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_______________________________________________________________

Final Report for 2018 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

Ambrish Sharma, Air Quality Analyst

May 2021

TABLE OF CONTENTS

Table of Contents .................................................................................................................................. ii

Table of Figures .................................................................................................................................... iii

List of Tables......................................................................................................................................... iv

List of Acronyms ................................................................................................................................. v

Executive Summary ....................................................................................................................... 1

II.

Overview ....................................................................................................................................... 3

II.1

Purpose of Inventory ............................................................................................................. 3

II.2

Geographic Location of southern Ute Indian Reservation .................................................... 3

II.3

Climate .................................................................................................................................. 3

II.4

Geology ................................................................................................................................. 4

II.5

Sources .................................................................................................................................. 4

III.

Data Quality Objectives............................................................................................................. 5

III.1

Accuracy ................................................................................................................................ 5

III.2

Uncertainty............................................................................................................................ 5

III.3

Completeness ........................................................................................................................ 6

III.4

Comparability ........................................................................................................................ 6

IV.

Point sources ............................................................................................................................. 7

IV.1

Title V Permitted Sources ...................................................................................................... 7

IV.2

Permitted Tribal Minor New Source Review Point Sources ................................................ 16

Quality Assurance Summary ....................................................................................................... 25

V.1

Quality Assurance Checks ................................................................................................... 25

V.2

Criteria, HAP Pollutants and Equipment Count .................................................................. 26

V.3

GHG ..................................................................................................................................... 28

V.4

CY2018 Emission Summary ................................................................................................. 29

VI.

Bibliography ............................................................................................................................ 30

TABLE OF FIGURES

Figure 1: Title V and permitted TMNSR sources located within the exterior boundaries of the Southern

Ute Indian Reservation ......................................................................................................................... 1

Figure 2: 2018 Total Criteria Pollutant and Total HAP Emissions on the Southern Ute Indian

Reservation [Tons] ................................................................................................................................ 2

Figure 3: 2018 Title V Source Criteria Pollutant and Total HAP on the Southern Ute Indian

Reservation [Tons] ................................................................................................................................ 9

Figure 4: 2018 NOx Emissions at Title V Sources on the Southern Ute Indian Reservation by

Equipment Type [Tons] ....................................................................................................................... 10

Figure 5: 2018 VOC Emissions at Title V Sources on the Southern Ute Indian Reservation by

Equipment Type [Tons] ....................................................................................................................... 11

Figure 6: CO Emissions at Title V Sources on the Southern Ute Indian Reservation by Equipment Type

[Tons] .................................................................................................................................................. 12

Figure 7: 2018 Title V Source HAP Emissions on the Southern Ute Indian Reservation [Tons] ...... 13

Figure 8: 2018 HAP Emissions at Title V Sources on the Southern Ute Indian Reservation by

Equipment Type [Tons] ....................................................................................................................... 14

Figure 9: 2018 Equipment Counts for Title V Sources on the Southern Ute Indian Reservation ...... 15

Figure 10: 2018 Criteria Pollutant and HAP Emissions for Permitted TMNSR Sources on the Southern

Ute Indian Reservation [Tons]............................................................ Error! Bookmark not defined.

Figure 11: 2018 NOx Emissions for Permitted TMNSR Sources on the Southern Ute Indian Reservation

by Equipment Type [Tons] .................................................................................................................. 18

Figure 12: 2018 VOC Emissions for Permitted TMNSR Sources on the Southern Ute Indian

Reservation by Equipment Type [Tons] .............................................................................................. 19

Figure 13: 2018 CO Emissions for Permitted TMNSR Sources on the Southern Ute Indian Reservation

by Equipment Type [Tons] .................................................................................................................. 20

Figure 14: 2018 Speciated HAP Emissions at Permitted TMNSR Sources on the Southern Ute Indian

Reservation [Tons] .............................................................................................................................. 21

Figure 15: 2018 Total HAP Emissions for Permitted TMNSR Sources on the Southern Ute Indian

Reservation by Equipment Type [Tons] .............................................................................................. 22

Figure 16: 2018 Equipment Counts for Permitted TMNSR Sources on the Southern Ute Indian

Reservation.......................................................................................................................................... 23

Figure 17: Comparison of Criteria Pollutants and Total HAP from CY2017 EI (navy blue) and CY

2018 EI (multi-color) on the Southern Ute Indian Reservation .......................................................... 26

