_______________________________________________________________ (2019)
Tribal code
Ask Donna
What actually matters in this document.
Text
_______________________________________________________________
Final Report for 2019 Southern Ute Indian Tribe
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
March 30, 2022
TABLE OF CONTENTS
Table of Contents .................................................................................................................................. ii
Table of Figures .................................................................................................................................... iii
List of Tables......................................................................................................................................... iv
List of Acronyms ................................................................................................................................. v
I.
Executive Summary ....................................................................................................................... 7
II.
Overview ....................................................................................................................................... 9
II.1
Purpose of Inventory............................................................................................................. 9
II.2
Geographic Location of southern Ute Indian Reservation .................................................... 9
II.3
Climate .................................................................................................................................. 9
II.4
Geology ............................................................................................................................... 10
II.5
Sources ................................................................................................................................ 10
III.
Data Quality Objectives........................................................................................................... 11
III.1
Accuracy .............................................................................................................................. 11
III.2
Uncertainty.......................................................................................................................... 11
III.3
Completeness ...................................................................................................................... 12
III.4
Comparability ...................................................................................................................... 12
IV.
Point sources ........................................................................................................................... 13
IV.1
Title V Permitted Sources .................................................................................................... 13
IV.2
Permitted Tribal Minor New Source Review Point Sources................................................ 19
V.
Quality Assurance Summary ....................................................................................................... 25
V.1
Quality Assurance Checks ................................................................................................... 25
V.2
Criteria, HAP Pollutants and Equipment Count .................................................................. 26
V.3
GHG ..................................................................................................................................... 27
V.4
CY2019 Emission Summary ................................................................................................. 28
VI.
Bibliography ............................................................................................................................ 29
ii
TABLE OF FIGURES
Figure 1: Title V and permitted TMNSR sources located within the exterior boundaries of the Southern
Ute Indian Reservation .......................................................................................................................... 7
Figure 2: 2019 Total Criteria Pollutant and Total HAP Emissions on the Southern Ute Indian
Reservation [Tons]................................................................................................................................. 8
Figure 3: 2019 Title V Source Criteria Pollutant and Total HAP on the Southern Ute Indian Reservation
[Tons]................................................................................................................................................... 15
Figure 4: 2019 NOx Emissions at Title V Sources on the Southern Ute Indian Reservation by
Equipment Type [Tons] ....................................................................................................................... 15
Figure 5: 2019 VOC Emissions at Title V Sources on the Southern Ute Indian Reservation by Equipment
Type [Tons] .......................................................................................................................................... 16
Figure 6: CO Emissions at Title V Sources on the Southern Ute Indian Reservation by Equipment Type
[Tons]................................................................................................................................................... 16
Figure 7: 2019 Title V Source HAP Emissions on the Southern Ute Indian Reservation [Tons] ...... 17
Figure 8: 2019 HAP Emissions at Title V Sources on the Southern Ute Indian Reservation by
Equipment Type [Tons] ....................................................................................................................... 18
Figure 9: 2019 Equipment Counts for Title V Sources on the Southern Ute Indian Reservation ...... 18
Figure 10: 2019 Criteria Pollutant and HAP Emissions for Permitted TMNSR Sources on the Southern
Ute Indian Reservation [Tons]............................................................................................................ 21
Figure 11: 2019 NOx Emissions for Permitted TMNSR Sources on the Southern Ute Indian Reservation
by Equipment Type [Tons] .................................................................................................................. 21
Figure 12: 2019 VOC Emissions for Permitted TMNSR Sources on the Southern Ute Indian
Reservation by Equipment Type [Tons] .............................................................................................. 22
