ExxonMobii Production Company

P. O. Box 4697

Houston, Texas 77210-4697

CERTIFIED MAIL, RETURN RECEIPT REQUESTED

December 5, 2005

Director, Air Division (AIR-1)'

U.S. Environmental Protection Agency, Region IX

75 Hawthorne Street

San Francisco, California 94105

Attention: John Kim

, Sara N. Ortwein

Production Manager

U.S. Production

EJf<onMobii

Production

RECE\VED

NOV 1 3· 2005

EnforCement QffiC~ Air- 5

U.S. EPA, RegiOO 9

k-A. ffLU-'

SUbject: United States v. Mobil Exploration and Producing U.S. Inc.

Civil Action Case No. 2:05-CV-00319PGC

DOJ Case No. 90-5-2-1-2237

Entered into on 06/08/2005

PSD Permit Application for Main Flare

Dear Mr. Kim:

In accordance with Paragraph 14.a of the Consent Decree for the referenced Civil Action Case

United States v. Mobil Exploration and Producing U.S. Inc., attached is a PSD permit application

for the Main Flare. This application is being submitted no later than 180 days after the Effective

Date noted above as required. It includes an analysis of the best available control technology

for the Main Flare for S02, CO, NOx, and VOC and a SCREEN 3 air quality analysis, which was

previously accepted via e-mail by Mr. Scott Bohning.

I certify under penalty of law that I have examined and am familiar with the information .

submitted in this document and all attachments and that this document and its attachments

were prepared either by me personally or under my direction or supervision in a manner

designed to ensure that qualified and knowledgeable personnel properly gathered and

presented the information contained therein. I further certify, based on my personal knowledge

or on my inquiry of those individuals immediately responsible for obtaining the information, that

the information is true, accurate, and complete. I am aware that there are significant penalties

for submitting false information, including the possibility of fines and imprisonment for knowing

and willful submission of a materially false statement.

If you have any questions, please contact Justin Harrison at 281-654-1127.

Sincerely,

Sara N. Ortwein

U.S. Production Manager

SNO/ccs

Attachments
PREVENTION OF SIGNIFICANT

DETERIORATION PERMIT APPLICATION

EXXON MOBIL CORPORATION

McELMO CREEK UNIT OIL PRODUCTION FACILITY -

MAIN FLARE, GAS COMPRESSION FACILITY

December 2005

Prepared for:

ExxonMobii Corporation

14950 Heathrow Forest Parkway

Houston, TX 77032

Prepared by:

McVehil-Monnett Associates, Inc.

44 Inverness Drive East

Building C

Englewood, Colorado 80112

MMA Project Number 1814-04
1.0

1.1

1.2

2.0

2.1

2.2

2.3

2.4

2.4.1

2.4.2

2.4.3

2.4.4

2.4.5

3.0

3.1

4.0

4.1

4.2

4.3

4.4

5.0

5.1

5.2

5.3

5.4

6.0

6.1

6.2

6.3

6.4

6.4.1

6.4.2

6.4.3

6.5

7.0

7.1

7.1.1

7.1.2

TABLE OF CONTENTS

Page No.

in Section

INTRODUCTION 1

GENERAL INFORMATION ; 1

PERMIT APPLICATION FORM 1

PROJECT DESCRIPTION 1

FACILITY AIR QUALITY PERMIT HISTORy 1

EXISTING FACILITY OPERATIONS 2

MODIFICATION 3

MAIN FLARE REGULATORY REQUIREMENTS 3

.New Source Review 3

Consent Decree Requirements : 4

New Source Performance Standards (NSPS) and National Emission

Standards for Hazardous Air Pollutants (NESHAP) 4

Other Air Quality Requirements 5

Title V Requirements 5

MAIN FLARE EMISSIONS 1

CRITERIA POLLUTANTS , / 1

BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS 1

VOLATILE ORGANIC COMPOUNDS (VOCs) , 2

CARBON MONOXIDE (CO) S

NITROGEN O~DES (NOx) 5

SULFUR DIOXIDE (S02) 8

EXISTING ENVIRONMENT 1

TOPOGRAPHY 1

AIR QUALITY 1

AREA CLIMATE AND METEOROLOGy 2

SOILS AND VEGETATION 4

IMPACT ASSESSMENT APPROACH 1

AIR QUALITY MODEL DESCRIPTION 2

MODEL INPUT 3

METEOROLOGICAL DATA 3

SOURCE CHARACTERISTICS AND EMISSION RATES 4

Flare Rate and Heat Release 4

Flare Height 5

Modeled Emission Rates 5

RECEPTOR SELECTION ;.. 6

AIR QUALITY IMPACTS 1

NITROGEN DIOXIDE (N02) 2

Increment Consumption 2

National Ambient Air Quality Standards (NAAQS) 3

1
7.2

7.2.1

7.2.2

7.3

7.3.1

8.0

SULFUR DIOXIDE (S02) 3

Increment Consumption 4

National Ambient Air Quality Standards (NAAQS) 5

CARBON MONOXIDE (CO) 5

National Ambient Air Quality Standards (NAAQS) 6

REFERENCES ' 1

11
TABLE 3-1

TABLE 4-1·

TABLE 4-2

TABLE 4-3

TABLE 4-4

TABLE 5-1

TABLE 5-2

TABLE 5-3

TABLE 5-4

TABLE 6-1

TABLE 6-2

TABLE 7-1

TABLE 7-2

TABLE 7-3

TABLE 7-4

TABLE 7-5

LIST OF TABLES

MAIN FLARE CRITERIA POLLUTANT EMISSION LIMITS

BACT/LAERCLEARINGHOUSE DATABASE SUMMARY -VOC

BACVLAER CLEARINGHOUSE DATABASE SUMMARY-CO

BACT/LAER CLEARINGHOUSE DATABASE SUMMARY -NOx

BACT/LAER CLEARINGHOUSE DATABASE SUMMARY - S02

AIR QUALITY IN THE MGELMO CREEK AREA

JOINT FREQUENCY DISTRIBUTION OF BLANDING, UTAH

ANNUAL STABILITY CLASS DISTRIBUTION AT BLANDING,UT

MONTHLY AVERAGE TEMPERATURE & TOTAL PRECIPITATION

SUMMARY OF NATIONAL AMBIENT AIR QUALITY STANDARDS

& PSD INCREMENTS

SCREEN3 MODELED STACK PARAMETERS & EMISSIONS FOR

THE MAIN FLARE '

COMPARISON OF MODELED MAIN FLARE N02 IMPACTS TO THE

PSD INCREMENTS

COMPARISON OF MODELED CUMULATIVE N02 IMPACTS TO

THENAAQS

COMPARISON OF MODELED MAIN FLARE S02 IMPACTS TO THE

PSDINCREMENTS

COMPARISON OF MODELED CUMULATIVE S02 IMPACTS TO

THENAAQS

COMPARISON OF MODELED CUMULATIVE CO IMPACTS TO

THENAAQS

111
LIST OF FIGURES

FIGURE 2-1 LOCATION MAP OF McELMO CREEK GAS COMPRESSION FACILITY

FIGURE 2-2 FLOW DIAGRAM OF EXISTING GATHERING SYSTEM OPERATIONS

FIGURE 2-3 BLOCK FLOW DIAGRAM OF GAS COMPRESSION FACILITY

FIGURE 5-1 WIND ROSE OF 2004 BLANDING, UTAH METEOROLOGICAL DATA

LIST OF APPENDICES

APPENDIX A

APPENDIXB

EXXONMOBIL MCELMO CREEK OIL PRODUCTION UNIT

CONSENT DECREE

SCREEN3 MODELING INPUT AND OUTPUT RESULTS

IV
1.0 INTRODUCTION

1.1 GENERAL INFORMATION

Exxon Mobil Corporation (ExxonMobil) IS submitting this Prevention of Significant

Deterioration (PSD) permit application for its Main Flare at the McElmo Creek Oil Production

Facility, located on the Navajo Nation near Aneth, Utah, in order to meet the terms ofits Consent,

Decree (DOJ Case No. 90-5-2-1-2237, filed June 8, 2005) with the U.S. Environmental

Protection Agency (US EPA). No modification is proposed with this permit application.

However, no later than June 8, 2006, ExxonMobil will install an automatic air-assistedsystem on

the Main Flare, pursuant to the provisions of 40 CFR § 60.18 (c)(5) and (f)(6), as required in

Paragraph II.b ofits Consent Decree.

This PSD permit application document presents a facility process description for existing

operations, criteria pollutant permit emission limits for the Main Flare, a Best Available Control

Technology (BACT) analysis for the Main Flare, air modeling methodology, and air modeling

results.

1.2 PERMIT APPLICATION FORM

A completed permit application form providing information on the existing facility, including the

Main Flare, is attached at the end ofthis section.

1-1
PSD Permit Application Form Page 1 of4

Company Name and Address:

Mobil Exploration and Producing U.S. Inc.

CORP-WGR-1260

396 West Greens Road

Houston, TX 77067

Phone No.: 713-431-1444

Fax No.: 713-431-1050

Facility Name and Address:

McElmo Creek Unit Oil Production Facility

23429 County Road G

Cortez, CO 81321

Phone No.: 970-564-5210

Fax No.: 970-564-5234

County where facility is located:

Sanjuan

Company Contact for Environmental Matters:

Neil J. Ryan, OIMS Supervisor

CORP-MI-4024

14950 Heathrow Forest Pkwy

Houston, TX 77032

Phone No.: 281-654-1042

Fax No.: 281-654-1183

Owners Name and Address:

Mobil Exploration and Producing U.S. Inc.

CORP-WGR-1260

396 West Greens Road

Houston, TX 77067

Phone No.e713-431-1444

Fax No.: 713-431-1050

Latitude and Longitude or UTM coordinates:

37° 15' 37.58" N

109° 12' 12.07" W

.. Directions to facility (street address and/or directions to site):

From Cortez Airport, take Hwy 160 South for 30 miles. Turn right (heading Northwest) on CO 41 to Utah. CO 41 turns

into UT 262 at the state line. Continue on UT 262 for 14 miles, through the town ofAneth. Turn Right at the

ExxonMobil sign and follow the road 3.1 miles to the office. The office is on the left and the gas compression plant is

on the right.

List current air quality per~its for facility:

U.S. EPA Region VIII PSD Permit 8AT-AP (last amended April 18, 1991)

Ifrequest for a modification, identify permit # to be modified:

Permit No.: 8AT-AP

Dated: April 18, 1991

Type of business at this facility:

Oil & Gas Production

Are the total number of company employees greater

than 100? Yes

Standard Industrial Code Classification: 1311

Application for:

New construction

lL-Existing equipment operating without permit

_ Change of permit condition

_Modification

__ Permanent site for portable equipment

_ Change of location

For new construction or modification, enter estimated start date: Flare Upgrade will begin in March 2006

estimated completion date: Must be completed by June 8, 2006

For change of permittee, location, or condition, enter

date of occurrence: N/A

For existing equipment in.operatlon without prior

permit, enter initial operation date: 1991
PSD Permit Application Form Page 2 of4

Name of process: Oil & Gas Production; Gas End product of this process: Oil

Dehydration and Compression; C02 and Water Injection

Primary process equipment: Dehydration System, Compressors, and Flare

Maximum Operating Schedule:

24 hours/day

Ldays/week

R weeks/year

Daily production rates:

Average: 3,700 bopd

Maximum: 5,000 bopd

Type of operation: X Continuous

Batch

Intermittent

Percent annual production by quarter:

Winter 25% Spring 25%

Summer

,--25% Fall --

25%

,Maximum annual production:

1,825,000bbls of oil

Projected percentannual increase in production: N/A

If batch, indicate minutes per cycle: N/A

Minutes between cycles: N/A

,Materials used in process: (1) raw material, (2) principal use, and (3) amounts:

3,700 bbls of oil produced (bop) and sold each day on average from the tank batteries

26,000 bbls of water produced (bwp) and injected each day on average

10-18 million cubic feet of gas produced each day on average

6-14 million cubic feet ofC02 is purchased each day to supplement injection to 24 million total cubic feet per day

"
PSD Permit Application Form Page 3 0/4

Manufacturer: Zeeco, Inc. will perform upgrade in March 2006; Originally by American Steel and Iron Works

Model No: N/A

Fuel Minimum Expected Flowrate Design Max Temp of Pressure (psig)

Waste gas stream: Dehydrated Produced Gas (approx, 70% C02 and 0.05% H2S) - Up to 14 million cubic feet per day

Fuel added to gas stream: NIA

Heat Content of flared gas 300-443 BTU/scf

Pilot fuel flow rate, per pilot (scfm 70°F & 14.7 psia): 1.0

Flare height: Currently 195 feet Flare tip inside diameter: 24 inches

Steam Injection

Steam pressure (psig):

Minimum expected:

Design maximum:

Total steam flowrate (lb/hr):

Temperature eF):

Velocity (ftlsec):

Number of jet streams:

Diameter of jet streams (in.):

Water Injection:

Water pressure (psig):

Minimum expected:

Design maximum:

Total water flowrate (gpm):

Minimum expected:

Design maximum:

Number of water jets:

Diameter of water jets (in.):

Air Assist:

Air pressure (psig):

Minimum expected:

Design maximum:

Total air flowrate:

Velocity (ft/sec):

Number of air jets:

Diameter of air jets (In.):

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

Currently in Design
PSD Permit Application Form

Certification Statement

Page 4 0/4

Date: liz9/0[) ,

I certify under penalty oflaw that I have examined and am familiar with the information

submitted in this document and all attachments and that this document and its

attachments were prepared either by me personally or under my direction or supervision

in a manner designed to ensure that qualified and knowledgeable personnel properly

gathered and presented the information contained therein. I further certify, based on my

personal knowledge or on my inquiry ofthose individuals immediately responsible for

obtaining the information, that the information is true, accurate, and complete. I ani

'aware that there are significant penalties for submitting false information, including the

possibility offines and imprisonment for knowing and willful submission of a materially

false statement.

Signature: ~1l. W-rI~

Name (type): Sara N. Ortwein

Title: U.S. Production Manager

Phone: 713-431-1444
2.0 PROJECT DESCRIPTION

This section presents an overview of the McElmo Creek Oil Production Facility, including a

summary of the facility's air permit history, overview of operations including the gas

compression plant and the Main Flare, and a review of applicable air quality requirements.

2.1 FACILITY AIR QUALITY PERMIT HISTORY

The McElmo Creek Oil Production Facility is located in San Juan County, Utah near Aneth,

Utah in Section 23 of T40S, R24E on Navajo Nation land. A location map of the facility is

presented in Figure 2-1.

The original oil well production facility, owned by Superior Oil, started operations in the 1950s.

Mobil Exploration and Producing U.S., Inc. (Mobil) purchased the facility from Superior Oil in

1984. In 1986, Mobil constructed a gas processing plant at the facility, including an upright

flare, dehydrator, amine treater, refrigeration separation unit, a natural gas liquids recovery unit

and compressors to transport the produced liquid natural gas. In 1991, the equipment was

switched out with an emergency flare added as a control device for the dehydrators. Petroleum

liquid storage tanks and heater treaters were also installed in the early 1990s. At that time, the

emergency flare was not permitted as an emission unit because it was viewed as an emergency

control device. The permit and facility operations have been overseen by EPA Region IX. EPA

has delegated oversight authority ofthis facility since it is on tribal land and is assisting the tribe

in administering its recently approved regulatory program.

In 1997, following a fire, all processing equipment except for one dehydrator was removed, the

compressors were converted to run on electricity, and the flare was kept for emergency flaring,

flaring closed drain system fumes, and control of dehydrator emissions. The former gas

processing plant is now referred to as the gas compression plant.

In 1997 and 1999, EPA issued NOVs (Notice ofViolations), asserting the flare should have been

permitted. The NOVs also cited the lack of fugitive VQC (volatile organic compounds)

monitoring per the New Source Performance Standards (NSPS) of40 CFR 60, Subpart KKK.

2-1
Figure 2-1: Facility Location Map

The McElmo Creek Oil Production Unit,

Gas Compression Facility

San Juan County, Utah

3r15'37.58" Nand 109°12'12.07"W

!

I

I

I miles

I0 10 15 20

MMAPROJECTNo.: DATEDRAWN:

A>r(Ml;\.".~~ 1814-04 11/17/2005
The following is a summary ofthe PSD permit history associated with the McElmo facility:

• March 14, 1985 - U.S. EPA Region VIII determined Stage I ofMcElmo Creek Unit does

not require a PSD permit;

• May 8, 1986 - Mobil Exploration and Producing North America submitted PSD Permit

Application for CO2 Project Stage 2;

• February 2, 1987 - U.S. EPA Region VIII issued PSD permit to Mobil;

• September 1, 1987 - Mobil submitted letter requesting to replace three reciprocating

internal combustion engines with two natural gas fueled turbines;

• October 27, 1987 - U.S. EPA Region VIII issued amended PSD permit for the change;

• February 21, 1991 -Mobil requested amendment ofPSD permit to allow construction of

waste heat recovery unit at turbine, replacing two existing pieces of fuel-burning

equipment;

• February 22, 1991 - Mobil requested EPA approval for temporary replacement ofturbine

with an identical unit, during turbine overhauls;

• April 18, 1991- U.S. EPA Region VIII issues amended PSD permit for requested

changes and also, rescinded approval of the second turbine since Mobil had no plans to

install it.

2.2 EXISTING FACILITY OPERATIONS

Currently, produced fluids at the oil production facility are processed, sold, and re-injected

through a series of satellite facilities, main tank batteries, and injection plants. Produced fluids

are gathered and separated at one of eleven satellite facilities located throughout the field. Gases

from the satellite facilities are directed to the gas compression plant, and liquids are pumped to

one offour central tank batteries. Gases sent to the gas compression plant are compressed, dried

through a glycol dehydrator, blended with carbon dioxide (C02) , and re-injected into the field.

Liquids are further separated at the central tank batteries, with oil being sold and transported

through a pipeline system. Water from the central tank batteries is pumped to the water flood

injection plant.

The Main Flare at the gas compression plant combusts gases that have been bypassed around the

plant's electric-driven compressors or that come through various emergency relief valves in the

2-2
compression plant. Additionally, the vent stream from the plant's glycol dehydrator is directed

to the Main Flare.

A flow diagram of the facility's gathering system operations is presented in Figure 2-2,

illustrating the flow through the satellite facilities, central tank batteries, water flood injection

plant, and gas compression plant. Figure 2-3 presents a simple block flow diagram for the gas

compression plant, including the streams directed to the Main Flare.