Figure 18: CY2017 (navy blue) and CY 2018 (multi-color) Equipment Count Comparison of Title V

and Permitted TMNSR Sources ........................................................................................................... 27

Figure 19: CY2017 (navy blue) and CY2018 (orange) GHG Emissions Comparison of Title V and

Permitted TMNSR Sources [Tons] ...................................................................................................... 28

iii

LIST OF TABLES

Table 1: 2018 Title V Source Criteria Pollutant, Total HAP and GHG Emissions for the Southern Ute

Indian Reservation [Tons] .................................................................................................................... 9

Table 2: 2018 Title V Sources HAP Emissions on the Southern Ute Indian Reservation [Tons] ....... 13

Table 3: 2018 Criteria Pollutant, HAP and GHG Emissions for permitted TMNSR Sources on the

Southern Ute Indian Reservation [Tons] ............................................................................................ 17

Table 4: Speciated HAP Emissions for Permitted TMNSR Sources on the Southern Ute Indian

Reservation [Tons] .............................................................................................................................. 21

Table 5: 2018 Criteria Pollutants, HAP and GHG Emissions on the Southern Ute Indian Reservation

[Tons] .................................................................................................................................................. 29

List of Acronyms

AP-42

EPA Compilation of Air Pollutant Emission Factors

AQP

Air Quality Program

CAA

Clean Air Act

Carbon Monoxide

CO2e

Carbon Dioxide Equivalent

Calendar Year

CFR

Code of Federal Regulations

Emissions Inventory

EIS

Emission Inventory System

EPA

United States Environmental Protection Agency

FLIGHT

Facility Level Information on GreenHouse gases Tool

GHG

Greenhouse gas

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

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

TPY

Tons per Year

VOC

Volatile Organic Compounds

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) 2018. The EI was prepared with data from federal annual emission

reports and tribal annual emission fee forms.

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.

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 (Figure Courtesy: Matt Wampler, Air Quality

Technical Manager, Air Quality Program, SUIT)

Reservation emission totals for CY2018 were 2,687.1 tons of oxides of Nitrogen (NOx),

1,185.5 tons of Volatile Organic Compounds (VOC), 52.0 tons of Sulfur Dioxide (SO2),

109.4 tons of Particulate Matter shown as PM10-PRI here (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), 2,444.6 tons of Carbon Monoxide (CO), 373.5

tons of total Hazardous Air Pollutants (HAP), and 2,104,212 tons of Greenhouse Gas (GHG)

emissions measured in Carbon Dioxide Equivalents (CO2e). Total criteria pollutant and

HAP emissions on the Reservation for 2018 are presented below in Figure 2.

Figure 2: 2018 Total Criteria Pollutant and Total HAP Emissions on the Southern Ute Indian

Reservation [Tons]

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 2018 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 2018 calendar year the coldest month was

December with a monthly average of 28.2 degrees Fahrenheit. January had the lowest

temperature with 2.2 degrees Fahrenheit. During the summer months, the peak temperatures

typically remain in the high eighties to low nineties. The warmest month of 2018 was July

with a monthly average of 73.1 degrees Fahrenheit. June had the highest temperature with

97.1 degrees Fahrenheit. Snow is the dominant form of precipitation on the Reservation. The

total precipitation for calendar year 2018 was 23.88 inches. The driest month was March

Southern Ute Indian Tribe (2018). History of the Southern Ute. Retrieved from: https://www.southernutensn.gov/history/

with 0.36 inches of precipitation and the wettest month was August with 4.95 inches of

precipitation.2

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 2018.

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

Data. Retrieved from: http://www.southernute-nsn.gov/environmental-programs/air-quality/ambientmonitoring/

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

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 CY2018, then the GHG emissions were either used from CY2017 or

calculated by the AQP using an emissions calculator tool or obtained from EPA’s

Facility Level Information on GreenHouse gases Tool (FLIGHT) map .

III.3 Completeness

•

Capture 100% of Title V point source emissions reported in the annual emission fees

for CY2018.

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 CY2017 Comprehensive Emissions Inventory report.

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.

IV. POINT SOURCES

IV.1 Title V Permitted Sources

Description of Sources

Thirty-five Title V sources operated on the Reservation during CY2018. 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 2018,

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

CY2018 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.

Dehydration Units: 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 usually 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 source, open

storage piles and unclassified sources.