Figure 13: 2019 CO Emissions for Permitted TMNSR Sources on the Southern Ute Indian Reservation
by Equipment Type [Tons] .................................................................................................................. 22
Figure 14: 2019 Speciated HAP Emissions at Permitted TMNSR Sources on the Southern Ute Indian
Reservation [Tons] .............................................................................................................................. 23
Figure 15: 2019 Total HAP Emissions for Permitted TMNSR Sources on the Southern Ute Indian
Reservation by Equipment Type [Tons] .............................................................................................. 23
Figure 16: 2019 Equipment Counts for Permitted TMNSR Sources on the Southern Ute Indian
Reservation.......................................................................................................................................... 24
Figure 17: Comparison of Criteria Pollutants and Total HAP from CY2018 and CY2019 EI on the
Southern Ute Indian Reservation ........................................................................................................ 26
Figure 18: Comparison of Equipment Counts from 2018 and 2019 on the Southern Ute Indian
Reservation (Title V and TMNSR Sources) ......................................................................................... 27
Figure 19: Comparison of GHG Emissions from Title V and Permitted TMNSR Sources from 2018 and
2019 on the Southern Ute Indian Reservation (CO2e) ......................................................................... 28
iii
LIST OF TABLES
Table 1: 2019 Title V Source Criteria Pollutant, Total HAP and GHG Emissions for the Southern Ute
Indian Reservation [Tons] .................................................................................................................. 14
Table 2: 2019 Title V Sources HAP Emissions on the Southern Ute Indian Reservation [Tons] ....... 17
Table 3: 2019 Criteria Pollutant, HAP, and GHG Emissions for permitted TMNSR Sources on the
Southern Ute Indian Reservation [Tons] ............................................................................................ 20
Table 4: Speciated HAP Emissions for Permitted TMNSR Sources on the Southern Ute Indian
Reservation [Tons] .............................................................................................................................. 22
Table 5: 2019 Criteria Pollutants, HAP, and GHG Emissions on the Southern Ute Indian Reservation
[Tons] .................................................................................................................................................. 28
iv
List of Acronyms
AP-42
EPA Compilation of Air Pollutant Emission Factors
AQP
Air Quality Program
CAA
Clean Air Act
CO
Carbon Monoxide
CO2e
Carbon Dioxide Equivalent
CY
Calendar Year
CFR
Code of Federal Regulations
EI
Emissions Inventory
EIS
Emission Inventory System
EPA
United States Environmental Protection Agency
FLIGHT
Facility Level Information on GreenHouse gases Tool
GHG
Greenhouse gas
IC
Internal Combustion
HAP
Hazardous Air Pollutants
Kdf
Cretaceous Fruitland Formation
Kpcl
Cretaceous Picture Cliffs Sandstone
NEI
National Emissions Inventory
NOx
Oxides of Nitrogen
PM10
Particulate Matter 10 microns and smaller
PM10-PRI
Particulate Matter 10 microns and smaller – Primary Emissions
PSD
Prevention of Significant Deterioration
PTE
Potential to Emit
QA
Quality Assurance
Reservation
Southern Ute Indian Reservation
SO2
Sulfur Dioxide
TEG
Tri-Ethylene Glycol
TEISS
Tribal Emissions Inventory Software Solutions
Title V
Title V Operating Permit Program
TMNSR
Tribal Minor New Source Review Program
Tribe
Southern Ute Indian Tribe
v
TPY
Tons per Year
VOC
Volatile Organic Compounds
vi
I. EXECUTIVE SUMMARY
The Southern Ute Indian Tribe (Tribe) Air Quality Program (AQP) has prepared an emissions
inventory (EI) of all Title V Operating Permit Program (Title V) and Synthetic Minor
quantifiable point sources on the Southern Ute Indian Reservation (Reservation) for calendar
year (CY) 2019. The EI was prepared with data from federal annual emission reports, tribal
annual emission fee forms, and emission calculations completed by the AQP.
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 and other pertinent reports.
As of January 2019, there were a total of 35 sources operating under Title V operating permits
and six sources operating as Synthetic Minor Sources under Tribal Minor New Source Review
(TMNSR) permits. Figure 1 shows a map of the Southern Ute Indian Reservation with the
Title V and permitted TMNSR Sources.
Figure 1: Title V and permitted TMNSR sources located within the exterior boundaries of
the Southern Ute Indian Reservation
7
Reservation emission totals for CY2019 were 2,520.0 tons of Oxides of Nitrogen (NOx),
1,143.1 tons of Volatile Organic Compounds (VOC), 51.2 tons of Sulfur Dioxide (SO2), 106.2
tons of Particulate Matter shown as PM10-PRI (primary particulate matter with diameter less
than or equal to 10 micrometers emitted directly into air by a source, includes both filterable
and condensable components), 1,925.3 tons of Carbon Monoxide (CO), 337.9 tons of total
Hazardous Air Pollutants (HAP), and 1,946,432 tons of Greenhouse Gas (GHG) emissions
measured in Carbon Dioxide Equivalents (CO2e). Total criteria pollutant and HAP emissions
on the Reservation for 2019 are presented below in Figure 2.
2019 Total Criteria Pollutant and Total HAP Emissions on the Southern Ute Indian
Reservation (Tons)
1,925.3, 32%
2,520.0, 41%
1,143.1, 19%
51.2, 1%
106.2, 2%
337.9, 5%
Oxides of Nitrogen
Volatile Organic Compounds
Sulfur Dioxide
Carbon Monoxide
PM10 Primary (Filt + Cond)
Total HAP
Figure 2: 2019 Total Criteria Pollutant and Total HAP Emissions on the Southern Ute Indian
Reservation [Tons]
8
II. OVERVIEW
II.1 Purpose of Inventory
The purpose of this EI was to compile emissions from Title V and TMNSR permitted sources
for the 2019 calendar year. As required by the Clean Air Act (CAA) 103 work plan
components 3.2 and 3.4, the AQP compiles and submits yearly EIs to EPA’s National
Emission Inventory (NEI). The emissions data for the Reservation presented in this EI has
been organized by pollutant and equipment type. The EI may 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, PM10, SO2, VOC, HAP and GHG.