2.3 MODIFICATION

As noted in Section 1, no modification of existing operations is proposed with this PSD permit

application. This application is submitted in order to meet the requirements of ExxonMobil's

Consent Decree (DOJ Case No. 90-5-2-1-2237, filed June 8, 2005). Paragraph 14.a requires

ExxonMobil to submit an application for a PSD permit for the Main Flare, including "(i) an

analysis of the best available control technology for the Main Flare for [sulfur dioxide] S02,

[carbon monoxide] CO, [nitrogen oxides] NOx, and [volatile organic compounds] VOC; and (ii)

an air quality analysis" no later than 180 days after the Consent Decree's effective date ofJune 8,

2005.

2.4 MAIN FLARE REGULATORY REQUIREMENTS

2.4.1 New Source Review

No modifications are being proposed to necessitate a PSD petmit application. However,

ExxonMobil's Consent Decree requires a PSD permit application submittal for the Main Flare,

including a BACT analysis for S02, CO, NOx, and VOC, and an air quality analysis to assess the

impacts of the Main Flare's criteria emissions to ambient air quality standards. Based on an email directive from EPA Region IX, no further assessment ofthe Main Flare's emission impacts,

beyond what is presented in this application, is required.

2-3
• WATER

J 1 I '" '(INJECTION SlSTEM

C02 I

PURCHASES ill

FROM I McELMO DOME

C02 PIPEUNE II

I

I

I I : ( '(INJ~~~ON SYSTEM

Figure 2·2

Block Flow Diagram of Existing

Gathering System Operations

McElmo Creek Oil Production Unit

I

I I

~~~~L.o.O~.~~ ~~~

rl

- ·· _ ·· _ ·· _ ·· ...,

I

I

L..G~ :9~R.E.S~~. ~~I;:.J.G:nJ

LEGEND

• = SUBBATTERY

GPS--

WATER--

Oll--

EOF == EMERGENCY OVER FLOW --

LACT '" LEASE AUTOMATIC CUSTODY TRANSFER

I

I

L .._ .. _C.E.N~k.~K••BAn~~UcJ~L.. _ ...-J (TYPICAL OF 4)

PRODUCTION

SEPARATOR

I

I

L.._~~B~~1]~ •• _ ••.J (lYPICAL OF 11)

r ··_··_··_··_··--' r··_··_··_··_··_··_··_··_··.., TEST

SEPARATOR

FROM

OTHER

WEu.5

WFP~
FLARE

:' (CK 1070-4083) J LL FLARE METER ~O_ a

An

2 0 0'"

'1J';tis:

';lfTl

zs:~

I -l_0 ;0

Alv>

Cl »»

(-)6' z-<

,~ n

I A'" fTl 02

t/l o

"~C3~ I ;:: 1-<

n n fTl

~~ 40# 2800# -<

A A rn 0-<

0 CD 4202 ;u ~fTl

-< 0- H HO$-4 ;u

" ,,2 COMP, I a or 1 V> 1':1 .. V> "" 10 ;:: 10;:: 10 1OfT1 10 fT1 10-< <, -i '-fT1 10 fT1 _;u t-'l 10 ;u 10 10 10

s: s: 'I"

40# 2800# ,i •

H HOS-6 4203

COMP, I

EXXONMOBIL A B TEXACO

METER METER

L

I.

40# 2800#

TO TEXACO

~--J AGC -- COMP,

l-'l

L\~

GAS FROM: 40# 2800#

MCU BAn. 1 -,-----., Y AGC

4205

COMPo TO MCU

MCU BAn. 2 -,-----.,

INJECTION WELLS

MCUBATT. 4 -,-----., FUEL TO OEHY/FLARE

MCU BAn. 6 -,-----., .. I~

NO. DATE REVISION BY CHI(.Y'PPR M'. IEl.tOnMobil .ACCOUNTING FLOW DIAGRAM

A= EXXONMOBIL CORIOLIS METER 0 9/05/01 ORIGINAL D~~AWING NJP Production MCELMO CREEK COMPRESSOR PLANT

B= TEXACO CORIOLIS METER 2004 ANNUAL REVIEW JM U.s. WEST 4 12/0. DEL· COMpo METER uPDATES Fe HouIlon,T8X8S ANETH FIELD f1. ~v REo ). J SAN JUAN COUNTY, UTAH w

2 12/02 UPDATE METER H OW SCALE .1 REV'sOON.1

2

Y

: .IAE

"'Z~N 11070 '~c~o; .I c;1~E 1S~~NCE ! ~~

~~

3 3/03 2003 ANNUAL REVIEW NONE 4 00 "0OW

Ow

NO CHANGES 00

I: II~P\I "'AI s LFD'S 1400\\C K\CK1070X29.DWG
2.4.2 Consent Decree Requirements

The Consent Decree further requires in Paragraph 14.a that the PSD application include "among

other things, terms and conditions that are at least as stringent as the terms and conditions

included in Paragraphs 9.a, 10, 11, and 25(i)-(ix) ofthis Consent Decree, with the exception that

the quarterly report required by Paragraph 25 may be changed, at the discretion ofthe permitting

authority, to a semiannual report." Paragraph 9.a ofthe Consent Decree refers to the rolling 365-

day cumulative emission limits for S02, CO, NOx, and VOC, which will be discussed in Section

3 of this application document. Paragraph 10 of the Consent Decree addressing monitoring

requirements for the Main Flare, and Paragraph 11 presents operation and maintenance

requirements for the Main Flare and compressors at the gas compression plant. Paragraph 25 of

the Consent Decree details a quarterly reporting system, the frequency ofwhich may be changed

by the permitting authority, as noted earlier. A copy ofthe Consent Decree has been attached as

an appendix to this application. The air permit for the Main Flare will contain the terms and

conditions found in Paragraphs 9.a, 10, 11, and 25(i)-(ix) of the Consent Decree either by I

reference or by direct inclusion in the permit.

2.4.3 New Source Performance Standards (~"8PS) and National Emission Standards for

Hazardous Air Pollutants (NESHAP)

The Consent Decree specifies recordkeeping, maintenance, and operational procedures to

demonstrate a98 percent destruction efficiency on VOCs consistent with 40 CFR § 60.18

(NSPS) and 40 CFR § 63.11 (NESHAP). These procedures and limitations are applicable to a

flare used as a control device for affected facilities subject to individual NSPS and/or NESHAP

subparts. Such is not the case here. Rather, the Main Flare at the McElmo Creek Gas Plant has

been typically used as an emergency flare to control process gas and waste gas release emissions

when the injection system (the primary control "device") is malfunctioning and/or undergoing

maintenance. As such, it 'is the Consent Decree alone that compels the flare destruction

efficiency requirement.

2-4
2.4.4 Other Air Quality Requirements .'

Since the facility is located on the Navajo Nation, it is the Navajo Nation, and not the state of

Utah that has the authority (aside from EPA) to implement air quality programs relevant to the

facility. Although the Navajo Nation has been granted delegated authority as of October 15,eJJ(~

2004, EPA is acting as an oversight reviewing agency assisting the Navajo Nation in/ /fl(

administering their approved program. 6/t.~

2.4.5 Title V Requirements

A Title V operating permit application must be submitted, as required by Paragraph 14.b of the

Consent Decree, no later than 180 days after the Consent Decree's effective date ofJune 8, 2005.

Similar to the requirements for the PSD permit application, the Title V operating permit

application must include terms and conditions at least as stringent as those in Paragraphs 9.a, 10,

11, and 25(i)-(ix) ofthe Consent Decree, with the exception that the quarterly report described at

Paragraph 25 may become a semiannual report.

2-5
3.0 MAIN FLARE EMISSIONS

3.1 CRITERIA POLLUTANTS

Table 3-1 presents a summary of criteria pollutant emission limits for the Main Flare as listed in

Paragraph 9.a of Exxon Mobil's Consent Decree. No changes to these emission limits are

proposed.

Table 3-1

Main Flare Criteria Pollutant Emission Limits'

Pollutant tons/year''

S02 60

CO 73

NOx 13.4

VOC 95.4

1. As listed 10 Paragraph 9.a ofConsent Decree (DOJ Case No. 90-5-

2-1-2237)

2. Cumulative 365-day rolling average.

3-1
4.0 BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS

The 1977 Clean Air Act Amendments established revised conditions for the approval of

preconstruction permit applications under the PSD Program. One of these requirements is that

Best Available Control Technology (BACT) be installed for all pollutants regulated under the

Act emitted in significant amounts from new major sources or modifications. BACT is defined

as an emission limitation based on the maximum degree of pollutant reduction determined on a

case-by-case basis considering technical, economic, energy, and environmental factors.

Additionally, a BACT limitation cannot be less stringent than emissions limits established by an

applicable New Source Performance Standard (NSPS). For!!J:~_s__~_p~cific case, a BACT analysis

wi~L be performed for voc,gQ?NOx, ._and S02 from the Main Flare as required.

ExxonMobil's Consent Decree (DOJ Case No. 90-5:'2-1-2237). Current and future operation of

the Main Flare will not otherwise trigger PSD review. The Main Flare is used to incinerate the

residual hydrocarbons and sulfur in the injection gas stream during times when injection is not

possible, thus, controlling VOC and H2S emissions.

EPA has specified use of a "top-down" approach to BACT determinations, in order to bring

consistency to the BACT process. The steps of a Top-Down BACT determination are:

1. Identify all available control options;

2. Evaluate and eliminate those options that are technically infeasible;

3. Rank remaining control alternatives by:control effectiveness;

4. Evaluate feasibility of each control option and combinations of control options on the

basis of energy, environmental and economic factors;

5. The most stringent control option orc?mbination of options found to be feasible on the

basis oftechnical, energy, environmental and economic factors is selected as BACT.

The first step, to determine all control options for the pollutant in question and emission unites)

under review, requires research to determine what available control options exist. The EPA

maintains a "RACT/BACT/LAER" clearinghouse of historical BACT determinations, known as

the "RBLC" database, which can be very us,~f41 ingathering an initial list of control options.

Other resources may be used as available to complete the 'list. Following a technical feasibility

assessment for all options, those found to be technically feasible are evaluated and ranked on the

4-1
basis of control effectiveness (encompassing percent removal, amount of emission reduction,

energy impacts, environmental impacts, and economic factors). When investigating each control

option in order of effectiveness, it is important to identify individual controls that can be

combined on the basis of technical feasibility. These combinations may result in control

alternatives that are more effective than the separate individual control options. As the final step,

the most effective control option or combination of options that has not been eliminated is

selected as BACT.

4.1 VOLATILE ORGANIC COMPOUNDS (VOCs)

The purpose of a flare system is to control process equipment operation through the safe and

effective disposal of gases and liquids. Flare systems are considered as an emission control

device for VOCs, since combustion through a flaring system prevents the release of

hydrocarbons to the atmosphere. When combustion is not complete, flares will emit voo in

the form of unburned hydrocarbons. The EPA addressed this issue through regulations ill: the

New Source Performance Standard's (NSPS) General Control Device Requirements at 40 CFR §

60.18 and in the Control Device Requirements for the National Emission Standards for

. Hazardous Air Pollutants (NESHAP) regulations at 40 CFR § 63.11. These requirements

establish specifications on visible emissions, continuous presence of a flame, exit velocities, fuel

heating value, and monitoring for flare systems applicable to any NSPS, 40 CFR Part 61

NESHAP, or 40 CFR Part 63 NESHAP, with the intent to ensure 98 percent control

(hydrocarbon destruction) efficiency for applicable flares. This objective was based on tests

confirming 98 percent control efficiencies for flares combusting organic emissions.

Additionally, flare manufacturers such as the John Zink Company LLC established that a

"properly designed and operated" flare burner will have a combustion efficiency ofmore than 98

percent. Flares not subject to an NSPS or NESHAPs are not required to meet these

specifications.

In order to achieve the visible emission requirements of 40 CFR§ 60.18 and 40 CFR § 63.11,

"smokeless" flare systems are designed with some type of external momentum force, such as

steam, air, water spray, natural gas, or a specialized high velocity vortex design. An external

momentum force provides for more complete combustion by improving the fuel flow

momentum, which allows a sufficient amount of combustion air to be educted into the

4-2
combustion zone just outside the flare burner. High-pressure flares (5 to 10 psig or more) might

not require a supplemental external momentum design in order to achieve smokeless

combustion. However, many flare systems require some type of supplemental assist in order to

achieve smokeless operation and 98 perc.ent control efficiency. Steam injection is common, as it

can add sufficient momentum and aid the chemistry of the combustion process. Low-pressure

air can be used as an assist medium in locations where steam, water, or gas is not readily

available or where cold temperatures present freezing issues. In this case, a blower is utilized to

inject approximately 15 to 50 percent of the stoichiometric air requirement into the flame,

providing adequate momentum to achieve smokeless and complete combustion. Air-assist

design is often used in remote locations. Gas-assist with natural gas can provide an additional

benefit by increasing the heating value to the fuel stream, in situations where the waste gas to be

combusted does not have a sufficient heating value for safe combustion. Available literature

suggests that each technology option for supplemental external momentum provides similar

additional control to VOC emissions from flare systems.

Table 4-1 presents a summary of recent BACT cl~terminati0!:"l:~Jrol11Jl1eEPA'sRBLC database

for flare VOC emissions. The table shows that seven ofthe twelve RBLC determinations did not

list any control technology for VOCs, although four ofthose seven determinations noted flares as

the control device for VOC emissions. Three ofthe entries which noted flares as a VOC control

device went on to state the flare would have 98% control efficiency, and one entry also stated the

flare would be designed and operated to meet 40 CFR§ 60.18 specifications. Four ofthe twelve

entries noted the use of "gas-assisted" smokeless flare systems as the VOC control technology.

. (Note that it is not clear in the RBLC if "gas-assisted" refers to the use of air or natural gasas the

source of external momentum.) One ofthe twelve determinations noted "good combustion

practices" as the control technology. For those seven determinations where no control

technology was specified, including those noting the flare system as the control device for

VOCs, it cannot be determined ifthose flare systems are designed and operated with any type of

supplemental external momentum technology such as steam, air, or gas-assist. It is logical to

conclude that some ofthese systems might have an "assisted" design, particularly in the case of

the refinery flares, ifthecompliance with the provisions of40 CFR § 60.18 or 40 CFR § 63.11 is

required.

4-3
Based on review of Table 4-1 and knowledge of controls used to reduce VOC emissions from

flare systems, the possible VOC control options for the Main Flare are:

• No control/good combustion practices;

• Meet requirements of40 CFR § 60.18 and/or 40 CFR § 63.11 for flare systems; and

• Supplemental external momentum design - steam, air, or gas-assist technology.

Some overlap exists between the second and third options, because as explained previously, the

visible emission requirements of 40 CFR § 60.18 and 40 CFR § 63.11 are frequently met by the

use of a supplemental external momentum design, such as steam, air, or gas technology.

Therefore, in some cases, compliance with the requirements of the NSPS or NESHAP control

device regulations can only occur by utilizing a supplemental external momentum design such as

,steam, air, or gas-assist technology.

Of the options listed above, steam-assisted technology is immediately determined to be

infeasible. The McElmo Creek Gas Plant is located in a remote area, where steam is not readily

available. Therefore, the only feasible supplemental external momentum designs are air and gasassist technologies.

The McElmo Creek Gas Plant's Main Flare has not been previously viewed as subject to the

requirements at 40 CFR § 60.18 or 40 CFR § 63.11, because its use was not specifically for

compliance with a provision of a NSPS or NESHAP. However, Paragraph 11(b) ofthe Consent

Decree with the EPA (DOl Case No. 90-5-2-1-2237) states that " ...[t]hereafter, Mobil shall

operate and maintain the Main Flare in compliance with 40 CFR § 60.18(c)(1), (c)(2), (c)(3)(ii),

(c)(5), (d), (e), (f)(1) through (f)(4), and (f)(6). Additionally, Paragraph II(b) of the Consent

Decree states that "Within three hundred sixty-five (365) days from the Effective Date, Mobil

shall install an automatic air-assisted flare system on the Main Flare, pursuant to the provisions

of 40 CFR §60.18(c)(5) and (£)(6). Therefore, Consent Decree conditions requiring compliance

with NSPS requirements (typical starting point for BACT), supplemented by one of the three

supplemental external momentum technologies, represents the most stringent BACT currently

implemented. On this basis, further analysis of employing a gas-assist technology rather than

air-assist is unnecessary, since there would be no additional environmental benefit from using

gas-assist. VOC BACT is proposed to be the combination of air-assist technology and

4-4
complying with the flare specifications ofthe General Control Device Requirements at 40 CFR §

60.18 as specified in the Consent Decree.

4.2 CARBON MONOXIDE (CO)

Carbon monoxide (CO) from flare systems is formed in the same manner as any combustion

process - through incomplete combustion. VOC emissions from flare systems also originate

from incomplete combustion. Therefore, control options to address CO emissions from flares

will be the same as those for VOC emissions.

Table 4-2 presents a summary of recent BACT determinations from the EPA's RBLC database

for flare CO emissions. Nine of the sixteen determinations do not cite a specific CO control

technology. It is uncertain how many of the flares represented by these determinations are

designed and operated with any type of supplemental external momentum technology such as

steam, air, or gas-assist technology; however, it is reasonable to conclude that some ofthe listed

flares, particularly those located at petroleum refineries, utilize an assist technology in order to

meet NSPS andNESHAP requirements. Four ofthe sixteen determinations note the use of "gasassist" smokeless technology (note that it is not clear in the RBLC if "gas-assisted" refers to the

use of air or natural gas as the source of external momentum). Two entries cite "proper

operation and maintenance," and one entry cites "good combustion practices" as the CO control

technology, with no further detail provided.

Based on review of Table 4-2, and typical flaresystem operations, BACT options for CO are

considered to be identical as those for VOc. 'Therefore, CO BACT is proposed to be the

combination of air-assist technology and the req-uirement to meet the flare specifications under

the General Control Device Requirements at 40 CFR § 60.18.

4.3 NITROGEN OXIDES (NOx)

There are three principal forms of NOxs design~~ed as "thermal" NOx, "prompt NOx," and "fuel"

NOx• Thermal NOx formation is the result of oxidationof atmospheric nitrogen contained in the

inlet gas in the high-temperature, post-flame r~giondfthecombustion zone. The major factors

influencing thermal NOx formation are temperature, concentrations ofnitrogen and oxygen in the

4-5
