air quality and meteorological monitoring system designed to be class leading in size, reliability, and flexibility. With cellular communication these systems can be placed nearly anywhere to provide measurements on particulate matter, targeted gases, and meteorological data. Multiple units can be deployed to create a network of real-time data integrated into existing customer databases or into Lunar Outpost’s platform. II. Mechanical A. Physical Properties See Table 1. B. Mounting Options The Canary enclosure allows mounting to either tripods, large diameter poles, or DIN rails. C. Certifications and Environmental The Canary enclosure meets the following certifications: UL508A, UL 50, CSA-C22.2 No. 14, NEMA 1,2,3,3R,4,4X,5,6,6P,12,13, UL94V-0 Flame rating, and UL746C-F1 UV and submersion testing. The original enclosure before modification had an IP68 rating. The rating after modification is reduced due to the designed addition of vents for airflow, but the unit maintains protections against inclement weather when mounted correctly. The enclosure is UV-Stabilized Polycarbonate and the units have undergone extensive testing in a variety of outdoor environments to ensure robust functionality. Canary units have an operational temperature range of -20F to 140F (-28.89C to 60C). III. Power Table 2: Power characteristics of air quality monitor Battery Charging Chemistry Lithium-Ion Solar Panel 12V DC (20W) Capacity 8000 mAh Solar Charge Controller 12V DC Run-time without power input 120 hours* *under proper conditions Wall Charger 120V AC (US std) input to 12V DC output (24W) Dimension Value Width 8.6 in Height 10.0 in Depth 6.7 in Weight ~4.3 lbs Canary – S Air Quality Monitoring System Gen 4 Revised: 12/17/19 8.6in (21.8cm) 10.0in (25.4cm) 6.7in (17.0cm) Table 1: Physical Properties of air quality monitor Canary-S Datasheet Lunar Outpost 2019 IV. Communication and Data Canary-S units communicate over commercial cellular bands and data is transmitted to a secure cloud. From the cloud, the data can be routed to the customer’s database or Lunar Outpost’s custom database. The connection to the cloud is database agnostic, allowing integration with a variety of commercial or custom databases. Table 3 and 4 outline the cellular data connection specifications of two of the cellular modems used in the Canary units. A. Cellular Communication Table 3: 2G/3G Cellular Data Connection Specifications Network 2G/3G HSPA/GSM Cellular Modem Ublox SARA-U260 HSPA Bands 850/1900 MHz GSM Bands 850/1900 MHz Table 4: 4G Cellular Data Connection Specifications Network 4G LTE Cat M1 Cellular Modem Ublox SARA-R410M LTE Bands 3, 4, 5, 8, 12, 13, 20, 28 2G/3G Bands None B. Data The Canary-S allows for data integration into the platform of choice and puts data ownership and control in the customer’s hands. JSON formatting is used for the data unless otherwise requested by the customer. Micro-SD capability allows for data-backups and redundancy storing up to 7 years of data locally.  Integrate to client database: Canary-S data can be routed to a customer’s existing database or routed to multiple databases simultaneously.  Lunar Outpost’s custom database: Lunar Outpost’s custom database is an effective, user friendly platform that allows customers to view, interact with, analyze, and download data. V. Sensors Table 5: Base Unit Sensor Specs Table 6: Optional Sensor Specs Property Range Max Resolution Limit Total VOC (tVOC) 0 to 50 ppm 1 ppb Ozone (O3) 0 to 20 ppm 15 ppb NO2 0 to 20 ppm 15 ppb CO 0 to 1000 ppm 4 ppb CO2 0 to 5% volume 1 ppm H2S 0 to 100 ppm 5 ppb SO2 0 to 100 ppm 5 ppb CH4 0 to 50000 ppm 100 ppm External Temperature -40 to 80°C (-40 to 176°F) +/-0.3 °C (0.54 °F) External Humidity 0-100% RH +/-2% Wind Speed 0-75 m/s (0-168mph) 0.01 m/s Wind Direction 0-360 deg +/- 2 deg For more information: info@lunaroutpost.com Property Range Resolution PM2.5 0~1000 μg/m³ 