II.2 Geographic Location of southern Ute Indian Reservation
The Reservation is located in southwestern Colorado. The Reservation land area covers 1,064
square miles in three counties (La Plata, Archuleta, and Montezuma) and borders New Mexico
to the south.1 The total area covered by this inventory is approximately 681,000 acres, which
encompasses all land within the external boundaries of the Reservation. The Tribe and/or its
members own approximately 320,000 acres, while the remaining land mass is comprised of
non-Indian (private) and government land in a checkerboard fashion. The primary land use is
agricultural, and the predominant industry is oil and natural gas production.
II.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 is between 20 and 40 degrees Fahrenheit. Freezing temperatures are
common throughout the winter and during the 2019 calendar year the coldest month was
December with a monthly average of 19.4 degrees Fahrenheit and had the lowest temperature
with -7.2 degrees Fahrenheit. During the summer months, the peak temperatures typically
remain in the high eighties to low nineties. The warmest month of 2019 was July with a
monthly average of 68.9 degrees Fahrenheit. July had the highest temperature with 92.5
degrees Fahrenheit. Snow is the dominant form of precipitation on the Reservation. The total
Southern Ute Indian Tribe (2019). History of the Southern Ute. Retrieved from: https://www.southernutensn.gov/history/
1
9
precipitation for calendar year 2019 was 21.7 inches. The driest month was October with 0.2
inches of precipitation and the wettest month was February with 4.2 inches of precipitation. 2
[Winter months have been defined as the months from November through February. Summer months have been
defined as the months from June through September.]
II.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 largest
coal-bed methane natural gas fields in the world within the Cretaceous aged Fruitland
Formation. 3 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 2019.
II.5 Sources
The only sources included in this emissions inventory are larger point sources, either permitted
under the Tribe’s Title V Program or permitted through EPA’s TMNSR Program.
Southern Ute Indian Tribe: Ambient Monitoring. (2018). 2018 AQS Ute 3 Humidity and Temperature Hourly
http://www.southernute-nsn.gov/environmental-programs/air-quality/ambientData.
Retrieved
from:
monitoring/
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
3
10
III. DATA QUALITY OBJECTIVES
Data objectives for this inventory are as follows:
III.1 Accuracy
•
•
•
•
•
•
Data for this EI were collected using measured data from reputable sources such as
EPA, direct emission measurements and calculated emissions from permitted sources.
The AQP staff also uses professional judgement to review the emissions from
permitted facilities and flags any conspicuously inconsistent data.
Title V facilities are required to submit an Annual Fee Calculation Worksheet to AQP.
Emissions are calculated by the operator using calculation models and emission factors
of their choice. Permitted TMNSR (Synthetic Minor) facilities submit an annual
emission report to EPA. AQP obtains the emissions for permitted TMNSR facilities
from EPA.
Utilize emission calculation models when available (GRI-GLYCalc 4.0; Tanks 4.09d;
AP-42, Fifth Edition; Caterpillar Engine Rating Pro 4.01.02; Waukesha Bulletin 7005
0710; Solar Turbines February 12, 2013 Predicted Emission Performance Emission
Factors; etc.)
Actual running times were used when available. If actual running times were not
available, maximum running times (8,760 hours) were used.
Quality Assurance tests are run through the Tribal Emission Inventory Software
Solution (TEISS), version 3.6.26 and EPA’s Emissions Inventory System (EIS).
o Quality assurance tests check for data completeness, accuracy, format, and
pollutant emission ranges.
Staff spot review of larger reported emission calculations for accuracy and use of
professional judgement in review of smaller reported emissions.
III.2 Uncertainty
•
•
•
•
Some of the reported emissions by the operators may be inaccurate.
Some emissions may be reported as Potential to Emit (PTE) and may not represent
actual emissions.
If actual facility criteria and HAP emissions or PTE were not reported, previous
calendar year emissions may be used.
Not all facilities are required to submit GHG emissions. If GHG emission were not
reported for CY2019, then the GHG emissions were either used from CY2018 or
calculated by the AQP using an emissions calculator tool or obtained from EPA’s
Facility Level Information on GreenHouse gases Tool (FLIGHT) map.
11
III.3 Completeness
•
•
•
Capture 100% of Title V point source emissions reported in the annual emission fees
for CY2019.
TMNSR permitted facilities are required to report emissions for the pollutants
specifically regulated with enforceable emission limits in each respective permit. The
missing criteria and HAP emissions estimates as well as GHG data for permitted
TMNSR sources were calculated using emissions calculator tool developed by AQP
which takes into account factors such as equipment type, equipment site rating, hours
of operation, fuel consumption rate, emissions factor from EPA’s AP-42 resource,
along with data from the CY2018 Comprehensive Emissions Inventory report.
