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Final Report for 2020 Southern Ute Indian Tribe

Comprehensive Emissions Inventory for Criteria Pollutants,

Hazardous Air Pollutants, and Greenhouse Gases

__________________________________________________________________

Prepared by:

Southern Ute Indian Tribe

Environmental Programs Division

Air Quality Program

P.O. Box 737, MS# 84

Ignacio, Colorado 81137

(970) 563-4705

Emission Inventory report prepared by Matt Wampler, Air Quality Technical Manager

January 2023

Table of Contents

List of Figures ................................................................................................................................. 2

List of Tables .................................................................................................................................. 3

List of Acronyms ............................................................................................................................ 5

I.

Executive Summary ............................................................................................................. 7

II.

Overview .............................................................................................................................. 8

1.

Purpose of Inventory .................................................................................................... 8

2.

Geographic Location of Southern Ute Indian Reservation .......................................... 8

3.

Climate.......................................................................................................................... 9

4.

Geology ........................................................................................................................ 9

5.

Sources........................................................................................................................ 10

III.

Data Quality Objectives ..................................................................................................... 11

1.

Accuracy ..................................................................................................................... 11

2.

Uncertainty ................................................................................................................. 11

3.

Completeness .............................................................................................................. 11

4.

Comparability ............................................................................................................. 11

IV.

Point Sources ..................................................................................................................... 12

1.

Title V Permitted Oil and Gas Sources ...................................................................... 12

2.

Minor Oil and Gas Point Sources ............................................................................... 14

3.

Permitted Point Sources.............................................................................................. 22

4.

Landfill Gas ................................................................................................................ 22

5.

Airports ....................................................................................................................... 25

V.

Non-Point Sources ............................................................................................................. 27

1.

Small Oil and Gas Sources ......................................................................................... 27

2.

Fruitland Formation Outcrop Natural Gas Seeps ....................................................... 62

3.

Gas Stations ................................................................................................................ 63

4.

Aviation Gasoline ....................................................................................................... 64

5.

Gravel Pits .................................................................................................................. 65

6.

Residential Heating..................................................................................................... 66

7.

Agricultural Burning................................................................................................... 71

VI.

1

Mobile Sources .................................................................................................................. 72

1.

On-Road Mobile Sources ........................................................................................... 72

2.

Non-Road Mobile Sources ......................................................................................... 73

VII.

Events ................................................................................................................................. 74

1.

Wildland Fires and Prescribed Burns ......................................................................... 74

VIII. Biogenic ............................................................................................................................. 76

IX.

Summary ............................................................................................................................ 77

X.

Bibliography ...................................................................................................................... 86

XI.

Appendix – Quality Assurance Review ............................................................................. 89

List of Figures

Figure 1: Southern Ute Indian Reservation total criteria pollutant emissions [tons] .....................................................8

Figure 2: Southern Ute Indian Reservation total criteria pollutant emissions [tons] .....................................................9

Figure 3: Criteria pollutant and HAP emissions at Title V sources [tons] .....................................................................13

Figure 4: NOx and CO emissions from Title V sources by equipment type [tons] ........................................................13

Figure 5: VOC and HAP emissions from Title V sources by equipment type [tons] ......................................................14

Figure 5: Title V speciated HAP emissions [tons] .........................................................................................................14

Figure 6: Criteria pollutant and HAP emissions from synthetic minor sources [tons] ..................................................16

Figure 7: NOx and CO emissions from synthetic minor sources by equipment type [tons] .........................................17

Figure 8: VOC and HAP emissions from synthetic minor sources by equipment type [tons] .......................................17

Figure 9: Speciated HAP emissions from synthetic minor sources [tons].....................................................................18

Figure 10: Criteria pollutant and HAP emissions from true minor oil and gas sources [tons] .....................................20

Figure 11: NOx and CO emissions from true minor oil and gas sources by equipment type [tons] .............................20

Figure 12: VOC and HAP emissions from true minor oil and gas sources by equipment type [tons] ...........................21

Figure 13: GHG emissions from true minor oil and gas sources by equipment type [tonnes] ..................................... 21

Figure 14: Municipal solid waste landfill emissions [tons]...........................................................................................24

Figure 15: CO and NOx emissions from airports [tons] ................................................................................................ 26

Figure 16: VOC and Total HAP emissions from airports [tons] ....................................................................................26

Figure 17: Criteria pollutant and HAP emissions from small oil and gas sources [tons] ..............................................29

Figure 18: NOx and CO emissions from small oil and gas sources by equipment type [tons]......................................29

Figure 19: VOC and HAP emissions from small oil and gas sources by equipment type [tons] ................................... 29

Figure 20: GHG emissions from small oil and gas sources by equipment type [tonnes]..............................................30

Figure 21: Speciated HAP emissions from small oil and gas sources [tons]................................................................. 31

Figure 22: Engine counts by engine configuration and horsepower at small oil and gas sources ...............................31

Figure 23: CO and NOx emission from small oil and gas sources by engine type [tons]..............................................34

Figure 24: VOC and Total HAP emissions from small oil and gas sources by engine type [tons] .................................34

Figure 25: Liquid storage tanks at small oil and gas sources by tank contents ........................................................... 42

Figure 26: VOC and HAP emissions from liquid storage tanks at small oil and gas sources [tons] ............................. 51

Figure 27: VOC and HAP emissions from Fugitives, Blowdowns, Recompletions, and Pneumatics [tons] .................. 60

Figure 28: GHG emissions from Fugitives, Blowdowns, Recompletions, and Pneumatics [tonnes] .............................61

Figure 29: Average equipment counts at small oil and gas sources by equipment type .............................................61

Figure 30: NOx and CO emissions by source category [tons] .......................................................................................80

Figure 31: VOC and HAP emissions by source category [tons] * ................................................................................... 80

Figure 32: NOx and CO emissions from oil and gas sources [tons] ..............................................................................81

Figure 33: VOC and HAP emissions from oil and gas sources [tons] ............................................................................ 82

Figure 34: GHG (CO2e) emissions from oil and gas sources [tonnes] ...........................................................................82

Figure 35: Comparison of NOx, CO, and VOC emissions from the 2015 SUIT EI, 2017 SUIT EI, and the 2017 SUIT EI

[tons] 83

Figure 36: Comparison of oil and gas NOx, CO, and VOC emission estimations for the Southern Ute Indian

Reservation from the 2015, 2017, and 2020 SUIT EIs [tons]........................................................................................84

2

List of Tables

Table 1: Title V criteria pollutant, HAP, and GHG emissions estimations [tons] * ........................................................13

Table 2: Title V HAP emissions [tons] ...........................................................................................................................14

Table 3: 40 CFR Part 49 Minor New Source Review Program Emissions Thresholds ................................................... 15

Table 4: Criteria Pollutant, HAP, and GHG emissions for synthetic minor sources [tons]* .......................................... 16

Table 5: Speciated HAP emissions from synthetic minor sources [tons] ...................................................................... 18

Table 6: Criteria pollutant and HAP emissions from true minor sources [tons] *..........................................................20

Table 7: Criteria pollutant and HAP emissions from permitted non-oil and gas point sources [tons] .........................22

Table 8: Municipal solid waste landfill refuse in place [tons] and emissions [tons] * ...................................................24

Table 9: Criteria pollutant and HAP emission from airports [tons]* ............................................................................26

Table 10: Emissions from small oil and gas sources [tons]* .........................................................................................28

Table 11: Speciated HAP emissions from small oil and gas sources [tons] ..................................................................30

Table 12: Natural gas-fired reciprocating internal combustion engine counts and criteria pollutant, HAP, and GHG

emissions for small oil and gas sources [tons]*............................................................................................................33

Table 13: Turbine count and criteria pollutant, HAP, and GHG emissions at small oil and gas sources [tons] * ..........36

Table 14: Theoretical extended natural gas analysis – average of 31 natural gas analyses from the Southern Ute

Indian Reservation .......................................................................................................................................................38

Table 15: GRI-GLYCalc Model input parameters for TEG Dehydration units at small oil and gas sources ..................39

Table 16: GRI-GLYCalc Model emissions output for TEG Dehydration units [tons] ......................................................40

Table 17: VOC and HAP Emissions from TEG Dehydration Units from small oil and gas sources [tons] ..................... 41

Table 18: Assumed annual average liquid throughput values for produced water, oil, and condensate tanks at small

oil and gas sources* .....................................................................................................................................................43

Table 19: Produced water flash gas analysis from small oil and gas sources on the Southern Ute Indian Reservation

[Mol %]* .......................................................................................................................................................................46

Table 20: Condensate flash gas analysis from small oil and gas sources on the Southern Ute Indian Reservation [Mol

%]*

46

Table 21: Average gas to water and gas to condensate ratios for small oil and gas sources * ....................................48

Table 22: VOC, HAP, and GHG Emissions from liquid storage tanks at small oil and gas sources [tons] * ...................51

Table 23: Criteria pollutant, HAP, and GHG emissions from heaters and boilers at small oil and gas sources [tons] *53

Table 24: Assumed fugitive emission component counts at single and co-located natural gas well-sites .................. 54

Table 25: Emissions of VOC, HAP, and GHG from equipment leaks and fugitive emission sources at small oil and gas

sources [tons]* .............................................................................................................................................................55

Table 26: VOC, HAP, and GHG emissions from natural gas driven pneumatic devices at small oil and gas sources

[tons]* 57

Table 27: Assumed values for annual natural gas compressor blowdown events occurring at small oil and gas

sources in 2017 ............................................................................................................................................................ 58

Table 28: VOC, HAP, and GHG emissions from natural gas blowdowns at small oil and gas sources [tons] * .............58

Table 29: Assumed values for well completion and recompletion activities at small oil and gas sources * ................. 59

Table 30: VOC, HAP, and GHG emissions from well recompletion activities at small oil and gas sources [tons] * .......60

Table 31: Average equipment counts at single and co-located well-sites at small oil and gas sources ......................61

Table 32: Emissions of methane, CO2, and total GHG in CO2 Equivalent [tonnes] .......................................................63

Table 33: Annual gasoline throughput at gasoline stations located on the Southern Ute Indian Reservation [gal/yr] *

64

Table 34: VOC emissions from gasoline dispensing stations [tons] .............................................................................64

Table 35: VOC and HAP emissions from aviation gasoline [tons]* ...............................................................................65

Table 36: Emissions of PM10 and PM2.5 from active gravel pits ...................................................................................66

Table 37: Fireplace and wood burning residential heating data .................................................................................67

Table 38: Criteria pollutant and GHG emissions from fireplaces and wood burning stoves [tons] * ............................68

Table 39: Liquid propane residential heating data ......................................................................................................69

Table 40: Criteria pollutant and GHG emissions from liquid propane gas heating at residential sources [tons] * .......70

Table 41: Natural gas residential heating data ...........................................................................................................70

Table 42: Criteria pollutant and GHG emissions from natural gas heating at residential sources [tons] * ..................71

3

Table 43: Criteria pollutant, NH3, and HAP emissions from agricultural burning [tons]* ............................................72

Table 44: Criteria pollutant emissions from on-road mobile sources [tons] ................................................................73

Table 45: Criteria pollutant emissions from non-road mobile sources [tons] ..............................................................74

Table 46: Forest fire occurrence by fuels characteristic classification system, fuel bed type, and acres burned.........75

Table 47: Criteria pollutant, NH3, and GHG emissions from prescribed burns and wildland fires [tons] * ...................76

Table 48: Criteria pollutant and HAP emissions from biogenic sources [tons] * ...........................................................77

Table 49: Criteria pollutant, HAP, and GHG emissions on the Southern Ute Indian Reservation [tons] *.....................79

Table 50: Emissions from oil and gas sector sources [tons]* .......................................................................................81

4

List of Acronyms

AP-42

EPA Compilation of Air Pollutant Emission Factors

API

American Petroleum Institute

AQP

Air Quality Program

BIA

United States Bureau of Indian Affairs

BSFC

Brake Specific Fuel Consumption

BTEX

Benzene, Toluene Ethyl-Benzene, Xylene

bbl

Barrel (42 U.S. Gallons)

CAA

Clean Air Act

CARMMS

Colorado Air Resource Management Modeling Study

CDPHE

Colorado Department of Health and Environment

CNG

Compressed Natural Gas

CO

Carbon Monoxide

CO2e

Carbon Dioxide Equivalent

COGCC

Colorado Oil and Gas Conservation Commission

CY

Calendar Year

CFR

Code of Federal Regulations

DRMS

Colorado Division of Reclamation Mining and Safety

EI

Emissions Inventory

EIA

Environmental Impact Assessment

EPA

United States Environmental Protection Agency

FAA

Federal Aviation Administration

GHG

Greenhouse gas

GSJB

Greater San Juan Basin

HAP

Hazardous Air Pollutants

hp

Horse Power

H2S

Hydrogen Sulfide

ICR

Information Collection Request

ITEP

Institute for Tribal Environmental Professionals

Kdf

Cretaceous Fruitland Formation

Kpcl

Cretaceous Picture Cliffs Sandstone

LFG

Landfill Gas

5

LP

Liquid Petroleum

LTO

Landing and Take-off Cycles

MMscf

Million Standard Cubic Feet

MSW

Municipal Solid Waste

NEI

National Emissions Inventory

NMHC

Non-methane Hydrocarbons

NMOC

Non-methane Organic Compounds

NOx

Oxides of Nitrogen

NPS

National Park Service

O3

Ozone

Pb

Lead

PM10

Particulate Matter 10 microns and smaller

PM2.5

Particulate Matter 2.5 microns and smaller

PSD

Prevention of Significant Deterioration

PTE

Potential to Emit

QA

Quality Assurance

RICE

Reciprocating internal combustion engine

scf

Standard Cubic Feet

SO2

Sulfur Dioxide

SUIT

Southern Ute Indian Tribe

TEG

Tri-ethylene Glycol

TEISS

Tribal Emissions Inventory Software Solutions

THC

Total Hydrocarbons

TMNSR

Tribal Minor New Source Review Program

TOC

Total Organic Compounds

tpy

Tons per Year

USFS

United States Forest Service

VOC

Volatile Organic Compounds

WRAP

Western Regional Air Partnership

4SLB

Four stroke lean burn

4SRB

Four stroke rich burn

2SLB

Two stroke lean burn

6

I.

Executive Summary

The Southern Ute Indian Tribe (Tribe) Air Quality Program (AQP) has prepared an emissions

inventory of quantifiable point and non-point sources on the Southern Ute Indian

Reservation (Reservation) for calendar year 2020 (CY2020). The emissions inventory was

prepared according to the Environmental Protection Agency Class II emission inventory

guidelines of using measured data when available or data and emissions factors from

reputable sources when measured data were not available.

Oil and natural gas production is the predominant industry on the Reservation and emissions

data for these sources were collected directly from source operators through annual

emission inventories, registrations from sources under the Tribal Minor New Source Review

(TMNSR) program (true minor sources), and a Clean Air Act (CAA) Section 114 information

collection request issued by the Tribe in June 2021. Data for other sources were collected

from various reputable state, local, and federal data sources.

This report also covers emissions from landfills, nonpoint sources, mobile sources, wildfires,

biogenic sources, and the Fruitland outcrop. Nonpoint sources include agricultural burning,

residential heating, gravel pits. gas stations, and airports.

Reservation emission totals for CY 2020 were 19,743.58 tons of oxides of Nitrogen (NOx),

8,773.01 tons of Volatile Organic Compounds (VOC), 80.94 tons of Sulfur Dioxide (SO 2),

396.57 tons of Particulate Matter 10 micrometers or less in diameter (PM 10), 146.02 tons of

Particulate Matter 2.5 micrometers or less in diameter (PM 2.5), 18,767.33 tons of Carbon

Monoxide (CO), 1,527.28 tons of total Hazardous Air Pollutants (HAP), and 11,342,510.62

metric tonnes of Greenhouse Gas (GHG) emissions measured in Carbon Dioxide Equivalent

(CO2e).

Total criteria pollutant (NOx, VOC, SO2, PM10, PM2.5, CO) and HAP emissions on the

Reservation for 2020 are presented below in Figure 1.

7

Figure 1: Southern Ute Indian Reservation total criteria pollutant emissions [tons]

Total Criteria Pollutant Emissions on the Southern

Ute Indian Reservation in CY 2020 (tons)

1,527.28

18,767.33

542.58

NOx

II.

19,743.58

8,773.01

80.94

VOC

SO2

PM

CO

HAP

Overview

1. Purpose of Inventory

The purpose of this Emissions Inventory (EI) was to establish baseline emissions estimates

for the 2020 calendar year for all quantifiable air emission sources located within the

exterior boundaries of Reservation. The emissions data for the Reservation presented in this

EI has been organized by source category and pollutant. The EI will be used for future air

quality planning purposes, such as development of air quality regulations targeted at ozone

precursors for maintaining attainment with the National Ambient Air Quality Standards,

emissions modeling, and Title V permitting fee analysis.

The primary air pollutants included in this EI are NOx, CO, PM 10, PM2.5, VOC, HAP, and GHG.

2. Geographic Location of Southern Ute Indian Reservation

The Reservation is located in southwestern Colorado. The Reservation land area covers 1,066

square miles in three counties (La Plata, Archuleta, and Montezuma) and borders New

Mexico to the south (Figure 2). The total area covered by this inventory is approximately

682,590 acres, which encompasses all land within the external boundaries of the

Reservation. The Southern Ute Indian Tribe (Tribe) and/or its members own approximately

320,000 acres, while the remaining land mass is comprised of non-Indian and government

land in a checkerboard fashion. The primary land use is agricultural, and the predominant

industry is oil and natural gas production.

8

Figure 2: Southern Ute Indian Reservation total criteria pollutant emissions [tons]

3. Climate

The Reservation remains generally semi-arid throughout the year. Located north of northern

New Mexico desert land and south of the Colorado alpines, the average temperature range

during the winter months average temperatures are between 20 and 40 degrees Fahrenheit.

Freezing temperatures are common throughout the winter and during the 2020 calendar

year the coldest month was February with a low of 3.4 degrees Fahrenheit and a monthly

average of 32.4 degrees Fahrenheit. During the summer months the average high

temperatures were in the high eighties and nineties. The warmest month of 2020 was July

with a high of 99.6 degrees Fahrenheit, and a monthly average of 73.6 degrees Fahrenheit.