inlet air, and residence time within the combustion zone. Prompt NOx is formed through

relatively fast reaction between nitrogen, oxygen, and hydrocarbon radicals and is an important

mechanism in lower temperature combustion processes. Fuel NOx is formed by the oxidation of

fuel-bound nitrogen. It is not a concern for high-quality gaseous fuels such as natural gas or

propane, because these fuels normally have no organically-bound nitrogen. Fuel NOx is a

concern when burning oil, coal, or waste fuels.

Generally, several options exist to reduce NOx emissions from combustion processes, such as

pre-treating the fuel or switching fuels and/or oxidizers to prevent NOx formation, modifying the

combustion process or equipment to lower NOx formation, and post-treatment end-of-pipe

technologies to remove NOx • These options are listed below:

Pre-Treatment

• Fuel switching

• Fuel additives

• Oxidizer switching

Combustion Modification

• Air Preheat Reduction

• Burners Out-of-Service

• Low NOx burner

Post-Treatment

• SCR

• SNCR

Post-treatment, end-of-pipe options are not technically feasible for flare systems, due to the

inherent design of flaring and the fact that literally, no end-of-pipe exists after the combustion

zone. Combustion modification options have limited technical feasibility for flare systems, as

well. Reducing the amount of air preheat and taking burners out ofservice are options intended

for process heaters and boilers, where the combustion air is heated for more efficiency and where

multiple burners exist. Low NOx burners incorporate concepts such as lowering excess air, fuel

staging, and gas recirculation, which can be successfully implemented with process heaters and

boilers. However, flare burner design differs substantially from process heater and boiler burner

design, because the primary objective of flare burner design is to achieve safe and complete

combustion of unwanted hydrocarbons, sometimes in emergency situations, and often in

unpredictable volumes, flowrates, and temperatures. Essentially, the best 10w-NOx burner for a

flare is a well-designed one, properly sized and constructed for a specific flare's conditions.

Thus, the only technically feasible options for NOx control from the Main Flare fall within the

pre-treatment category; however, few options in this category are technically feasible.

4-6
Fuel additives, intended to change the chemistry of the combustion process, operate under

specific temperature conditions and stable operations, neither of which are possible with flare

systems. Oxidizer switching, where pure oxygen is used for combustion rather than air, is not

widely used in the hydrocarbon, petrochemical, and power generation industries due to the cost

and energy requirements of producing pure oxygen. Fuel switching from fuels with higher

fuel-bound nitrogen contents to those with lower fuel-bound nitrogen contents is a possible

option for reducing NOx from flare systems, but only in specific cases where the fuel to the flare

can be controlled and predicted.

Table 4-3 presents a summary of recent BACT determinations from the EPA's RBLC database

for flare NOx emissions. Eight of the twelve determinations do not cite a specific NOx control

technology. Two of the twelve determinations note "proper operation and maintenance" as the

control technology, one notes a limitation on fuel type (use ofnatural gas only) and one notes the

flare will be operated in accordance with 40 CFR § 60.18 General Control Device requirements.

Based on review of Table 4-3, and the previous discussion of possible NOx control technologies

for combustion processes, the list ofpossible NOx control options for the Main Flare are:

• No control/good combustion practices;

• Meet requirements of 40 CFR § 60.18 and/or 40 CFR § 63.11 for flare systems; and

• Fuel switching.

Of these options, fuel switching has been determined to be technically infeasible for the Main

Flare. Fuel is sent to the Main Flare through various pressure-reliefpiping or compressor bypass

piping, as a result of emergency or maintenance situations, and also continuously from the

dehydration reboiler. This fuel stream to the Main Flare cannot be switched without inherently

changing the compressor plant's purpose and design. Furthermore, the fuel to the Main Flare

consists of light hydrocarbons (methane, ethane, propane) and carbon dioxide, with very little

fuel-bound nitrogen content.

Given the fact that Exxon Mobil is required by its Consent Decree to "operate and maintain the

Main Flare in compliance with 40 CFR § 60.18(c)(I), (c)(2), (c)(3)(ii), (c)(5), (d), (e), (f)(I)

through (f)(4), and (f)(6)" following installation ofan air-assist technology, BACT for NOx is

proposed as meeting the General Control Device requirements of 40 CFR § 60.18 for flare

4-7
systems. Compliance with these requirements also guarantees that good combustion practices

are being followed.

4.4 SULFUR DIOXIDE (S02)

Sulfur dioxide emissions from flare systems depend on the amount of sulfur in the fuel stream.

Typically, sulfur dioxide from combustion processes can be controlled through limiting the fuel

type or sulfur content, or through end-of-pipe control technology. As discussed in section 4.3,

end-of-pipe control technologies are not feasible for flare systems. Therefore, the primary means

of controlling SOz emissions from flare systems is to limit the fuel type or sulfur content, where

possible.

Table 4-4 presents a summary of recent BACT determinations from the EPA's RBLC database

for flare SOz emissions. Ten of the sixteen determinations note some .type of fuel sulfur

limitation as the control technology. Five entries do not list any type of SOzcontrol technology,

and one entry contains a reference to continuous pilot ignition, flame monitors, and other

specifications that can be found in the 40 CFR § 60.18 flare requirements. Following this

review, the SOz control options for the Main Flare are determined to be:

• No control/good combustion practices;

• Limit fuel type; and

• Limit sulfur content.

Limiting the fuel type has been determined to be a technically infeasible option for the Main

Flare. As discussed in Section 4.3 for NOx, the fuel sent to the Main Flare is a combination of

the process gas which is compressed for re-injection and the vent stream from the dehydration

reboiler. This fuel stream cannot be switched to a different type without inherently changing the

compressor plant's purpose and design.

Additionally, limiting the fuel's sulfur content has been determined to be technically infeasible.

The compressor plant is designed and operated to compress gas and re-inject it into the field.

The gas directed to the compressor plant is not processed for sale or sold to outside customers.

Its average hydrogen sulfide (HzS) content is 400-500 ppm, with the maximum HzS content

4-8
potentially higher, depending on the quality of product from the field. Limiting the sulfur or

hydrogen sulfide content in the gas directed to the Main Flare could result in an inherent change

to the compressor plant's purpose and design, because the gas to the Main Flare is a combination

of process gas and dehydrator vent gas, and because the plant's design does not call for any .

sweetening process due to the factthat it is re-injected, and not sold.

The only remaining technically feasible option is no control/good combustion practices.

Therefore, BACT for 802 is proposed as good combustion practices, which will be achieved

through compliance with 40 CFR § 60.18 flare operational requirements.

4-9
Table 4-1.

BACT/LAER Clearinghouse Database Summary

Determinations 1995 - 2005

Industrial Flares (RBLC Report 8/4/05)

BACT Determinations for Flare VOC Emissions

Page 1 of8

Company Location Emission Throughput Pollutant Emission Limit Control Technology BACT, LAER, or Permit Date

Source (Size) Other

Exxon Mobil Kent County, 2 Flares Not provided VOC 42.82 Ib/hr, each None listed- BACT 1/31/2003

Salt Creek Gas Plant TX 156.31 tpy, Notes flare as VOC control

combined device,with 98% efficiency

Conoco, Inc. Kay County, I Flare 0.20 Ib/MMbtu- VOC O.l4lb/MMbtu Good combustion practice BACT 7/1/2002

Ponca City Refinery OK no further detail

provided

Valero Refining Co. Nueces County, Main Flare- Not provided VOC 2261b/hr None listed. Notes flare as VOC BACT 6/11/2002

Corpus Christi TX 2 groups of 39.6 tpy, and control device, with 98%

Refinery equipment 4,013 Ib/hr efficiency.

vents to flare 1,544 tpy Process notes indicate flare will be

designed & operated per 40 CFR §

(2 s~ts of limits) 60.18.

Duke Energy Field Webster Parish, I Flare,' Not provided VOC 2.821b/hr Nolie listed "other case by case" 1/24/2002

Services - Minden LA 8.73 tpy - this action was a

minor modification

only

Orion Refining Co. St. Charles 2 Flares ,60,700,000 Btu!hr, VOC 25.4 Ib/hr, each None listed. Notes flare as VOC BACT 1/10/2002

Parish, LA each 16.7 tpy, each control device, with 98% control

- efficiency.

Flint Hills Resources Nueces, TX Flares Not provided VOC 4,036.26 lb/hr None listed. "other case-by-case" 10/5/2001

LP 2,982.09 tpy,

West Refinery Both "initial" caps

Trifinery Petroleum Nueces, TX I Flare Not provided VOC 12.741b/hr None listed. Notes flare as VOC "other case-by-case" 8/7/2000

Service 55.79 tpy control device.

Trigeant Corpus

Christi

Citgo Refining & Nueces, TX I Flare (HI» 80,000 scf/day VOC None listed "Gas- Assist" smokeless "other case-by-case" 10/15/1999

Chemicals Co LP technology

Corpus Christi

Refinery - West

Plant

/
BACT/LAERClearinghouse Database Summary

Determinations 1995 - 2005

Industrial Flares (RBLC Report 8/4/05)

Page 2 of8

Company Location Emission Throughput Pollutant Emission Limit Control Technology BACT, LAER, or Permit Date

Source (Size) Other

Citgo Refining & Nueces, TX I Flare (LP) 20,000 scf/day NG VOC None listed "Gas- Assist" smokeless "other,case-by-case" 10/15/1999

Chemicals Co LP technology

430,000 scf/day

Corpus Christi produced gas

Refinery - West

Plant

BP Exploration Inc. AK I Flare (HP) 660,000,000 scfd VOC None Gas-assist smokeless flare "other case by case" 2/5/1999

Northstar technology

Development Facility

BP Exploration Inc. AK I Flare (LP) 18,022,000 scfd VOC None Gas-assist smokeless flare "other case by case" 2/5/1999

Northstar Natural and technology

Development Facility Produced

Gas

Mobil Exploration & Kent County, Process Not provided VOC 0.01 Ib/hr None listed "other case,by case" 10/13/1998

Producing US, Inc. TX Emergency 0.01 tpy

Salt CreekGas Plant Flare
BACT/LAER Clearinghouse Database Summary

Determinations 1995 - 2005

Industrial Flares (RBLC Report 8/4/05)

Page 3 of8

Table 4-2. BACT Determinations for Flare CO Emissions

Company' Location Emission Throughput Pollutant Emission Limit Control Technology BACTorLAER Permit Date

Source (Size) ..

Exxon Mobil Kent County, 2 Flares Not provided CO 37.2 lb/hr, each None listed BACT 113112003

Salt Creek Gas Plant TX 135.8 tpy, combined

Conoco, Inc. Kay County, I Flare 0.20 IbIMMbtu - CO 0.37lbIMMbtu Good combustion practice BACT 7/112002

Ponca City Refinery OK no further detail

provided

Valero Refining Co. Nueces County; Main Flare Not provided CO 4721b/hr None listed. BACT 6/1112002

Corpus Christi TX 90.5 tpy

Refinery

Duke Energy Field Webster Parish, I Flare Not provided CO 0.261b/hr None listed "other case by case" 1124/2002

Services - Minden LA 1.14 tpy - this action was a

minor modification

.only

Orion Refining Co. St. Charles 2 Flares 60,700,000 Btu/hr, CO 149 lb/hr, each None listed. BACT 1110/2002

Parish, LA each 98.3 tpy, each

Flint Hills Resources Nueces, TX Flares Not provided CO 901.5lb/hr None listed. "other case-by-case" 1015/2001

LP 2,657.98 tpy,

West Refinery Both "initial" caps

Trifinery Petroleum Nueces, TX I Flare Not provided CO 16.3 lb/hr None listed. "other case-by-ease" 81712000

Service 71.36 tpy

Trigeant Corpus

Christi

Tesoro Alaska Co AK I Flare 1,000,000 Btu!hr CO 0.04 IbIMMBtu None listed. "other case-by-ease" 3/2112000

Kenai Refinery

Tesoro Alaska Co AK I Flare (HP) 261,000,000 scfd CO 0.37 IbIMMBtu Proper Operation & Maintenance "other case-by-case" 3/2112000

Kenai Refinery -

Tesoro Alaska Co AK I Flare (LP) 212,000,000 scfd CO 0.371bIMMBtu Proper Operation & Maintenance "other case-by-ease" 3/2112000

Kenai Refinery

Citgo Refining & Nueces, TX I Flare (HP) 80,000 scfJday CO None listed "Gas- Assist" smokeless "other case-by-ease" 10/15/1999

Chemicals Co LP technology

Corpus Christi
BACT/LAER Clearinghouse Database Summary

Determinations 1995 - 2005

Industrial Flares (RBLC Report 8/4/05)

Page 4 of8

Company Location Emission Throughput Pollutant Emission Limit Control Technology BACT or LAER Permit Date

Source (Size)

Refinery - West

Plant

Citgo Refining & Nueces, TX I Flare (LP) 20,000 scf/day NG CO None listed "Gas- Assist" smokeless "other case-by-ease" 10/15/1999

Chemicals Co LP 430,000 scf/day technology ,

Corpus Christi produced gas

Refinery- West

Plant

BP Exploration Inc. AK 1 Flare (HP) 660,000,000 scfd CO None r Gas-assist smokeless flare "other case by case" 2/5/1999

.Northstar technology

Development Facility

BP Exploration Inc. AK I Flare (LP) 18,022,000 scfd CO None Gas-assist smokeless flare "other case by 'case" 2/5/1999

Northstar technology

Development Facility

Mobil Exploration & Kent County, 1 Flare Not provided CO 1.1 lb/hr None listed "other case by case" 10/13/1998

Producing US, Inc. TX 4.8 tpy

Salt Creek GasPlant

Equistar Chemicals, Nueces, TX 2 Flares Not provided CO 0.05 Ib/hr, each None listed. BACT 10/8/1998

LP 0.23 tpy, each
BACTILAER Clearinghouse Database Summary

Determinations 1995 - 2005

Industrial Flares (RBLC Report 8/4/05)

Page 5 of8

Table 4-3. BACT Determinations for Flare NOx Emissions

Company Location Emission Throughput Pollutant Emission Limit Control Technology BACT or LAER Permit Date

Source (Size)

Exxon Mobil Kent County, 2 Flares Not provided NOx 4.37 lb/hr, each None listed BACT 1/31/2003

Salt Creek Gas Plant TX 15.85 tpy, combined

Conoco, Inc. Kay County, I Flare 020 Ib/MMbtu - NOx 0.068 Ib/MMbtu Limit fuel to pipeline-grade natural BACT 7/1/2002

Ponca City Refinery OK no further detail gas

provided

Valero Refining Co. Nueces County, Main Flare Not provided NOx 75.8Ib/hr None listed. BACT 6/11/2002

Corpus Christi TX 18.8 tpy

Refinery

Orion Refining Co. St. Charles 2 Flares 60,700,000 Btu/hr, NOx 33.6Ib/hr, each None listed. BACT 1/10/2002

Parish, LA each 45.3 tpy, each

Flint Hills Resources Nueces, TX Flares Not provided NOx 1,409.8Ib/hr None listed. "other case-by-ease" 10/5/2001

LP 5,266.82 tpy,

West Refinery Both "initial" caps

Trifinery Petroleum Nueces, TX I Flare Not provided NOx 3.2Ib/hr None listed. "other case-by-ease" 81712000

Service 14.01 tpy

Trigeant Corpus

Christi

Tesoro Alaska Co AK I Flare 1,000,000 Btu/hr NOx 0.14 Ib/MMBtu None listed. N/A 3/21/2000

Kenai Refinery

Tesoro Alaska Co AK I Flare (HP) 261,000,000 scfd NOx 0.0681b/MMBtu Proper Operation & Maintenance "other case-by-ease" 3/21/2000

Kenai Refinery

Tesoro Alaska Co AK I Flare (LP) 212,000,000 scfd NOx 0.068 Ib/MMBtu Proper Operation & Maintenance "other case-by-ease" 3/21/2000

Kenai Refinery

Conoco, Inc. Calcasieu I Flare Not provided NOx 1.21b/hr Operate in accordance with BACT 12/22/1998

Lake Charles Parish, LA 5.0 tpy 40 CFR § 60.18 General Control

Refinery . Device Requirements

Mobil Exploration & Kent County, I Flare Not provided NOx 0.08Ib/hr None listed "other case by case" 10/13/1998

Producing US, Inc. TX 0.4 tpy

Salt Creek Gas Plant
BACT/LAER Clearinghouse Database Summary

Determinations 1995 2005

Industrial Flares (RBLC Report 8/4/05)

Page 60f8

Company Location Emission Throughput Pollutant Emission Limit Control Technology BACT or LAER Permit Date

Source (Size)

Equistar Chemicals, Nueces, IX 2 Flares Not provided NOx 0.01 lb/hr None listed. "other case-by-case" 10/8/1998

LP

0.04 tpy
BACT/LAER Clearinghouse Database Summary

Determinations 1995 - 2005

Industrial Flares (RBLC Report 8/4/05)

Page 7 of8

Table 4-4. BACT Determinations for Flare S02 Emissions

Company Location Emission Throughput Pollutant Emission Limit Control Technology BACT or LAER Permit Date

Source (Size)

Exxon Mobil Kent County, 2 Flares Not provided S02 50.48 Ib/hr, each None listed "other case by case" 1/31/2003

Salt Creek Gas Plant TX 184.24 tpy,

combined

Conoco, Inc. Kay County, I Flare 0.20 Ib/MMbtu- S02 0.0006 Ib/MMbtu Limit fuel to pipeline-grade natural BACT 7/1/2002

Ponca City Refinery OK no further detail gas

provided

Valero Refining Co. Nueces County, Main Flare Not provided S02 51.1lb/hr None listed. BACT 6/11/2002

Corpus Christi TX 12 tpy

Refinery

Orion Refining Co. St. Charles 2 Flares 60,700,000 Btu/hr, S02 133 Ib/hr, each None listed. BACT 1/10/2002

Parish, LA each 87.6 tpy, each

BP Exploration AK I Flare Max rate S02 500 ppm, 3-hr Bum fuel oil with no greater than SIP , 7/13/2001

(Alaska) Inc. 83,000,000 scfd average 0.3 wt"10 sulfur, and

Milne Point Nominal rate Bum natural gas with no greater

Production Facility 340,000 scfd than 100 ppmvd H2S

Flint Hills Resources Nueces, TX Flares Not provided S02 962.12 lb/hr None listed. BACT 10/5/2001

LP 118.76 tpy,

West Refinery Both ''initial'' caps

TrifineryPetroleum Nueces, TX I Flare Not provided S02 71.48 lb/hr Continuous ignition with two BACT 817/2000

Service 263.31 tpy pilots, UV fire-eye flame monitor,

Trigeant Corpus KO pot & sealdruml; 98% control

Christi efficiency

Tesoro Alaska Co AK 1 Flare 1,000,000 Btu/hr S02 500 ppm, 3-hr Fuel sulfur content limits: BACT 3/21/2000

Kenai Refinery average 0.35% sulfur in diesel,

0.01% sulfur in natural gas,

0.01% sulfur in LPG, and

168 ppmv H2S in refinery gas
BACT/LAER Clearinghouse Database Summary

Determinations 1995 - 2005

Industrial Flares (RBLC Report 8/4/05)

Page 8 of8

Company Location Emission Throughput Pollutant Emission Limit Control Technology BACT or LAER Permit Date

Source (Size)

Tesoro Alaska Co AK I Flare (HP) 261,000,000 scfd S02 None listed Fuel sulfur content limits: BACT 3/21/2000

Kenai Refinery 0.15% sulfur in distillate, and

200 ppm HZS in fuel gas

Tesoro Alaska Co AK 1 Flare (LP) 212,000,000 scfd S02 None listed Fuel sulfur content limits: "other case-by-ease" 3/21/2000

Kenai Refinery 0.15% sulfur in distillate, and

200 ppm HZS in fuel gas

Citgo Refining & Nueces, TX 1 Flare (HP) 80,000 scf/day S02 500 ppm, 3-hr H2Scontent limited to 50 ppmv "other case-by-ease" 10/15/1999

Chemicals Co LP average

Corpus Christi

Refinery - West

Plant

Citgo Refining & Nueces, TX 1 Flare (LP) 20,000 scf/day NG S02 500 ppm, 3-hr Fuel sulfur content limits: "other case-by-ease" 10/15/1999

Chemicals Co LP - 430,000 scf/day average 0.15% sulfur in fuel oil, and

Corpus Christi produced gas 50 ppmv HZS in fuel gas I

Refinery - West

Plant

BP Exploration Inc. AK 1 Flare (HP) 660,000,000 scfd S02 500 ppm, 3-hr H2Scontent of the fuel shall not "other case by case" 2/5/1999

Northstar average exceed 50 ppmv

Development Facility

BP Exploration Inc. AK 1 Flare (LP) 18,022,000 scfd S02 500 ppm, 3-hr H2Scontent ofthe fuel shall not "other case by case" 2/5/1999