TMNSR permitted facilities are only required to report emissions for emission units
specifically regulated with enforceable emission limits or controls in each respective
permit. Emission units not listed in the TMNSR permit may be unaccounted for.
III.4 Comparability
•
•
EI results will be compared with results from previous emission inventories.
Emission factors and assumptions will be compared with methodologies used in
similar emission calculation applications.
12
IV. POINT SOURCES
IV.1 Title V Permitted Sources
Description of Sources
Thirty-five Title V sources operated on the Reservation during CY2019. Sources include
natural gas compressor stations, central delivery points, treating plants, processing plants, a
saltwater disposal facility, and a municipal solid waste disposal site.
Title V sources are defined as sources with the PTE 100 tons of a single criteria pollutant, 25
tons of HAP in aggregate, or ten tons 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 2019, all
35 oil and gas sources operated under Tribally-issued Part 70 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
CY2019 fee calculation worksheets submitted by each source to the Tribe. Actual emissions
data were available for all 35 Title V oil and gas sources. Some facilities did not report GHG
emissions. The missing GHG emissions data for these sources were obtained from the EPA’s
FLIGHT map.
Equipment
A brief description of equipment from which emissions are included in this report is provided
in the following:
•
•
Internal Combustion (IC) Engines: The IC Engines are used in the oil and gas industry
to compress natural gas, pump liquids, generate electricity and to provide artificial lift.
In an IC Engine, the combustion and ignition of the fuel occurs within the engine itself.
IC Engines can be two-stroke or four-stroke, the difference between them being how
quickly the combustion cycle process (intake, compression, combustions, exhaust)
takes, based on the number of times of piston movement in the engine.
Turbines: Natural gas-fired turbines are used by the oil and gas industry for natural
gas transmission and electricity generation. They 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.
13
•
•
•
•
•
Distillation Column/Stripper: Tri-ethylene glycol (TEG) dehydration units are
commonly used in the oil and 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 where entrained
water is absorbed by the TEG. During this step, hydrocarbons present in the natural
stream are also absorbed in the glycol. Following the absorption step, the water
saturated glycol is then distilled to drive off absorbed water before being re-circulate
to the absorber.
Tanks: The oil and gas industry utilize liquid storage tanks for the storage of produced
water, condensate, oil, coolants, and lubricants. Emissions from storage tanks include
breathing and working losses, flash emissions, and tank loadout.
Heaters: These are natural gas fired external combustion sources used widely in the
oil and gas industry. Thermal fluid heaters are used for various process heating
applications such as heating emulsions, natural gases, regeneration gases, chemical,
heat transfer and specialty fluids.
Boilers: Boilers in the oil and gas industry are commonly used to generate large
amounts of steam. The steam can be used for variety of different purposes which
include steam stripping, steam distillation, process heating and vacuum distillation.
Others: This category includes collection of miscellaneous equipment/emission
sources for which emissions were included in this report. These include but are not
limited to flares, cooling towers, engine test cells, open air fugitive sources, open
storage piles and unclassified sources.
Emissions
Total criteria pollutant, total HAP and GHG emissions from Title V sources for CY2019 are
displayed below in Table 1 and Figure 3.
Table 1: 2019 Title V Source Criteria Pollutant, Total HAP and GHG Emissions for the Southern
Ute Indian Reservation [Tons]
Pollutant
Oxides of
Nitrogen
Carbon
Monoxide
Emissions
2,155.0
1,692.2
Volatile
PM10
Organic
Primary
Compounds (Filt + Cond)
982.9
99.7
Sulfur
Dioxide
Total HAP
45.3
294.7
Greenhouse
Gases
(CO2e)
1,797,643.5
14
2019 Title V Source Criteria Pollutant and Total HAP Emissions for the Southern Ute
Indian Reservation (Tons)
1,692.2, 32%
982.9, 19%
2,155.0, 41%
45.3, 1%
99.7, 2%
294.7, 5%
Oxides of Nitrogen
Volatile Organic Compounds
Sulfur Dioxide
Carbon Monoxide
PM10 Primary (Filt + Cond)
Total HAP
Figure 3: 2019 Title V Source Criteria Pollutant and Total HAP on the Southern Ute Indian
Reservation [Tons]
NOx emissions by equipment type at Title V sources for the 2019 calendar year are displayed
below in Figure 4.
2019 NOx Emissions at Title V Sources on the Southern Ute Indian
Reservation by Equipment Type (Tons)
2,000.0
1,799.3
1,500.0
1,000.0
500.0
207.9
63.5
62.4
17.9
4.0
0.0
Reciprocating IC Engine
Process Heater
Boiler
Turbine
Unclassified
Flare
Figure 4: 2019 NOx Emissions at Title V Sources on the Southern Ute Indian Reservation by
Equipment Type [Tons]
15
VOC emissions by equipment type at Title V sources for the 2019 calendar year are displayed
below in Figure 5.