Rain was the dominant form of precipitation on the Reservation and total precipitation for

calendar year 2020 was 4.0 inches. The driest month was June with 0.3 inches of

precipitation and the wettest month was August with 2.2 inches of precipitation. 1

4. Geology

The Reservation is situated in the northern portion of the San Juan Basin, a geologic

structural basin underlying southwestern Colorado and northwestern New Mexico. The basin

is composed of Cambrian to Holocene aged sedimentary rocks and contains one of the

1

Southern Ute Indian Tribe: Ambient Monitoring. (2020). 2020 AQS Ute 3 Humidity and Temperature Hourly Data.

Retrieved from: http://www.southernute-nsn.gov/environmental-programs/air-quality/ambient-monitoring/.

9

largest coal-bed methane natural gas fields in the world within the Cretaceous aged Fruitland

Formation.2 The majority of the natural gas production on the Reservation is coalbed

methane from the Fruitland Formation, but conventional natural gas is also produced from

Cretaceous aged sandstone reservoirs of the Pictured Cliffs Formation, Mesa Verde Group,

and the Dakota Sandstone. Tight gas reservoirs of the Cretaceous aged Mancos Shale have

also been drilled, however, no significant exploration and production has occurred within the

Reservation as of 2020.

5. Sources

The sources included in this emissions inventory were organized according to source type

and size. These sources are as follows:

A. Point Sources

1) Title V permitted oil and natural gas sources

2) TMNSR minor oil and natural gas sources, including:

a. Permitted minor TMNSR sources,

b. Registered minor TMNSR sources,

3) Municipal solid waste landfills, and

4) Airports.

B. Non-point Sources

1) Small oil and gas sources,

2) Fruitland Formation Outcrop natural gas seeps,

3) Gasoline stations,

4) Aviation gasoline dispensing,

5) Gravel pits,

6) Residential heating, and

7) Agricultural burning.

C. Mobile Sources

1) On-road vehicles, and

2) Non-road equipment.

D. Events

2

Fasset, J. E., & Hinds, J. S. (1971). Geology and Fuel Resources of the Fruitland Formation and Kirtland Shale of the

San Juan Basin, New Mexico and Colorado. Geological Survey Professional Paper 676. United States Government

Printing Office. Retrieved from https://pubs.usgs.gov/pp/0676/report.pdf.

10

1) Fire events (wildland fires and prescribed burns).

E. Biogenic Sources

III.

Data Quality Objectives

Data objectives for this inventory are as follows:

1. Accuracy

Data for this EI were collected according to EPA level II EI guidelines using measured data

when available or data from reputable sources such as EPA, the Colorado Oil and Gas

Conservation Commission (COGCC) and professional organizations when measured data

were not available.

Emission factors were developed using measured data or commonly accepted emissions

factors and assumptions from EPA and professional organizations.

All data sources, emission factors, assumptions, and emission calculation methodologies

were documented.

Emission calculation models were utilized when available (GRI-GLYCalc 4.0, Tanks 4.09d,

etc.) and all inputs are provided in annual emission reports or 2020 CAA Section 114

Information Collection Request (ICR) worksheets.

Results of the 2020 SUIT EI were compared with results from the 2017 SUIT EI.

Quality Assurance review of emission totals, assumptions, emission factors, and

calculation methodologies was conducted by a third-party contractor.

2. Uncertainty

Reported emissions may be inaccurate.

The number of unreported oil and gas sources is unknown and can only be estimated

based on sources reported to COGCC.

Emissions differences between CY2020 SUIT EI, CY2017 SUIT EI, and CY2015 SUIT EI may

occur due to different preparation methodologies and assumptions.

3. Completeness

Capture 100% of point source emissions reported in the annual emission fees for CY2020.

Capture 95% of non-point oil and gas sources in the 2020 CAA 114 ICR.

Reported information will be used to extrapolate emissions to 100% to fill data gaps.

Capture 80% of area sources (gas stations, etc.).

4. Comparability

11

IV.

EI results will be compared with results from the 2017 SUIT EI and 2015 SUIT EI.

Emission factors and assumptions will be compared with methodologies used in similar

emission calculation applications.

Point Sources

As of 2020, there were a total of 2,860 oil and gas production sources operating on the

Reservation. These sources consisted of 35 sources operating under Title V operating

permits, 11 sources operating under TMNSR permits (synthetic minor sources), 238 true

minor sources, and 2,582 non-point sources with emissions below the TMNSR program

thresholds, referred to in this emissions inventory as “small oil and gas sources”.

1. Title V Permitted Oil and Gas Sources

Description of Sources

Thirty-five oil and gas Title V sources operated on the Reservation during calendar year 2020.

Sources include natural gas compressor stations, central delivery points, treating plants, and

processing plants.

Title V sources are defined as sources with the potential to emit (PTE) 100 tons per year (tpy)

of a single criteria pollutant, 25 tpy of HAP in aggregate, or ten tpy of an individual HAP. The

Tribe has full delegation of a Title V operating permit program under 40 CFR Part 70 and

during calendar year 2020, 35 oil and gas sources operated under Tribally-issued Title V

permits.

Data Collection

Title V sources are required to report emissions annually and pay a per-ton emission fee for

pollutants emitted. Emissions data for Title V sources were collected directly from the

calendar year 2020 fee calculation worksheets submitted by each source to the Tribe. Actual

emissions data were available for all 35 Title V oil and gas sources. GHG emissions, reported

as carbon dioxide equivalent (CO2e) were obtained from fee calculation worksheets (if

provided) and if not, the PTE listed in their most recent Title V permit renewal was used and

cross checked with EPA Facility Level Information on GreenHouse Gases Tool (FLIGHT) at

https://ghgdata.epa.gov/ghgp/main.do. This data collection methodology adheres to the

EPA level II EI guidelines for utilizing measured data when available.

Emissions

12

Total criteria pollutant, HAP, and GHG emissions estimated from Title V sources for the 2020

calendar year are displayed below in Table 1.

Table 1: Title V criteria pollutant, HAP, and GHG emissions estimations [tons] *

Pollutant

NOx

VOC

SO2

PM

CO

Total HAP

GHG

Emissions 2,359.8 1,032.9 46.9 101.9 1,872.9

306.1

2,124,765.3

*CO2e emissions for all Title V sources are reported values obtained from annual Title V fee forms

and EPA GHG data and are reported in metric tonnes

Total criteria pollutant and HAP emissions by equipment type from Title V sources for the

2020 calendar year are displayed below in Figures 3 through 5.

Figure 3: Criteria pollutant and HAP emissions at Title V sources [tons]

Title V Criteria Pollutant and HAP Emissions

for the Southern Ute Indian Reservation in CY

2020 (tons)

306.1

2,359.8

1,872.9

101.9

46.9

NOx

1,032.9

VOC

SO2

PM

CO

Total HAP

Figure 4: NOx and CO emissions from Title V sources by equipment type [tons]

1,573.7

2,000.0

1,821.7

Title V NOx and CO Emissions by Equipment

Type (tons)

5.3

1.0

4.9

20.7

104.6

500.0

136.2

376.9

1,000.0

160.3

1,500.0

Engine

Turbine

Heater

NOx

Boiler

Other

CO

*”Other” includes emissions from amine units, excess emission events, blowdowns, maintenance, and fugitive

emission sources

13

Figure 5: VOC and HAP emissions from Title V sources by equipment type [tons]

681.9

800.0

Title V VOC and Total HAP Emissions by

Equipment Type (tons)

6.5

25.6

46.5

111.5

0.5

19.8

0.0

1.1

2.0

200.0

9.9

90.1

400.0

3.0

247.7

600.0

Engine

Turbine

Heater

Boiler

VOC

Tank

Dehydrator

Other

Total HAP

*”Other” includes emissions from amine units, excess emission events, blowdowns, maintenance, and fugitive

emission sources

Speciated HAP emissions from Title V sources are displayed below in Table 2 and Figure 5.

Table 2: Title V HAP emissions [tons]

Pollutant Formaldehyde Benzene Toluene Ethylbenzene Xylenes Acetaldehyde Acrolein Methanol n-Hexane

Emissions

210.5

8.7

20.8

6.9

27.2

18.9

11.0

4.3

0.9

Figure 5: Title V speciated HAP emissions [tons]

Title V Speciated HAP Emissions (tons)

250.0

210.5

200.0

150.0

100.0

50.0

8.7

20.8

0.0

2. Minor Oil and Gas Point Sources

14

6.9

27.2

18.9

11.0

4.3

0.9

The Tribal Minor New Source Review (TMNSR) permitting program is found at 40 CFR Part

§49.151 through §49.164.3 The TMNSR permitting program includes new or modified source

permitting, permits by rule, and a registration program. For the purposes of this inventory,

two main categories of emission sources under this program were considered: a.) Permitted

TMNSR oil and gas sources, and b.) Registered TMNSR Oil and Gas Sources.

The emission thresholds for the TMNSR permitting program are located at 40 CFR Part

§49.153. Minor sources with emissions less than the levels displayed in Table 3 below are

not required to obtain a permit or register under the program.

The emission thresholds from 40 CFR Part §49.153 are displayed below in Table 3.

Table 3: 40 CFR Part 49 Minor New Source Review Program Emissions Thresholds

Regulated NSR Pollutant

Carbon Monoxide (CO)

Nitrogen Oxides (NOx)

Sulfur Dioxide (SO2)

Volatile Organic Compounds (VOC)

PM Total

PM10

PM2.5

Lead

Fluorides

Sulfuric Acid Mist

Hydrogen Sulfide (H2S)

Total Reduced Sulfur (including H2S)

Reduced Sulfur Compounds (including H2S)

Municipal Waste Combustor Emissions

Municipal Solid Waste Landfill Emissions (measured

as non-methane organic compounds)

Minor NSR Thresholds for

Attainment/ Unclassifiable

[tpy]

10

10

10

5

10

5

3

0.1

1

2

2

2

2

2

10

A. Synthetic minor Oil and Gas Sources

Description of Sources

This category reflects larger emission sources that would be subject to either the

Prevention of Significant Deterioration (PSD), Title V operating permit program, or both

programs absent enforceable emission limitations to reduce the source’s PTE. These

types of permits are often referred to as “synthetic minor permits”.

3 40 CFR Part 49 - Indian Country: Air Quality Planning and Management. (2020). U.S. Government Publishing Office.

Retrieved from http://www.ecfr.gov/cgi-bin/textidx?SID=bc4187dbf0b08beb092efe4251fe4493&mc=true&tpl=/ecfrbrowse/Title40/40cfr49_main_02.tpl

15

During calendar year 2020, eleven sources on the Reservation operated under TMNSR

permits. Of the eleven sources in this category, nine sources are natural gas compressor

stations, and one source is a natural gas processing plant. Five sources have permits to

reduce emissions below Title V permitting thresholds and six sources have permits for

various other reasons.

Data Collection

Only the five oil and gas sources with TMNSR permitted emissions below the Title V

permitting thresholds were included in this category to avoid double counting emissions.

Emissions from the remaining six oil and gas sources, which also hold Title V operating

permits issued by the Tribe, were already accounted for under the Title V Oil and Gas

Sources category of this inventory.

Synthetic minor sources are required to submit annual emissions inventories to EPA

Region 8 for the pollutants regulated under each permit and emissions data was

collected directly from the annual emissions inventories submitted for calendar year

20204. For the pollutants and emission units that were not reported to EPA Region 8,

AQP calculated emissions or utilized data that was submitted for its 2017 emission

inventory. If actual operating hours were not available, maximum operating hours were

used. This data collection methodology adheres to the EPA level II EI guidelines for using

measured data when available.

Emissions

Total 2020 criteria pollutant, HAP, and GHG emissions from permitted TMNSR oil and gas

sources on the Southern Ute Indian Reservation are presented below in Table 4.

Table 4: Criteria Pollutant, HAP, and GHG emissions for synthetic minor sources [tons]*

Pollutant

NOx

CO

VOC

PM

SO2

Total HAP

GHG (CO2e)

Emissions 253.9 137.5 126.2

*GHG emissions reported in tonnes.

3.8

5.9

29.7

69931.4

Total criteria pollutant and HAP emissions from synthetic minor sources on the Southern

Ute Indian Reservation by equipment type are presented below in Figure 6, Figure 7, and

Figure 8.

Figure 6: Criteria pollutant and HAP emissions from synthetic minor sources [tons]

4

Emissions from Southern Ute Indian Tribe (2021). CY 2020 EPA TMNSR Fee Forms.

16

Synthetic Minor Source Criteria Pollutant

and HAP Emissions (tons)

29.7

137.5

253.9

126.2

3.8

5.9

NOx

VOC

SO2

PM

CO

Total HAP

Figure 7: NOx and CO emissions from synthetic minor sources by equipment type [tons]

250.0

200.0

150.0

131.4

300.0

248.2

Synthetic Minor Source NOx and CO

Emissions by Equipment Type (tons)

Engine

Heater

Boiler

NOx

Dehydrator

1.6

0.3

1.3

1.5

0.1

0.0

0.1

3.8

50.0

3.1

100.0

Other

CO

*”Other” includes emissions from insignificant emission units

Figure 8: VOC and HAP emissions from synthetic minor sources by equipment type [tons]

17

120.0

100.0

97.4

Synthetic Minor Source VOC and Total

HAP Emissions by Equipment Type (tons)

80.0

Engine

Heater

Tank

VOC

2.1

6.1

Dehydrator

0.0

0.0

12.1

0.0

0.2

20.0

1.1

40.0

14.4

22.4

60.0

Other

Total HAP

*”Other” includes emissions from insignificant emission units

Total 2020 speciated HAP emissions from synthetic minor sources on the Southern Ute

Indian Reservation are displayed below in Table 5 and Figure 9.

Table 5: Speciated HAP emissions from synthetic minor sources [tons]

Pollutant

Emissions

Formaldehyde

14.6

Benzene

0.7

Toluene

2.2

Xylenes

4.1

Acetaldehyde

3.7

Acrolein

2.3

Methanol

0.9

Figure 9: Speciated HAP emissions from synthetic minor sources [tons]

Synthetic Minor Source Speciated HAP

Emissions (tons)

16.0

14.0

12.0

10.0

8.0

6.0

4.0

2.0

0.0

14.6

4.1

0.7

2.2

3.7

2.3

B. Registered Tribal Minor New Source Review Oil and Gas Sources

Description of Sources

18

0.9

1.0

n-Hexane

1.0

The TMNSR program required operators of true minor sources, as defined in §49.152, to

register each oil and gas source with EPA Region 8 by no later than March 1, 2013.

Existing oil and gas sources constructed or modified after March 1, 2013, but before

October 3, 2016 were also required to register. All oil and gas sources constructed after

March 1, 2013 are required to apply for a site-specific TMSNR permit or comply with the

Oil and Gas Federal Implementation Plan for Indian Country at 40 CFR Part 49, Subpart C.

For CY 2020, the AQP had record of 238 active oil and gas source registrations for the

Reservation.5 The registrations included source locations, emission unit descriptions, and

actual emissions calculations. All of the registered sources are natural gas production

sources, primarily well-sites. Certain non-oil and gas sources, such as hot mix asphalt

plants and stone quarrying, crushing and screening operations, also required registration

with the EPA under the TMNSR program, but to date, no such sources have been

registered. Presumably, non-oil and gas sources that did not register with the EPA may

exist on the Reservation, and this issue will be addressed below in the data collection

section.

Data Collection

For the purposes of this emission inventory section, only emissions from true minor

sources were included. Sources with Title V operating permits or synthetic minor permits

were not required to register under 40 CFR Part 49; therefore, there is little risk of double

counting emissions from these sources. Emissions from Title V sources and synthetic

minor sources were assessed separately, as discussed in Chapter IV Section 1 and 2A of

this report.

Due to the potential for registration information to be stale or out of date, the AQP

issued a mandatory Clean Air Act Section 114 ICR in June 2021 to obtain updated and

reconciled registration data for true minor sources from each facility operator. The ICR

included data for registered oil and gas sources. Specifically, the ICR requested

reconciliation of the operational status of each previously registered true minor source,

equipment located at each source, and the actual emissions for calendar year 2020.

The ICR also requested information that was exempted from TMNSR registration

including emissions estimates for engines less than or equal to 50-hp and facility-wide

emissions of HAP and GHG. It was anticipated that the ICR could also result in emissions

reporting by sources that had never registered with the EPA. This data collection

methodology adheres to the EPA level II EI guidelines for utilizing measured data when

available.

Emissions

5

Southern Ute Indian Tribe. (2021). Information Collection Request.

19

Total 2020 emissions of criteria pollutants, HAP, and GHG from true minor sources on the

Reservation are displayed below in Table 6.

Table 6: Criteria pollutant and HAP emissions from true minor sources [tons] *

Pollutant

NOx

CO

VOC

PM

SO2

Total HAP

GHG (CO2e)

Emissions

4,575.2

3,248.1

834.5

42.8

16.1

291.0

1,568,843.6

*GHG emissions reported in metric tonnes.

Total 2020 criteria pollutant and HAP emissions from true minor sources on the

Reservation by equipment type are displayed below in Figures 10 through 12. GHG

emissions from true minor sources are displayed below in Figure 13.

Figure 10: Criteria pollutant and HAP emissions from true minor oil and gas sources [tons]

True Minor Oil and Gas Source Criteria

Pollutant and Total HAP Emissions (tons)

291.0

3,248.1

4,575.2

42.8

16.1

834.5

NOx

VOC

SO2

PM

CO

Total HAP

Figure 11: NOx and CO emissions from true minor oil and gas sources by equipment type

[tons]

20

4,446.9

True Minor Oil and Gas Source NOx and CO

Emissions by Equipment (tons)

3,149.0

5,000.0

4,000.0

3,000.0

23.0

26.2

0.8

1.1

6.1

7.5

57.5

11.7

21.9

1,000.0

71.6

2,000.0

Engine

Turbine

Heater

Boiler

NOx

Dehydrator

Other

CO

*”Other” consists of combustors, flares, and undefined equipment

Figure 12: VOC and HAP emissions from true minor oil and gas sources by equipment type

[tons]

Heater

Boiler

VOC

Tank

Dehydrator

Fugitives

-

8.1

2.5

0.6

28.5

8.5

13.7

1.0

115.3

Turbine

3.9

0.2

0.6

Engine

61.6

309.1

162.8

450.0

400.0

350.0

300.0

250.0

200.0

150.0

100.0

50.0

-

409.0

True Minor Oil and Gas Source VOC and HAP

Emissions by Equipment Type (tons)

Other

Total HAP

*”Other” consists of combustors, flares, and undefined equipment

Figure 13: GHG emissions from true minor oil and gas sources by equipment type [tonnes]

21

450.0

409.0

True Minor Oil and Gas Source VOC and HAP

Emissions by Equipment Type (tons)

309.1

400.0

350.0

-

2.5

0.6

28.5

8.5

1.0

3.9

0.6

50.0

0.2

100.0

13.7

150.0

8.1

200.0

115.3

162.8

250.0

61.6

300.0

Engine

Turbine

Heater

Boiler

VOC

Tank

Dehydrator

Fugitives

Other

Total HAP

*”Other” consists of combustors, flares, and undefined equipment

3. Permitted Point Sources

In 2020, the one non-oil and gas point source operating under a TMNSR permit on the

Reservation is a gravel pit. The operator reported the facility did not operate in 2020 and

therefore, no emissions were reported for the source.

