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F., Mr. Mark Del Pico <br />March 22, 2011 <br />- Page 2 of 2 <br />Reporting of GHG emissions under the federal reporting requirements is triggered <br />if the total GHG emissions from the facility exceeds 25,000 tons/year C02e. These <br />reporting requirements apply to sources listed in 40 CFR Part 98. <br />Based on the information you have provided, ExxonMobil proposes to emit up to <br />230 lbs. of SF6 during the tracer test. SF6 has a global warming potential of up to <br />23,900 times that of CO2. Thus, the C02e from the proposed test could be as high <br />as 2,749 tons. The total mass of SF6 and the C02e from the test is well below any <br />permitting threshold provided by the CDPHE. Additionally, it does not appear that <br />the reporting of these emissions is required at this time. ExxonMobil's testing <br />operations at the Colony Mine does not constitute one of the regulated sources <br />identified under 40 CFR Part 98. <br />Separately, we have reviewed the applicable CDPHE regulations to determine if the <br />release of SF6 is subject to emissions limitations or control. We have confirmed <br />there are no applicable regulations at this time. <br />Notwithstanding the foregoing, we recommend that ExxonMobil carefully track the <br />amount of SF6 used during the test and have those records available to validate the <br />conclusions of this analysis. <br />Please give me a call at 805-764-6012 if you have any questions. <br />Very truly yours, <br />Bart Leininger, <br />Principal <br />Attachment.