2019 VOC Emissions at Title V Sources on the Southern Ute Indian
Reservation by Equipment Type (Tons)
700.0
600.0
638.6
500.0
400.0
300.0
92.2
200.0
75.7
100.0
24.5
11.3
8.3
1.1
0.1
0.0
Reciprocating IC Engine
Distillation Column/Stripper
Flare
Boiler
Turbine
Unclassified
Process Heater
Other fugitive
Figure 5: 2019 VOC Emissions at Title V Sources on the Southern Ute Indian Reservation by
Equipment Type [Tons]
CO emissions by equipment type at Title V sources for the 2019 calendar year are displayed
below in Figure 6.
2019 CO Emissions at Title V Sources on the Southern Ute Indian
Reservation by Equipment Type (Tons)
1,600.0
1,400.0
1,200.0
1,000.0
800.0
600.0
400.0
200.0
0.0
1,406.2
157.7
52.7
43.1
28.0
Reciprocating IC Engine
Turbine
Process Heater
Unclassified
Flare
Boiler
4.5
Figure 6: CO Emissions at Title V Sources on the Southern Ute Indian Reservation by Equipment
Type [Tons]
16
Total and speciated 2019 HAP emissions from Title V sources are displayed below in Table
2 and Figure 7.
Table 2: 2019 Title V Sources HAP Emissions on the Southern Ute Indian Reservation [Tons]
Pollutant
Formaldehyde
Toluene
Acetaldehyde
Xylenes
Acrolein
Benzene
Methanol
Ethylbenzene
n-Hexane
Other HAP
Total
Emissions
[Tons]
197.9
27.2
21.6
16.5
13.1
9.5
6.1
2.1
0.6
0.1
294.7
2019 Title V Source HAP Emissions on the Southern Ute Indian
Reservation (Tons)
200.0
197.9
150.0
100.0
27.2 21.6
16.5 13.1
50.0
9.5
6.1
2.1
0.6
0.1
0.0
Formaldehyde
Toluene
Acetaldehyde
Xylenes
Acrolein
Benzene
Methanol
Ethylbenzene
n-Hexane
Other HAP
Figure 7: 2019 Title V Source HAP Emissions on the Southern Ute Indian Reservation [Tons]
17
HAP emissions by equipment type at Title V sources for CY2019 are displayed below in
Figure 8.
2019 HAP Emissions at Title V Sources on the Southern Ute Indian
Reservation by Equipment Type (Tons)
246.0
250.0
200.0
150.0
100.0
31.9
50.0
13.4
2.9
0.4
0.1
0.0
Reciprocating IC Engine
Distillation Column/Stripper
Unclassified
Turbine
Storage Tank
Open Storage Pile
Figure 8: 2019 HAP Emissions at Title V Sources on the Southern Ute Indian Reservation by
Equipment Type [Tons]
Title V equipment counts for the CY2019 EI are displayed below in Figure 9.
2019 Equiment Counts for the Title V Sources on the Southern Ute
Indian Resrvation
140
133
120
100
80
60
40
20
33
14
11
9
8
7
5
3
0
Reciprocating IC Engine
Distillation Column/Stripper
Unclassified
Turbine
Other Fugitive
Process Heater
Boiler
Storage Tank
Flare
Figure 9: 2019 Equipment Counts for Title V Sources on the Southern Ute Indian Reservation
Summary
NOx emissions represent the largest portion of criteria pollutant emissions from Title V
sources on the Reservation, with 41% of the total criteria pollutant emissions. CO emissions
represent the second largest pollutant emission with 32% of the total criteria pollutant
emissions. Title V sources reported emissions from more than 200 pieces of equipment, with
18
IC engines representing the majority of the equipment type at 60% of the total equipment
count. Proportionally high IC engine counts correlate with NOx and CO emissions
representing the majority of criteria pollutant emissions.
Formaldehyde emissions represent the largest portion of HAP emission from Title V sources
on the Reservation with 67% of the total HAP emissions on the Reservation. As previously
stated, IC engines are the primary equipment type at Title V sources and are responsible for
majority of formaldehyde emissions.
IV.2 Permitted Tribal Minor New Source Review Point Sources
The TMNSR permitting program is found at 40 CFR Part §49.151 through §49.164. 4 The
TMNSR permitting program includes new or modified source permitting, permits by rule, and
a registration program for true minor sources that commenced construction prior to the date
of the rule promulgation. For the purposes of this inventory, only “Synthetic Minor” TMNSR
permitted oil and natural gas sources have been included.