Table 7: Criteria pollutant and HAP emissions from permitted non-oil and gas point sources

[tons]

Pollutant

Emissions

NOx

0

CO

0

VOC

0

PM10

0

PM2.5

0

PM

0

SO2

0

Total HAP

0

CO2e

0

4. Landfill Gas

The Southern Ute Indian Tribe has two Class II municipal solid waste (MSW) landfills within

the Reservation boundaries. The first one is the Bondad Recycling Center and Depository

(Bondad Landfill) located in Bondad, Colorado and the second one is the Archuleta County

Landfill, located south of Pagosa Springs, Colorado. Both MSW disposal sites accept nonhazardous residential, commercial, and industrial waste. The Bondad Landfill is owned and

operated by Transit Waste, LLC and has been in operation since 1997. The Archuleta County

Landfill is owned and operated by Archuleta County and began operation in 1985. The

Bondad Landfill operates under a tribally issued Title V operating permit and the Archuleta

County Landfill reports annual landfill gas emissions to the Colorado Department of Public

Health and Environment (CDPHE).

Data Collection

22

The Archuleta County Landfill submitted acceptance volumes for 2018, 2019, and 2020 for

input in LandGEM 3.02 with a density 0.79 Megagram/cubic yard. The density was estimated

from the reported Megagrams per cubic yard for the years 2013 through 2015. All reports

were previously submitted by Archuleta County to the CDPHE. Emissions data for the Bondad

Landfill were directly obtained from the CY 2020 Title V emissions fee form submitted to the

Tribe.

Emission Calculation Methodology

Emissions for the Archuleta County landfill were estimated using the EPA’s MSW landfill

emissions model, LandGEM version 3.02 (LandGEM).6 Emissions data for the Bondad Landfill

were obtained from the CY 2020 Title V emissions fee form submitted to the Tribe by Transit

Waste, LLC, who ran LandGEM to estimate emissions from this facility. The LandGEM model

estimates total landfill gas, non-methane organic compounds (NMOC), and hazardous air

pollutants (HAP).

The LandGEM model is based on a first-order decomposition rate equation for quantifying

emissions from the decomposition of landfilled waste in MSW landfills.

n

Q CH 4  

i1

1

 M i 

 kL  10  e

j  0 .1

0

 kt ij

Where:

QCH4 = annual methane generation in the year of calculation (m3/year)

i = 1 year time increment

n = (year of the calculation) – (initial year of waste acceptance)

j = 0.1 year time increment

k = methane generation rate (year-1)

Lo = potential methane generation capacity (m3/Mg)

Mi = mass of waste accepted in the ith year (Mg)

tij = age of the jth section of waste mass Mi accepted the ith year (decimal years, e.g., 3.2

years)

LandGEM Inputs and Assumptions

Complex microbial and biochemical reactions occur within the landfill’s interior after the

waste has been deposited. The two primary constituents of landfill gas (LFG) are methane

(CH4) and carbon dioxide (CO2). LFG also contains small amounts of non-methane organic

6

U.S. EPA - Landfill Gas Emissions Model. (2021). Retrieved from https://www.epa.gov/catc/clean-air-technologycenter-products#software.

23

compounds, which includes VOC, HAP, and GHG. LandGEM estimates the LFG from

anaerobic decomposition of the waste with CH4 and CO2 content between 40 and 60 percent.

The LandGEM default used for methane is 50 percent by volume (the model default value).

The production of LFG is a continuous process until microbial reactions are limited by

substrate or moisture. Other factors include climate, moisture conditions, and types of solid

waste accepted (degradable vs. inert).

Parameters for climatic conditions used in the LandGEM model were a k-value of 0.02 year -1

(an arid area that receives less than 25 inches of rain annually) and a L o-value of 170 cubic

meter per megagram. The VOC concentrations are assumed to be 39 percent of NMOC

concentrations, consistent with the footnote C Table 2.4-2 of the EPA’s publication titled AP42, Fifth Edition Compilation of Air Emission Factors (EPA AP-42).7 HAP emissions for the

Archuleta County Landfill are from the LandGEM report using default emissions factors from

EPA AP-42. The total estimated emissions of LFG were estimated using the flow rate and

molecular weights.

Emissions

The estimated LandGEM emissions for Bondad Landfill were provided to the Tribe in a Title V

emissions fee form package submitted by Transit Waste for calendar year 2020. Emissions

estimates for Archuleta County Landfill were calculated by the Tribe using LandGEM and the

waste acceptance rates and waste-in-place data values for 2018-2020 along with the

historical data submitted

To avoid double counting emissions from the Bondad Landfill, emissions from Bondad

Landfill were only included in the Landfill gas emission totals and not included in the Title V

emission totals presented in Section IV.1 of this report.

Total refuse in place in tons and total emissions of GHG, VOC and HAP from MSW landfills on

the Reservation for 2020 are displayed below in Table 8 and Figure 14.

Table 8: Municipal solid waste landfill refuse in place [tons] and emissions [tons] *

Refuse in Place

GHG

VOC

HAPs¹

Bondad Landfill

1,667,802

4,846.5

4.6

1.7

Archuleta County Landfill

548,775

18,380.2

2.5

1.9

Totals

2,216,577

23,226.7

7.1

3.6

An insignificant quantity of double counting of VOCs occurs because many reported HAPs are also

considered VOCs.

*

Figure 14: Municipal solid waste landfill emissions [tons]

7

U.S. Environmental Protection Agency. (2020). AP-42: Compilation of Air Emission Factors. Retrieved from

https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-compilation-air-emissions-factors.

24

Landfill VOC and Total HAP Emissions

(tons)

5.0

4.6

4.0

3.0

2.5

1.9

1.7

2.0

1.0

0.0

Bondad

Archuleta

VOC

Total HAP

5. Airports

There are three airports located within the Reservation: the Durango-La Plata County

Airport, the Animas Air Park, and the Animas Air Park Helipark.

Data Collection

The AQP obtained CY 2018 data from EPA’s National Emissions Inventory database (NEI),

which includes total landing and take-off cycles (LTOs) and piston and turbine engine

emission estimates for the heliport, taxi, and general aviation at the Animas Air Park. 8 The

LTOs were from the Federal Aviation Administration (FAA). The methodologies used by EPA

to calculate airport emissions are detailed in the Eastern Research Group’s document titled

Documentation for Aircraft Component of the National Emissions Inventory Methodology. 9

Emissions data for the Animas Air Park and Animas Air Park Heliport were submitted to the

NEI by EPA. Emissions data for the Durango-La Plata airport were reported to the NEI by the

CDPHE.

Assumptions

8

U.S. EPA National Emission Inventory Emissions Inventory System. (2020). Retrieved from

https://www.epa.gov/air-emissions-inventories/national-emissions-inventory-nei.

9

Eastern Research Group. (2001, January). Documentation for Aircraft Component of the National Emissions

Inventory Methodology. (ERG No. 0245.03402.011).

25

Calendar year 2020 airport emissions are assumed to be similar to emissions from the

airports during CY 2018.

Emissions

Total criteria pollutant and HAP emissions from airports on the Reservation for 2020 are

displayed in Table 9 and Figure 15 and Figure 16 below.

Table 9: Criteria pollutant and HAP emission from airports [tons] *

Durango-La Plata County

NOx

0.01

0.40

36.07

VOC

0.01

0.84

13.09

SO2

0.00

0.08

4.94

PM2.5

0.01

0.51

3.29

PM10

0.01

0.66

3.83

Lead

0.00

0.03

0.1

CO

0.27

30.93

185.91

Total HAP

0.00

0.31

3.59

Totals

36.47

13.94

5.02

3.81

4.50

0.13

217.11

3.90

Animas Air Park Heliport

Animas Air Park

*Emissions estimations for airports are from the 2018 EPA National Emission Inventory Database and

assumed to be realistic estimations of airport emissions for 2020.

Figure 15: CO and NOx emissions from airports [tons]

Airport NOx and CO Emissions (tons)

200.0

180.0

160.0

140.0

120.0

100.0

80.0

60.0

40.0

20.0

0.0

185.9

30.9

0.01

0.3

Animas Airpark Heliport

36.07

0.40

Animas Airpark

NOx

Durango - La Plata

CO

Figure 16: VOC and Total HAP emissions from airports [tons]

26

Airport VOC and Total HAP Emissions

(tons)

13.1

14.0

12.0

10.0

8.0

6.0

3.6

4.0

2.0

0.0

0.0

0.0

Animas Airpark Heliport

0.8

Animas Airpark

VOC

V.

0.3

Durango - La Plata

Total HAP

Non-Point Sources

1. Small Oil and Gas Sources

Description of Sources

For the purpose of this EI small oil and gas sources are defined as: oil and gas sources with

emissions below the thresholds that require registration under the EPA Tribal Minor New

Source Review (TMNSR) Program at 40 CFR Part 49. The majority of these sources are natural

gas well sites, which are comprised of artificial lift engines, separators, filter coalescers,

compressor engines, reciprocating compressors, lube oil tanks, tank heaters, dehydration

units, and produced water, condensate, and oil tanks.

Data Collection

Source information for small oil and gas sources was obtained through a mandatory Clean

Air Act Section 114 ICR issued by the AQP in June of 2021 to each known operator with

sources operating on the Reservation. To identify the operators within the Reservation and

estimate the total number of small oil and gas sources on the Reservation, the AQP compiled

site and ownership data from the COGCC and Drilling Edge databases.10,11

The ICR was the basis for collecting the information necessary to calculate emissions from

small oil and gas sources and required each recipient to provide actual equipment counts

10

COGCC. (2020). Production Data. La Plata. Retrieved from http://cogcc.state.co.us/data2.html#/downloads.

11

Drilling Edge Database (2016). Retrieved from http://www.drillingedge.com/colorado.

27

and production information. Data was requested for each company’s operations on the

Reservation in its entirety and not specific to any single source location.

Completed ICRs were submitted by 27 of the 32 (84%) companies that reported production

on the Reservation in CY 2020 to the COGCC database. The completed ICRs accounted for

2,570 of the 2,582 (99.5%) known small oil and gas sources on the Reservation. The AQP

used 2017 ICR submitted information for the remaining unreported sources.

Calculation Methodology

The AQP calculated emissions for small oil and gas sources on an equipment basis using

measured data, widely accepted emission factors and emission calculation methodologies,

the equipment counts reported in the ICR, and CY 2020 production data from the COGCC.

Descriptions of how emissions were calculated for each equipment type are included later in

this section.

Emissions

Criteria pollutant, HAP, and GHG emission estimations from small oil and gas sources on the

Reservation in 2020 are displayed below in Table 10.

Table 10: Emissions from small oil and gas sources [tons]*

Pollutant

NOx

VOC

SO2

PM

CO

Total HAP

GHG

Emissions

11,664.0

798.8

5.6

183.8

9,716.6

233.9

1,575,054.1

*GHG emissions reported in metric tonnes.

Criteria pollutant, HAP, and GHG emissions from small oil and gas sources on the Reservation

by equipment type are displayed below in Figures 17 through 20.

28

Figure 17: Criteria pollutant and HAP emissions from small oil and gas sources [tons]

Small Oil and Gas Source Criteria

Pollutant and Total HAP Emissions

(tons)

233.8

9,716.6

11,664.0

183.8

NOx

5.6

798.9

VOC

SO2

PM

CO

Total HAP

Figure 18: NOx and CO emissions from small oil and gas sources by equipment type [tons]

Small Oil and Gas Source NOx and CO

Emissions by Equipment Type (tons)

12,000.0

10,000.0

11,124.9

9,264.2

8,000.0

6,000.0

4,000.0

2,000.0

0.8

Engine

537.7

0.2

Turbine

NOx

451.7

Heater

0.6

0.5

Boiler

CO

Figure 19: VOC and HAP emissions from small oil and gas sources by equipment type

[tons]

29

278.4

Small Oil and Gas Source VOC and Total HAP

Emissions by Equipment Type (tons)

146.4

10.2

0.1

42.9

0.0

0.1

19.4

2.1

0.0

0.0

0.0

0.0

50.0

29.2

100.0

7.4

150.0

8.7

110.3

200.0

0.4

250.0

172.2

205.1

300.0

VOC

Pneumatics

Recompletions

Blowdowns

Fugitives

Dehydrator

Tank

Boiler

Heater

Turbine

Engine

-

Total HAP

Figure 20: GHG emissions from small oil and gas sources by equipment type [tonnes]

586,063.8

Small Oil and Gas Source GHG (CO 2 e) Emissions by

Equipment Type (tonnes)

400,000.0

217,529.5

500,000.0

298,443.7

600,000.0

432,779.0

700,000.0

27,232.2

182.2

100,000.0

372.4

255.9

698.0

200,000.0

11,451.6

300,000.0

-

2020 Speciated HAP emissions are displayed below in Table 11 and Figure 21.

Table 11: Speciated HAP emissions from small oil and gas sources [tons]

Pollutant

Formaldehyde

Benzene

Toluene

Ethylbenzene

Xylenes

Acetaldehyde

Acrolein

Methanol

n-Hexane

Emissions

143.9

8.1

7.8

0.8

4.9

20.3

18.4

11.6

20.7

30

Figure 21: Speciated HAP emissions from small oil and gas sources [tons]

Small Oil and Gas Source Speciated HAP

Emissions (tons)

160.0

140.0

120.0

100.0

80.0

60.0

40.0

20.0

0.0

143.9

8.1

7.8

0.8

4.9

20.3

18.4

11.6

20.7

A. Natural Gas-Fired Reciprocating Internal Combustion Engines

Description of Units

Natural gas-fired spark-ignited reciprocating internal combustion engines (RICE) are used

by the oil and gas industry to compress natural gas, pump liquids, generate electricity,

and to provide artificial lift. The most prevalent pollutants emitted from natural gas-fired

RICE are NOx, CO, VOC, and HAP.

Data Collection

The ICR required recipients to list the total number of natural gas-fired spark-ignition and

compression ignition RICE operated by their company on the Reservation. Engines were

reported according to horsepower range, and engine configuration. Engine

configurations included two-stroke lean-burn (2SLB), four-stroke lean-burn (4SLB), fourstroke rich-burn (4SRB), and diesel. The ICR included assumed values for engine

operating hours and average brake specific fuel consumption (BSFC) and provided

recipients the option to provide values more representative of their operations. A

summary of reported engines at small oil and gas sources on the Reservation in 2020 are

displayed below in Figure 22.

Figure 22: Engine counts by engine configuration and horsepower at small oil and gas

sources

31

Engine Counts by Engine Configuration and

Horsepower at Small Oil and Gas Sources

600

481

500

400

246

300

200

100

0

47

5

37

9

41

17

73

27

32

1

3

1

1

63

5

7

2

5

1

Emission Calculation Methodology

Criteria Pollutant and HAP Emissions:

Criteria pollutant and HAP emissions were calculated for each engine configuration and

horsepower rating category reported in the ICR. Emission calculations were based on the

maximum horsepower of each reported horsepower range, the appropriate emission

factors for stationary internal combustion sources from Chapter 3 of EPA AP-42, an

assumed BSFC of 7,500 Btu/hp-hr (if the operator did not input anything more

representative of their operating conditions), an assumed 100% engine operating load,

and assumed operating schedule of 8,760 hours per year (if the operator did not input a

different number of annual operating hours). The assumed BSFC value was derived by

averaging the BSCF from all natural gas-fired engines in the Caterpillar Gas Engine Rating

Pro software.12 All emissions were calculated for uncontrolled operation. The natural gas

on the Reservation contains negligible amounts of sulfur, therefore SO 2 emissions from

engines are minimal.

GHG Emissions:

Greenhouse gas emissions were calculated using the default values from Tables C-1 and

C-2 of 40 CFR Part 98, Subpart C and the same methodology as used for criteria

pollutants and HAP.13

12

Caterpillar, Inc. (2015). Gas Engine Rating Pro Emissions Estimation Software. Retrieved from

http://www.cat.com/en_US/articles/solutions/oil-gas/gas_engine_rating_pro.html.

13

40 CFR Part 98 - Mandatory Greenhouse Gas Reporting. (2021). U.S. Government Publishing Office. Retrieved

from http://www.ecfr.gov/cgi-bin/textidx?SID=32c4baa0d0aff54fa651d1cdb1cd7934&mc=true&tpl=/ecfrbrowse/Title40/40cfr98_main_02.tpl.

32

Example Calculation

Calculation of engine heat rate (MMBtu/hr) using AQP’s assumed brake specific fuel

consumption (Btu/hp-hr):

HR (MMBtu/hr) = BSFC (7500 Btu/hp-hr)/10^6 x hp

Where:

HR = heat rating (MMBtu/hr)

BSFC = brake-specific fuel consumption

hp = engine horsepower

Engine emission calculation:

tpy = (EF) x HR x OH/2000 pounds/ton

Where:

tpy = tons per year

EF = emission factor (lb/MMBtu)

HR = heat rate

OH = annual operating hours

Example Nox emissions calculation for a 200 hp four-stroke rich-burn engine operating

8,760 hours per year:

tpy = (2.21 lb/MMBtu) x (1.5 MMBtu/hr) x (8760 hr)/2000 lb/ton = 14.52 tpy Nox

Emissions

Total criteria pollutant, HAP, and GHG emissions from natural gas-fired RICE at small oil

and gas sources are displayed below in Table 12 and Figures 23 and 24.