Emissions

Total criteria pollutant, total HAP and GHG emissions from Title V sources for CY2018 are

displayed below in Table 1 and Figure 3.

Table 1: 2018 Title V Source Criteria Pollutant, Total HAP and GHG Emissions for the Southern

Ute Indian Reservation [Tons]

Pollutant

Emissions

NOx

2,379.1

2,220.2

VOC

1,051.8

PM10

105.3

SO2

46.3

Total HAP

331.3

CO2e

2,003,362

Figure 3: 2018 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 2018 calendar year are

displayed below in Figure 4.

Figure 4: 2018 NOx Emissions at Title V Sources on the Southern Ute Indian Reservation by

Equipment Type [Tons]

VOC emissions by equipment type at Title V sources for the 2018 calendar year are

displayed below in Figure 5.

Figure 5: 2018 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 2018 calendar year are displayed

below in Figure 6.

Figure 6: CO Emissions at Title V Sources on the Southern Ute Indian Reservation by Equipment

Type [Tons]

Total and speciated 2018 HAP emissions from Title V sources are displayed below in Table

2 and Figure 7.

Table 2: 2018 Title V Sources HAP Emissions on the Southern Ute Indian Reservation [Tons]

Pollutant

Formaldehyde

Toluene

Xylenes

Acetaldehyde

Benzene

Acrolein

Methanol

n-Hexane

Other HAP

Total

Emissions [Tons]

214.0

34.3

20.8

24.0

9.8

13.7

6.9

2.0

5.5

331.0

Figure 7: 2018 Title V Source HAP Emissions on the Southern Ute Indian Reservation [Tons]

HAP emissions by equipment type at Title V sources for CY2018 are displayed below in

Figure 8.

Figure 8: 2018 HAP Emissions at Title V Sources on the Southern Ute Indian Reservation by

Equipment Type [Tons]

Title V equipment counts for the CY2018 EI are displayed below in Figure 9.

Figure 9: 2018 Equipment Counts for Title V Sources on the Southern Ute Indian Reservation

Summary

Nitrogen Oxides (NOx) emissions represent the largest portion of criteria pollutant emissions

from Title V sources on the Reservation, with 38% of the total criteria pollutant emissions.

CO emissions represent the second largest pollutant emission with 36% of the total criteria

pollutant emissions. Title V sources reported emissions from 200 pieces of equipment, with

IC engines representing the majority of the equipment type at 65% 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 65% 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 2018 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 seven 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 2018.5 Two TMNSR permitted facilities reported only CO and formaldehyde

emissions. 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

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

CY 2018 EPA TMNSR Annual Emissions Forms.

factor from EPA’s AP-42 resource, along with data from the CY2017 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 2018 criteria pollutant, HAP, and GHG emissions from permitted TMNSR sources on

the Southern Ute Indian Reservation are presented below in Table 3.

Table 3: 2018 Criteria Pollutant, HAP and GHG Emissions for permitted TMNSR Sources on the

Southern Ute Indian Reservation [Tons]

Pollutant

Emissions

NOx

308.0

224.4

VOC

133.8

PM10

4.2

SO2

5.7

Total HAP

42.2

CO2e

100,850

Total criteria pollutant and HAP emissions from permitted TMSNR sources on the Southern

Ute Indian Reservation are presented below in Figure 10.

Figure 10: 2018 Criteria Pollutant and HAP Emissions for Permitted TMNSR Sources on the

Southern Ute Indian Reservation [Tons]

Total 2018 NOx emissions by equipment type from permitted TMNSR sources on the

Reservation are displayed below in Figure 11.

Figure 11: 2018 NOx Emissions for Permitted TMNSR Sources on the Southern Ute Indian

Reservation by Equipment Type [Tons]

Total 2018 VOC emissions by equipment type from permitted TMNSR sources on the

Reservation are displayed below in Figure 12.

Figure 12: 2018 VOC Emissions for Permitted TMNSR Sources on the Southern Ute Indian

Reservation by Equipment Type [Tons]

Total 2018 CO emissions by equipment type from permitted TMNSR sources on the

Reservation are displayed below in Figure 13.