The Synthetic Minor TMSNR permitted category reflects larger emission sources that would
be subject to either the Prevention of Significant Deterioration (PSD), Title V Program, or
both programs absent enforceable emission limitations to reduce the source’s PTE. To avoid
the double counting of emissions for sources that have both a Title V and Synthetic Minor
Permits, this section of the inventory only includes emissions from sources that obtained
Synthetic Minor Source permits to reduce emission levels below the Title V Program emission
thresholds.
During calendar year 2019 six sources operated under Synthetic Minor permits to reduce
emissions below Title V permitting thresholds and did not operate under a Title V permit.
Data Collection
Only the six sources with Synthetic Minor TMNSR permitted emissions below the Title V
permitting thresholds were included in this category in order to avoid double counting
emissions. Emissions from the remaining five sources, which 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 TMNSR permitted sources are required to submit annual emissions
inventories to EPA Region 8 for the pollutants regulated under each permit. Emission data
was collected directly from these annual emissions inventories submitted to EPA for calendar
year 2019. 5 Two TMNSR permitted facilities reported only CO and formaldehyde emissions.
4
40 CFR Part 49 - Indian Country: Air Quality Planning and Management. (2018). 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
5
CY 2018 EPA TMNSR Annual Emissions Forms.
19
One TMNSR permitted facility reported CO and NOx emissions for one engine, and CO and
formaldehyde for the other. Three permitted TMNSR facilities provided emissions for criteria
pollutants and HAP. Green House Gas (GHG) emissions were not reported by any Synthetic
Minor TMNSR permitted facilities. The missing criteria and HAP emissions estimates as well
as GHG data for permitted TMNSR sources were calculated using emissions calculator tool
developed by AQP which takes into account factors such as equipment type, equipment site
rating, hours of operation, fuel consumption rate, emissions factor from EPA’s AP-42
resource, along with data from the CY2018 Comprehensive Emissions Inventory report
Equipment
The equipment used by the permitted TMNSR sources, from which emissions are included in
this report, are the same equipment type described in Section IV.1 Title V Permitted Sources
of this report.
Emissions
Total 2019 criteria pollutant, HAP, and GHG emissions from permitted TMNSR sources on
the Southern Ute Indian Reservation are presented below in Table 3.
Table 3: 2019 Criteria Pollutant, HAP, and GHG Emissions for permitted TMNSR Sources on the
Southern Ute Indian Reservation [Tons]
Pollutant
Oxides of
Nitrogen
Carbon
Monoxide
Volatile
Organic
Compounds
PM10
Primary
(Filt + Cond)
Total HAP
Emissions
365.0
233.1
160.2
6.5
43.2
Greenhouse
Gases (CO2e)
148,788.8
Total criteria pollutant and HAP emissions from permitted TMSNR sources on the Southern
Ute Indian Reservation are presented below in Figure 10.
2019 Criteria Pollutants and HAP Emissions for Permitted TMNSR Sources on the
Southern Ute Indian Reservation (Tons)
233.1, 29%
365.0, 45%
160.2, 20%
43.2, 5%
Oxides of Nitrogen
Volatile Organic Compounds
Total HAP
6.5, 1%
Carbon Monoxide
PM10 Primary (Filt + Cond)
20
Figure 10: 2019 Criteria Pollutant and HAP Emissions for Permitted TMNSR Sources on the
Southern Ute Indian Reservation [Tons]
Total 2019 NOx emissions by equipment type from permitted TMNSR sources on the
Reservation are displayed below in Figure 11.
2019 NOx Emissions for Permitted TMNSR Sources on the Southern
Ute Indian Reservation by Equipment Type (Tons)
400.0
350.0
358.5
300.0
250.0
200.0
150.0
4.6
100.0
0.8
0.3
50.0
0.0
Reciprocating IC Engine
Process Heater
Distillation Column/Stripper
Other fugitive
Figure 11: 2019 NOx Emissions for Permitted TMNSR Sources on the Southern Ute Indian
Reservation by Equipment Type [Tons]
Total 2019 VOC emissions by equipment type from permitted TMNSR sources on the
Reservation are displayed below in Figure 12.
2019 VOC Emissions for Permitted TMNSR Sources on the Southern
Ute Indian Reservation by Equipment Type (Tons)
140.0
120.0
130.0
100.0
80.0
60.0
40.0
5.5
2.1
20.0
1.1
0.0
Reciprocating IC Engine
Distillation Column/Stripper
Other fugitive
Process Heater
21
Figure 12: 2019 VOC Emissions for Permitted TMNSR Sources on the Southern Ute Indian
Reservation by Equipment Type [Tons]
Total 2019 CO emissions by equipment type from permitted TMNSR sources on the
Reservation are displayed below in Figure 13.