Table 12: Natural gas-fired reciprocating internal combustion engine counts and criteria

pollutant, HAP, and GHG emissions for small oil and gas sources [tons] *

Engine Configuration

and Horsepower (hp)

2SLB 0-50 hp

2SLB 51-100 hp

2SLB 101-200 hp

2SLB 201-300 hp

33

Number of

Engines

47

5

37

9

NOx

VOC

SO2

PM

CO

Total

HAP

GHG

170.8

61.3

774.3

270.0

6.5

2.3

29.3

10.2

0.0

0.0

0.1

0.1

4.1

1.5

18.8

6.5

20.8

7.5

94.3

32.9

4.2

1.5

18.8

6.7

5,722.5

2,055.0

25,948.5

9,046.7

1,707.8

64.6

1,062.2

40.2

472.4

13.7

361.9

10.5

788.1

22.8

35.7

1.0

148.7

4.3

59.4

1.7

93.8

2.7

1,715.2

23.0

1,785.7

23.9

900.9

12.1

106.9

1.5

203.3

2.7

87.1

1.2

254.1

3.4

65.3

0.9

11,059.6 277.6

2SLB 301-400 hp

41

2SLB 501-600 hp

17

4SLB 0-50 hp

73

4SLB 51-100 hp

27

4SLB 101-200 hp

32

4SLB 201-300 hp

1

4SLB 301-400 hp

3

4SLB 401-500 hp

1

4SLB 601-700 hp

1

4SRB 0-50 hp

481

4SRB 51-100 hp

246

4SRB 101-200 hp

63

4SRB 201-300 hp

5

4SRB 301-400 hp

7

4SRB 501-600 hp

2

4SRB 601-700 hp

5

4SRB 801-900 hp

1

Totals:

1104

*

GHG reported in metric tonnes.

0.3

0.2

0.1

0.1

0.1

0.0

0.0

0.0

0.0

0.5

0.5

0.2

0.0

0.1

0.0

0.1

0.0

2.4

41.4

25.7

0.0

0.0

0.0

0.0

0.0

0.0

0.0

14.8

15.4

7.7

0.9

1.7

0.6

2.2

0.6

141.5

208.0

129.3

36.7

28.1

61.2

2.8

11.6

4.6

7.3

2,887.2

3,005.7

1,516.5

183.3

342.2

146.6

427.7

110.0

9,154.2

41.5

25.8

8.4

6.3

13.7

0.6

2.4

1.0

1.6

24.3

25.3

12.8

1.5

2.9

1.2

3.6

0.9

204.2

57,232.6

35,595.9

12,301.5

9,422.4

20,520.4

928.6

3,872.2

1,547.7

2,442.9

82,450.5

85,836.0

43,306.7

5,234.7

9,771.4

4,187.7

12,214.3

3,140.8

429,638.2

Figure 23: CO and NOx emission from small oil and gas sources by engine type [tons]

500.0

1,516.5

3,005.7

106.9

183.3

203.3

342.2

87.1

146.6

254.1

427.7

65.3

110.0

1,000.0

170.8

20.8

61.3

7.5

1,500.0

774.3

94.3

270.0

32.9

2,000.0

208.0

1,707.8

2,500.0

1,062.2

129.3

472.4

36.7

361.9

28.1

788.1

61.2

35.7

2.8

148.7

11.6

59.4

4.6

93.8

7.3

1,715.2

3,000.0

900.9

3,500.0

1,785.7

2,887.2

Small Oil and Gas Source Engine NOx and CO Emissions

by Engine Type (tons)

4SRB 801-900 hp

4SRB 601-700 hp

4SRB 501-600 hp

4SRB 301-400 hp

4SRB 201-300 hp

4SRB 101-200 hp

4SRB 51-100 hp

4SRB 0-50 hp

CO

4SLB 601-700 hp

4SLB 301-400 hp

NOx

4SLB 401-500 hp

4SLB 201-300 hp

4SLB 101-200 hp

4SLB 51-100 hp

4SLB 0-50 hp

2SLB 501-600 hp

2SLB 301-400 hp

2SLB 201-300 hp

2SLB 101-200 hp

2SLB 51-100 hp

2SLB 0-50 hp

-

Figure 24: VOC and Total HAP emissions from small oil and gas sources by engine type

[tons]

34

64.6

Small Oil and Gas Source Engine VOC and Total HAP

Emissions by Engine Type (tons)

70.0

41.5

40.2

60.0

20.0

10.0

6.5

4.2

2.3

1.5

30.0

18.8

10.2

6.7

40.0

25.8

13.7

8.4

10.5

6.3

22.8

13.7

1.0

0.6

4.3

2.4

1.7

1.0

2.7

1.6

23.0

24.3

23.9

25.3

12.1

12.8

1.5

1.5

2.7

2.9

1.2

1.2

3.4

3.6

0.9

0.9

29.3

50.0

VOC

4SRB 801-900 hp

4SRB 601-700 hp

4SRB 501-600 hp

4SRB 301-400 hp

4SRB 201-300 hp

4SRB 101-200 hp

4SRB 51-100 hp

4SRB 0-50 hp

4SLB 601-700 hp

4SLB 401-500 hp

4SLB 301-400 hp

4SLB 201-300 hp

4SLB 101-200 hp

4SLB 51-100 hp

4SLB 0-50 hp

2SLB 501-600 hp

2SLB 301-400 hp

2SLB 201-300 hp

2SLB 101-200 hp

2SLB 51-100 hp

2SLB 0-50 hp

-

Total HAP

B. Stationary Natural Gas Turbines:

Description of Units

Natural gas-fired stationary turbines are a type of rotary internal combustion engine

used by the natural gas industry for natural gas transmission and for electric generation.

Turbines operate by introducing compressed air and fuel into a combustion chamber to

generate hot gases, which are expanded into the power turbine to rotate the power

shaft and create work. Two types of combustion processes are used in turbines, the first

being lean-premix staged combustion in which a lean air and fuel mixture is introduced

into the combustion chamber, and the second type being diffusion flame combustion

where the air and fuel mixing occurs within the combustion chamber. The power shaft is

used to run a centrifugal compressor for gas transmission, or to rotate an alternator

when used for electric generation.

Data Collection

The ICR required recipients to list the total number of natural gas-fired turbines operated

by their company on the Reservation. Turbines were reported according to horsepower

or kilowatt range and, turbine configuration. Turbine configurations included

uncontrolled, water-steam injection, and lean-premix. The AQP assumed turbines to

operate for 8,760 hours per year. Average brake specific fuel consumption (BSFC) was

assumed to be 11,000 Btu/hp-hr, as established in the document titled Stationary

35

Combustion Turbines in the United States.14 If an operator specific BSFC was reported in

the ICR, this value was used in place of the assumed BSFC value.

Only one turbine was reported at a small oil and gas source in the ICR. The turbine was a

0-50 hp, lean pre-mix unit, operated 8,760 hours per year, with a BSFC of 11,000 Btu/hphr.

Emission Calculation Methodology

Criteria Pollutant and HAP Emissions:

Criteria pollutant and HAP emissions were calculated based on the maximum reported

horsepower, emission factors for stationary gas turbines from Chapter 3.1 of EPA AP-42,

100% engine operating load, an operating schedule of 8,760 hours per year and a

reported BSFC of 11,000 Btu/hp-hr. The calculation methodology for natural gas turbines

is the same methodology used for reciprocating internal combustion engines and

displayed in an example calculation earlier in this section. The natural gas on the

Reservation contains negligible amounts of sulfur, therefore SO 2 emissions from turbines

are minimal.

GHG Emissions:

Greenhouse gas emissions were calculated using the default values from Tables C-1 and

C-2 of 40 CFR Part 98, Subpart C and the same methodology as used for criteria

pollutants and HAP.

Emissions

Criteria pollutant, HAP, and GHG emissions from natural gas turbines on the Southern

Ute Reservation for 2020 are displayed in Table 13.

Table 13: Turbine count and criteria pollutant, HAP, and GHG emissions at small oil and

gas sources [tons]*

Turbine configuration

and horsepower

Number of

turbines

NOx

CO

PM10

VOC

Total

HAP

GHG

(CO2e)

Lean-Premix 0-50 hp

1

0.77

0.20

0.02

0.01

0.00

255.92

*GHG reported in metric tonnes.

C. Tri-Ethylene Glycol Dehydration Units

Description of Units

14

McGowin (1973) Stationary Combustion Turbines in the United States.

36

Tri-ethylene glycol (TEG) dehydration units are commonly used in the natural gas

industry to remove entrained water from the natural gas stream to meet pipeline

contract water specifications. The dehydration process begins with routing the natural

gas stream through TEG in an absorber (or contactor tower) where the entrained water is

absorbed by the TEG. During this step, hydrocarbons present in the natural gas stream

are also absorbed in the glycol. Following the absorption step, the water saturated (rich)

glycol is then distilled to drive off absorbed water before being re-circulated to the

absorber. The distillation step results in emissions of VOC and HAP from the reboiler stillvent. The common still-vent HAP emissions are benzene, toluene, ethyl-benzene, and

xylene.

Data Collection

The AQP collected dehydration unit counts from the ICR, which required operators to

enter the total number of dehydration units operated by their company at small oil and

gas sources on the Reservation during calendar year 2020. The ICR included assumed

dehydration unit operating parameters and a theoretical extended natural gas analysis,

as described later in this section, which could be accepted or overridden with values

more representative of the operators’ operations. The theoretical extended gas analysis

is displayed below in Table 14.

Fifty dehydration units were reported in the ICR submittals and all submittals accepted

the AQP’s assumed operation and natural gas composition values.

Emissions Calculation Methodology

Emissions for glycol dehydration units were calculated using the GRI-GLYCalc 4.0 model

(GLYCalc), the AQP’s theoretical values for dehydration unit operating parameters and

natural gas composition, and the methodology outlined in the GLYCalc user’s manual. 15

GLYCalc is the EPA’s preferred method of quantifying emissions from glycol dehydration

units for the development of tribal/state/local emissions inventories.16

Product of combustion emissions from dehydration unit reboilers were included in the

emission totals for heaters and boilers presented in Section V.1.E. of this report to avoid

double counting.

15

Gas Research Institute. (2000). GLYCalc Version 4.0. Retrieved from http://sales.gastechnology.org/000102.html.

16

U.S. EPA. (1995). Glycol Dehydrator Emissions Test Report and Emissions Estimation Methodology. Retrieved from

https://www3.epa.gov/ttn/chief/old/efdocs/glycoldehydratortestreport.pdf.

37

Table 14: Theoretical extended natural gas analysis – average of 31 natural gas analyses

from the Southern Ute Indian Reservation

Component

Methane

Ethane

Propane

Isobutane

n-Butane

Isopentane

n-Pentane

n-Hexane

Carbon Dioxide

Nitrogen

Hydrogen Sulfide

2,2 Dimethylbutane

2,3 Dimethylbutane

Cyclopentane

2-Methylpentane

3-Methylpentane

2,2 Dimethylpentane

Methylcyclopentane

2,4-Dimethylpentane

2,2,3-Trimethylbutane

Benzene

3,3-Dimethylpentane

Cyclohexane

2-Methylhexane

2,3-Dimethylpentane

1,1-Dimethylcyclopentane

3-Methylhexane

1,t-3-Dimethylcyclopentane

1,c-3-Dimethylcyclopentane

3-Ethylpentane

1,t-2-Dimethylcyclopentane

2,2,4 Trimethylpentane

n-Heptane

Methylcyclohexane

Toluene

n-Octane

Ethylbenzene

2,3-Dimethylheptane

m-Xylene

p-Xylene

o-Xylene

n-Nonane

n-Decane

n-Undecane

Total:

Total VOC:

38

Average

92.3814%

0.9867%

0.2291%

0.0349%

0.0468%

0.0107%

0.0070%

0.0028%

6.1663%

0.1134%

0.0000%

0.0000%

0.0000%

0.0003%

0.0004%

0.0029%

0.0012%

0.0000%

0.0012%

0.0000%

0.0000%

0.0005%

0.0000%

0.0008%

0.0002%

0.0000%

0.0000%

0.0002%

0.0000%

0.0000%

0.0000%

0.0000%

0.0002%

0.0028%

0.0021%

0.0010%

0.0017%

0.0001%

0.0000%

0.0002%

0.0003%

0.0001%

0.0008%

0.0006%

100.00%

0.35%

GRI-GLYCalc Model Input Parameters

The AQP developed assumed dehydration unit operational values for natural gas

temperature, pressure, and flowrate by averaging operational information from

dehydration units at small oil and gas sources provided by two of the largest operators

on the Reservation. An assumed extended natural gas analysis was prepared by

averaging 31 individual extended gas analyses from natural gas production sector

compressor stations that were reported to the AQP in Title V operating permit

applications between 2017 and 2020.

The AQP’s assumed values were input into the GLYCalc emissions model using a pipeline

water content specification of seven pounds of water per MMscf of natural gas, 1.5%

H2O lean glycol, and assuming uncontrolled operation with no flash tank.

The assumed GLYCalc input parameter values are provided below in Table 15.

Table 15: GRI-GLYCalc Model input parameters for TEG Dehydration units at small oil

and gas sources

Wet Gas Temperature [°F]

Wet Gas Pressure [psig]

Dry Gas Flowrate/ Throughput [MMscf/day]

Lean Glycol Water Content [weight % H2O]

Glycol Pump Type

Pipeline Water Content Specification [lb H2O/MMscf]

68.5

353.5

0.9

1.5

Electric/ Pneumatic

7.0

GRI-GLYCalc Model Emissions Output:

Fifty dehydration units were reported for small oil and gas sources in the ICR submittals

and all dehydration unit emissions were calculated using the AQP’s default GRI-GLYCalc

emissions report. The GRI-GLYCalc report was applied once to each of the 50 dehydration

units reported in the ICR, and then summed to derive a reservation-wide emissions

estimate for glycol dehydration units located at small oil and gas sources.

No operator specific GLYCalc reports or dehydration unit emission estimations were

provided in the ICR submittals.

Modeled GRI-GLYCalc emissions for a single TEG dehydration unit and using the AQP’s

assumed model inputs are provided in Table 16.

39

Table 16: GRI-GLYCalc Model emissions output for TEG Dehydration units [tons]

Pollutant

Methane

Ethane

Propane

Isobutane

n-Butane

Isopentane

n-Pentane

Cyclopentane

n-Hexane

Cyclohexane

Other Hexanes

Heptanes

Methylcyclohexane

2,2,4-Trimethylpentane

Benzene

Toluene

Ethylbenzene

Xylenes

C8+ Heavies

Total HC Emissions

Total VOC Emissions

Total HAP Emissions

Total BTEX Emissions

Uncontrolled

Emissions

0.2341

0.0226

0.0211

0.0076

0.0156

0.0057

0.0050

0.0000

0.0080

0.0048

0.0000

0.0000

0.0097

0.0002

0.0237

0.0796

0.0122

0.0998

0.1469

0.6966

0.4399

0.3849

0.2153

Example Calculation

Example calculation for VOC emissions from ICR Reported dehydration units:

VOC Emissions (tpy) = AQP Generated GRI-GLYCalc Emissions Output x Number of 2020

ICR Reported Dehydration Units

Example:

24.2 tpy annual VOC emissions = 0.4399 tpy VOC x 50 reported dehydration units

Emissions

VOC and HAP emissions from 50 TEG Dehydration Units at small oil and gas sources on

the Reservation are provided in Table 17.

40

Table 17: VOC and HAP Emissions from TEG Dehydration Units from small oil and gas

sources [tons]

Totals

Number of

Dehydration Units

50

VOC

19.4

Total

HAP

8.7

Benzene

Toluene

Ethylbenzene

Xylenes

1.0

3.4

0.5

3.6

D. Liquid Storage Tanks

Description of Equipment and Emissions Categories

The oil and gas industry utilize liquid storage tanks for the storage of produced water,

condensate, oil, coolants, and lubricants. The primary emissions from liquid storage tanks

are methane, VOC and HAPs. Emission categories include breathing and working losses,

flash emissions, and tank loadout.

Breathing and Working Losses:

Breathing losses occur when vapor expansion generated during temperature fluctuations

increases the vapor pressure within a tank and cause fugitive emissions to escape from

the roof vent. Light colored tanks and tank heaters can help maintain more consistent

tank temperatures and reduce breathing losses by reducing vapor pressure variations.

Full tanks also produce lower breathing losses due to less space for vapors to expand and

escape from roof vents. Working losses occur when liquids are pumped into and out of

storage tanks. The displacement of vapors within the tank and the turbulence caused by

the movement of the liquid create airborne vapors. Submerged fill tanks can be effective

for reducing turbulence and the creation of airborne vapors.

Flash Emissions:

Flash emissions are emissions that occur when liquid dumped from the separator into

the liquid storage tank goes from higher pressure to lower pressure, resulting in the

entrained gas being released as a vapor from the liquid. The gas to liquid ratio, pressure

and temperature of the liquids in the separator, and the temperature and pressure of the

liquid storage tank influence the amount of flashing losses.

Tank Loadout Emissions:

Tank loadout emissions are vapor loss from transport tanks that occur during the transfer

of liquids from a storage tank to a transport tank. Loadout emissions occur due to the

generation of vapors in transport tanks during liquid loading, the transfer of vapors from

the liquid storage tank to the transport tank, and the displacement of vapors trapped in

transport tanks from previous loads during loading.

41

Data Collection

Tank Counts and Data for Calculating Breathing and Working Losses:

The ICR required each operator to provide the total number of produced water,

condensate, and oil tanks located at their small oil and gas sources on the Reservation.

Reported tank counts were based on tank capacity and contents.

A summary of tanks reported in the ICR, by tank contents, is displayed below in Figure

25.

Figure 25: Liquid storage tanks at small oil and gas sources by tank contents

Small Oil and Gas Source Tank Count

1800

1633

1600

1400

1200

1000

800

600

400

200

79

44

Condensate

Oil

0

Produced Water

The ICR also provided operators with the opportunity to override assumed data values

for annual liquid throughput, Reid Vapor Pressure, and general tank characteristics with

values more representative of their operations. Tank characteristics include roof type,

color, condition, and presence of a tank heater. Development of liquid throughput values

is discussed later in this section. Emissions from lubricant oil and glycol storage tanks

were assumed to be negligible and no data was requested for these sources.

Methodology for Deriving Average Liquid Throughput Values:

The AQP developed two types of annual liquid throughput values, based on the

availability of data in the COGCC database for sources in La Plata County, Colorado for CY

2020. If data were available from COGCC, the AQP used operator-specific throughput

values and if the data were not available, the AQP developed assumed annual average

liquid throughput values. The operator-specific annual average liquid throughput values

were derived by dividing their total reported produced water and condensate/oil

42

production numbers by the total number of sources that reported production for CY

2020.