Northstar average exceed 50 ppmvrn, and

Development Facility Sulfur content offuel oil shall not

exceed 0.15 wt%

Conoco, Inc. Calcasieu 1 Flare Not provided S02 0.3 Ib/hr None listed "other case-by-ease" 12/22/1998

Lake Charles Parish, LA 1.1 tpy

Refinery

Mobil Exploration & Kent County, 1 Flare Not provided S02 39.741b/hr None listed "other case by case" 10/13/1998

Producing US, Inc. TX 174.1 tpy Fuel limited to pipeline quality

Salt Creek Gas Plant sweet natural gas with no more

than 5 grains sulfur/dscf
5.0 EXISTING ENVIRONMENT

5.1 TOPOGRAPHY

The McElmo Creek Oil Production Facility is located on Navajo Nation land in southeastern

Utah, in San Juan County, near the town of Aneth. The gas compression plant is located

approximately 23 km (14 miles) northwest of theNMt.ah / Colorado border@d4.8km(3miles)

! \J5LH ..;( ill y.:> ~-Ul

north of State Highway 262. Arches National Park and Canyonlands National Park are located ~._---... - . /-

to the northwest, approximately 160 km (100 miles) and 9~_!an (60 miles), respectively. !'1esa -----._---... ---, Verde National Park is located approximately 60 km (38 miles) east of the gas plant site. The ...-----_._--_...._-----_....,. . .

western boundary of the C~)'()l1_of the Ancients National Monument is approximately Ijikm

(10 miles) northwest ofthe plant site.

Elevations around the gas compression plant range from 5,500 feet to 5,900 feet. Terrain

generally increases in both the north and south directions from the east-west valley formed by

the San Juan River. Ground cover is relatively sparse because of the semiarid climatic

conditions surrounding the gas plantsite.

5.2 AIR QUALITY

Background air quality monitoring data for 1999-2003 are presented in Table 5-1 for ozone (03) ,

nitrogen dioxide (N02), carbon monoxide (CO), and sulfur dioxide (S02)' Ozone concentrations

are cited as surrogate for VOC impacts because VOCs do not have an ambient air quality

standard; rather, VOC is considered a contributor to the formation ofOJ.

No site or area-specific data was available for southeastern Utah for N02, CO, S02 and 0 3;

therefore, air quality data gathered from monitoring stations located in north central Utah,

primarily within the Salt Lake City metropolitan area, are used as conservative indicators of air

quality for this rural area of Utah. Background PMIO concentrations are not addressed since

PM10 emissions are insignificant from a flare, and the Consent Decree does not cite emission

limits for PMlO•

5-1

P

<: V .-' ( 0D
Table 5-1.

Air Quality in the McElmo Creek Area.

Pollutant Monitor Maximum Annual Mean NAAQS

Location/County! Year Averaging Period PpmlILg/mJ ppm/ ILg/mJ ppm

fl1!/m J

Spanish ForklUtah 1999 8 hour 0.102/200

Spanish ForklUtah 2000 8 hour 0.100/196 0.08 2

Ozone (03) Spanish ForklUtah 2001 8 hour 0.081/159 157 Spanish ForklUtah 2002 8 hour 0.081/159

Spanish ForklUtah 2003 8 hour 0.080/157

North ProvolUtah 1999 Annual 0.024/45

Nitrogen Dioxide North ProvolUtah 2000 Annual 0.024/45 0.053 North ProvolUtah 2001 Annual 0.024/45 (N02) North ProvolUtah 2002 Annual 0.Q25/47 100

North ProvolUtah 2003 Annual 0.022/41

North ProvolUtah 1999 8 hours 5/5,726

Carbon Monoxide North ProvolUtah 2000 8 hours 4/4,581 35

(CO) North ProvolUtah 2001 8 hours 4/4,581 40,000 North ProvolUtah 2002 8 hours 4/4,581

North ProvolUtah 2003 8 hours 3/3,436

North Salt Lake/Salt Lake 1999 3 hours 0.033/86 No data

Sulfur Dioxide North Salt 'Lake/Salt Lake 2000 3 hours 0.042/110 No data 0.50

(S02) North Salt Lake/Salt Lake 2001 3 hours 0.041/107 No data 1,300 North Salt Lake/Salt Lake 2002 3 hours 0.052/136 No data

North Salt Lake/Salt Lake 2003 3 hours 0.036/94 No data

North Salt Lake/Salt Lake 1999 24 hours 0.012/31 No data

North Salt Lake/Salt Lake 2000 ~4 hours 0.014/37 No data 0.14 North Salt Lake/Salt Lake 2001 24 hours 0.013/34 No data

North Salt Lake/Salt Lake 2002 .. 24 hours 0.010/26 No data 365

North Salt Lake/Salt Lake 2003 24 hours 0.015/39 No data

1. No site-specific data IS available. These momtonng locations provide the closest available data.

2. To attain this standard, the 3-year average ofthe fourth-highest daily maximum 8-hour average ozone concentrations

measured at each monitor within an area over each year must not exceed 0.08 ppm.

This table shows that with the exception ofozone, all pollutants are well below the National

Ambient Air Quality Standards (NAAQS). Note that compliance with the 8-hour ozone NAAQS

is based on the 3-year average of the 4th highest daily maximum value; Table 5-1 presents only

the 1st highest ozone value for each year and cannot directly be compared to the 8-hour ozone

standard. However, these concentrations represent maximum worst-case background conditions

as an indicator of potential compliance with the ozone NAAQS.

5.3 AREA CLIMATE AND METEOROLOGY

The southeastern area of the state, where the McElmo Creek facility is located, can be

characterized as an area of low precipitation, high summer temperatures, and moderate winter

temperatures. Meteorological monitoring has.not been conducted onsite at the McElmo Creek

5-2
facility. The nearest meteorological monitoring station with available data is located by

International Uranium Corporation's White Mesa Mill near Blanding, Utah. This data can be

considered as representative of the southeastern Utah area. The annual 2004 wind frequency

distribution is presented in Table 5-2, and graphically as a wind rose in Figure 5-1. The average

wind speed for 2004 was 3.4 meters/second (m/s), or 7.6 miles per hour (mph). Thepredominant

wind directions were from the north-northeast (15.5%), from the north(11%), and from the

south-southwest (10.8%). Annual atmospheric stability distribution for 2004 is in Table 5-3.

Table 5-3. Annual Stability Class Distribution at Blanding, Utah.

Stability Class Percent of Occurrence (%)

A 15.2

B 10.1

C '" 12.2

D , 36.0

E 13.2

F 13.3

Temperature and precipitation conditions in vicinity ofthe gas plant are depicted by a long-term

, climatic monthly summary (12/8/1904 - 3/31/2005) of data from Blanding, Utah in Table 5-4.

Table 5-4. Monthly Average Temperature and Total Precipitation at Blanding, Utah.

Month Avg. Temp, Avg. Temp. Avg. Temp. Precipitation Total

Max. ('F) Min. ('F) Mean ('F)' (inches)

January 39.1 ,

" 17.1 28.1 1.39 :

February 44.8 : 22.3 33.6 1.23

March 52.7, : 27.8 40.3 1.04

April 62.2 ' 34.3 49.3 0.87

May 72.2 42.0 57.1 0.71 , ,

June 83.3 " , 50.7 67.0 0.45

July 88.6 > 57.8 " 72.2 1.15

August 86.2 .;,.' 56.1 71.1 1.39

September 78.2 48..3 63.3 1.28

October 66.0 .37.9 51.9 1.45

November 51.4 .} 26.6 41.0 1.06

December 41.1 19;1 ' 30.1 1.35

Annual Avg. Temp./Annual Total Precip. 63.8 36.7 50.3 13.35

5-3
Table 5-2

10 METER WIND DATA ANALYSIS

FROM 1/ 1/2004 THROUGH 12/31/2004

INTERNATIONAL URANIUM METEOROLOGICAL STATION

FREQUENCY OF OCCURRENCE OF WIND SPEED BY DIRECTION

+----------WIND SPEED CLASSES (M/S)----------+

AVERAGE

0.0- 1. 8- 3.3- 5.4 8.4 > WIND

DIR 1.8 3.3 5.4 8.4 11.0 11.0 TOTAL SPEED

-------------------------------------------------------------------------

N .0141 .0514 .0388 .0052 .000-4 .0000 0.110 3.2

NNE .0216 .0895 .0360 .0028 .0012 .0001 0.151 2.,9

NE .0231 .0370 .0098 .0018 .0005 .0000 0.072 2.5

ENE .0124 .0121 .0043 .0013 .0000 .0000 0.030 2.4

E .0082 .0072 .0031 .0008 .0000 .0000 0.019 2.5

ESE .0085 .0091 .0024 .0012 .0000 .0000 0.021 2.4

SE .0097 .0186 .0095 .0028 .0002 .0000 0.041 3.4

SSE .0108 .0242 .0112 .0018 .0006 .0000 0.049 2.9

S .0100 .0375 .0254 .0079 .0014 .0000 0.082 3.5

SSW .0073 .0352 .0376 .0199 .0057 .0020 0.108 4.4

SW .0073 .0227 .0197 .0170 .0026 .0011 0.070 4.3-

WSW .0054 .0134 .0109 .0105 .0020 .0001 0.042 4.3

W .0064 .0109 .0098 .0082 .0004 .0004 0.036 3.9

WNW .0071 .0117 .0078 .0033 .0000 .0000 0.030 3.2

NW .0087 .0179 .0162 .0095 .0017 .0000 0.054 3.9

NNW .0110 .0218 .0322 .0164 .0026 .0002 0.084 4.1

--'-----------------------------------------------------------------------

TOT: 0.172 0.420 0.275 0.110 0.019 0.004 1. 000

AVG: 1.4 2.6 4.2 6.7 9.4 12.0 3.4

TOTAL NUMBER OF VALID READINGS FOR THIS TABLE => - 8456

OUT OF 8456 TOTAL VALID HOURS

TOTAL NUMBER OF MISSING HOURS => 328

TOTAL NUMBER OF CALM HOURS => 41
White Mesa Mill - Blanding; Utah

---; NORTH ---- _ I

I

I __ _ _ 1 _

I

·1

I

I

I

_----1--.---

Wind Speed

Direction (blowing from)

, , ,

-,,

WIND SPEED

(m/s)

I

I

I

I

- - -1- --

I

I

I

I

- - - ---I-I

I

I

:SOUTH ---- L --

•

•

•

•

o

•

>= 11.1

8.8 -11.1

5.7 - 8.8

3.6 - 5.7

2.1 - 3.6

0.5- 2.1

COMMENTS: DATA PERIOD: COMPANY:

Calms: 0.15%

International Uranium Corporation

WRPLOT View - Lakes Environmental Software

2004

Jan 1 - Dec 31

00:00 - 23:00

CALM WINDS:

0.15%

AVG. WIND SPEED:

3.43 m/s

PREPARED BY:

McVehil-Monnett

Associates

TOTAL COUNT:

8456 hrs.

DATE:

1/19/2005

FIGURE 5-1

PROJECT NO.:

1721-03
5.4 SOILS AND VEGETATION

Soils within this area of Utah have textural, depth, and drainage characteristics that limit the

amount of water the soils can hold and make available for plant growth. Vegetation in the

vicinity of the project area is sparse, predominantly sagebrush with scattered grasses and forbs.

No listed threatened or endangered plant species are known to occur within the project area.

5-4
6.0 IMPACT ASSESSMENT APPROACH

This section presents the methodology used to evaluate the potential ambient air quality impacts

resulting from the operation of the Main Flare. These analyses are compared against the

National Ambient Air Quality Standards (NAAQ~) and PSD increments presented in Table 6-1.

TABLE 6-1

SUMMARY OF NATIONAL AMBIENT AIRJQUALITY

STANDARDSANDPSDINCREMENTS

NAAQS Class II PSD

Averaging Primary Increment J

Pollutant Time ' ug/m" (ppm) ug/m" (ppm)

Carbon Monoxide l-hour" 40,600 (35) -- ,

8-houra 10,000 (9) --

Nitrogen Dioxide Annual (arith, mean) 100 (0.05) 25 (0.013)

Ozone 8-Hour b (0.08) --

Particulates (PM10) 24-houra 150(--) 30 (--)

Annual (arith. mean) 50 (--) 17 (--)

Sulfur Dioxide 3-houra ,'J 1,300 (0.50) 512 (0.20) ,<.

24-hour a i 365 (0.14) 91 (0.035)

Annual (arith. mean) , 80 (0.03) 20 (0.008)

Lead Calendar Quarter (arith. mean) 1.5(--) --

a. Not to be exceeded more than once per year. " .

b. The 3-year average ofthe 4th highest daily maximum concentrations must not exceed this standard. -, ij

J -i'

6-1
6.1 AIR QUALITY MODEL DESCRIPTION

SCREEN3 is an EPA-approved screening model for estimating near-field impacts from a single

emission source or group of emission sources that can be characterized from one location.

SCREEN3 utilizes Gaussian dispersion to estimate concentrations within a plume, with

maximum impacts estimated at the plume centerline. Version 96043 of SCREEN3 was used for

this application.

SCREEN3 transport is assumed to instantaneously occur at specified receptor distances from the

source with specific dispersion dependent upon the atmospheric stability class, using Pasquill

stability categories and wind speed. The intended use of SCREEN3 is for short-term averaging

periods on the order of one hour or less. However, estimated maximum short-term impacts can

be extrapolated to longer averaging periods by adjustment factors referenced from the

"Screening Procedures for Estimating the Air Quality Impact of Stationary Sources" (EPA,

1992). These factors are intended to account for long-term wind direction meander as

summarized below:

Averaging Time

3 hours

8 hours

24 hours

Annual

Multiplying Factor

0.9

0.7

0.4

0.08

The SCREEN3 model is most suitable for estimating concentrations for distances greater than

100 meters from the source and for source plume heights less than 300 meters. In addition,

SCREEN3 internally examines a full range of meteorological conditions, representative of

possibly occurring stability class and wind speed combinations to find maximum impacts.

The SCREEN3,model also simulates the effects of buoyancy-induced dispersion (BID). The

inclusion ofBID in SCREEN3 can affect estimated concentrations, depending on the source and

distance. For sources with plume heights below 300 meters, the effect of BID on estimated

maximum concentrations will usually be less than about ± 10 percent. For elevated sources with

relatively large buoyancy, the inclusion of BID may be expected to decrease the estimated

maximum concentration by as much as 25 percent.

6-2
6.2 MODEL INPUT

The Main Flare is a point (stack) source that routinely operates in the stand-by mode as reflected

in the annual emissions presented as limits in Section 3. For modeling purposes, particularly for

comparison to short-term standards and PSD increments, the worst-case impacts from the Main

Flare would be during an upset episode when all process gas is sent to the flare, rather than reinjected into the ground. Thus, modeled flare stack) parameters were based on using the

buoyancy flux algorithm in SCREEN3. This algorithm estimates an effective stack diameter at

an assumed stack velocity of 20 mls at the estimated heat release (in calories per second) ofthe

flare when combusting all process gas that would otherwise be re-injected.

Modeling was performed to estimate impacts of N02, CO and S02 only, since PM IO emissions

are insignificant and VOCs are not modeled directly except as a precursor to ozone. The annual

emission limit for VOCs (95.4 tons per year) is below the 100 ton per year criterion typically

cited as that level requiring ozone modeling.

Refer to Section 6.4 for additional information about source characteristics and emission rates

used in the model input.

6.3 METEOROLOGICAL DATA

The selection of an appropriate meteorological data set for air quality modeling is based on

proximity to the project site, similarity of topography and conformity of the data collection and

reporting procedures to PSD monitoring requirements. Another consideration is that the

meteorological data can be readily processed into a format compatible for use in air dispersion

modeling.

For this screening model application, the full array of 44 discrete meteorological conditions

internally generated by SCREEN3was used to estimate potential worst-case short-term (i.e.,

one-hour averaged) impacts for each modeled pollutant. The maximum impact cited by

SCREEN3 from a specific discrete meteorological condition (wind speed, stability class and

mixing height combination) and receptor distance was used as the basis for estimating maximum

pollutant impacts. The maximum one-hour impact for each pollutant was extrapolated to values

6-3
for each averaging period for which a pollutant has an applicable NAAQS and PSD increment,

using the adjustment factors referenced in Section 6.1.

6.4 SOURCE CHARACTERISTICS AND EMISSION RATES

6.4.1 Flare Rate and Heat Release

Short-term pollutant emission rates were estimated by assuming that the maximum volume of

process gas that could be generated from the well field would be sent to the flare at two different

heat content values (in BTU/SCF). These two heat content values represent lower and upper

range estimates. The lowest value input was 300 BTU/scf, which is the lowest allowable LHV

as stated in 40 CFR 60.18(c)(3)(ii). The higher value utilized was 443 BTU/scf, which is the

lowest of four recent actual plant gas samples from McElmo. (The four analyses are dated

4/28/04, 5/27/04, 8/29/04, and 9/29/04; and their LHV values were 443, 505, 512, and 453

BTU/scf, respectively.) The LHV of 443 BTU/scf was utilized due to the assumption that it

would provide the least amount ofheat rise, thus producing the lowest effective release height.

The maximum flare rate utilized was 689,423 acflhr (618,104 scflhr), which assumes that the

flare is operating at 14.83 MCFD for the entire year. The flare rate value of618,104 scflhr was

based on the assumption that the new flare tip will be 24 inches in diameter and will have a flare

tip exit velocity of 64.74 ft/s. This exit velocity is below the maximum exit velocity as specified

by 40 CFR 60.18, which is 66.98 ft/s.

The heat released from the flare tip was then calculated and converted to a rate of calories per

second based on the conversion of 1 BTU = 252.1644 calories. The equation used for this

calculation is as follows:

. heat(cal / 8) = (LHV)(V)(252.1644cal)

36008

Where:

LHV = lower heating value of gas burned (BTU/set)

V = 618,104 scflhr.

6-4
6.4.2 Flare Height

The actual flare stack height of 195 feet was taken from drawing D-SA-107 as provided by

Zeeco, Inc. from 1991. This measurement was fieldverified to ensure proper stack height.

6.4.3 Modeled Emission Rates

The emission factors for NOx and CO were derived by the Chemical Section ofthe Texas

Commission on Environmental Quality NSRDivi~ion based on data published in the 1983

Chemical Manufacturer's Association document.entitled "A Report On A Flare Efficiency

Study." The factors used were as follows:

NOx = 0.0641 lb/MMBTU

CO = 0.5496 lb/MMBTU.

Therefore, the equation used to calculate the emission rate for NOx and CO contaminants at the

specified LHV is as follows:

rate( / s) =V scf*LHV BTU * MMBTU *EF lb * 453.59g * hr

g . hr scf 106 BTU MMBTU lb 3600s

Where:

v = 618,104 scf/hr

LHV = lower heating value of gas burned (BTU/set)

EF = emission factor (lb/MMBTU);. .

.. ,

Regarding the SOz emission calculation, recenttests at the McElmo site indicate the plant inlet

gas contains approximately 500 ppm HzS. Howeeer, it was assumed that the flared gas contains

700 ppm HzS on the SCREEN3 SOz dispersion model, This HzS value was used in order to

provide a conservative estimate of SOz emissions from: theflare. The emission rate was

calculated as follows:

6-5
rate = 6l8,104scf / hr *700ppm *64tb/ molS02 =73.06lbS02/ hr

379scf / mol*lMMparts

In summary, the stack parameters and estimated emission rates for the Main Flare at the two

representative heat content values during upset conditions are summarized below in Table 6-2.

Table 6-2

SCREEN3 Modeled Stack Parameters and Emissions for the Main Flare

(Maximum Volumetric Process Gas Flow of 618.104 SCF/hr)

Heat Total Heat Stack Effective Stack Short-Term Short-Term Short-Term

Content Release Height Release Velocity NOx Emission S02 Emission CO Emission

(BTU/SCF) (callsec) (m.) Height (m.) (m/s) Rate (gm/sec) Rate (gm/sec) Rate (gm/sec)

300 12,988,700 59.45 70.9117 20.0 1.50 9.21 12.84

443 19,179,900 59.45 73.2591 20.0 2.21 9.21 18.96

6.5 RECEPTOR SELECTION

Receptor points were generated using the automated grid option of SCREEN3, starting at 200

meter from the Main Flare and extending out to 4,000 meters. Since the flare is a highly buoyant

source with a stack height ofnearly 60 meters, in-close impacts would be minimal and maximum

ground-level impacts would likely be located at least one or more kilometers away from the

stack. Receptors were placed at 100 meter intervals from 200 to 3,000 meters and at 500 meter

intervals from 3,000 to 4,000 meters.

Since terrain within 5 kilometers of the Main Flare is relatively flat, SCREEN3 was run in the

simple terrain mode and all receptor elevations were assumed to be at the elevation of the Main

Flare stack base.

6-6
7.0 AIR QUALITY IMPACTS