2019 CO Emissions for Permitted TMNSR Sources on the Southern
Ute Indian Resrvation by Equipment Type (Tons)
250.0
227.3
200.0
150.0
100.0
2.9
50.0
1.6
0.7
0.0
Reciprocating IC Engine
Process Heater
Other fugitive
Distillation Column/Stripper
Figure 13: 2019 CO Emissions for Permitted TMNSR Sources on the Southern Ute Indian
Reservation by Equipment Type [Tons]
Total 2019 speciated HAP emissions from permitted TMNSR sources on the Reservation are
displayed below in Table 4 and Figure 14.
Table 4: Speciated HAP Emissions for Permitted TMNSR Sources on the Southern Ute Indian
Reservation [Tons]
Pollutant
Formaldehyde
Acetaldehyde
Acrolein
Methanol
Benzene
Total
Emissions
[Tons]
27.1
4.2
2.5
1.0
0.7
35.6
22
2019 Permitted TMNSR Source HAP Emissions on the Southern Ute
Indian Reservation (Tons)
30.0
25.0
27.1
20.0
15.0
10.0
4.2
2.5
5.0
1.0
0.7
0.0
Formaldehyde
Acetaldehyde
Acrolein
Methanol
Benzene
Figure 14: 2019 Speciated HAP Emissions at Permitted TMNSR Sources on the Southern Ute Indian
Reservation [Tons]
Total 2019 HAP emissions by equipment type from permitted TMNSR sources on the
Reservation are displayed below in Figure 15.
40.0
35.0
2019 HAP Emissions for Permitted TMNSR Sources on the Southern
Ute Indian Reservation by Equipment Type (Tons)
36.0
30.0
25.0
20.0
15.0
0.6
10.0
0.01
5.0
0.0
Reciprocating IC Engine
Distillation Column/Stripper
Process Heater
Figure 15: 2019 Total HAP Emissions for Permitted TMNSR Sources on the Southern Ute Indian
Reservation by Equipment Type [Tons]
23
Permitted TMNSR equipment counts for the CY2019 inventory are displayed below in Figure
16.
2018 Equipment Counts for Permitted TMNSR Sources on the
Southern Ute Indian Reservation
25
20
15
21
12
10
6
1
5
0
Reciprocating IC Engine
Process Heater
Distillation Column/Stripper
Other fugitive
Figure 16: 2019 Equipment Counts for Permitted TMNSR Sources on the Southern Ute Indian
Reservation
Summary
NOx emissions represent the largest portion of criteria pollutant emissions from Synthetic
Minor TMNSR permitted sources on the Reservation with 45% of the total criteria pollutant
emissions. CO emissions represent the second largest pollutant emission with 29% of the
total criteria pollutant emissions. Permitted TMNSR sources reported emissions from 40
pieces of equipment from four different categories (including others) with internal combustion
engines being the most commonly reported equipment type. IC engines represented 52% of
the total equipment reported. Proportionally high IC engine counts correlate with NOx and
CO emissions representing the majority of criteria pollutant emissions.
Formaldehyde emissions represent the largest portion of HAP emission from permitted
TMNSR sources on the Reservation with 76% of the total HAP emissions on the Reservation.
As previously stated, IC engines are the primary equipment type at permitted TMNSR sources
and they account for most of the formaldehyde emissions in this source category.
24
V. QUALITY ASSURANCE SUMMARY
V.1 Quality Assurance Checks
Quality assurance (QA) checks were run through TEISS and through EPA’s EIS. TEISS QA
checks ensures the EI data contains all required components to submit to EIS. This includes
facility, release point, emission unit, emission process, release point apportionment, reporting
periods, and emissions. The CY2019 EI passed TEISS QA checks.
The EIS completes QA checks prior to submitting data for production. EI QA categorizes the
data into “Total System Errors,” Total Critical Errors,” Total Protected Errors,” “Total
Warnings,” and “Total Duplicates.” The facility inventory and point inventory passed all QA
without any errors and warnings.
Environmental Protection Agency performed QA comparisons on the CY2019 emission
inventory. Emissions were compared to the finalized 2018 NEI and flagged if reported Tons
were less than or greater than 25% of the 2018 NEI v2 amount. No emissions from the
CY2019 emission inventory were flagged.
25
V.2 Criteria, HAP Pollutants and Equipment Count
Emissions from the CY2018 EI were compared to the CY2019 EI to ensure accuracy and
identify possible inaccuracies. There was consistency in emissions records between the two
years tested, with no greater than 25% difference found in emissions between the two years
for criteria pollutants emitting more than 1000 tons (NOx, CO, and VOC), and the difference
under 3% between the two years for criteria pollutants emitting less than or equal to 110 tons
(PM10, and SO2) during the CY2019 on the Southern Ute Indian Reservation. The difference
in Total HAP emissions between the two compared years was 10%. All criteria pollutants and
total HAP emissions showed a decrease in emissions between the two years. With the
exception of SO2.