Assumed average annual liquid throughput values were developed for operators that

reported active sources to the COGCC in 2020 but did not report production. The

assumed annual throughput value for produced water was derived by dividing the total

CY 2020 produced water production values reported to the COGCC database by the total

number of reported sources. A combined condensate and oil assumed annual average

tank throughput value was derived by dividing the total CY 2020 combined condensate

and oil production value reported to the COGCC database by the number of small oil and

gas sources that reported condensate or oil production. Not all companies reported

condensate or oil production to COGCC, and four companies reported much larger

condensate and oil production numbers than other companies producing condensate

and oil. Companies that did not produce any condensate or oil and the few companies

with large production numbers were dropped from the calculations to avoid skewed

production numbers. Assumed annual average liquid throughput values for the produced

water, oil, and condensate at small oil and gas sources on the Reservation are displayed

below in Table 18.

Table 18: Assumed annual average liquid throughput values for produced water, oil, and

condensate tanks at small oil and gas sources *

Number of Sources Operating in 2020

2020 Oil/Condensate Produced [bbl]

2020 Water Produced [bbl]

Average Oil/Condensate per source per year [bbl]

Average Water per source per year [bbl]

2,903

13,933

9,018,787

0.12

1,361

*

Throughput numbers were derived from averaging production numbers from COGCC (2020).

Production Data. Retrieved from http://cogcc.state.co.us/data2.html#/downloads.

Emission Calculation Methodology

Liquid storage tank emissions are calculated based on three separate emission event

categories that occur during normal tank operation at atmospheric pressures, as

described earlier in this section. The emissions categories include: breathing and working

losses, flash emissions, and loadout emissions. Discussions are provided below the

methodologies used to calculate emissions for each tank emissions category.

Breathing and Working Losses

Data Collection and Assumptions:

Emission totals for the Reservation were developed for each individual operator by

running the EPA TANKS 4.09d Emissions Estimation Software (TANKS) model once for

each tank size and production type category reported in the ICR and then multiplying

43

each modeled emissions total by the number of corresponding tanks reported. 17

Reported liquid throughput values were used when provided and assumed throughput

values were used when data was not provided.

Emission Calculations:

Standing, and working losses were calculated using the TANKS model and reported or

assumed input data values for liquid throughput, Reid vapor pressure, and tank

characteristics. An equal distribution through all tanks was assumed by dividing the total

production by the total number of tanks in a given category. Produced water was

assumed to consist of a mixture of 99% water and 1% condensate. Condensate was

assumed to have a Reid Vapor Pressure of 10 in the TANKS model. The default values for

crude oil were used for oil tank calculations. The model was run for tanks operating at

atmospheric pressure and the TANKS model meteorological conditions for Albuquerque,

New Mexico. Emission estimates using this geographic location may be biased slightly

higher, as average temperatures in Albuquerque are warmer than within the

Reservation. All tanks were assumed to have a cone shaped roof, to be gray in color, and

equipped with a tank heater.

Liquid Storage Tanks Flash Emissions

Data Collection and Assumptions:

The ICR requested flash gas liberation data from produced water, condensate, and oil, to

aid in calculating flash emissions. No ICR submittals were returned with flash liberation

data, as this type of sampling is not common practice on the Reservation.

In September 2016, the AQP contracted a third-party vendor to perform flash liberation

sampling at well-site locations operated by two different companies on the Reservation.

Sampling was performed on the separator at each well-site in order to obtain a

pressurized sample. In total, seven produced water samples were obtained from coalbed methane wells of the Fruitland Coal Formation on the east and west sides of the

Reservation. Two produced water samples and one condensate sample were obtained

from conventional natural gas wells of the Picture Cliffs Sandstone Formation in the

south central portion of the Reservation.18 Due to the very low oil production numbers

reported to the COGCC database for La Plata County Colorado in CY2020 and the absence

of viable sampling locations, the AQP elected to not obtain oil flash gas samples, but to

use the condensate flash sampling results to estimate oil flash emissions

17

U.S. EPA. (2006). TANKS 4.09d Emissions Estimation Software. Retrieved from

https://www3.epa.gov/ttnchie1/software/tanks.

18

Air Pollution Testing, Inc. (2016). Southern Ute Indian Tribe Flash Liberation Analyses.

44

Two additional condensate flash samples were provided by an operator that performed

sampling in August 2016 from liquid knockout locations on a well-site gathering pipeline

containing natural gas from conventional wells in the southern portion of the

Reservation.

All sampling reports included an extended gas analysis, gas to water ratio, gas specific

gravity, separator temperature and pressure, and ambient temperature and pressure.

Results from the six valid produced water samples were averaged to obtain assumed gas

composition, gas to water ratio values, gas molecular weight, and gas component weight

percent to be used in the development of emission factors for estimating storage tank

flash emissions. The same methodology was applied for deriving average composition

values from the three valid condensate samples.

Averaged extended gas analysis values for produced water and condensate are displayed

below in Table 19 and Table 20, respectively. Averaged gas to water and gas to

condensate values are displayed below in Table 21.

45

Table 19: Produced water flash gas analysis from small oil and gas sources on the Southern

Ute Indian Reservation [Mol %]*

Flash Gas Component

Sample 1 Sample 2 Sample 3 Sample 4 Sample 5 Sample 6

Average

Hydrogen Sulfide

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

Nitrogen

0.0373%

0.0000%

1.0883%

1.0464%

2.6862%

0.5921%

0.9084%

Carbon Dioxide

72.3236% 68.4996% 36.5680% 29.7757% 5.8668% 16.3515% 38.2309%

Methane

26.6076% 31.0289% 62.2021% 67.0612% 91.4075% 76.3697% 59.1128%

Ethane

0.3200%

0.0271%

0.1155%

0.0138%

0.0119%

4.0640%

0.7587%

Propane

0.0359%

0.0231%

0.0124%

0.037%

0.0079%

1.0078%

0.1874%

Isobutane

0.0036%

0.0035%

0.0012%

0.0049%

0.0007%

0.1582%

0.0287%

N-Butane

0.0100%

0.0160%

0.0015%

0.0163%

0.0029%

0.1689%

0.0359%

2,2 Dimethylpropane

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

Isopentane

0.0028%

0.0037%

0.0003%

0.0071%

0.0005%

0.1027%

0.0195%

N-Pentane

0.0039%

0.0078%

0.0005%

0.0117%

0.0012%

0.0612%

0.0144%

2,2 Dimethylbutane

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

Cyclopentane

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0108%

0.0018%

2,3 Dimethylbutane

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

2 Methylpentane

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

3 Methylpentane

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

N-Hexane

0.4360%

0.1881%

0.0005%

1.8678%

0.0035%

0.2114%

0.4512%

Methylcyclopentane

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

Benzene

0.0085%

0.0000%

0.0000%

0.0227%

0.0000%

0.1056%

0.0228%

Cyclohexane

0.0084%

0.0000%

0.0000%

0.0418%

0.0021%

0.0481%

0.0167%

2-Methylhexane

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

3-Methylhexane

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

2,2,4 Trimethylpentane 0.0000%

0.0000%

0.0000%

0.0000%

0.0003%

0.0088%

0.0015%

Other C7’s

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

N-Heptane

0.0000%

0.0000%

0.0006%

0.0000%

0.0026%

0.2092%

0.0354%

Methylcyclohexane

0.0037%

0.0000%

0.0000%

0.0081%

0.0029%

0.0865%

0.0169%

Toluene

0.0108%

0.0000%

0.0000%

0.0514%

0.0016%

0.1397%

0.0339%

Other C’8s

0.1872%

0.0000%

0.0091%

0.0196%

0.0011%

0.2745%

0.0819%

N-Octane

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

Ethylbenzene

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0049%

0.0008%

M&P Xylenes

0.0008%

0.0000%

0.0000%

0.0141%

0.0000%

0.0242%

0.0065%

O-Xylene

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

Other C9’s

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

N-Nonane

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

Other C10’s

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

N-Decane

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

Undecanes(11)

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

0.0000%

Totals:

100%

100%

100%

100%

100%

100%

100%

Total VOC:

0.7116%

0.2422%

0.0261%

2.1029%

0.0273%

2.6225%

0.9554%

Total HAP:

0.4561%

0.1881%

0.0005%

1.9560%

0.0054%

0.4946%

0.5168%

*

Air Pollution Testing, Inc. (2016, September). Southern Ute Indian Reservation Flash Liberation Analyses.

Table 20: Condensate flash gas analysis from small oil and gas sources on the Southern Ute

Indian Reservation [Mol %]*

Flash Gas Component

Hydrogen Sulfide

46

Sample 1

0.000%

Sample 2

0.000%

Sample 3

0.0000%

Average

0.000%

Nitrogen

6.633%

5.170%

0.5871%

4.130%

Carbon Dioxide

3.053%

2.564%

2.8208%

2.813%

Methane

62.466%

62.678%

50.2222%

58.455%

Ethane

14.918%

16.162%

20.4293%

17.170%

Propane

6.279%

7.028%

12.0540%

8.454%

Isobutane

1.371%

1.353%

3.2488%

1.991%

N-Butane

1.738%

1.840%

3.6206%

2.400%

2,2 Dimethylpropane

0.000%

0.000%

0.0000%

0.000%

Isopentane

0.794%

0.769%

1.7594%

1.107%

N-Pentane

0.551%

0.560%

1.0198%

0.710%

2,2 Dimethylbutane

0.000%

0.000%

0.0000%

0.000%

Cyclopentane

0.000%

0.000%

0.1844%

0.061%

2,3 Dimethylbutane

0.000%

0.000%

0.0000%

0.000%

2 Methylpentane

0.000%

0.000%

0.0000%

0.000%

3 Methylpentane

0.000%

0.000%

0.0000%

0.000%

N-Hexane

0.869%

0.748%

1.4232%

1.013%

Methylcyclopentane

0.000%

0.000%

0.0000%

0.000%

Benzene

0.105%

0.076%

0.1128%

0.098%

Cyclohexane

0.000%

0.000%

0.0000%

0.000%

2-Methylhexane

0.000%

0.000%

0.0000%

0.000%

3-Methylhexane

0.000%

0.000%

0.0000%

0.000%

2,2,4 Trimethylpentane

0.003%

0.003%

0.0291%

0.012%

Other C7’s

0.000%

0.000%

0.0000%

0.000%

N-Heptane

0.557%

0.461%

0.7371%

0.585%

Methylcyclohexane

0.000%

0.000%

0.2793%

0.093%

Toluene

0.166%

0.126%

0.1768%

0.156%

Other C’8s

0.000%

0.000%

0.8700%

0.290%

N-Octane

0.304%

0.247%

0.0000%

0.184%

Ethylbenzene

0.008%

0.007%

0.0076%

0.008%

M&P Xylenes

0.071%

0.074%

0.1086%

0.085%

O-Xylene

0.000%

0.000%

0.0000%

0.000%

Other C9’s

0.000%

0.000%

0.0000%

0.000%

N-Nonane

0.088%

0.088%

0.0000%

0.059%

Other C10’s

0.000%

0.000%

0.0000%

0.000%

N-Decane

0.027%

0.048%

0.0000%

0.025%

Undecanes(11)

0.000%

0.000%

0.0000%

0.000%

Totals:

100%

100%

100%

100%

Total VOC:

12.9310%

13.4280%

25.6315%

17.3302%

Total HAP:

1.2220%

1.0340%

1.8581%

1.3714%

*

Air Pollution Testing, Inc. (2016, September). Southern Ute Indian Reservation Flash Liberation Analyses.

47

Table 21: Average gas to water and gas to condensate ratios for small oil and gas sources *

Gas/Water [scf/bbl]

Gas/Condensate [scf/bbl]

3.3

16.5

*

Air Pollution Testing, Inc. (2016, September). Southern Ute Indian Reservation Flash

Liberation Analyses.

Flash Emission Calculation Methodology:

Flash emission factors in pounds per barrel (lb/bbl) were developed for VOC, BTEX,

methane, and carbon dioxide. The measured gas oil/gas water ratio (scf/bbl) was divided

by the ideal gas law conversion factor (scf/lb-mol) and then multiplied by the molecular

weight of the flash gas (lb/lb-mol) and then multiplied by the weight percent of each

specific component to derive the emission factors. The total emissions were calculated

by multiplying the emission factors for each component by the total reported production

in barrels. Tank throughput values in barrels per day were either reported values or the

assumed values developed by AQP, as described previously in this section. Flash emission

totals for the Reservation were developed for each individual operator using either

reported or assumed liquid throughput values.

Example Emission Factor Development for Flash Emissions:

Emission Factor (lb/bbl) = GOR/R*MW*Wt%

Where:

GOR = measured gas oil/gas water ratio (scf/bbl)

R = ideal gas law conversion factor (scf/lb-mol)

MW = molecular weight of flash gas (lb/lb-mol)

Wt% = weight percent of desired component in flash gas

Example Emission Calculation:

Emissions (ton/year) = EF*P/2000

Where:

EF = emission factor (lb/bbl)

P = annual production (bbl/year)

2000 = conversion factor (lb/ton)

Liquid Storage Tank Loadout Emissions

Data Collection and Assumptions:

48

Tank loadout emissions were calculated by conservatively assuming that all liquid storage

tanks are unloaded manually by truck, and not sent through pipeline. Emission factors

and emission calculations were derived from Section 5.2 of EPA AP-42 for Transportation

and Marketing of Petroleum Liquids. Loading was assumed to be submerged fill and the

saturation emission factor for submerged dedicated normal service was selected for

calculating loading losses. Truck tank capacity was assumed to be 100 bbl per loadout

event and reported or assumed liquid production numbers were used for calculating the

number or loadout events per year. Each loadout event was assumed to be one-hour in

duration and the assumed annual hours of unloading operations for each operator were

directly correlated to the reported or assumed annual liquid production. Molecular

weight and true vapor pressure values were derived from TANKS model runs for

produced water and condensate.

Example Tank Loadout Emissions Calculation Methodology:

Tank loadout emissions are calculated using two separate calculations. The first equation

is used to estimate the total molecular weight of loading emissions losses and a second

equation is used to estimate the total emission rate on a pollutant basis. Both

calculations are displayed below:

Loading Losses Calculation:

L = 12.46 x (S) x (P) x ((MW)/T) x (1-eff)

Where:

L=Loading Losses (lb/1000 gallons)

S = Saturation Factor

P = True Vapor Pressure (Pva @ T)

MW = Molecular Weight (lb/lb-mol)

T = Temperature

E = Control Efficiency of Loading

Total Emission Rate Calculation:

Tons Per Year = L*Annual Throughput/2000*Wt%

Where:

L = Loading Losses (lb/1000 gallons)

Annual Throughput = annual throughput (1000 gallons)

2000 = conversion factor (lb/ton)

Wt% = Component Weight Percentage from Flash Gas Analysis

49

Liquid Storage Tank GHG Emissions

Tank Flash Greenhouse Gas Emissions:

Flash greenhouse gas (GHG) emissions for storage tanks were calculated using the

measured data from the flash liberation sampling completed in 2016 from well-sites on

the Reservation. Emission factors for Methane and Carbon Dioxide were developed as

cited in the Flash Emission Calculation Methodology section of this report. These

emission factors were multiplied by the total production and divided by a conversion

factor to provide an output in tons per year. This was then multiplied by a conversion

factor to convert to metric tonnes and then multiplied by the global warming potential of

each component, found in Sixth Assessment Report of the Intergovernmental Panel on

Climate Change (IPCC) Table 7.15, to provide an output total in metric tonnes of carbon

dioxide equivalent.

Example Calculation for Tank Flash GHG Emission:

CH4 (CO2e) = (EF*P/CF1)*CF2*GWP

Where:

EF = emission factor (lb/bbl)

P = annual production (bbl/year)

CF1 = conversion factor (2000lb/ton)

CF2 = conversion factor (0.907185 metric tonnes/ton)

GWP = global warming potential (29.8 for Methane, 273 for N2O)

Tank Loadout GHG Emissions

GHG emissions from tank loadout were calculated using the same methodology found in

the Liquid Storage Tank Loadout Emissions section of this report. Once the loadout

emissions, in tons per year, are determined for a GHG, it is multiplied by a conversion

factor to convert it to metric tonnes. This metric tonnes number is then multiplied by the

global warming potential of the individual component to provide an output in metric

tonnes of carbon dioxide equivalent.

Example Tank Loadout GHG Calculations:

CO2e = tpy*CF*GWP

Where:

CO2e = carbon dioxide equivalent (metric tonnes)

tpy = emissions (tons per year)

CF = conversion factor (0.907185 metric tonnes/ton)

GWP = global warming potential of individual pollutant

50

Total Liquid Storage Tank Emissions

Total liquid storage tank emissions at small oil and gas sources from working and

breathing losses, flash emissions, tank loadout, and GHG emissions on the Reservation

are displayed in below in Table 22 and Figure 26. Emissions are displayed by tank

contents.

Table 22: VOC, HAP, and GHG Emissions from liquid storage tanks at small oil and gas

sources [tons]*

Tank Contents

Tank Count

VOC

Condensate

79

50.8

Oil

44

11.1

Produced Water

1633

48.3

Totals

1756

110.2

*GHG emissions reported in metric tonnes

Total HAP

0.01

0.02

2.0

2.1

GHG

5.3

14.8

11,477.4

11,497.5

Figure 26: VOC and HAP emissions from liquid storage tanks at small oil and gas sources

[tons]

Small Oil and Gas Source Tank

Emissions (tons)

60.0

50.0

50.8

48.3

40.0

30.0

20.0

11.1

10.0

0.01

0.0

0.02

Condensate

Oil

VOC

2.0

Produced Water

Total HAP

E. External Combustion Sources

Description of Sources

Natural gas-fired external combustion sources are widely used by the natural gas

industry as tank heaters, heated separators, reboilers, and boilers.

Data Collection

51

The ICR required each operator to report the total number of heaters and boilers

operated by their company on the Reservation. Heater and boiler counts were reported

according to heat rate range in MMBTU/hr. Operators were also given the option to

report average heater and boiler operating hours to override the AQP’s assumed

operating hours. A description of the AQP’s assumed values is included in the emission

calculation discussion.

Assumptions

If no hours of operation were reported in the ICR, AQP assumed heaters to operate 24

hours per day for half of the year (183 days per year) which equates to 4,392 hours per

year. Boilers were assumed to operate for 24 hours per day, 365 days a year, which

equates to 8,760 hours per year.

Emission Calculation Methodology

Criteria pollutant and HAP emissions for external combustion sources were calculated

using the emission factors from EPA AP-42 Chapter 1.4 for uncontrolled natural gas-fired

external combustion sources, the maximum heat rating from each heat rating category

reported in the ICR, a default natural gas heating value of 1,026 Btu/scf and assumed or

reported operating hours.

The AQP used the default natural gas heating value of 1,026 Btu/scf from 40 CFR Part 98

to convert the EPA emission factors from lbs/MMscf to lbs/MMBtu.