This section presents modeled air quality impacts of the Main Flare facility to demonstrate

compliance with the National Ambient Air Quality Standards (NAAQS) and Prevention of

Significant Deterioration Increments for Class II Areas. Air quality impacts are presented from

the Main Flare alone and combined with representative ambient air background concentrations

for an assessment of cumulative impacts.

As discussed in the previous section, in order to conservatively calculate emission rates from the

"Main Flare for use in this modeling analysis, several assumptions were made. Many ofthese

assumptions were made with the intent ofproviding conservative estimates including:

1. The lowest heat value rating for the gas at McElmo to lower the effective release height

ofthe emissions produced by the McElmo Main Flare;

2. The maximum design flare rate of 14.83 MCPD; and

3. The HzS concentration of700 ppm instead ofthe actual measured value of approximately

450 ppm.

Emission limitations established by the Consent Decree for the Main Flare are 60 tons per year

of SOz, 73 tons per year of CO, 13.4 tons per year of NOx, and 94.5 tons per year of VOc.

However, the worst-case conditions based on the modeled maximum flare rate of 14.83 MCFD

and LHV of 443 BTU/scfresult in emissions of 320.00 tons per year of SOz, 659.1 tons per year

of CO, and 76.8 tons per year of NOx. These very conservative worst-case conditions result in

emission rates in the analysis that are over five times greater than current air permit limits. In

addition, the actual field conditions are not capable of sustaining a flow rate of 14.83 MCFD.

The remainder of this section will show that even with these worst-case emission estimates that

far exceed the current air permit limits and actual flow rate conditions, the modeling results show

no exceedances ofthe NAAQS or the PSD Class II Increments.

Hard copies of the SCREEN3 model run input and output are contained in Appendix B. Model

runs for estimated NOz, CO and SOz impacts for process gas with a heat content of either 300 or

443 BTU/SCF were generated.

7-1
7.1 NITROGEN DIOXIDE (NOz)

The Main Flare was modeled at the heat content scenarios of 300 and 443 BTU/SCF. The

modeled impact concentrations from SCREENJ were multiplied by a factor 0.75, the default

ozone limiting factor, and the annual averaging period adjustment factor of 0.08. The ozone

limiting factor takes into account the conversion of NO (the majority of a NOx release) to N02

by reacting with ozone, assuming that approximately 75% is converted as a long-term average.

A maximum background annual averaged N02 concentration from Table 5-1 of47 p,g/m3 is cited

as the value to add to the maximum modeled annual N02 impact to obtain an estimate of

cumulative impacts for comparison to the N02 NAAQS.

7.1.1 Increment Consumption

Table 7-1 summarizes estimation of the maximum annual averaged N02 impact from the Main

Flare, with a heat content of either 300 or 443 BTU/SCF. The resultant values from the Main

Flare are compared to the annual N02PSD Class II Increment.

Table 7-1

Comparison of Modeled Main Flare NOz Impacts to the PSD Increment --

Max. Modeled Max. Adjusted

Heat One-Hour Modeled PSD Class II Percent of

Content Concentration Averaging Adjustment Concentration Increment Increment

(BTU/SCF) (ug/rrr') Period Factora" (ug/rrr') (ug/rrr') (%)

300 1.893 Annual 0.06 0.11 25 0.44%

443 2.148 Annual 0.06 0.13 25 0.52%

a. Combination of ozone limiting adjustment factor' of 0.75 and the annual averaging period adjustment factor of 0.08. I

(0.75 x 0.08 = 0.06)

The predicted maximum annual averaged concentration from the Main Flare is 0.13 p,g/m3

located 1,075 meters from the flare stack. This maximum concentration is approximately only

0.52% of the PSD Class II increment of 25 p,g/m3

. In addition, the maximum annual

concentration is only 13% ofthe Class II significant impact level (SIL) of I" p,g/m3

.

7-2
7.1.2 National Ambient Air Quality Standards (NAAQS)

Table 7-2 provides a comparison of the estimated cumulative maximum annual averaged N02

impact from the Main Flare, with a heat content of either 300 or 443 BTU/SCF, to the annual

N02NAAQS. The modeled results are added to 'the cited background concentration to arrive at

the estimated cumulative concentration, and the total value is compared to the annual N02

NAAQS.

Table 7-2.

Comparison of Modeled Cumulative N02 Impacts to the NAAQS

Max. Modeled Max. Adjusted Monitored Maximum National

Heat One-Hour Modeled Background Cumulative Ambient Air Percent of

Content Concentration Averaging Adjustment Concentration Concentration Concentration Quality Std. NAAQS

(BTU/SCF) (ug/m') Period Factor CuWm3

) .: (ug'/m3

) (ua/m') (uz/rrr') (%)

300 1.893 Annual 0.06 0~11 47.00 47.11 100 47.11%

443 2.148 Annual 0.06 0.t'3 47.00 47.13 100 47.13%

The predicted maximum annual averaged concentration from the Main Flare is 0.13 p,glm3

located 1,075 meters from the flare stack. This maximum concentration, added to the

background concentration of 47 p,glm3, results In a cumulative concentration which is

approximately 47.13% ofthe NAAQS.

7.2 SULFUR DIOXIDE (S02)

The Main Flare was modeled at the heat content scenarios of 300 and 443 BTU/SCF. The " ~;

modeled impact concentrations from SCREENJ were multiplied by the 3-hour, 24-hour and

annual averaging period adjustment factors ofQ.90; 0040 and 0.08, respectively. Maximum

background 3-hour, 24-hour and annual averaged,'SOi concentration from Table 5.... 1 of 136, 39 if .

and 39 !-tglm3 are cited as the values to add to the rhaximum modeled S02 impacts from the Main

Flare to obtain an estimate of cumulative impacts for comparison to the S02 NAAQS. Note that

. the cited 24-hour background concentration has beenassumed to also represent the annual

background concentration since no specific annual averaged monitoring data were available.

7-3
7.2.1 Increment Consumption

Table 7-3 .summarizes estimation of the maximum 3-hour, 24-hour and annual averaged S02

impacts from the Main Flare, with a heat content of either 300 or 443 BTU/SCF. The resultant

maximum values from the Main Flare are compared to the S02 PSD Class II Increments..

Table 7-3

Comparison of Modeled Main Flare S02 Impacts to the PSD Increment

Max.Modeled Max.Adjusted

Heat One-Hour Modeled PSD Class II Percent of

Content Concentration Averaging Adjustment Concentration Increment Increment

(BTU/SCF) (ug/rrr') Period Factor (ug/nr') (ug/rrr') (%)

300 11.63 3-hour 0.90 10.47 512 2.04%

443 8.951 3-hour 0.90 8.06 512 1.57%

300 24-hour 0..40 4.65 91 5.11%

443 24-hour 0.40 3.58 91 3.93%

300 Annual 0.08 0.93 20 4.65%

443 Annual 0.08 0.72 20 3.60%

The predicted maximum 3-hour, 24-hour and annual averaged concentrations from the Main

Flare are 10.47, 4.65 and 0.93 p,g/m3

, respectively, located 1,097 meters from the flare stack.

These maximum concentrations are approximately only 2.04%, 5.11% and 4.65% of the PSD

Class II increments of 512, 91 and 20 p,g/m3.for the 3-hour, 24-hour and annual averaging

periods, respectively. In addition, the maximum 3-hour, 24-hour and annual concentrations are

less than the Class II SILs of 25, 5 and 1 p,g/m3

, respectively.

7-4
7.2.2 National Ambient Air Quality Standards (NAAQS)

Table 7-4 provides a comparison of the estimated cumulative maximum 3-hour, 24-hour and

annual averaged S02 impacts from the Main Flare, with a heat content of either 300 or 443

BTU/SCF, to the corresponding S02 NAAQS. The modeled results are added to the cited

background concentrations to arrive at the estimated cumulative concentration for each

averaging time, and the total value is compared to the 3-hour, 24-hour and annual S02 NAAQS.

Table 7-4.

Comparison of Modeled Cumulative S02 Impacts to the NAAQS

Max.Modeled Max. Adjusted Monitored Maximum National

Heat One-Hour Modeled Background Cumulative AmbientAir Percent of

Content Concentration Averaging Adjustment Concentration Concentration Concentration Quality Std. NAAQS

(BTU/SCF) (uz/rrr') Period Factor (ug/rrr') (ug/rrr') (ug/nr') (ug/nr') (%)

300 11.63 3-hour 0:90 10.47 136 146.47 1300 11.27%

443 8.951 3-hour 0.90 8.06 136 144.06 1300 11.08%

300 24-hour OAO 4.65 39 43.65 365 11.96%

443 24-hour 0.40 3.58 39 42.58 365 11.67%

300 Annual 0.08 0.93 39 39.93 80 49.91%

443 Annual 0.08 0.72 39 39.72 80 49.65%

The predicted maximum 3-hour, 24-hour and annual averaged concentrations from the Main

Flare are 10.47, 4.65 and 0.93 /lglm3

, respectively, located 1,097 meters from the flare stack.

These maximum concentrations added to the background concentrations of 136, 39 and 39 /lglm3

result in cumulative concentrations of 11% to 12% ofthe 3-hour and 24.-hour averaged NAAQS

of 1300 and 365 /lglm3

, respectively, and less.than 50% of the annual averaged NAAQS of 80

/lglm3

•

7.3 CARBON MONOXIDE (CO)

The Main Flare was modeled. at the heat content scenarios of 300 and 443 BTU/SCF. The

modeled impact concentrations from SCREEN3 were multiplied by the I-hour and 8-hour

averaging period adjustment factors of 1.00 and 0.70, respectively. The maximum background

l-hour and 8-hour averaged CO concentration from Table 5-1 of 5,726 /lglm3 is cited as the

7-5
value to add to the maximum modeled CO impacts from the Main Flare to obtain an estimate of

cumulative impacts for comparison to the CO NAAQS. Note that the cited 8-hour background

concentration hasbeen assumed to also represent the l-hour background concentration since no

specific l-hour averaged monitoring datawas available.

7.3.1 National Ambient Air Quality Standards (NAAQS)

Table 7-5 provides a comparison of the estimated cumulative maximum I-hour and 8-hour

averaged CO impacts from the Main Flare, with a heat content of either 300 or 443 BTU/SCF, to

the corresponding CO NAAQS. The modeled results are added to the cited background

concentrations to arrive at the estimated cumulative concentration for each averaging time, and

the total value is compared to the l-hour and 8-hour CO NAAQS.

Table 7-5.

Comparison of Modeled Cumulative CO Impacts to the NAAQS

Max. Modeled Max. Adjusted Monitored Maximum National

Heat One-Hour Modeled Background Cumulative Ambient Air Percent of

Content Concentration Averaging Adjustment Concentration Concentration Concentration QualityStd. NAAQS

(BTU/SCF) (ug/rrr') Period Factor (ug/rrr') (ug/rrr') (ug/rrr') (ug/nr') (%)

300 16.21 l-hour 1.00 16.21 5,726 5742.21 40,000 14.36%

443 18.43 l-hour 1.00 18.43 5,726 5744.43 40,000 14.36%

300 8-hour 0.70 11.35 5,726 5737.35 10,000 57.37%

443 8-hour 0.70 12.90 5,726 5738.90 10,000 57.39%

The predicted maximum l-hour and 8-hour averaged concentrations from the Main Flare are

18.43 and 12.90 p,g/m3

, respectively, located 1,075 meters from the flare stack. These maximum

concentrations added to the background concentrations of 5,726 p,g/m3 results ·in cumulative

concentrations of 14.36% of the I-hour and 57.39% of the 8-hour averaged NAAQS of 40,000

and 10,000 p,g/m3

, respectively.

In addition, the maximum l-hour and 8-hour averaged concentrations of 18.43 and 12.90 p,g/m3

are less than the Class II SILs 012,000 and 500 p,g/m3

, respectively.

7-6
8.0 REFERENCES

Baukal, Jr., C. (Ed.). (2001). The John Zink Combustion Handbook. CRC Press: New York.

Consent Decree, United States ofAmerica v. Mobil Exploration & Producing, U.S., Inc., DOJ

Case No. 90-5-2-1-2237, filed June 8,2005 in United States District Court, District of

Utah.

U.S. Environmental Protection Agency, 2000. Compilation ofAir Pollution Emissions Factors,

5th Edition, AP 42, Office ofAir and Radiation, Office ofAir Quality Planning and

Standards, Research Triangle Park, North Carolina.

U.S. Environmental Protection Agency (EPA) Electronic Bulletin Board, RACT/BACT/LAER

Clearinghouse.

8,.1
APPENDIX A

EXXONMOBIL MCELMO CREEK OIL PRODUCTION UNIT

CONSENT DECREE
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 1 of 35

FI.F?l J?~

~~ :;. r:::~ .I:' _~: :;~~.~;~~.~::

FILED/NUNITEDS "r'~ .~ 'f ..,.,

COURT, D/ST T~1TES DISTRICl.,.:J - I.: ,..:\ : i; ..J j

RICT OF UTAH T.. .. .. .. .. iI.; ,,-'1, " ., ',. -, •• 1.

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Attorneys for PlaintiffUnited States ofAmerica

LARRY W. LINDEEN

12 Exxon Mobil Corporation

800 Bell Street

13 Houston, Texas 77002-7426

Telephone: (713) 656..J429

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF UTAH, CENTRAL DIVISION

Plaintiff,

v.

UNITED STATES OF AMERICA,

Attorney for Defendant Mobil Exploration & Producing U.S. Inc.

)

) CIVIL ACTION NO.

)

)

) CONSENT DECREE

)

)

) Judge Paul G~ Cassell

) DECK TYPE: Civil

) DArE STAMP: 04/08/2005 @ 11:35:40 ______________) CASE IUHBER: 2:05CV00319 PGC

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MOBIL EXPLORATION &

21 PRODUCING U.S. INC.,

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Gase 2:05-cv-00319-PGG Document7 Filed 06/08/2005 Page 2 Of 35

TABLE OF CONTENTS

I. JURISDICTION AND PARTIES BOUND 1

II. DEFINITIONS 2

III. "OBJECTNES 6

IV. CIVIL PENALTY : 6

"V. COMPLIANCE MEASURES 7

7 9. Emission Limits; 7

10. Monitoring.. 9

8 11. Operation and Maintenance ofMain Flare and Compressors 10

12. Root Clluse Analysis. . 11

9 13.. Corrective Action 13

14. Permitting " 14

10

VI. SUPPLEMENTAL ENVIRONMENTALPROJECT 15

11 18. SEP Completion Report. . 16

12 VIT. COMPLIANCE REPORTING AND RECORDKEEPING 17

13 VIII. STIPULATED PENALTIES 19

27. Stipulated Penalties 19

14 29. Interest. ................................•........................·22

15 IX. RIGHT OF ENTRY "' 23

16 X. FORCE MAJEURE 23

17 XI. DISPUTE RESOLUTION 25

18 XU. NOTIFICATION 26

19 xm, EFFECT OF SETTLEMENTINON-WAIVER PROVISIONS 27

20 XIV. EFFECTIVE DATE AND TERMINATION 28

21 XV. MISCELLANEOUS 29

54 Fees 29

22 55: iirtegration and Modifications..- 29

56. Retention ofJurisdiction 29

23 57. Public Comment. ; " 30

58. Final Judgment. 30

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Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 3 of 35

WHEREAS, concurrent with the Lodging ofthis Consent Decree, PlaintiffUnited States

2 ofAmerica, on behalfofthe United States Environmental Protection Agency ("EPA"), is filing a

3 Complaint against Defendant Mobil Exploration & Producing U.S. Inc. (hereinafter referred to as

4 "Mobil" or "Defendant"), alleging violations ofthe federal Clean Air Act, 42 U.S.C. §§ 7401-

5 7671q (the "Act"), at Mobil's McElmo Creek Unit oil production facility and associated oil

6 fields (the "Facility"), located near Aneth, Utah, on the Navajo Nation;

7 WHEREAS, Mobil, without filing any answer in this action, neither admits nor denies the

8 violations alleged in the Complaint;

9 WHEREAS, the Parties recognize, and the Court by entering this Consent Decree finds,

10 that this Consent Decree has been negotiated by the Parties in good faith and that this Consent

11 Decree is fair, reasonable, and in the public interest;

12 NOW, THEREFORE, before taking any testimony, without the adjudication of any issue

,,~.

13 offact or law, and upon the consent and agreement ofthe Parties to this Consent Decree, it is

14 hereby ORDERED, ADJUDGED, AND DECREED as follows:

15 1. JURISDICTION AND PARTIES BOUND

16 1. This Court has jurisdiction over the subject matter ofthis action under Section

17 113(b) ofthe Act, 42 U.S.C. § 7413(b), and 28 U.S.C. §§ 1331, 1345, and 1355: This Court also

18 has personal jurisdiction over Defendant. Venue is proper in this judicial district under Section

19 113(b) ofthe Act, 42 U.S.C. §7413(b), and 28 U.S.C. §§ 1391 and 1395, because it is the.

20 judicial district in which Mobil resides and in which the violations alleged in the Complaint have

21 occurred and are occurring. Notice ofthe commencement ofthis action has been given to the

22 Utah Department ofEnvironmental Quality and the Navajo Nation Environmental Protection

23 Agency in accordance with Section I 13(b) ofthe Act, 42 U.S~C. § 7413(b). Mobil consents to

24 and shall not challenge entry ofthis Consent Decree or this Court's jurisdiction to enter, enforce,

25 modify, or terminate this Consent Decree.

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2. This Consent Decree shall apply to and be binding upon Mobil and its successors

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Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 4 of 35

and assigns, and upon the United States on behalfofEPA.

3. IfMobil transfers any ownership interest or right to operate the Facility, including,

but not limited to, the sale, lease, or licensing ofothers to operate all or part ofthe Facility, Mobil

shall give notice ofthis Consent Decree to any successor-in-interest prior to such transfer. Mobil

shall send a copy ofsuch written notification to EPA, at the address listed in SectionXII

(Notification) ofthis Consent Decree, concurrently with such sale or transfer. Upon sale or

transfer ofsuch Facility, Mobil shall attach a copy ofthis Consent Decree to the agreement by

which such Facility is sold or transferred and shall make performance ofthe obligations ofMobil

under this Consent Decree an obligation of any purchaser or transferee. For 180 days after sale

or transfer ofsuch Facility, Mobil and its successor in interest shall be jointly and severally liable

for obligations under this Consent Decree. Thereafter,'Mobil shall either retain or be relieved of

its obligations under the Consent Decree as provided in Appendix A.

II. DEFIN1TIONS

4. Unless otherwise expressly provided herein, terms used in this Consent Decree

shall have the meanings assigned to those terms in the Act, 42 U.S.C. §§ 7401-7671q, and the

federal rules and regulations promulgated thereunder. Whenever terms listed below are used in

this Consent Decree or any appendices or documents incorporated by reference hereto, the

following definitions shall apply:

a. "Act" shall mean the Clean Air Act, as amended, 42 U.S.C. §§ 7401-

7671q.

b. "C.F.R." shall mean the Code ofFederal Regulations.

c. "CO" shall mean carbon monoxide.

d. "C02 Breakthrough" shall mean an event where a gas or fluid injected in

the Facility's oil field for the purpose of promoting the production ofoil contacts a producing

well and results in an increase in gas volume to compressor station equipment.

e. "Consent Decree" or "Decree" shall mean this written agreement and all

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Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 5 of 35

appendices hereto and any modifications ofthe agreement or appendices.

f. "Day" shall mean a calendar day, unless expressly stated to be a working

day. In computing any period oftime under this Consent Decree, where the last day ofsuch

period would fall on a Saturday, Sunday, or federal holiday, the period shall run until the close of

business on the next day that is not a Saturday, Sunday,or federal holiday.

g. "Defendant" or "Mobil" shall mean Mobil Exploration and Producing U.S.

Inc.

h. "Dispute Resolution" shall mean the dispute resolution procedures set

forth in Section XI ofthis Consent Decree.

1. "DO],' shall mean the United States Department ofJustice.

J. "Effective Date" shall mean the date of entry ofthe Consent Decree by the