1 μg/m³ PM10 0~1000 μg/m³ 1 μg/m³ Internal Temperature -40 to 85 °C (-40 to 185°F) +/-1.5 °C (2.7 °F) Internal Humidity 0-100% RH +/-3% Atmospheric Pressure 300-1250 hPa (mbar) +/-1.7 hPa (mbar) Kahuna Ventures Letter 11400 Westmoor Circle, Ste. 325 303.451.7374 Westminster, CO 80021 www.kahunaventures.com January 13 2020 Chad Schlichtemeier HES Manager Occidental Petroleum Corp. 1099 18th Street, Suite 1800 Denver, Colorado 80202 RE: Air Monitoring Procedure and Duration Guideline Dear Mr. Schlichtemeier: Occidental Petroleum Corp. (Oxy) has asked Kahuna Ventures (KAHUNA) to recommend sampling procedure and duration guidelines for air monitoring in the vicinity of their operations in Northeastern Colorado. This recommendation will allow for Oxy to best compare air sampling results to the Agency for Toxic Substances and Disease Registry (ATSDR) acute inhalation Minimum Risk Levels (MRL), especially the acute inhalation MRL for benzene. The acute inhalation MRL for benzene is 9 parts per billion (ppb). MRLs are derived when reliable and sufficient data exists to determine an estimate of the daily human exposure to a hazardous substance that is likely to be without appreciable risk of adverse, non-cancer health effects over a specified duration of exposure. Acute inhalation MRLs are derived for a 1 to 14-day inhalation exposure duration. Additionally, MRLs are generally based on the most sensitive chemical-induced end point considered to be of relevance to humans and ATSDR uses a conservative approach in determining the specific MRL in order to address any uncertainty related to the population considered to be most sensitive (infants, elderly, nutritionally or immunologically compromised). Therefore, it is my opinion Oxy should collect a 14-day air sample to compare to the acute inhalation MRL for benzene (9 ppb) and best assess potential impacts to surrounding populations. Sampling should follow the US Environmental Protection Agency (EPA) Method 325A—Volatile Organic Compounds from Fugitive and Area Sources. This Method has been established by the EPA to screen average airborne VOC concentrations at facility property boundaries or monitoring perimeters over an extended period of time. The duration of each sampling period is normally 14 days. This method allows for the collection of volatile organic compounds (VOCs) using passive (diffusive) tube samplers (Supelco Radiello 130 passive badges). This method also requires the collection of local meteorological data (wind speed and direction, temperature, and barometric pressure) in order to effectively determine emission sources and potential impact areas. In addition, Oxy should continuously monitor the sampling locations for Total Organic Vapors (TOCs). This will provide Oxy the data necessary to evaluate potential high emission periods and design further sampling actions. Oxy can then use data obtained as screening levels for potential impacts to surrounding populations. In the event that the average airborne benzene concentration exceeds the acute inhalation MRL for benzene (9 ppb), additional sampling should be conducted. This additional sampling may include 11400 Westmoor Circle, Ste. 325 303.451.7374 Westminster, CO 80021 www.kahunaventures.com evaluation of the continuous VOC monitoring data in order to collect additional samples related to a specific event, such as initial flowback. I would then recommend a 24-hour air sample be collected during this specific event using a SUMMA canister, to further evaluate potential impacts to surrounding populations. If anyone has questions regarding this guideline, please contact me. KAHUNA looks forward to working with Oxy on any future projects relating to this guideline. Sincerely, Jeffrey Citrone, CIH, CSP Manager Health & Safety Compliance 11400 Westmoor Circle, Suite 325 Westminster, CO. 80021 303-407-3150 (Direct) 720-822-3298 (Cell)