GHG emissions were calculated using the Tier 1 calculation methodology, the natural gas

emission factors from Tables C-1 and C-2 of 40 CFR Part 98 and assumed or reported

operating hours.

Example Calculations

Criteria and HAP Example Calculations:

lb/hr = (EF/HV) x (HR)

Where:

EF = Emission Factor (lb/MMscf)

HV = Default Heat Value of Natural Gas fuel (Btu/scf)

HR = Heat Rate of Boiler/Heater (MMBtu/hr)

Example NOx lb/hr calculation for 0.5 MMBtu/hr natural gas-fired boiler/heater:

52

lb/hr = (100/1,026) x 0.5 = 0.05

tpy = (lb/hr) x OH/2000

Where:

(lb/hr) = Emission Rate

OH = Annual Operating Hours

2000 = Pounds per ton

Example NOx tpy calculation for 0.5 MMBtu/hr natural gas-fired boiler/heater operating

4392 hours per year:

tpy = (0.05) x 4392/2000= 0.1098

GHG Example Calculation:

GHG Calculation Methodology:

= EF x HR x CF x GWP

Where:

EF = fuel specific default emission factor, from tables C-1 and C-2 of Part 98 (kg/MMBtu)

HR = heat rate (MMBtu/hr)

CF = conversion factor (lb/kg)

GWP = global warming potential

Emissions

Criteria pollutant, HAP, and GHG emissions from external combustion sources located at

small oil and gas sources on the Reservation for calendar year 2020 are displayed below

in Table 23. Emissions are displayed by unit count and heat rating in MMBtu/hr.

Table 23: Criteria pollutant, HAP, and GHG emissions from heaters and boilers at small oil

and gas sources [tons]*

Equipment Type

and Heat Rating

Heaters

0.25 MMBtu/hr

0.5 MMBtu/hr

1.0 MMBtu/hr

100 MMBtu/hr

Heaters Total

Boilers

0.25 MMBtu/hr

Boilers Total

53

Unit Count

NOx

VOC

SO2

PM

CO

HAP

GHG (CO2e)

1798

328

1001

9

3136

95.8

35.0

214.2

92.6

537.7

4.9

1.9

11.8

10.6

29.2

0.6

0.2

1.3

1.2

3.2

7.8

2.9

16.3

14.6

41.6

80.5

29.4

180.0

161.8

451.7

1.7

0.6

1.5

3.6

7.4

104,417.2

38,162.0

233,523.4

209,961.1

586,063.8

6

6

0.6

0.6

0.0

0.0

0.0

0.0

0.1

0.1

0.5

0.5

0.0

0.0

698.0

698.0

Total

3142

*GHG reported in metric tonnes.

538.3

29.3

3.2

41.7

452.2

7.4

586,761.7

F. Equipment Leaks and Fugitive Emissions

Description of Sources

Natural gas leaks from components commonly used in the natural gas industry result in

emissions of methane, CO2, VOC, and HAP. Components include: valves, pumps, pressure

relief valves, connectors, flanges, and, open-ended lines. These components are ancillary

equipment to many larger equipment source types including: headers, separators,

heaters, filters, engines, compressors, dehydration units, and storage tanks.

Data Collection

The ICR provided operators with the option to report average fugitive component counts

for single and co-located well-sites. In the absence of ICR provided component counts,

the AQP relied on assumed component counts, as detailed below.

Assumptions

Fugitive component counts were assumed based on component counts for natural gas

production contained in the Canadian Association of Petroleum Producers (CAPP)

document titled Guide to Calculating Greenhouse Gas Emissions.19 Component counts for

single and co-located well-site locations are displayed below in Table 24.

Table 24: Assumed fugitive emission component counts at single and co-located natural gas

well-sites

Valves-Gas/Vapor

Component

count for a

Single well

16

Component

count for Two

co-located wells

32

Component

count for Three

Co-located wells

48

Component

count for Four

Co-located wells

64

Connectors-Gas/Vapor

60

120

180

240

Open-Ended Lines-Gas/Vapor

3

6

9

12

Component Type-Service

Emission Calculation Methodology

GHG, VOC, and HAP Emission Calculations:

GHG, VOC, and HAP emissions from equipment leaks and fugitive emissions were

calculated using the average emission factor approach and the gas/vapor total organic

compound (TOC) emission factors for oil and gas production from Table 2-4 of EPA’s

19

Canadian Association of Petroleum Producers. (2003). Guide to Calculating Greenhouse Gas Emissions. Retrieved

from http://www.capp.ca/publications-and-statistics/publications/241974.

54

OAQPS document titled Protocol for Equipment Leak Emission Estimates. The TOC

emission factor for gas/vapor was chosen as the most representative of production on

the Reservation in CY2020 and is the most conservative emission factor available. TOC

emissions were calculated by multiplying the gas/vapor emission factor by component

counts calculated using the CAPP generic fugitive component count and the number of

sources entered in the ICR. Each source was assumed to operate for 8,760 hours

annually. GHG, VOC, and HAP emissions were then derived by multiplying the TOC

emissions by the GHG, VOC, and HAP molecular weight fraction percentages of an

assumed extended natural gas analysis for the Reservation. If component counts were

provided by operators in the ICR, emissions for their company’s productions were

calculated using their reported counts in place of the CAPP component counts.

Example Calculations

GHG, VOC, and HAP Emission Calculation Methodology:

GHG, VOC, or HAP Emissions = EPA OAQPS Average Emission Factor for Gas Valves x CAPP

Generic Valve Count x Annual Operating Hours x (Ton/2000lb0 x weight percent (GHG,

VOC, or HAP) = tpy GHG, VOC, or HAP emissions

Valves VOC Emissions (tpy) = (0.00992 lb/hr/valve) x 1000 valves x (8760 hr/yr) x

(Ton/2000 lb) x (1.51%) = 0.66 tons/year

Emissions

Volatile organic compound, HAP, and GHG emissions from equipment leak and fugitive

emission sources located at small oil and gas sources on the Reservation for calendar

year 2020 are displayed below in Table 25.

Table 25: Emissions of VOC, HAP, and GHG from equipment leaks and fugitive emission

sources at small oil and gas sources [tons]*

Fugitives

VOC

Total HAP

GHG

172.2

0.4

298,443.7

*GHG reported in metric tonnes.

G. Natural Gas Driven Pneumatic Devices

Description of Sources

Natural gas-driven pneumatic controllers and pumps are used in the oil and natural gas

industry for maintaining liquid levels, pressures, pressure differentials, and temperature.

Many devices are designed to leak, or “bleed”, natural gas and in doing so emit natural

gas containing methane, CO2, VOC, and HAP. Pneumatic devices are classified as high or

55

low continuous bleed controllers, intermittent bleed controllers, or zero bleed

controllers.

Data Collection

The AQP assigned an assumed value for the average number of pneumatic devices

located at a single wellsite from the 2014 Environmental Science and Technology report

titled Methane Emissions from Process Equipment at Natural Gas Production Sites in the

United States.20 The assumed pneumatic device count value was provided in the ICR and

operators were provided the opportunity to override the assumed value with values

more representative of their operations.

Emission Calculation Methodology

Pneumatic device emissions were calculated by applying the generic natural gas emission

factors found in EPA’s April 2014 Report for Oil and Natural Gas Sector Pneumatic

Devices to the AQP’s assumed average device count or average device counts reported in

the ICR.

Example Emission Calculation:

lb/hr = Count x Bleed Rate x R x MW x Y

Where:

Count = total number of devices

Bleed Rate = bleed rate from device (scf/hr/device)

R = Universal gas constant (lb-mol/379.4scf)

MW = molecular weight of the component (lb/lb-mol)

Y = volume fraction of component in the vented gas

Example for Methane:

lb/hr = 2695 x 5.5 x 1/379.4 x 16.01 x 92% = 575.4 lb/hr

tpy = lb/hr x OH/2000

Where:

lb/hr = emission rate in pounds per hour

OH = annual operating hours

20

Allen, D. (2014). Methane Emissions from Process Equipment at Natural Gas Production Sites in the United States:

Pneumatic Controllers. Environmental Science & Technology, 49, 633-640. Retrieved from

http://pubs.acs.org/doi/pdf/10.1021/es5040156.

56

2000 = pounds per ton

tpy methane = 575.4 x 8760/2000 = 2520.3 tpy

Emissions

VOC, HAP, and GHG emissions from natural gas driven pneumatic devices on the

Reservation during 2020 are displayed below in Table 26.

Table 26: VOC, HAP, and GHG emissions from natural gas driven pneumatic devices at

small oil and gas sources [tons]*

VOC

Total HAP

Pneumatics

146.4

10.2

*

GHG reported in metric tonnes.

GHG

217,529.5

H. Natural Gas Blowdowns

Description of Sources

Natural gas blowdowns are intentional and unintentional gas releases during

maintenance, routine operations, and emergencies. Blowdowns occur from gas

compressors, compressor startups, gas wellbores, vessels, pipelines, and various

equipment.

Data Collection

The ICR requested emissions resultant from maintenance and emergency natural gas

blowdowns from compressors. Due to the burden of capturing actual emissions for each

blown down event at a large number of small oil and gas sources, emissions from such

events are based on assumptions on the amount of gas released, the AQP’s assumed

extended gas analysis, and an assumed number of events anticipated during a calendar

year. The ICR provided operators with the opportunity to override the AQP’s assumed

values with values more representative of their operations.

Assumptions

The AQP developed assumed values for the number and time duration of annual

compressor blowdowns that occur per year and the volume of natural gas vented per

event. Assumed values were based on the 2015 Colorado Air Resources Management

Modeling Study (CARMMS)21. The values assumed for 2020 are displayed below in Table

27.

ENVIRON International Corp.; Carter Lake Consulting; Environmental Management and Planning Solutions. (2015).

Colorado Air Resources Management Modeling Study. Retrieved from

21

57

Table 27: Assumed values for annual natural gas compressor blowdown events occurring at

small oil and gas sources in 2017

Compressors

Annual compressor blowdowns per compressor

2

Estimated amount of gas lost per blowdown [Mscf/event]

10

Emissions Calculation Methodology

Emissions from natural gas blowdowns were calculated using either the AQP’s assumed

extended gas analysis or reported natural gas analysis, and assumed or reported event

frequencies, duration, and gas loss values.

Example Calculations:

tpy = Total vented x Ideal Gas Density/2000

Where:

Total vented = total volume of gas vented (for specific component) (scf/yr)

= (volume vented per blowdown (Mscf/event) x frequency (events/yr) x 1000scf/Mscf) x

%vol of component

Ideal Gas Density (lb/scf) = MW/(R*T)

MW = molecular weight of the component

R = universal gas constant (0.730235 scf.atm/°R.lb-mol)

T = temperature (60 °F converted to 519.67 °R)

2000 = pounds per ton

Emissions

Emissions from natural gas blowdown activities occurring on the Reservation during 2020

are displayed below in Table 28.

Table 28: VOC, HAP, and GHG emissions from natural gas blowdowns at small oil and gas

sources [tons]*

Pollutant

VOC

Total HAP

GHG

Blowdowns

0.1

0.0

182.2

*GHG reported in metric tonnes.

https://www.blm.gov/sites/blm.gov/files/documents/files/program_natural%20resources_soil%20air%20water_air

co_quicklins_CARMMS2.0.pdf.

58

I. Well Completion and Re-completion Venting

Description of Sources

Well completions and recompletions, when not employing closed vent system

techniques, also known as “green completions”, release natural gas during the “flow

back” stage of the process. Flow back is the stage in which drilling fluid and hydrocarbon

reservoir fluids return to the surface prior to well production. Green completion

techniques capture flow back materials, including natural gas.

Data Collection

The number of well completions that occurred in calendar year 2020 were obtained from

the COGCC database. Zero well completions occurred on the Reservation in calendar year

2020. No data were available for well recompletions in the COGCC database and an

assumed recompletion value of 1% of all operating wells per year was obtained from the

2015 CARMMS.

The ICR also provided the opportunity for operators to report the number of well

completion and recompletion events that occurred in calendar year 2020, including

natural gas lost per event, and completion by type (conventional or green completion).

Assumptions

Fifty percent of all well completions and recompletions were assumed to utilize green

completion technology with no natural gas vented to atmosphere. Conventional well

completions and recompletions were assumed to vent 1,000 Mscf of natural gas per

event. These assumptions were derived from the 2015 CARMMS.

For well recompletions, the assumed well recompletion value of 1% of all operating wells

per year was obtained from the CARMMS study and assumed to be accurate and

representative of operations on the Reservation.

All completion and recompletion activities were assumed to be either conventional or

green completions, based on information provided by two large natural gas operators on

the Reservation. Therefore, the AQP did not estimate emissions from flaring events that

may occur during well completion or re-completion activities. Assumed well completion

and recompletion values for 2020 are displayed below in Table 29.

Table 29: Assumed values for well completion and recompletion activities at small oil and

gas sources*

Completion Type

Percent of completions by type:

59

Conventional

50%

Green Technology

50%

Estimated amount of gas vented to atmosphere per event

[Mscf/event]:

Estimated amount of gas controlled via closed loop

system per event [Mscf/event]:

*Assumed values are based on the 2015 CARMMS.

1000

0

0

1000

Emission Calculation Methodology

Emissions from well completion and recompletions were calculated using an assumed

extended gas analysis and reported or assumed event frequencies and gas loss values.

Emissions from drilling engines that are employed during well completion and recompletion activities were not calculated.

Emissions

Emissions from well completion and recompletion venting on the Reservation in calendar

year 2020 are displayed below in Table 30.

Table 30: VOC, HAP, and GHG emissions from well recompletion activities at small oil and

gas sources [tons]*

VOC

Total HAP

Recompletions

42.9

0.1

*GHG reported in metric tonnes.

GHG

27,232.2

VOC, HAP, and GHG emissions from Fugitives, Blowdowns, Recompletions, and

Pneumatics are displayed below in Figure 27 and Figure 28.

Figure 27: VOC and HAP emissions from Fugitives, Blowdowns, Recompletions, and

Pneumatics [tons]

Small Oil and Gas Source VOC and

Total HAP Emissions From Various

Sources (tons)

200.0

172.2

146.4

150.0

100.0

42.9

50.0

-

0.4

10.2

Fugitives

Pneumatics

VOC

60

0.1

0.0

0.1

Blowdowns

Recompletions

Total HAP

Figure 28: GHG emissions from Fugitives, Blowdowns, Recompletions, and Pneumatics

[tonnes]

Small Oil and Gas Source GHG

Emissions From Various Sources

(tonnes)

350,000.0

300,000.0

298,443.7

250,000.0

217,529.5

200,000.0

150,000.0

100,000.0

50,000.0

27,232.2

182.2

Fugitives

Pneumatics

Blowdowns

Recompletions

J. Typical Well-Site Configuration

Description

The AQP compiled equipment count information collected in the previous

comprehensive emission inventory ICRs in CY 2015 to prepare average equipment type

counts based on the number of natural gas wells located on a single well-pad. This

information can be used to gain a better understanding of typical well-site configurations

on the Reservation and to assist with estimating emissions from any proposed natural

gas development schedules.

Average equipment counts at small oil and gas sources on the Reservation are displayed

below in Table 31 and Figure 29.

Table 31: Average equipment counts at single and co-located well-sites at small oil and gas

sources

Number of

Wells per Pad

Heater

Separator

Dehydrators

Compressors

Produced

Water Tanks

Condensate

Tanks

Engine

1

2

3

4

0.5

1.3

1.6

1.0

1.0

2.4

2.5

3.0

0.2

0.2

0.2

0.0

0.1

0.2

0.1

0.0

0.8

1.4

1.9

1.5

0.1

0.0

0.0

0.0

0.4

1.2

1.5

2.5

Figure 29: Average equipment counts at small oil and gas sources by equipment type

61

2.5

1 Well

2 Well

3 Well

1.2

1.5

Engine

Condensate Tanks

0.1

0

0

0

Produced Water Tanks

0.4

1.4

0.8

Dehydrators

Compressors

0

0.2

0.2

0.2

Separator

0.1

0.2

0.1

0

1

1

Heater

1.9

1.5

2.4

2.5

1.3

1.6

0.5

3.5

3

2.5

2

1.5

1

0.5

0

3

Average Equipment Counts at Single and

Co-Located Natural Gas Well Sites by

Equipment Type (2015)

4 Well

2. Fruitland Formation Outcrop Natural Gas Seeps

Description of Sources

Naturally occurring methane and CO2 seepage from outcrops of the Cretaceous Fruitland

Formation (Fruitland Outcrop) contribute a significant quantity of the GHG emissions on

the Reservation.

Data Collection

The data used to quantify emissions from the Fruitland Outcrop were provided to the

AQP from the SUIT Department of Energy (SUIT DOE). SUIT DOE has collected outcrop

seepage data on an annual basis since 2007 using an independent contractor between

2007 and 2020. The goal of the study is identification, mapping, and quantification of

methane seeps on the Fruitland Outcrop. A backpack mounted, hand-held gas flux meter

manufactured by WEST Systems is used to measure methane and CO 2 soil gas flux

concentrations in moles per meters squared per day [mol/m² day] at thirty-five seep

areas, totaling 51,667,675 square feet (1.9 miles) of ground. The flux concentrations

were then used by the contractor to calculate volumetric methane and CO2

concentrations for 2020 in MCFD.

Emission Calculation Methodology

62

The AQP calculated ton per year emission rates for methane and CO2 by converting the

volumetric methane and CO2 flux concentrations from MSCF to SCFD and then dividing

the flux concentrations by the ideal gas law constant and multiplying the constants by

the molecular weight of each gas. GHG emissions in CO2 equivalence (CO2e) were

calculated by multiplying methane emissions by the IPCC’s global warming potential

factor of 29.8 for methane.

Example Calculations

Calculation to Convert Flux Rate in SCFD to lb/day

lb/day = Flux/Ideal Gas Law Conversion Factor*molar mass

Where:

Flux = Volumetric gas flux in SCFD

Ideal Gas Law Conversion Factor = 379.3 SCF/mol

Molar Mass = g*Mol¯¹ (CH4 = 16.04; CO2 = 44.01)

lb/day Methane = 27,574,000/379.3*16.04 = 1,166,061 lb/day Methane

Calculation to convert lb/day to tpy:

tpy = lb/day/2000(lb/ton)*365 (days/year)

Emissions

Emission calculations for methane, CO2, and total GHG in CO2e are displayed below in

Table 32:

Table 32: Emissions of methane, CO2, and total GHG in CO2 Equivalent [tonnes]

Methane

CO2

Total GHG (CO2e)

5,753,025.33

170,315.82

5,923,341.15

3. Gas Stations

Description of Sources

There are five road and one marina gasoline service station that operated on the

Reservation during calendar year 2020.