Clerk ofthe United States District Court for the District ofUtah.

k. "Eligible SEP Costs" shall mean money that Mobil spends to purchase

equipment specified in Appendix D to this Consent Decree, or substantially similar equipment.

1. "EPA" shall mean the United States Environmental Protection Agency.

m. "Facility" shall mean Mobil's McEhno Creek Unit oil production facility

and associated oil fields, located near Aneth, Utah, on the Navajo Nation.

n. "Field Flares" shall mean the following flares at the Facility: (i) Tank

Battery Flares at MCV Area 1Battery, MCV Area 2 Battery, MCV Area 4 Battery, and MCV

Area 6 Battery; and (ii) Satellite Flares at MCV Section 2, MCU Section 3, MCV Section 5,

MCV Section 6, MCU Section 9, MCV Section 11, MCU Section 17, MCV Section 19, MCV

Section 32, and MCV Section 33.

o. "Final PSD Permit" shall mean a permit (i) that is issued in accordance

with the provisions of40 C.F.R. § 52.21; (ii) that includes, but is not limited to, federallyenforceable tenus and conditions that are at least as stringent as all ofthe tenus and conditions

included in Paragraphs 9.a., 10, 11, and 25(i) through (ix) ofthis Consent Decree, with the

. 3
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 6 of 35

1 exception that the quarterly report required by Paragraph 25 may be changed, at the discretion of

2 the permitting authority, to a semiannual report; and (iii) that is no longer subject to any judicial

3 review procedures.

4 p. "Final Title V Permit" shall mean a permit (i) that is issued in accordance

5 with the provisions of40 C.F.R. Parts 70 and 71, whichever is applicable; (ii) that includes, but

6 is not limited to, federally-enforceable terms and conditions that are at least as stringent as all of

7 the terms and conditions included in the Final PSD Permit; and (iii) that is no longer subject to

8 any judicial review procedures.

9 q. "Flaring Incident" shall mean continuous or intermittent flaring at the

10 Main Flare that occurs after the Effective Date ofthis Consent Decree and results in the

11 emissions ofS02 equal to, or greater than, five-hundred (500) pounds in any twenty-four (24)

12 hour period; provided, however, that iffive-hundred (500) pounds or more ofS02 have been

,.

13 emitted in a twenty-four (24) hour period and the flaring continues into subsequent, contiguous,

14 non-overlapping twenty-four (24) hour period(s), each period ofwhich results in emissions equal

15 to, or greater than, five-hundred (500) pounds ofS02, then only one Flaring Incident shall have

16 occurred. Subsequent, contiguous, non-overlapping periods are measured from the initial

17 commencement offlaring within the Flaring Incident.

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s.

"H2S" shall mean hydrogen sulfide.

"Lodging" or "Date ofLodging" shall mean the date on which Plaintiff

·20 lodges this Consent Decree with the United States District Court for the purpose ofseeking

21 public comment on the Consent Decree.

22 t. "Main Flare" shall mean the flare installed as part ofthe Facility's former

23 gas processing plant.

24 u. "Main Flare Emissions" shall mean the emissions from the Main Flare at

25 the Facility as well as all emissions that result from: (l) combustion offuel gas in the Main

26 Flare's pilot, (2) the closed drain and filter backwash operations, (3) CO2 Breakthroughs, (4) any

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Case 2:05-cv-00319-PGC Document 7 -, Filed 06/08/2005 Page 7 of 35

Scheduled Maintenance, and (5) unscheduled maintenance ofthe Facility's compressors.

v. "Malfunction" shall mean any sudden and unavoidable breakdown of

process or pollution control equipment. CO2 Breakthroughs or Scheduled Maintenance ofthe

Facility's compressors are not Malfunctions.

w. "NOx" shall mean oxides ofnitrogen.

x. "Paragraph" shall mean a portion ofthis Consent Decree identified by an

Arabic numeral or an upper or lower case letter. Any reference to a Paragraph designated by an

Arabic numeral includes all subsequent Paragraphs designated by consecutive lower case letters.

y. "Parties" shall mean the United States and Mobil.

z. - "Plaintiff' shall mean the United States.

aa. "PSD Permit" shall mean a construction permit issued in accordance with

the provisions of40 C.F.R. § 52.21.

bb. "Root Cause" shall mean the primary cause of a Flaring Incident as

determined through a process ofinvestigation; provided, however. that if a Flaring Incident

encompasses multiple releases ofS02' the "Root Cause" may encompass multiple primary

causes.

cc. "Scheduled Maintenance" shall mean work that is part ofthe routine work

plan for the compressors located at the Facility's former gas processing plant. This work is

typically planned and arranged on a set frequency, usually based on periods oftime (e.g., daily,

weekly or monthly) or on the operating hours ofthe equipment. Scheduled Maintenance shall

not include work necessitated by the failure of a part ofa compressor.

dd. Section" shall mean a portion ofthis Consent Decree identified by an

upper-case Roman numeral.

ee. "SEP" shall mean the supplemental environmental project required by this

Consent Decree.

ff. "S02" shall mean sulfur dioxide.

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gg. "United States" shall mean the United States ofAmerica, acting on behalf

ofEPA.

hh. "VOC" shall mean volatile organic compounds as defined in 40 C.F.R.

§ 51.100(s).

m. OBJECTIVES

5. It is the express purpose ofthe Parties entering into this Consent Decree to further

the objectives ofthe Act and to resolve the violations that the United States specifically alleged

in the Complaint filed in this action. To further these objectives, Mobil agrees, inter alia, to pay

the civil penalty as set forth in Section IV (Civil Penalty), to comply with the measures as set

forth in Section V'(Compliance Measures), and to perform theSEP as set forth in Section VI

(Supplemental Environmental Project).

IV. CIVIL PENALTY

6. After the Effective Date and within ten (10) days ofthe receipt ofthe Electronic

Fund Transfer procedures described in Paragraph 7 below, Mobil shall pay to the United States a

civil penalty in the amount ofTHREE HUNDRED FIFTY THOUSAND DOLLARS ($350,000), ,

plus interest at 1.29 percent per year from the date ofAugust 21, 2003, through the date of

payment

7. Payments under this Consent Decree shall be made by Electronic Funds Transfer

("EFT") to the United States Treasury according to current United States EFT procedures. The

United States shall provide a copy of current EFT procedures to Mobil at the address listed in

Section XII (Notification) ofthis Consent Decree. Concurrently with the electronic funds

transfer, Mobil shall send, by facsimile, notice ofpayment to the person designated as "Point of

Contact" on the EFT instructions, and shall send notice ofpayment to both EPA andDOJ at the

addresses listed in Section XII (Notification). The notice ofpayment shall identify (i) the date

and amount ofmoney transferred; (ii) the name and address ofthe transferring bank; (iii) the civil

action case name and case number; (iv) USAO File Number 2003V00248; (v) DOJ Case Number

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Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 'Page 9 of 35

1 90-5-2-1-2237; (vi) this Consent Decree (including Effective Date); and (vii) a description ofthe

2 reason for payment (including the Paragraph number(s) ofthis Consent Decree that are most

3 relevant to thepayment).

8. The payment ofthe civil penalty specified in this Section shall not be deductible

5 by Mobil or any other person or entity for federal taxation purposes.

6 V. COMPLIANCE MEASURES

7 Emission Limits.

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9.

a. From the Effective Date ofthis Consent Decree through the effective date

9 ofthe Final Title V Permit, Mobil's Main Flare Emissions shall not exceed the following rolling

10 365-day cumulative amounts (to be calculated each day): (i) 60 tons per year of S02' (ii) 73 tons

11 per year ofCO, (iii) 13.4 tons per year ofNOx• and (iv) 95.4 tons per year-ofVOC. Field Flares

12 shall not be used to circumvent the emission limits ofthis Paragraph.

13 b. The provisions ofSection VIII ofthis Consent Decree (Stipulated

14 Penalties) shall apply for Mobil's failure to comply with any ofthe emission limits in Paragraph

15 9.a above. However, Mobil may assert, as an affirmative defense to a demand by the United

16 States for stipulated penalties, that the alleged violation was due to a Malfunction. To qualify as

17 a Malfunction, Mobil has the burden ofproofofdemonstrating that:

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(1)

(2)

(3)

(4)

The emissions in question were not the result of any CO2Breakthroughs or

any Scheduled Maintenance ofthe Facility's compressors;

The emissions in question were caused by ,a sudden. unavoidable

breakdown ofprocess or pollution control equipment, beyond the control

ofMobil, its contractors, or any entity controlled by Mobil;

The emissions in question (i) did not stem from any activity or event that

'-.-

could have been foreseen and avoided, or planned for, and (ii) could not

have been avoided by better operation and maintenance practices;

To the maximum extent practicable, the air pollution control equipment or

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Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 10 of 35

processes were maintained and operated in a manner consistent with good

engineering practice for minimizing emissions;

(5) . Repairs were made in an expeditious fashion when Defendant knew or

should have known that SOz emissions resulting from the event would be

equal to, or greater than,.SOO pounds in a 24-hour period; (off-shift labor

and overtime must have been utilized, to the extent practicable, to ensure

that such repairs were made as expeditiously as practicable);

(6) The amount and duration ofthe emissionsin question were minimized to

the maximum extent practicable during periods ofsuch emissions;

(7) All possible steps were taken to minimize the impact ofthe emissions in

question on ambient air quality;

(8) All emission monitoring systems were kept in operation if at all possible;

(9) The actions ofMobil, its contractors, oranyentity controlled by Mobil in

response to the emissions in ques~ion were docwnented by properly

signed, contemporaneous operating logs, or other relevant evidence:

(10) The emissions in question were not part ofa recurring pattern indicative of,

inadequate design, operation, or maintenance. (Emissions associated with

a Flaring Incident are presumed to be part of a recurring pattern indicative

ofinadequate design, operation, or maintenance ifthe Root Cause ofthe

Flaring Incident is a recurrence ofthe same Root Cause that caused a

previous Flaring Incident, unless EPA agrees that such previous Flaring

'Incident was the result ofa Malfunction);

(11) lfthe emissions in question are associated with a Flaring Incident, Mobil

complied with all ofthe applicable requirements ofParagraphs 12 and 13

ofthis Consent Decree; and

(12) Mobil properly and promptly notified EPA as follows:

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Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 11 of 35

(a) ifthe emissionsin question are associated with a Flaring Incident,

Mobil compliedwith the notification and reporting requirements of

Paragraphs 12 and 25 ofthis Consent Decree;

(b) ifthe emissionsin question are not associated with a Flaring

Incident, Mobil listed such emissions as attributable to a

Malfunction in the quarterlyreport required by Paragraph 25 ofthis

Consent Decree.

c. IfSOz emissions exceedLoeu pounds per day, Mobil may submit a

written notificationto EPA, claiming that the emissionsresulted from a major Malfunction. In

the written notification, Mobil shall submit information to show that the incident qualifies as a

Malfunction pursuant to Paragraph9.b.(1)- (10). EPA agreesto review promptly such written

notificationregardinga major Malfunctionand to respond to the notification within 30 days after

EPA receives the written notification.

10. Monitoring. In determining compliancewith the emission limits referred to in

Paragraph9 above, from the EffectiveDate ofthis Consent Decree through the effective date of

the Final Title V Permit, Mobil shall measure and record the H2S concentration'in the field gas at

the Facilityin each calendarmonth at the inlet to the Facility's former gas processing plant where

the Main Flare is located,and shall continuouslymeasure and record the volume ofgas

combusted in the Main Flare. Each and everycalendar day, Mobil shall calculate and record the

daily emissions from the Main Flare based on the last recorded measurement ofHzS

concentrationin the field gas at the Facility and that day's recorded volume ofgas combusted in

the Main Flare. IfMobil is unable to measurethe volume ofgas combusted in the Main Flare on

any day, the volume ofgas for that day shall be deemed to be equal to the daily averagevolume

of gas combusted in the Main Flare based on the previous 12 months' emissions data. However,

the use of this daily averageas substitutedata neither relieves nor excuses Mobil from complying

with the sampling, data collection, and monitoringrequirements ofthis Paragraph.

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Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 'Page 12 of 35

1 11. Operation and Maintenance of~ain Flare and Compressors.' From the Effective

2 Date, Mobil shall at all times and to the extent practicable, including during periods ofstartup,

3 shutdown, Malfunction, CO2 Breakthrough, Scheduled Maintenance, or unscheduled

4 maintenance ofthe Facility's compressors, operate and maintain the compressor station

5 equipment and Main Flare in a manner consistent.with good air pollution control practices for

6 minimizing emissions.

7 a. As ofthe Effective Date, Mobil shall comply with the provisions ofthe

8 Operations and Maintenance Plan C'O&M Plan") contained in Appendix B, which is hereby

9 incorporated'by reference into this Consent Decree. Mobil shall follow the procedures for the

10 inspection ofthe Facility's compressors and associated equipment as set forth in the Life Cycle

II Maintenance Plan in Appendix B,' and shall maint~in i~spection logs at the Facility documenting

12 that these inspections have been conducted. Mobilshall.maintain daily records at the Facility

13 regarding operation ofthe Facility's compressors on a Daily Plant Reading Form. {An exemplar,

14 ofsuch a Formis contained in Appendix B.) Mobil shall also maintain a supply ofdesignated

15 spare parts for the Facility's compressors and associated equipment that includes all ofthe

16 equipment on the Spare Parts List contained in Appendix B. After using equipment on its Spare

17 Parts List, Mobil shall replace such equipment as'expeditiously as possible. Mobil shall place a

, . 18 purchase order for such equipment within 45 days after it is used. Mobil shall conduct training

19 ofFacility operators in accordance with the Training Program for Plant Operators contained in

20 Appendix B. and shall maintain records documenting that the training has been conducted.

21 Mobil shall retain copies ofinspection logs and other records required by this Paragraph l1.a.

22 untiltermination ofthis Consent Decree. Mobil'sfailure to comply with any requirement ofthe

·>',l " 23 O&M Plan shall constitute a violation ofthis ConsentDecree subject to stipulated penalties.

24 b. Within three hundred sixty-five (365) days from the Effective Date, Mobil

'.

25 shall install an automatic air-assisted flare system on the Main Flare, pursuant to the provisions

26 of40 C.F.R. § 60.18(c)(5) and (f)(6). Thereafter, Mobil shall operate and maintain the Main

27

,28 10
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 13 of 35

1 Flare in compliance with 40 C.F.R. § 60.18(c)(I), (c)(2), (c)(3)(ii), (c)(5), (d), (e), (f)(I) through

2 (f)(4), and (t)(6).

3 c. Within three hundred ninety-five (395) days from the Effective Date,

4 Mobil shall submit to EPA, at the address listed in Section XII (Notification), a certification that

5 the Main Flare is equipped with an automatic air-assisted flare system and is in compliance with

6 all applicable provisions of40 C.F.R. § 60.18(c){I), (c)(2), (c)(3)(ii), (c)(5), (d), (e), (f)(l)

7 through (f)(4), and (f)(6).

812. Root Cause Analysis. No later than 72 hours after an event first qualifies as a

9 Flaring Incident, Mobil shall notify by telephone, at (415) 947-8715, the Chiefofthe Air

10 Enforcement Office, Air Division ofEPA Region IX, ofsuch Flaring Incident. Telephone

i 1 notification shall be followed by a detailed written notification to EPA, at the address listed in

12 Section XU (Notification) ofthis Consent Decree, made within seven (7) working days after the

13 event first qualifies as a Flaring Incident. For a Flaring Incident caused by Scheduled

14 Maintenance or a CO2 Breakthrough, Mobil shall submit a report to EPA, at the address listed in

15 Section XII (Notification), no later than sixty (60) days following the end ofsuch a Flaring

16 Incident, that sets forth the information required by Paragraph 12.a. through d. below. Except for

17 those Flaring Incidents caused by Scheduled Maintenance or a CO2 Breakthrough, Mobil shall

. 18 conduct a Root Cause Analysis in accordance with the program described in Appendix C to

19 evaluate the cause of each Flaring Incident and shall submit a report to EPA, at the address listed

20 in Sectio~ XII (Notification), no later than sixty (60) days following the end of a Flaring Incident,

21 that sets forth all ofthe following:

22 a. The date and time that the Flaring Incident started and ended. To the

23 extent that the Flaring Incident involved multiple releases either within a twenty-four (24) hour

24 period or within subsequent, contiguous, non-overlapping twenty-four (24) bour periods, Mobil

25 shall set forth the starting and ending dates and times of each release;

26 b. An estimate ofthe quantity ofS02 that was emitted and the calculations

27 that were used to determine that quantity;

28 11
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 14 of 35

1 c. The steps, ifany, that Mobil took to limit the duration and/or quantity of

2 S02 emissions associated with the Flaring Incident;

3 d. Except for those. Flaring Incidents caused by Scheduled Maintenance or a

4 CO2Breakthrough, a detailed analysis that sets forth the Root Cause and all contributing causes

5 ofthat Flaring Incident, to the extent determinable; however, if a Flaring Incident is caused by

6 Scheduled Maintenance or CO2 Breakthrough, then Mobil need only identify the Root Cause as

7 Scheduled Maintenance or CO2 Breakthrough (whichever is applicable), and either (i) describe

8 the nature ofthe work done for Scheduled Maintenance or (ii) identify the specific wells that

9 most likely experienced the CO2Breakthrough;

10 e. An analysis of'the measures, including possible design, operational, and