Figure 13: 2018 CO Emissions for Permitted TMNSR Sources on the Southern Ute Indian

Reservation by Equipment Type [Tons]

Total 2018 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

Xylene

Acrolein

Toluene

Methanol

n-Hexane

Benzene

Other HAP

Total

Emissions

[Tons]

22.5

5.1

4.1

3.2

2.4

2.0

1.4

0.9

0.6

42.2

Figure 14: 2018 Speciated HAP Emissions at Permitted TMNSR Sources on the Southern Ute Indian

Reservation [Tons]

Total 2018 HAP emissions by equipment type from permitted TMNSR sources on the

Reservation are displayed below in Figure 15.

Figure 15: 2018 Total HAP Emissions for Permitted TMNSR Sources on the Southern Ute Indian

Reservation by Equipment Type [Tons]

Permitted TMNSR equipment counts for the CY2018 inventory are displayed below in

Figure 16.

Figure 16: 2018 Equipment Counts for Permitted TMNSR Sources on the Southern Ute Indian

Reservation

Summary

Nitrogen Oxides (NOx) emissions represent the largest portion of criteria pollutant emissions

from Synthetic Minor TMNSR permitted sources on the Reservation with 42% of the total

criteria pollutant emissions. Carbon Monoxide (CO) emissions represent the second largest

pollutant emission with 31% of the total criteria pollutant emissions. Permitted TMNSR

sources reported emissions from 45 pieces of equipment from six different categories

(including others) with internal combustion engines being the most commonly reported

equipment type. IC engines represented 44% 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 53% 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.

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 CY2018 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 CY2018 emission

inventory. Emissions were compared to the finalized 2017 NEI and flagged if reported Tons

were less than or greater than 25% of the 2017 NEI v2 amount. No emissions from the

CY2018 emission inventory were flagged.

V.2 Criteria, HAP Pollutants and Equipment Count

Emissions from the CY2017 EI were compared to the CY2018 EI to ensure accuracy and

identify possible inaccuracies. There was consistency in emissions records between the two

years tested, with no greater than 7% difference found in emissions between the two years

for criteria pollutants emitting more than 1000 tons (NOx, VOC, CO), and the difference

under 35% between the two years for criteria pollutants emitting less than or equal to 110

tons (SO2 and PM10) during the CY2018 on the Southern Ute Indian Reservation. The

difference in Total HAP emissions between the two compared years was less than 11%.

Nitrogen Oxides (NOx) and CO were the greatest emitted pollutants. Nitrogen Oxides

(NOx) and CO showed a slight decrease in emissions between the two years while VOC,

PM10, Total HAP and SO2 showed slight increases in emissions. Comparison of criteria

pollutants and total HAP from CY2017 and CY2018 are displayed below in Figure 17.

Figure 17: Comparison of Criteria Pollutants and Total HAP from CY2017 EI (navy blue) and CY

2018 EI (multi-color) on the Southern Ute Indian Reservation

The AQP also compared equipment counts from the CY2017 EI and the CY2018 EI for

Title V and Synthetic Minor TMNSR permitted sources. Equipment counts were

consistently lower in CY2018 than in CY2017, with the exception of storage tanks. The

CY2017 inventory was comprehensive and included insignificant emission sources

equipment than operators are not normally required to report emissions from during nontriennial emissions inventory years.

Comparison of Title V and permitted TMNSR source equipment counts from the CY2017

and CY2018 is displayed below in Figure 18.

Figure 18: CY2017 (navy blue) and CY 2018 (multi-color) Equipment Count Comparison of Title V

and Permitted TMNSR Sources

V.3 GHG

Total GHG Emissions from Title V Sources from CY2017 were compared to CY2018 to

ensure accuracy and identify possible inaccuracies. An increase of 36% was found in GHG

emissions from the Title V and permitted TMNSR sources during the CY2018 from the

CY2017 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, CY2018 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.. Figure 19 illustrates GHG emissions

of Title V and Synthetic Minor TMNSR permitted sources for calendar years 2017 and

2018.

Figure 19: CY2017 (navy blue) and CY2018 (orange) GHG Emissions Comparison of Title V and

Permitted TMNSR Sources [Tons]

V.4 CY2018 Emission Summary

Table 5 summarizes the emissions from and Title V and Synthetic Minor TMNSR permitted

sources on the Reservation during CY2018. NOx, CO and VOC represent dominant

pollutants on the reservation of the pollutants and Title V sources account for majority of

emissions.

Table 5: 2018 Criteria Pollutants, HAP and GHG Emissions on the Southern Ute Indian Reservation

[Tons]

Source