Data Collection

63

2020 gasoline throughput values were provided to the AQP by representatives of each

gas station, and the total throughput is displayed below in Table 33.

Table 33: Annual gasoline throughput at gasoline stations located on the Southern Ute

Indian Reservation [gal/yr]*

Total Gasoline Throughput:

1,650,141.75

Assumptions

AQP assumed that gasoline throughput values reported by gas station representatives

are valid.

Due to the absence of emission factors for diesel fuel dispensing in EPA AP-42 Section

5.22, the AQP assumed emissions from diesel fuel dispensing to be negligible and did not

calculate emissions for this activity. EPA AP-42 Section 5.2.2, also assumes a negligible

methane content from gasoline evaporative emissions; therefore, AQP did not calculate

GHG emissions for gas stations.

Emission Calculation Methodology

Gas station emissions were calculated using the Tribal Emissions Inventory Software

Solutions (TEISS) emissions calculator for gasoline service stations. 22 The calculator

employs emission factors from EPA AP-42 Section 5.2.2. Total reported fuel throughputs

were input into the TEISS emissions calculator for two stages of gasoline service station

emissions. Stage 1 includes underground tank filling and submerged filling. Stage 2

includes underground tank breathing and emptying, vehicle refueling displacement

losses (uncontrolled), and spillage.

Emissions

Total VOC emissions from gas stations on the Reservation during 2020 are displayed

below in Table 34.

Table 34: VOC emissions from gasoline dispensing stations [tons]

Pollutant

VOC

Emissions

16.83

4. Aviation Gasoline

22

Institute for Tribal Environmental Professionals. (2021). Tribal Emissions Inventory Software Solution Version 3.6.

Retrieved from http://www7.nau.edu/itep/main/air/air_aqt_teiss.

64

Description of Sources

Emission estimates for aviation gasoline and the amount of lead in the leaded gasoline

for counties were last developed by EPA for calendar year 2014. Lead is an additive in

aviation gasoline used for piston-engine aircrafts (either general aviation or air taxi) to

increase the fuel octane and prevent valve seat decline, which is a safety concern.

Data Collection

Data was obtained from the EPA NEI for calendar year 2017. EPA’s data collection

methodology is described in EPA’s 2008 Technical Support Document titled Lead

Emissions from the Use of Leaded Aviation Gasoline in the United States.23

Assumptions

The AQP assumed EPA’s calendar year 2017 EPA’s aviation gasoline emission estimates

for La Plata County and Animas Air Parks would be the most representative emission

estimates available for calendar year 2020.

Emissions

VOC and HAP emissions from aviation gasoline usage on the Reservation in 2020 is

displayed below in Table 35.

Table 35: VOC and HAP emissions from aviation gasoline [tons] *

Total VOC Emissions

6.28

Total HAP Emissions

0.33

*

Emissions for aviation gasoline fueling are estimated from data sourced from the 2017 EPA

National Emission Inventory Database and assumed to be realistic estimations of aviation

gasoline fueling emissions for 2020.

5. Gravel Pits

Description of Sources

Twelve sand and gravel pits operated within the exterior boundaries of the Reservation

during calendar year 2020. Data was collected from the Colorado Division of Reclamation

23

U.S. EPA. (2008, October). Lead Emissions from the use of Leaded Aviation Gasoline in the United States.

Retrieved from: https://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=P1004MXJ.TXT.

65

Mining and Safety (DRMS) database24. The emissions from pits on the Reservation were

estimated by scaling down the emissions estimates reported to the 2017 EPA NEI for La

Plata and Archuleta counties for calendar year 2017.

Data Collection

The AQP identified active gravel pits located within the exterior boundaries of the

Reservation through the DRMS ArcGIS data set. AQP identified the gravel, sand, and

combined sand and gravel permits located within the exterior boundaries of the

Reservation in La Plata and Archuleta counties. Permits with an active status for 2020

were then cross-referenced with the DRMS Imaged Document data to determine if there

was production in 2020. This methodology determined nineteen active gravel pits in La

Plata County and three active gravel pits in Archuleta County during 2020.

Emissions

Gravel pit emissions for La Plata County were obtained from the EPA’s calendar year

2017 Nonpoint Emission Inventory for gravel pits. Emission totals were reported to NEI

for La Plata and Archuleta counties and not for individual gravel pits. To derive emission

estimates for the Reservation, the reported emission totals for La Plata County were

downscaled by the percentage of the affected acreage of active gravel pits that are

located within the exterior boundaries of the Reservation. For example, 30.71% of the

affected acreage of active gravel pits in La Plata County are within the Reservation

boundaries, therefore, gravel pits on the Reservation account for 30.71% percent of

emissions in La Plata County. Emission totals for 2020 are displayed below in Table 36.

Table 36: Emissions of PM10 and PM2.5 from active gravel pits

County

Pollutant

County emissions

[tpy]

Percent of active

permitted pits within

SUIR

Reservation

Emissions

[tpy]

La Plata

La Plata

Archuleta

Archuleta

PM10

PM2.5

PM10

PM2.5

176.38

22.05

29.40

3.67

30.71%

30.71%

10.88%

10.88%

54.16

6.77

3.20

0.40

6. Residential Heating

A. Description of Sources: Fireplaces and Wood Burning Stoves

24

Colorado Division of Reclamation Mining and Safety. (2021). Active Hardrock Permits. Department of Natural

Resources. Retrieved from https://maps.dnrgis.state.co.us/drms/Index.html?viewer=drms.

66

Fireplaces and wood burning stoves are a significant source of residential heating within

the exterior boundaries of the Reservation. The predominant types of solid fuel available

are pinyon-juniper, pine, and aspen.

Data Collection

The U.S. Census 2015-2019 American Community Survey 5-Year Estimate (survey) was

used to determine the number of households on the Reservation that use fireplaces or

wood burning stoves for residential heating.25 The survey estimates the total number of

households on the Reservation that used wood as a heating source during the five-year

survey period.

The U.S. Energy Information Administration, Office of Energy Consumption and Efficiency

Statistics’ 2015 Residential Energy Consumption Survey (EIA) was used to obtain the

average number of cords used within a year at an average household. 26 Table CE7.2 of

the EIA lists the household wood consumption as 35.2 million BTU . Utah State

University Forestry Extension lists the Heating Value per Cord in million BTU from which

an average heating value for the predominant types of solid fuel available of pinyonjuniper, pine, and aspen was calculated. The average heating value per cord of 22.4

million BTU was used to calculate an average household usage of 1.6 cords per year. The

U.S. Census reported 925 households on the Reservation use fireplaces or woodstoves as

the primary heating source.

Fireplace and wood burning residential heating data for the Southern Ute Indian

Reservation in 2020 is displayed below in Table 37.

Table 37: Fireplace and wood burning residential heating data

Homes heated

with wood

815

Average fuel use per

household/year

1.6

Unit of

measurement

Cords

Total number of cords

used in 2020

1304

Emission Calculation Methodology

Emissions for residential fireplace and wood burning stoves were calculated using the

Tribal Emissions Inventory Software Solutions (TEISS) emission calculator. The calculator

employed emission factors from EPA AP-42 Section 1.10.2, which may be adjusted based

on the units of data input.

Example Calculations

25

U.S. Census Bureau. (2019). 2015-2019 American Community Survey 5-Year Estimates. Retrieved from

https://data.census.gov/cedsci/

26

U.S. Energy Information Administration. (2021) Table CE7.2 Household wood consumption in the U.S. – totals and

averages, 2015. Retrieved from: https://www.eia.gov/consumption/residential/data/2015/c&e/pdf/ce7.2.pdf.

67

Wood Type

Western Juniper

Pinyon

Quaking Aspen

Average

Heating Value

Mm BTU/cord

21.8

27.1

18.2

22.4

35.2 mmBTU x 1 cord = 1.6 cords (input into TEISS)

22.4 mm BTU

815 households x 1.6 cord = 1,304 cords (input into TEISS)

household

Assumptions

The U.S. Census surveyed 5,102 households and reported 815 with an estimated

uncertainty of ± 206 households on the Reservation use fireplaces or woodstoves for

home heating. The TEISS variables chosen were conventional pre-phase I wood stove,

Rocky Mountain and Pacific Coast region with Ponderosa Pine Hardwood Forest.

Emissions

Total criteria pollutant and GHG emissions from residential fireplace and wood-burning

stoves on the Reservation in 2020 are displayed below in Table 38.

Table 38: Criteria pollutant and GHG emissions from fireplaces and wood burning stoves

[tons]*

Pollutant

Total

NOx

1.87

SO2

0.27

PM10

20.49

CO

154.54

VOC

35.49

GHG (CO2e)

5629.94

*GHG reported in metric tonnes.

B. Description of Sources: Propane Heating

Liquid propane (LP) is the dominant source of residential heating on the Reservation and

in Southwest Colorado.

Data Collection

68

The U.S. Census 2015 -2019 American Community Survey 5-Year Estimate was used to

determine the number of households on the Reservation that use LP gas as a source of

heating.

The U.S. Energy Information Administration, Office of Energy Consumption and Efficiency

Statistics’ 2015 Residential Energy Consumption Survey (EIA) was used to obtain the

average of LP used per household. The survey estimated the average number of gallons

of LP used within a year for an average household.27 The U.S. Census surveyed 5,102

households and reported 2,555 with an estimated uncertainty of ± 331 households on

the Reservation use LP gas as the primary heat source and the EIA estimated 278 gallons

of LP gas are burned per year in households in Colorado.

Liquid Propane residential heating data for the Southern Ute Indian Reservation in 2020

is displayed below in Table 39.

Table 39: Liquid propane residential heating data

Homes Heated with

Liquid Propane

2,555

Average Fuel Use per

Household/Year

278

Unit of

Measurement

Gallons

Total Gallons

used in 2020

710,290

Emission Calculation Methodology

Emissions for residential LP gas heating were calculated using the TEISS emission

calculator. The calculator employed emission factors from EPA AP-42 Section 1.5.

Example Calculation

2,555 households x 278 gallons = 710,290 gallons *(input into TEISS)

household

Assumptions

The U.S. Census surveyed 5102 households and reported 2,555 with an estimated

uncertainty of ± 331 households on the Reservation use LP gas for home heating. The

actual sulfur content of LP gas on the Reservation is unknown and the default sulfur

content of 0.54 grains/100 ft3 was used in the TEISS emission calculator.

Emissions

Total criteria pollutant and GHG emissions from residential LP gas usage on the

Reservation in 2020 is displayed below in Table 40.

27

U.S. Energy Information Administration. (2021). Table CE2.5 Household Site Fuel Consumption in the West

Region, Totals and Average, 2015 Physical Units. Retrieved from https://www.eia.gov/consumption/.

69

Table 40: Criteria pollutant and GHG emissions from liquid propane gas heating at

residential sources [tons]*

Pollutant

NOx

SO2

Total

4.76

0.02

*

GHG reported in metric tonnes.

PM10

0.01

CO

1.35

VOC

0.19

GHG (CO2e)

4080.06

C. Description of Sources: Natural Gas Heating

Natural gas is a prevalent residential heating fuel on the Reservation.

Data Collection

The U.S. Census 2015-2019 American Community Survey 5-Year Estimate (survey) was

used to determine the number of households on the Reservation that use natural gas for

residential heating. The survey estimates the total number of households on the

Reservation that used natural gas as a heating source during the five-year survey period.

The U.S. Energy Information Administration, Office of Energy Consumption and Efficiency

Statistics’ 2015 Residential Energy Consumption Survey (EIA) was used to obtain the

average of natural gas used per household. The survey estimated the average cubic feet

of natural gas used within a year for an average household. The U.S. Census reported

1017 or 20% of households on the Reservation use natural gas as the primary heat

source and the EIA estimated 48.3 thousand cubic feet (48.3 Mcf) of natural gas are

burned per year in households in Colorado.

Natural Gas residential heating data for the Southern Ute Indian Reservation in 2020 is

displayed below in Table 41.

Table 41: Natural gas residential heating data

Homes Heated with

Natural Gas

1017

Average Fuel Use per

Household/Year

0.0483

Unit of

Measurement

MMcf

Total MMcf used in

2017

49.12

Emission Calculation Methodology

Emissions for residential natural gas heating were calculated using the TEISS emission

calculator. The calculator employed emission factors from EPA AP-42.

Example Calculation

1017 household x 0.0483 MMcf gas = 49.12 MMcf gas (input into TEISS)

household

70

Assumptions

The U.S. Census surveyed 1,017 households with an estimated uncertainty of ± 208

households that use natural gas for home heating. TEISS input variables were the EPA AP42 default heating value of 1020 Btu/ft3 and sulfur content of 2000 grains/ MMft3.

Emissions

Total criteria pollutant and GHG emissions from residential natural gas heating sources

on the Reservation in 2020 are displayed below in Table 42.

Table 42: Criteria pollutant and GHG emissions from natural gas heating at residential

sources [tons]*

Pollutant

NOx

SO2

Total

2.31

.01

*

GHG reported in metric tonnes.

PM10

.05

CO

0.98

VOC

0.14

GHG (CO2e)

2661.35

7. Agricultural Burning

Description of Activity

Agricultural burning is performed on the Reservation to clear irrigation ditches of

vegetation and to clear pastures of weeds and vegetation prior to crop cultivation.

Data Collection

Emissions from agricultural burning on the Reservation were obtained from the 2017 NEI

for La Plata County and 2014 NEI Archuleta County as the 2017 NEI contained no data for

Archuleta. EPA reported two types of agricultural burning: Agricultural Burning Grasses,

and Agricultural Burning Unspecified Crop Type. EPA did not report emissions for

Agricultural Burning Unspecified Crop Type for Archuleta County. Emissions were not

included in this emissions inventory for Montezuma County due to only 0.2% of the

county falling within the Reservation boundaries.

Emission Calculation Methodology

Emissions obtained from the NEI for La Plata and Archuleta County were scaled down

proportionally to the percentage of land in La Plata and Archuleta counties that fall

within the exterior boundaries of the Reservation. 38.9% and 29.5 % respectively.

Assumptions

71

AQP assumes the methods and calculations used to develop emissions from agricultural

burning are valid and acknowledges that the process used to reduce emissions for the

Reservation could result in a slight under or overestimation of emissions. It is also

assumed that emissions from agricultural burning from the 2014 and 2017 NEI are

realistic estimations that occurred in 2020.

Emissions

Criteria pollutants, NH3, and HAP emission estimates from agricultural burning that

occurred within the exterior boundaries of the Reservation in 2020 are displayed below

in Table 43.

Table 43: Criteria pollutant, NH3, and HAP emissions from agricultural burning [tons]*

Pollutant

PM10

PM2.5

CO

NOx

NH3

SO2

VOC

Total

1.40

1.03

8.05

0.19

0.55

0.07

0.67

Emissions for agricultural burning were estimated from data retrieved from the 2014 and 2017 EPA

National Emission Inventory Database and are assumed to be realistic estimations of agricultural

burning emissions that occurred in 2020.

*

VI.

Mobile Sources

Description of Sources

Mobile source emissions are generated from on-road vehicles and non-road engines

including lawn equipment, recreational vehicles, agricultural equipment, construction

equipment, etc.

1. On-Road Mobile Sources

AQP estimated emissions for on-road mobile sources using EPA’s 2017 NEI county level

mobile emissions data to estimate Reservation specific mobile emissions. On-road

mobile sources in 2017 NEI county level data include emissions from motorized vehicles

that are normally operated on public roadways. This includes diesel and non-diesel

(gasoline, compressed natural gas (CNG), and ethanol, etc.) fueled on-road mobile

sources such as passenger cars, motorcycles, minivans, sport-utility vehicles, light-duty

trucks, heavy duty trucks, and buses. The sector includes emissions generated from

parking areas as well as emissions while the vehicles are moving.

Data Collection

Data were collected from EPA’s 2017 NEI county level mobile emissions.

Emission Calculation Methodology

72

The 2017 NEI is comprised of mobile emission estimates calculated based on the MOVES

model run with S/L/T submitted activity data when provided, except for California and

tribes, for which the NEI includes submitted emissions. In cases where S/L/T submitted

data is not provided, EPA-developed default activity based on data from the Federal

Highway Administration.

Data values were derived from 2017 NEI for both La Plata and Archuleta counties. Data

adjustments were made to the emission totals for each county based on the percentage

of road miles in La Plata and Archuleta County that fall within the exterior boundaries of

the Reservation, as determined from GIS shapefiles obtained from the La Plata and

Archuleta County GIS departments.28,29 The data adjustment resulted in a reduction of

the emissions to 35% and 17% for La Plata and Archuleta Counties, respectively. No

significant roads on the Reservation are located in Montezuma County, and therefore

AQP assumed on-road emissions for Montezuma County to be negligible. The AQP

determined that 947.3 miles of roads are within the Reservation boundaries. The AQP

later combined the two adjusted county level datasets to obtain Reservation emission

totals. Data outputs were organized by criteria pollutants emissions.

Assumptions

AQP assumed that data from the 2017 NEI to be the best available data for estimating

2020 on-road mobile emissions on the Reservation.

Emissions

Criteria pollutant emissions from on-road mobile sources on the Reservation in 2017 are

displayed below in Table 44.

Table 44: Criteria pollutant emissions from on-road mobile sources [tons]

Pollutant

CO

NOx

VOC

PM10

PM2.5

Emissions

1590.27

383.96

216.13

16.99

10.63

2. Non-Road Mobile Sources

Non-road mobile sources contribute a significant portion of the NOx and CO emissions

from mobile sources. Non-road mobile sources on the Reservation include agricultural

equipment, construction and mining equipment, lawn and garden equipment, and

28

La Plata County. (2018). Roads. GIS/Mapping. Retrieved from ftp://ftp.laplata.co.us/shapefiles/.

29

Archuleta County. (2018). Roads - Archuleta County. GIS. Retrieved from

http://www.archuletacounty.org/504/Download-GIS-Data.

73

recreational equipment fueled by gasoline, diesel, other sources (CNG and liquified

petroleum gas (LPG), etc.).

Data Collection

Data were collected from EPA’s 2017 NEI county level mobile emissions.

Assumptions

AQP assumed that data from the 2017 NEI to be the best available data for estimating

2020.