Comparison of criteria pollutants and total HAP from CY2018 and CY2019 are displayed
below in Figure 17.
3000.0
2500.0
Comparison of Criteria Pollutants and Total HAP from 2018 and 2019 on the
Southern Ute Indian Reservation (Title V and TMNSR Sources) (Tons)
2687.1
2520.0
2444.6
1925.3
2000.0
1500.0
1185.5 1143.1
1000.0
108.4
500.0
0.0
Nitrogen Oxides
Carbon
Monoxide
Volatile Organic
Compounds
2018
106.2
PM10 Primary
(Filt + Cond)
52.0 51.2
373.5
Sulfur Dioxide
337.9
Total HAP
2019
Figure 17: Comparison of Criteria Pollutants and Total HAP from CY2018 and CY2019 EI on the
Southern Ute Indian Reservation
26
The AQP also compared equipment counts from the CY2018 EI and the CY2019 EI for Title
V and Synthetic Minor TMNSR permitted sources. Equipment counts were consistently lower
in CY2019 than in CY2018, with the exception of storage tanks.
Comparison of Title V and permitted TMNSR source equipment counts from the CY2018 and
CY2019 is displayed below in Figure 18.
Comparison of Equipment Counts from 2018 and 2019 on the Southern Ute Indian
150
Reservation (Title V and TMNSR Sources)
150
133
100
39
50
0
33
Reciprocating IC
Distillation
Engine
Column/Stripper
2018
19
8
Process Heater
11
11
10
Turbine
5
8
Storage Tank
7
Boiler
2019
Figure 18: Comparison of Equipment Counts from 2018 and 2019 on the Southern Ute Indian
Reservation (Title V and TMNSR Sources)
V.3 GHG
Total GHG Emissions from Title V Sources from CY2018 were compared to CY2019 to
ensure accuracy and identify possible inaccuracies. A decrease of 36% was found in GHG
emissions from the Title V and permitted TMNSR sources during the CY2019 from the
CY2018 GHG levels, with the differences in Title V GHG emissions between the two years
accounting for majority of the difference (99% of the difference).
Synthetic Minor TMNSR permitted sources do not report GHG emissions for emission fee
calculations to the EPA. Therefore, CY2019 GHG data for permitted TMNSR sources were
calculated using an emissions calculator tool developed by AQP which takes into account
factors such as equipment type, equipment site rating, hours of operation, fuel consumption
rate, emissions factors from EPA’s AP-42 resources.
27
Figure 19 illustrates GHG emissions of Title V and Synthetic Minor TMNSR permitted
sources for calendar years 2018 and 2019.
Comparison of GHG Emissions from Title V and Permitted TMNSR
Sources from 2018 and 2019 on the Southern Ute Indian
2,500,000
Reservation (CO2e)
2,003,362
2,000,000
1,797,644
1,500,000
1,000,000
100,850
500,000
0
Title V
148,789
TMNSR
2018
2019
Figure 19: Comparison of GHG Emissions from Title V and Permitted TMNSR Sources from 2018 and
2019 on the Southern Ute Indian Reservation (CO2e)
V.4 CY2019 Emission Summary
Table 5 summarizes the emissions from and Title V and Synthetic Minor TMNSR permitted
sources on the Reservation during CY2019. NOx, CO and VOC represent dominant pollutants
on the reservation of the pollutants and Title V sources account for majority of emissions.
Table 5: 2019 Criteria Pollutants, HAP, and GHG Emissions on the Southern Ute Indian
Reservation [Tons]
Oxides of
Nitrogen
Carbon
Monoxide
PM10
Primary
(Filt + Cond)
Total HAP
CO2e
Title V
Volatile
Organic
Compounds
2,155.0
1,692.2
982.9
99.7
294.7
1,797,643.5
TMNSR
365.0
233.1
160.2
6.5
43.2
148,788.8
Total
2,520.0
1,925.3
1,143.1
106.2
337.9
1,946,432.3
28
VI. BIBLIOGRAPHY
40 CFR Part 49 - Indian Country: Air Quality Planning and Management. (2019). 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
EPA: CY 2019 TMNSR Annual Emissions Forms.
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
Institute for Tribal Environmental Professionals. (2019). Tribal Emissions Inventory Software
Solution
Version
3.6.26.
Retrieved
from
http://www7.nau.edu/itep/main/air/air_aqt_teiss.
Southern Ute Indian Tribe: Calendar Year 2019 Part 70 FEE Forms.
Southern Ute Indian Tribe: Ambient Monitoring. (2019). 2019 AQS Ute 3 Precipitation and
Temperature
Hourly
Data.
Retrieved
from:
http://www.southernutensn.gov/environmental-programs/air-quality/ambient-monitoring/
Southern Ute Indian Tribe (2019). History of the Southern Ute.
https://www.southernute-nsn.gov/history/
Retrieved from:
29
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.