11 maintenance changes, that are available to reduce the likelihood of a recurrence of a Flaring

12 Incident resulting from the same Root Cause or contributing causes in the future. IfMobil

13 concludes that corrective action(s) is (are) required under Paragraph 13, the report shall include a

14 description ofthe action(s) and, ifnot already completed, a schedule for its (their)

15 implementation, including proposed commencement and completion dates. IfMobil concludes

16 that corrective action is not required under Paragraph 13, the report shall explain the basis for

17 that conclusion;

18 f. To the extent that investigations ofthe causes andlor possible corrective

19 actions still are under way on the due date ofthe report, a statement ofthe anticipated date by

20 which a follow-up report fully conforming to the requirements ofParagraph 12.d and 12.e will be

21 submitted; provided, however, that ifMobil has not submitted a report or a series ofreports

22 containing the information required to be submitted under this Paragraph within forty-five (45)

23 days (or such additional time as EPA may allow) after the due date for the initial report for the

24 Flaring Incident, the stipulated penaltyprovisions ofSection VIII ofthis Consent Decree shall

25 apply, but Mobil shall retain the right to dispute, under Section XI (Dispute Resolution) ofthis

26 Consent Decree, any demand for stipulated penalties that was issued as a result ofMobil's failure

27 to submit the report required under this Paragraph within the time frame set forth. Nothing in

28 12
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 15 of 35

1 this Paragraph shan be deemed to excuse Mobil from its investigation, notification, reporting,

2 and corrective action obligations under this Section V (Compliance Measures) for any Flaring

3 Incident that occurs after the Flaring Incident for which Mobil has requested an extension oftime

4 under this Paragraph 12.f.

5 g. To the extent that completion ofthe implementation ofcorrective

6 action(s), ifany, is not finalized at the time ofthe submission ofthe report required under this

10 13. CQrrective Action. In response to any Flaring Incident, Mobil shall take, as

11 expeditiously as practicable, such interim and/or long-term corrective actions, if any, as are )

12 consistent with good 'engineeringpractice to minimize the likelihood of a recurrence ofthe Root

13 Cause and all contributing causes ofthat Flaring Incident.

14 a. IfEPA does not notify Mobil in writing within sixty (60) days ofreceipt of

15 the report(s) required by Paragraph 12 that it objects to one or more aspects ofMobil's proposed

16 corrective action(s), ifany, and schedule(s) ofimplementation, ifany, then that (those) action(s)

17 and schedule(s) shall be deemed approved for purposes ofMobil's compliance with Paragraph 13

18 ofthis Consent Decree. Upon approval by EPA, the provisions ofthe corrective action plan shall

19 become incorporated into this Consent Decree, and Mobil's failure to comply with any

20 requirement ofthe EPA-approved corrective action plan shall constitute a violation ofthis

21 Consent Decree subject to stipulated penalties.

22 b. EPA does not, however, by its agreement to the entry ofthis Consent

23 Decree or byits failure to object to any corrective action that Mobil may take in the future,

24 warrant or aver in any manner that any ofMobif's corrective actions in the future will result in

25 compliance with the provisions of the Act. Notwithstanding EPA's review ofany plans, reports,

26 corrective measures, or procedures under this Section V (Compliance Measures) ofthis Consent

27 Decree, Mobil shall remain solely responsible for compliance with the Act.

28 13
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 16 of 35

1 c. IfEPA does object, in whole or in part, to Mobil's proposed corrective

2 action(s) and/or its schedule(s) ofimplementation, or, where applicable, to the absence ofsuch

3 proposal(s) andlor schedule(s), EPA shall notify Mobil ofthat fact within sixty (60) days

4 following receipt ofthe report(s) required by Paragraph 12 above. IfEPA and Mobil cannot

5 agree within sixty (60) days on the appropriate corr~ctive action(s), if any, to be taken in response

6 to a particular Flaring Incident, disputes may be resolved under Section XI (Dispute Resolution)

7 ofthis Consent Decree.

8 d. Nothing in this Section V (Compliance Measures) shall be construed as a

9 waiver ofEPA's rights under the Act for future violations ofthe Act or its regulations nor to

10 limit Mobil's right to take such corrective actions as itdeems necessary and appropriate

:'. , ,J

11 immediately following a Flaring Incident or inthe period during preparation and review ofany

12 reports required under this Section.

13 14. Permitting. Not later than one hundred eighty (180) days after the Effective

14 Date, Mobil shall submit to EPA's permitting office, the following applications:

15 a. An application for a PSD permit for the Main Flare, which shall include,

16 among other things, the following requirements: (i) an analysis ofthe best available control

17 technology for the Main Flare for S02' CO, NOx, and VOC; and (ii) an air quality analysis. Such . ---_._--..

18 application shall be submitted in accordance witli the requirements ofthe Act and 40 C.F.R. _.~._, .._"- ..-.. __.... -- "',,'-;---'--" , .....,.-_ ..-...-- ..... ,

19 § 52.21, and shall include, among other things, termsand.ccnditions that are at least as stringent

20 as the tenus and conditions included in Paragraphs9.a, 10, 11, and 25(i) - (ix) ofthis Consent

21 Decree, with the exception that the quarterly report,required by Paragraph 25 may be changed, at

.

22 the discretion ofthe permitting authority, to asemiannual report.' Nothing in this Consent Decree

23 is intended to nor shall be construed to operate in any way to prohibit the applicable permitting

24 authority from issuing a PSD permit that includes requirements that differ from or are more

25 stringent than the requirements ofthis Consent Decree (e.g., emissions limits on a monthly, daily,

26 or hourly basis).

27

28

b. An application for a Title V Permit. which includes, among other things,

14
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 17 of 35

1 terms and conditions that are at least as stringent as the terms and conditions in Paragraphs 9.a,

2 10, ll,and 25(i) - (ix) ofthis Consent Decree, with the exception that the quarterly report

3 required by Paragraph 25 may be changed, at the discretion ofthe permitting authority, to a

4 semiannual report: Such application shall be submitted in accordance with the requirements of

5 Title V ofthe Act and 40 C.F.R. Part 71.

6 VI. SUPPLEMENTAL ENVIRONMENTAL PROJECT

7 15. In partial satisfaction ofPlaintiffs claims, Mobil shall implement a SEP to

8 support public health for the local residents in the vicinity ofAneth, Utah, on the Navajo Nation.

9 Mobil shall spend at least $99,849 to purchase the x-ray equipment, x-ray processor, and

10 pulmonary function testing machine specified in Appendix D ofthis Consent Decree, or

11 substantially similar equipment. Mobil shall order the equipment specified in Appendix D

12 within ninety (90) days after the Effective Date and have it delivered to:

13 Nettie Prack

Utah-Navajo Health Systems. Inc.

14 Montezuma Creek Community Health Center

Highway 262 East

15 Montezuma Creek, Utah 84534-0130

Telephone: (435) 651-3291

16

17 16. Mobil is responsible for the satisfactory completion oftheSEP in accordance with

18 the requirements ofthis Consent Decree. Mobil may use contractors and/or consultants in

19 planning and implementing the SEP, but costs incurred for contractors or consulting services do

20 not constitute Eligible SEP Costs.

21 17. With regard to the SEP, Mobil certifies the truth and accuracy ofeach ofthe

22 following:

23 a. That to the best ofMobil's knowledge, a reasonable and good faith

24 estimate ofthe cost ofthe SEP is $99,849;

25 b. That, as ofthe Effective Date. Mobil is not required to perform or develop

26 the SEP by any federal, state. or local law or regulation. nor is Mobil required to perform or

27 develop the SEP by agreement. grant, or as injunctive relief awarded in any other action in any

28 15
Case2:05-cv-00319-PGC .Document 7 Filed 06/08/2005 Page 18 of 35

1 forum;

2 c. That Mobil has not received, and is not negotiating to receive, credit for

3 the SEP in any other enforcement action; and,

4 d. That Mobil will not receive reimbursement for any portion ofthe SEP

5 .from any other person.

6 18. SEP Completion Report.

7 a. Within thirty (30) days after Mobil concludes that the SEP has been fully

8 implemented in accordance with the requirements ofthis Consent Decree, Mobil shall submit a

9 SEP Completion Report to EPA and DOl at the addresses listed in Section XII (Notification) of

10 this Consent Decree. The SEP Completion Report shall contain the following information:

11 (1) A detailed description ofthe SEP as implemented;

12 (2) A description ofany problems encountered in completing the SEP and the

13 solutions thereto;

14 (3) An itemized list of all Eligible SEP Costs and acceptable evidence ofsuch

15 costs;

16 (4) Certification that the SEP has been fully implemented pursuant to the

17 provisions ofthis Consent Decree; and

18 (5) A description ofthe environmental and public health benefits anticipated

19 to result from implementation ofthe SEP.

20 19. For purposes ofParagraph 18.a.(3), "acceptable evidence" includes invoices,

21 purchase orders, or other documentation that specifically identifies and itemizes the individual

22 costs ofthe goods or services for which payment is made. Canceled drafts do not constitute

23 acceptable evidence unless such drafts specifically identify and itemize the individual costs ofthe

24 goods or services for which payment is made.

25 20. Within sixty (60) days after receipt ofa SEP Completion Report (unless the

26 United States notifies Mobil that additional time is required), the UnitedStates shall notify Mobil

27 whether or not Mobil has satisfactorily completed the SEP. IfMobil's total Eligible SEP Costs

28 16
1

2

3

4

5

6

7

8

9

-10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 19 of 35

17
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 20 of 35

1 25. Within thirty (30) days following the end of each calendar quarter (i.e., January to

2 March, April to June, July to September, October to December) after the Effective Date, Mobil

3 shall submit to EPA, at the address listed in Section xn (Notification) ofthis Consent Decree

4 and bearing the certification language set forth in Paragraph 42 ofthis Consent Decree, a

5 quarterly report that includes: (i) a list ofthe rolling365-day cumulative Main Flare Emissions

6 for each day in that quarter; (ii) a list of each day in the quarter when the emissions limits in

7 Paragraph 9 ofthis Consent Decree were exceeded and, for each such day, the limit(s) exceeded

8 and the amount(s) ofexcess emissions; (iii) a 'list of all emissions for the quarter that Mobil

9 claims are attributable to Malfunctions and, for each such item on the list, a detailed . 1

10 demonstration that all ofthe qualifying criteria for Malfunctions that are listed in Paragraph 9.b

11 ofthis Consent Decree have been satisfied; (iv) a list of;UI emissions for the quarter that may be

12 attributable to'CO2 Breakthroughs, Scheduled Maintenance, or unscheduled maintenance ofthe

13 Facility's compressors; (v) the date(s) and time(s) during the 'quarter when the thermocouple or

14 flow meter associated with the Main Flare was inoperative; (vi) the date(s) and time(s) duringthe

15 quarter when Mobil failed to measure or record the H2S concentration in the field gas at the

16 Facility or failed to continuously measure orrecord the volume of gas combusted in the Main

17 Flare; (vii) a certification that during the calendar quarterMobil operated and maintained the,

18 compressor station equipment and Main Flare in:a manner consistent with good air pollution

19 control practices for minimizing emissions, and performed all ofthe obligations (including, but ,

20 not limited to, inspection and training obligations) contained in the O&M Plan in Appendix B; .,") .

21 (viii) a certification that the Field Flares have not peen used to circumvent the emission limits in

22 Paragraph 9; (ix) a list oftotal emissions fromWk"Fiy,ld Flares 'and the reason for the flaring; and

23 (x) any and all reports generated from the root cause analysis and corrective action program of

24 Paragraphs 12 and 13 above. ,

25 26. Mobil shall maintain at the Facility copies of all notices, reports, information,

26 submissions, and records required by this Consent Decree until the termination ofthis Consent

27 Decree or as required by applicable law, whichever is later. Mobil shall provide any ofthese

28 18
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 21 of 35

1 documents to EPA upon request.

2 Vill.STIPULATED PENALTIES

3

4

27. Stipulated Penalties.

a. . Subject to the force majeure provisions ofSection X (Force Majeure),

5 Mobil shall be liable for stipulated penalties in the amounts set forth in this Paragraph 27 to the

6 United States for failure to comply with the terms and conditions ofthis Consent Decree as

7 follows:

8 (1) for Mobil's failure to pay the full amount ofthe civil penalty set forth in ,

9 Section N (Civil Penalty): $5,000 for each day that payment ofthe civil penalty is delayed

10 beyond the date due;

11 (2) for Mobil's failure to comply with any requirement ofSection V

12 (Compliance Measures):

13 (a) for Mobil's failure to comply with any ofthe emission limits in

14 Paragraph 9 ofthis Consent Decree (for the purpose ofdetermining stipulated penalties for the

15 emission limits only, days ofnoncompliance are cumulative from the Effective Date and need

16 not be continuous) :

Days ofNoncompliance from Effective Penalty per Day per Violation

Date to Termination ofthe Decree

15t through 51h day $1,000

6th through 10lb day $2,500

11th through 20th day $5,000

21st day and beyond $7,500

17

18

19

20

21

22

23

24 (b) for Mobil's failure to comply with any ofthe specific requirements

25 in Paragraphs 11 through 13 ofthis Consent Decree identified in the following table:

26

27

28 19
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 22 of 35

Requirement Penalty

Failure to implement O&M Plan requirements (~11.a.)

Failure to maintain inspection logs or records $250 per day for each day after

(excluding the first full calendar quarter the third day ofnoncompliance

after the Effective Date) within each calendar quarter

Levels 2,3, and 4 tasks $250 per task

Levels 5 and 6 tasks $500 per task

Failure to conduct training $500 per day

Failure to maintain spare parts $1,000 per day

Root Cause Analysis ('12) $5,000 per event

CorrectiveAction ('13) $7,500 per event

1

2

3

4

5

6

7

8

9

10

11

12 (c) for Mobil's failure to comply with any other requirement of

Period ofNoncompliance Penalty per Day per Violation

1st through io- day $1,000

11th through 20th day $2,500

215t day and beyond $5,000

(3) IfMobil's total Eligible SEP Costs are less than $99,849 in connection

13 Section V ofthis Consent Decree not specifically referenced in this Paragraph 27.a (2)(a) or 27.a

14 (2)(b) above:

15

16

17

18

, 19

20

21 with the performance ofthe SEP specified in Appendix D ofthis Consent Decree, or ifthe SEP

22 has not been satisfactorily completed, Mobil shall be liable for stipulated penalties, as set forth

23 below. IfMobil has halted or abandoned completion ofthe SEP, such penalties shall accrue

24 from the date of abandonment or the date set for completion ofthe SEP, whichever is earlier.

25 (a) Ifthe SEP has been satisfactorily completed but Mobil's total

26 Eligible SEP Costs for the SEP are less than $99,849, Mobil shall pay stipulated penalties at the

27 rate ofone dollar for every one dollar that Mobil's total Eligible SEP Costs for that SEP are less

28 20
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 23 of 35

1 than $99,849.

2 (b) Ifa SEP has not been satisfactorily completed, Mobil shall pay

3 stipulated penalties at the rate of$1.50 for every one dollar that Mobil's total Eligible SEP Costs

4 for that SEP are less than $99,849.~ However, to the extent that Mobil has made good faith and

5 timely efforts to complete the project, Mobil shall pay stipulated penalties at the rate of one

6 dollar for every one dollar that Mobil's total Eligible SEP Costs for that SEP are less than

7 $99,849. If a SEP is not satisfactorily completed but Mobil's total Eligible SEPCosts for that

8 SEP are equal to or exceed $99,849, Mobil shall not be liable for any stipulated penalties for that

9 SEP ifMobil has made good faith and timely efforts to complete the project and certifies with

10 .supporting documentation, no later than the date that Mobil is required to submit a SEP

11 Completion Report for that project, that it has spent at least $99,849. IfMobil does not provide

12 the certification and documentation required by this subparagraph, or ifthedocumentation

13 provided does not support Mobil's certification, Mobil shall be deemed to be in violation ofthis

14 Consent Decree and shall pay a stipulated penalty of$7,500. Mobil shall be deemed to have

15 made good faith and timely efforts to complete the project ifMobil complies with the specific

16 obligations set forth in Paragraphs 15, 17 through 19, and 21 through 23.

17 (c) IfMobil fails to: (i) order the equipment within 90 days after the

Period ofNoncompliance Penalty per Day per Violation

1st through 14th day $100

15th through 30th day $250

31st day and beyond $500

(4) for Mobil's failure to comply with any requirement ofSection IX (Right of

18 Effective Date as required by Paragraph 15; or (ii) timely submit a SEP Completion Report under.

19 Paragraph 18, Mobil shall pay stipulated penalties as follows:

20

21

22

23

24

25

26 Entry): $5,000 per day for each failure to comply; and

27

28

(5) for Mobil's failure to comply with any other requirement ofthis Consent

21
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 24 of 35

1 Decree not specifically referenced in this Paragraph 27.a (1) through (4) above: $1,000 per day

2 for each failure to comply.

3 b. All stipulated penalties shall automatically begin to accrue on the day after

4 the complete performance is due or the first day a violation occurs, and shall continue to accrue

5 through the final day ofthe correction ofthenoncompliance or completion ofthe activity. ,

6 Nothing herein shall prevent the simultaneous accrual ofseparate stipulated penalties for separate

7 violations ofthis Consent Decree. Stipulatedpenalties shall accrue regardless ofwhether

8 Plaintiffhas notified Mobil of a violation ofthe Consent Decree.

9 c. Any stipulated penalty accruing pursuant to this Consent Decree shali be

10 payable upon demand and due not later than thirty (30) calendar days from EPA's written

11 demand.