Emission Calculation Methodology

The 2017 NEI used MOVES2014b version of EPA’s Motor Vehicle Emissions Simulator

(MOVES) Model, to estimate non-road emissions. All the input and activity data required

to run the non-road component of MOVES model (MOVES-Nonroad) are contained

within the MOVES default database, which is distributed with the model. State- and

county-specific data can be used by creating a supplemental database known as a county

database (CDB) and specifying it in the MOVES run specification (runspec). State, local

and tribal (S/L/T) agencies can update the data within the CDBs to produce emissions

estimates that accurately reflect local conditions and equipment usage. MOVES first uses

the data in the CDBs and fills in any missing data from the MOVES default database.

Data values for non-road emissions were derived from 2017 NEI for both La Plata and

Archuleta counties. The emissions for La Plata and Archuleta County were reduced to

38.9% and 29.5% respectively based on the portion of these counties within the exterior

boundaries of the Reservation. The AQP later combined the adjusted emissions data sets

from La Plata and Archuleta counties to obtain Reservation emission totals.

Emissions

Criteria pollutant emissions from non-road mobile sources on the Reservation in 2017

are displayed below in Table 45.

Table 45: Criteria pollutant emissions from non-road mobile sources [tons]

Pollutant

Emissions

VII.

CO

816.51

NOx

50.67

Events

1. Wildland Fires and Prescribed Burns

74

VOC

90.10

PM10

6.58

PM2.5

6.23

Description of Activity

The forest on the Reservation is predominantly comprised of pinyon-juniper woodlands

with ponderosa, gambel oak, aspen and sub-alpine forest at higher elevation areas. The

forest is prone to wildfire and prescribed burns are utilized as a forest management

strategy to help prevent catastrophic fires, improve wildlife habitat, and improve overall

forest health. Wildfires and prescribed burns can be significant sources of air pollution on

the Reservation and the Four Corners area.

Data Collection

Wildland and prescribed burn fire (forest fire) data for calendar year 2020 were obtained

from the Bureau of Indian Affairs (BIA) and the Southern Ute Agency Fire Management

Division.30 The initial data identified 32 fires (31 wildfires and 1 prescribed fires). Data

sets included type of fire, latitude and longitude of fire perimeter, and acres burned.

Emission Calculation Methodology

Forest fire emission estimates were calculated using the USFS BlueSky Playground web

tool (BlueSky).31 BlueSky is comprised of several internal USFS datasets and modeling

programs, including the Fuels Characteristic Classification System fuel information

dataset (FCCS), the CONSUME3 fuel consumption model, and the FEPS emission factors

model.

Forest fire data including latitude and longitude and acres burned are input into BlueSky

and BlueSky selects the correct default model input values based on the fire location.

Input values include available fuel load, fuel consumed, emission factors, and

meteorological forecast data. “Dry” was selected for the fuel moisture value. Forest fire

event by FCCS fuel bed type are displayed below in Table 46.

Table 46: Forest fire occurrence by fuels characteristic classification system, fuel bed type,

and acres burned

FCCS Fuel Bed Description

Ponderosa Pine Savanna

Tobosa-Grama Grassland

Pinyon-Utah Juniper

Woodland

Low Sagebrush Shrubland

Totals

30

Number of Fires

3

1

Acres Burned

3.5

6

25

234.85

2

31

1.1

245.45

Bureau of Indian Affairs Fire Management. (2020). Southern Ute 2020 Fire Occurrence

31

U.S. Forest Service AirFire Research Team. (2020). BlueSky Playground (Version 2.0 beta). Retrieved from

https://playground.airfire.org/ .

75

Emission Equations

Emissions = (Area burned) x (Fuel Load Available) x (Fuel Consumed (Burn Efficiency)) x

(Emission Factors)

Mass of Emissions =

Area burned (input from AQP datasets)

Fuel Load Available (updated FCCS map)

Fuel Consumed (CONSUME3)

Emission Factors (FEPS plus HAPs)

Bluesky Playground Framework

Assumptions

Collected and reported fire related data is assumed to be accurate and to be the best

data available. BlueSky is assumed to function as intended and to select the proper fuel

characteristics from the USFS FCCS map when latitude and longitude coordinates are

input into the model.

Emissions

Total criteria pollutant, NH3 and GHG from prescribed burns and wildland fires that

occurred within the exterior boundaries of Reservation boundaries in 2020 are displayed

below in Table 47.

Table 47: Criteria pollutant, NH3, and GHG emissions from prescribed burns and wildland

fires [tons]*

Pollutant PM10

PM2.5

CO

Total

13.34

11.19

123.71

*GHG reported in metric tonnes.

VIII.

NOx

2.41

NH3

2.02

SO2

1.14

VOC

29.35

GHG (CO2e)

1873.41

Biogenic

Biogenic processes of trees, vegetation, soil, and microbial activities generate VOC, NOx,

CO, and HAP emissions. EPA estimates biogenic emissions for triennial inventory years,

with the last estimation performed for calendar year 2017.

Assumptions

The AQP assumed the emission estimations prepared by EPA to be performed correctly

and to be the best available emissions estimates for 2020.

Emission Calculation Methodology

76

Biogenic emissions estimated for La Plata and Archuleta County were prepared by EPA

using the EPA’s Biogenic Emission Inventory System and Biogenic Emissions Land Use

Database.32 AQP obtained the 2017 emission estimates for La Plata and Archuleta

counties from the 2017 NEI. Emissions estimates for Montezuma County were not

included in this emissions inventory due to only 0.2% of the county falling within the

Reservation boundaries.

County wide emissions were reduced for La Plata and Archuleta County to 38.9% and

29.5% respectively, based on the area of each county that is located within the exterior

boundaries of the Reservation.

Emissions

Criteria pollutant and HAP emissions from biogenic sources on the Reservation in 2020

are displayed below in Table 48.

Table 48: Criteria pollutant and HAP emissions from biogenic sources [tons] *

Pollutant

CO

NOx

VOC

HAP

Emissions

879.43

408.03

5,483.95

662.79

*

Emissions for biogenic sources were estimated from data retrieved from the 2017 EPA

National Emission Inventory data and are assumed to be realistic estimations of biogenic

source emissions for 2020.

IX.

Summary

1. Emissions Sources

Reservation emissions presented in this inventory are distributed between point, nonpoint, mobile, and biogenic sources.

A. Point Sources

There are four categories of point sources including:

1) Title V permitted oil and gas sources,

2) TMNSR permitted and true minor oil and gas sources,

3) Municipal solid waste landfills, and

4) Airports.

B. Non-Point Sources

There are eight categories of non-point sources including:

32

U.S. Environmental Protection Agency. (2021). Biogenic Emission Inventory System. Retrieved from

https://www.epa.gov/air-emissions-modeling/biogenic-emission-inventory-system-beis.

77

1) Small oil and natural gas sources,

2) Fruitland Formation Outcrop natural gas seeps

3) Gasoline stations,

4) Aviation gasoline dispensing,

5) Gravel pits,

6) Residential heating,

7) Fire events (wildland fires and prescribed burns), and

8) Agricultural burning.

C. Mobile Sources

Mobile sources are divided into two categories:

1) On-road, and

2) Non-road.

D. Biogenic Emissions

Biogenic emissions encompass all non-man-made emission sources.

2. Emission Inventory Findings

A summary of 2020 criteria pollutant, HAP, and GHG emissions by source category is

displayed below in Table 49.

78

Table 49: Criteria pollutant, HAP, and GHG emissions on the Southern Ute Indian

Reservation [tons]*

*

Source Category

NOx

Title V Oil and Gas

Synthetic Minor Oil and Gas

True Minor Oil and Gas

Municipal Solid Waste Landfills

Airports

Total Point Source Emissions

2,359.76

253.89

4,575.24

36.47

7,225.37

Small Oil and Gas Sources

Fruitland Formation Outcrop

Gas Stations

Aviation Gasoline

Gravel Pits

Residential Heating

Fire Events

Agricultural Burning

Total Non-Point Source Emissions

11,664.00

8.94

2.41

0.19

11,675.54

Mobile Sources

434.64

Biogenic

408.03

Total:

19,743.58

GHG gas emissions reported in metric tonnes.

VOC

SO2

PM10

Point Sources

1,032.92 46.85 101.94

126.22

5.86

3.75

834.57

16.07 42.81

7.09

15.21

13.94

5.02

4.50

2,014.75 73.80 168.20

Non-Point Sources

879.10

5.63

112.01

16.84

6.27

57.36

35.81

0.30

20.68

29.35

1.14

13.34

0.67

0.07

1.39

968.04

7.14

204.79

Mobile Sources

306.23

23.57

Biogenic Sources

5,483.95 Total Emissions

8,772.97 80.94 396.57

CO

Total HAP

GHG (CO2e)

1,872.89

137.54

3,248.08

0.30

217.11

5,475.92

306.09

29.68

290.97

3.55

0.31

630.61

2,124,765.29

69,931.40

1,568,843.62

23,226.65

3,786,766.97

9,716.55

156.88

123.71

8.05

10,005.19

233.90

233.90

1,618,203.64

5,923,341.15

12,371.35

1,873.41

7,555,789.54

2,406.78

-

-

879.43

662.79

-

18,767.33

1,527.29

11,342,556.51

Oil and natural gas production and mid-stream transmission are the predominant

industries on the Reservation. Of all the quantified emission categories, oil and gas

contributed the most significant quantities of NOx, CO, SO2 and PM10 to the airshed

during 2020. Oil and gas related activities accounted for 18,852.9 tons, or 95% of the

total NOx emissions quantified in the emission inventory; CO emissions accounted for

80% of the total quantified CO emissions, 14,975.1; SO2 accounted for 92% of the total

quantified SO2 emissions, 74.4 tons; PM10 accounted for 77% of the total quantified PM10

emissions, 260.5 tons; and HAP emissions accounted for 56% of the total quantified HAP

emissions, 860.6 tons.

Biogenic sources are the most significant source of VOC emissions to the airshed. VOC

emissions from this category account for 63% of the total VOC emissions to the airshed

at 5,483.9 tons.

The Fruitland Outcrop is the most significant source of GHG emissions, calculated to be

5,923,341.1 metric tons, or 52% of total Reservation emissions.

79

NOx, CO, VOC, and HAP emissions by source category on the Reservation in 2020 are

displayed below in Figures 30 and 31.

Figure 30: NOx and CO emissions by source category [tons]

19,000.0

14,975.1

18,852.9

NOx and CO Emissions on the Southern Ute Indian

Reservation by Source Category (tons)

15,000.0

NOx

CO

-

0.3

2,406.8

434.6

Landfills

Mobile Sources

217.1

36.5

Airports

Agricultural Burning

0.2

879.4

408.0

Biogenics

156.9

8.9

Residential Heating

Oil & Gas

(1,000.0)

Fire Events

2.4

3,000.0

123.7

7,000.0

8.1

11,000.0

Figure 31: VOC and HAP emissions by source category [tons] *

5,483.9

VOC and HAP Emissions on the Southern Ute

Indian Reservation by Source Category (tons)

6,000.0

-

16.8

3.55

7.1

-

306.2

0.31

20.2

-

0.7

662.79

-

35.8

1,000.0

-

2,000.0

29.4

3,000.0

860.64

4,000.0

2,872.8

5,000.0

VOC

80

HAP

Gas Stations

Landfills

Mobile Sources

Airports

Agricultural Burning

Biogenics

Residential Heating

Fire Events

Oil & Gas

-

*

Airport emissions include the point airport emissions as well as the non-point aviation gasoline emissions.

Due to the lack of accurate emission factors and reliable data, GHG emissions were not

estimated for every category presented in this inventory. Several categories that were

not evaluated or quantified, such as mobile sources and biogenic sources, would be

expected to contribute significant emissions of GHG.

3. Oil and Gas Emissions Summary

The bulk of the emission sources within the point source category are larger emission

sources such as natural gas compressor stations, central delivery points, treating plants,

and processing plants. Combined, the Title V, permitted TMNSR, and true minor sources

represent the bulk of NOx, CO, PM10, SO2, and non-biogenic VOC and HAP emissions.

Within the oil and gas sector, non-point source, small oil and gas sources such as

production well sites, contribute the most NOx, CO, and PM 10 emissions to the airshed in

contrast to the larger Title V, permitted TMNSR, and true minor sources. This is due to

the large number of small oil and gas sources, 2,582 sites, operating within the exterior

boundaries of the Reservation. This category alone accounts for 62% of the total airshed

NOx emissions at 11,664.0 tons and 65% of the total CO emissions at 9,716.6 tons.

Emissions of particulate matter 10 micrometers or less in diameter were 112.0 tons, or

about 43% of the total airshed emissions. Emissions totals from oil and gas sector

sources are displayed below in Table 50 and Figures 32 through Figures 34.

Table 50: Emissions from oil and gas sector sources [tons]*

Pollutant

NOx

VOC

Title V

2,359.8 1,032.9

Synthetic Minor

253.9

126.2

True Minor

4,575.2

834.6

Small Oil & Gas Sources 11,664.0 879.1

Totals:

18,852.9 2,872.8

*GHG emissions reported in metric tonnes.

SO2

46.9

5.9

16.1

5.6

74.4

PM10

101.9

3.8

42.8

112.0

260.5

PM2.5

71.8

71.8

CO

1,872.9

137.5

3,248.1

9,716.6

14,975.1

GHG (CO2e)

2,124,765.3

69,931.4

1,568,843.6

1,618,203.6

5,381,744.0

Figure 32: NOx and CO emissions from oil and gas sources [tons]

81

Total HAP

306.1

29.7

291.0

233.9

860.6

Oil and Gas NOx and VOC Emissions by

Source Category (tons)

14,000.0

11,664.0

12,000.0

10,000.0

8,000.0

6,000.0

4,575.2

4,000.0

2,359.8

2,000.0

1,032.9

253.9

Title V

Synthetic Minor

NOx

879.1

834.6

126.2

True Minor

Small Oil & Gas Sources

VOC

Figure 33: VOC and HAP emissions from oil and gas sources [tons]

Oil and Gas VOC and Total HAP

Emissions by Source Category (tons)

1,200.0

1,032.9

1,000.0

879.1

834.6

800.0

600.0

400.0

306.1

291.0

126.2

200.0

233.9

29.7

Title V

Synthetic Minor

VOC

True Minor

Small Oil & Gas

Sources

Total HAP

Figure 34: GHG (CO2e) emissions from oil and gas sources [tonnes]

82

Oil and Gas GHG (CO2e) Emissions by

Source Category (tonnes)

2,500,000.0

2,124,765.3

2,000,000.0

1,568,843.6

1,618,203.6

True Minor

Small Oil & Gas

Sources

1,500,000.0

1,000,000.0

500,000.0

69,931.4

Title V

Synthetic Minor

Within the small oil and gas sources, the emission unit type that contributed the most

NOx and CO emissions were natural gas-fired reciprocating internal combustion engines

(RICE). Four-stroke rich burn (4SRB) engines between 0-50 hp and 4SRB engines between

51-100 hp were the largest emitting subcategories.

4. Comparison of the 2020 SUIT EI to Previous Emissions Inventories

To evaluate the representativeness of oil and gas emission estimations from this 2020 SUIT

emissions inventory, the AQP has compared the results with oil and gas emission estimates

for the Reservation from the 2015 Southern Ute Indian Reservation Emission Inventory (2015

SUIT EI) and the 2017 Southern Ute Indian Reservation Emission Inventory (2017 SUIT EI)

Figure 35: Comparison of NOx, CO, and VOC emissions from the 2015 SUIT EI, 2017 SUIT

EI, and the 2017 SUIT EI [tons]

83

Comparison of NOx, CO, and VOC emissions from

the 2015 SUIT EI, 2017 SUIT EI, and the 2020

SUIT EI [tons]

20000.0

17795.1

18695.7

18852.9

15264.5 15464.3

16000.0

14975.1

12000.0

8000.0

3194.9 3102.2 2872.8

4000.0

0.0

NOx

VOC

2015

2017

CO

2020

A comparison of the 2015 SUIT EI, 2017 SUIT EI, and 2020 SUIT EI shows a 1,057.8 ton

increase in NOx emissions and a 289.4 ton decrease in CO emissions between 2015 and 2020

at oil and gas point sources and non-point sources. AQP attributes the increased NOx

emissions and decrease in CO emissions to 91 more lean burn engines being reported in

2020 than in 2015 and 46 less rich burn engines at the non-point oil and gas sources.

Between the 2015 and 2020 SUIT EIs, emissions decrease trends were observed at oil and

gas point sources. True minor sources, synthetic minor, and Title V sources showed a

decrease in NOx, CO, and VOC emissions. AQP attributes the decreases in NOx and VOC

emissions to decreased oil and gas production on the Reservation between 2017 and 2020.

A comparison of NOx, CO and VOC emissions at oil and gas sources on the Reservation from

the 2020 SUIT EI and the 2017 SUIT EI is displayed below in Figure 36.

Figure 36: Comparison of oil and gas NOx, CO, and VOC emission estimations for the

Southern Ute Indian Reservation from the 2015, 2017, and 2020 SUIT EIs [tons]

84

903

1,092

879

964

897

835

342.71

316

254

173

166

126

188

206

138

6,000.00

Small Oil and Gas Sources

True Minor

Synthetic Minor

4,000.00

2,000.00

2,598.16

2,382

2,360

1,155

948

1,033

2,817

2,388

1,873

8,000.00

3,905

3,508

3,248

10,000.00

4,895.28

4,609

4,575

12,000.00

8,355

9,363

9,717

14,000.00

9,958.97

11,388

11,664

Oil and Gas NOx, VOC, and CO Emissions

Comparison Between SUIT 2015, 2017, and 2020

EI (tons)

NOx 2015

85

NOx 2017

NOx 2020

VOC 2015

VOC 2017

VOC 2020

CO 2015

Title V

CO 2017

CO 2020

X.

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https://eis.epa.gov/eis-system-web/welcome.html

U.S. Forest Service AirFire Research Team. (2020). BlueSky Playground (Version 2.0 beta).

Retrieved from http://playground.airfire.org/home.php

Waste Industry Coalition. (2001, January). Comparison of Recent Landfill Gas Analysis with

Historic AP-42 Values.

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XI.

Appendix – Quality Assurance Review

Description of Quality Assurance Review

To meet the EPA emissions inventory level II data quality objective of conducting a third party

quality assurance (QA) review, the AQP contracted with Ramboll. The QA review included the

review of the data collection methodology, data, assumptions, emission factors, calculation

methodologies, and emission totals. An abridged version of the final QA report is attached as an

Appendix. A full version of the QA report, which contains all of the QA review forms can be

requested from the AQP.

89

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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