12 28. Stipulated penalties shall be paid by certified or cashier's check in the amount

13 due, shall be made payable to the "U.S. Department ofJustice," referencing DOJ #90-5-2-1-2237

14 and USAO File Number 2003V00248, and shall be delivered by certified mail with return receipt

15 requested to:

16 United States Attorney, District ofUtah

Attention: Financial Litigation Unit

17 185 South State Street, Suite 400

Salt Lake City, Utah 84111

18

19 Concurrently with making the payment, Defendant shall send notice ofpayment to EPA and ,

20 DOl, directed to the addresses provided in Section XU (Notification). The notice ofpayrnent

21 shall also identify: (i) the specific provision of'this Section vrn (Stipulated Penalties) related to ,

22 such payment, and (ii) a description ofthe viol~ti9n(s) ofthisConsent Decree for which the -.'

23 stipulated penalties or interest are being tendered.

24 29. Interest. IfMobil fails to pay the full amount.ofthe civil penalty specified in

25 Section IV (Civil Penalty) when due, or the full amount ofany stipulated penalty specified in this

26 Section VIII(Stipulated Penalties) within 30 days ofEPA's written demand, then Mobil shall pay

27 to the United States (in addition to the unpaid balance ofeach penalty) interest on the late

28 22
23

X. FORCE MNEURE

32. Mobil shall satisfy the requirements ofParagraphs 9 through 26 ofthis Consent

Decree except to the extent, and for the period oftime, that such performance is prevented or

delayed by events that constitute a force majeure.

33. For purposes ofthis Consent Decree, a "force majeure" is defined as an event

arising from causes beyond the control ofMobil, its contractors, or any entity controlled by

Mobil that prevents or delays the performance of any obligation 'under this Consent Decree

despite Mobil's best efforts to fulfill the obligation. "Best efforts" include anticipating any

potential force majeure event and addressing the effects of any such event (i) as it is occurring

and (ii) after it has occurred, such that delay is minimized to the extent possible. "Force

Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 25 of 35

1 payment for each day oflate payment after the initial 30-day time period. The rate ofinterest

2 shall be the most recent interest rate determined pursuant to 28 U.S.C. § 1961. IfMobil disputes

3 its obligation to pay part or all of a stipulated penalty, it shall initiate the dispute resolution

4 procedures under Section XI (Dispute Resolution). IfMobil invokes dispute resolution, Mobil

5 shall pay to the United States any amount that it does not dispute.

6 30. Payment ofstipulated penalties for a violation ofthis Consent Decree shall not

7 preclude the United States from seeking additional monetary penalties or other relieffor the

8 violations giving rise to the stipulated penalties. The United States reserves its right to pursue

9 any or all relieffor any or aU violations directly, either administratively orjudicially, and outside

10 the provisions ofthis Consent Decree. Where a violation ofthis Consent Decree is also a

11 violation ofthe Clean Air Act, Defendant shall be allowed a credit, for any stipulated penalties

12 paid, against any statutory penalties imposed for such violation.

13 IX. RlGHT OF ENTRY

14 31. EPA and its contractors, consultants, and agents shall have authority to enter the

15 Facility at all reasonable times, upon presentation of credentials. This provision in no way limits

16 or otherwise affects any right of entry held by EPA pursuant to applicable federal, state, or local

17 laws, regulations, or permits.

18

19

20

21

22

23

24

25

26

27

28
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 26 of 35

1 majeure" does not include Mobil's financial inability to perform any obligation under this

2 Consent Decree.

3 34. In the event of a force majeure, the time for performance ofthe' activity delayed by

4 the force majeure shall be extended for the time period ofthe delay attributable to the force

5 majeure. The time for performance of any activity dependent on the delayed activity shall be

6 similarly extended, except to the extent that the dependent activity can be reasonably

7 implemented in a shorter time. EPA shall determine whether the dependent activities will be

8 'delayed by the force majeure and whether the time period should be extended for performance of

9 such ~ctivities. Mobil shall adopt all reasonable measures to avoid' or minimize any delay caused

10 by a force majeure.

11 35. When an event occurs or has occurred that may delay or prevent the performance

12 of any obligation under this Consent Decree and that Mobil believes is a force majeure, Mobil

13 shall notify by telephone, at (415) 947-8715, the Chiefofthe Air Enforcement Office, Air

14 Division ofEPA Region IX, within 72 hours ofMobil's knowledge ofsuch event. Telephone

15 notification shall be followed by written notification to EPA, at the address in Section XU

16 (Notification) ofthis Consent Decree, made within seven (7) working days ofMobil's knowledge

17 ofthe event. The written notification shall fully describe (i) the event that may delay or prevent

18 performance; (ii) the reason that such event may delay or prevent performance; (iii) whether

19 Mobil claims that such event constitutes a force majeure under this Consent Decree; (iv) the

20 reasons any such delay is beyond the reasonable control ofMobil; (vythe anticipated duration of

21 the delay; (vi) actions taken or to be taken to prevent or minimize the delay; (vii) a schedule for

22 implementation of any measures to be taken to prevent or minimize the delay or the effect ofthe

23 delay; and (viii) the time needed to implement any dependent activities.

24 36. Mobil's failure to comply with the force majeure notice requirements provided in

25 Paragraph 35 above for any delay in performance will be deemed an automatic forfeiture ofits

26 right to assert that the delay was caused by a force majeure unless such failure to provide notice

27 was caused by a force majeure.

28 24

, .- _._-------~
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 27 of 35

37. Within seven (7) working days after receiving notice from Mobil of a force

majeure, EPA shall provide written notification to Mobil stating whether Mobil's request for a

delay is justified. EPA's failure to respond to a request for a delay shall be deemed a denial of

that request. IfMobil disagrees with EPA's force majeure determination, then Mobil may initiate

the dispute resolution procedures of Section XI (Dispute Resolution) ofthis Consent Decree.

XI. DISPUTE RESOLUTION

38. IfMobil disputes any determination made by EPA under this Consent Decree

related to (i) a request by EPA for stipulated penalties, (ii) EPA's determination pursuant to

Paragraphs 11, 13, or 20, (iii) EPA's determination related to force majeure, or (iv) the

termination ofthe Consent Decree under Paragraph 53, Mobil shall send a written notice to EPA

and DOl outlining the nature, ofthe dispute and requesting informal negotiations to resolve the

dispute. Such period ofinformal negotiations shall not extend beyond ten (10) working days

from the date when the notice was sent unless the Parties agree otherwise.

39. Ifthe informal negotiations are unsuccessful, then the determination ofEPA shall

control, unless Mobil files a motion with this Court for dispute resolution. Any such motion

must be filed within thirty (30) days after Mobil's receipt ofa notice in writing terminating

informal negotiations, and such motion must be concurrently sent to EPA and DOJ in accordance

with the Section XII (Notification) ofthis Consent Decree. The United States shall then have

thirty (30) days to respond to Mobil's motion. The Court's decision in any such dispute

resolution proceeding shall be based on the administrative record. Mobil shall bear the burden of

proving that (i) in disputes regarding EPA's request for stipulated penalties under Section VIII

(Stipulated Penalties) ofthis Consent Decree or EPA's determination under Paragraphs 11 or 13,

Mobil did not violate the terms and conditions ofthis Consent Decree; (ii) in disputes regarding

EPA's determination under Paragraph 20, Mobil has satisfied all ofits obligations under Section

VI (Supplemental Environmental Project); (iii) in disputes regarding Section X (Force Majeure),

the delay was caused by circumstances beyond the control ofMobil, its contractors, and agents,

all reasonable measures were taken to minimize delay, and the duration ofthe delay was

25

--------------------- --
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 28 of 35

1 reasonable under the circumstances; and (iv) in disputes regarding termination ofthis Consent

2 Decree under Paragraph 53, Mobil has satisfied all ofits obligations under this Consent Decree.

3 The Court shall uphold EPA's determination unless Mobil proves that the determination is

4 arbitrary and capricious, or otherwise not in accordance with law.

5 40. A timely motion by Mobil will not toll the accrual ofstipulated penalties under

• • I :

. 6 this Consent Decree for any ongoing noncompliance,with respect to the disputed matter.

7 XII. NOTIFICATION

8 41.· Except as otherwise specifically stated, all notices and submissions from Mobil to . , '

9 EPA required by this Consent Decree shall be sent by. certified mail, express mail, or similar ,

10 overnight mail delivery with return receipt requestedandaddressed to:

11 Director, Air Division (AIR.. 1) .

U.S. Environmental Protection Agency, Region IX

12 75 Hawthorne Street .

San Francisco, California 94105

13 Attention: John Kim

14 All notices and submissions sent to EPA or DOJ shall refer to this Consent Decree and the

15 Effective Date ofthe Consent Decree, and shall cite the case name ofUnited States v. Mobil

16 Exploration and Producing U.S. Inc., the civil action case number, and the DOJ Case Number

17 90-5-2-1-2237.

42. All notices and submissions made pursuant to this Consent Decree shall be signed

43.

and affirmed by a responsible official ofMobil using-the following certification statement:

I certify under penalty oflaw thatI.have examined and am familiar

with the information submitted in this document and all

attachments and that this document-and its attachments were

prepared either by me personally 0,1';under my direction or

supervision in a manner designed to ensure that qualified and

knowledgeable personnel properly gathered and presented the

information contained therein. I further certify, based on my

personal knowledge or on my inquiry ofthose individuals

immediately responsible for obtaining the information, that the

information is true, accurate, and complete. I am aware that there

are significant penalties for submitting false information, including

the possibility offmes and imprisonment for knowing and willful

submission of a materially false statement.

As to DOl, notices and submissions required.to be sent by this Consent Decree

18

19

20

21

22

23

24

25

26

27

28 26
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 29 of 35

. 1 shall be submitted to:

2 Chief, Environmental Enforcement Section

Attn: DOJ # 90-5-2-1-2237 (Mullaney)

3 United States Department ofJustice

301 Howard Street, Suite 1050

4 San Francisco, California 94105

5 44. As to Mobil, notices and submissions required to be sent by this Consent Decree

.6 shall be submitted to:

7 Vice President

Mobil Exploration and Producing U.S. me.

S CORP~WGR-1260

396 West Greens Road

9 Houston, Texas 77067

10 45. All submissions made pursuant to this Consent Decree shall be deemed submitted

lionthe date postmarked.

12 XIII. EFFECT OF SETTLEMENTINON-WANER PROVISIONS

13 46. Neither by entering into this Consent Decree nor by taking any action in

14 accordance with it (including paying the civil penalty required by this Consent Decree) shall

15 Defendant be deemed to have admitted any liability for any purpose or any responsibility for, or

16 wrongdoing relating to, the matters specifically alleged in the Complaint, or to have admitted any

17 issues oflaw or fact related to or arising from the matters specifically alleged in the Complaint,

18 except as set forth in Section I (Jurisdiction and Parties Bound) ofthis Consent Decree. It is the

19 intent ofthe Parties to this Consent Decree that neither the terms and conditions ofthis Consent

20 Decree nor any act ofperformance by Defendant shall be (i) admissible in any proceeding for the

21 purpose ofimputing, implying, or otherwise raising an inference ofwrongdoing by Defendant, or

22 (ii) used against Defendant as collateral estoppel in any other proceeding with any third party not

23 a signatory to this Consent Decree.

24 47. Entry ofthis Consent Decree and compliance with the requirements herein

25 resolves the civil claims ofthe United States against Defendant for the violations specifically

26 alleged in the Complaint filed in this action, up to the Date ofLodging ofthe Consent Decree.

27

28

48. Except as specifically provided herein, the United States does not waive any rights

27
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

'23

24

25

26

27

28

Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 30 of 35

or remedies available to it for violation by Defendant offederal or state laws or regulations. This

Consent Decree shall in no way affect the United States' ability to bring future actions for any

matters not specifically alleged in the Complaint filed in this action, up to the Date ofLodging of

the Consent Decree. Nothing in this Consent Decree is intended to nor shall be construed to

operate in any way to resolve any criminal liability of Defendant.

49. This Consent Decree in no way affects Defendant's responsibilities to comply

with all federal, state, or local laws. regulations or permits, including, but not limited to, the

reporting requirements ofSection 103(a) ofthe Comprehensive Environmental Response,

Compensation, and Liability Act, 42 U.S.C. § 9603(a), and Section 304 ofthe Emergency

Planning and Community Right-to-Know Act, 42 U.S.C. § 11004, and the regulations

promulgated thereunder. This Consent Decree is not, and shall not be construed as, a permit or a

modification of a permit. Nothing in this Consent Decree shall diminish EPA's ability to request

information from Defendant under applicable laws or regulations.

50. This Consent Decree does not limit or affect the rights ofthe Plaintiffor

Defendant against any third parties (parties not specifically part ofthis Decree), nor does it limit

the rights ofsuch third parties against Defendant. This Consent Decree shall not be construed to

create any rights in, or grant any cause of action to, any person not a party to this Consent Decree.

XN. EFFECTIVE DATE AND TERMINATION

51. This Consent Decree shall take effect on the date of entry by this Court.

52. This Consent Decree shall terminate when all ofthe following conditions have

been met:

a. Mobil has complied with all ofthe requirements set forth in Sections V

(Compliance Measures) and VI (Supplemental Environmental Project) ofthis Consent Decree;

b. Mobil has paid the civil penalty and interest as set forth in Section N

(Civil Penalty). all stipulated penalties and interest as set forth in Section vm(Stipulated

Penalties), and no penalties or other monetary obligations due under this Consent Decree are

outstanding or owed to theUnited States;

28
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 31 of 35

1

2

c.

d.

all disputes arising under the Consent Decree have been resolved;

Mobil has received a Final Title V Permit (i) for which Mobil submitted ,

3 an application in accordance with Paragraph 14 ofthis Consent Decree; and (ii) that includes, but

4 is not limited to, federally-enforceable terms and conditions that are at least as stringent as all of

5 the terms and conditions included in Paragraphs 9.a, 10, 11, and 25(i) - (ix) ofthis Consent

6 Decree, with the exception that the quarterly report required by Paragraph 25 may be changed, at

7 the discretion ofthe permitting authority, to a semiannual report; and

Mobil shall initiate termination ofthis Consent Decree by submitting a written

8

9 53.

e. this Court approves termination ofthis Consent Decree.

10 certification concurrently to EPA and DOJ at the addresses listed in Section XII (Notification),

11 that (i) all conditions for termination pursuant to Paragraph 52 above (except for the condition in

12 S2.e referring to this Court's approval oftennination) have been satisfied; and (ii) Mobil believes

13 that the Consent Decree should be terminated. After receiving notice from Mobil, EPA shall

14 provide Mobil with a written response, either stating that EPA agrees that the Consent Decree

15 should be terminated, and submitting a motion to this Court requesting that the Consent Decree

16 be terminated, orstating that EPA has determined that the Consent Decree should not be

17 terminated, IfEPA fails to provide written response within sixty (60) days after receiving written

18 notice from Mobil or ifEPA determines that the Consent Decree should not be terminated, Mobil

19 may initiate dispute resolution procedures pursuant to Section XI (Dispute Resolution).

20 XV. NITSCELLANEOUS

21

22

54.

55.

Fees. Each Party shall bear its own costs and attorneys' fees in this action.

Integration and Modifications. This Consent Decree (including its appendices)

23 contains the entire agreement between the Parties. The notification requirements ofthis Consent

24 Decree may be modified only ifsuch modifications are made in writing and approved by all

25 Parties. In all other respects, this Consent Decree may not be enlarged, modified, or altered

26 unless such modifications are made in writing and approved by all Parties and this Court.

27

28

56. Retention ofJurisdiction. Until the termination ofthis Consent Decree pursuant

29
Case 2:05'-cv-00319-PGC Document 7 Filed 06/08/2005 Page 32 of 35

1 to Section XIV (Effective Date and Termination), this Court shall retain jurisdiction over this

2 action and all disputes arising hereunder (to the extent that this Consent Decree provides for

3 resolution ofdisputes by this Court) for the purposes ofimplementing and enforcing the terms.

4 and conditions ofthis Consent Decree.

5 57. Public Comment. Mobil agrees and acknowledges that final approval ofthis

6 Consent Decree by the United States and entry ofthis Consent Decree by this Court is subject to

7 the requirements of28 C.F.R. § 50.7, which provides for notice ofthe Lodging ofthis Consent

8 Decree in the Federal Register, opportunity for-public comment for at least thirty (30) days, and

9 consideration by the United States of any comments prior to entry ofthe Consent Decree by this

10 Court. The United States reserves the right to withdraw its consent to this Consent Decree based

11 on comments received during the public notice period. Mobil consents to entry ofthis Consent

12 Decree without further notice and shall not oppose or appeal its entry by the Court.

13 58. Final Judgment. Upon entry by this Court, this Consent Decree shall constitute a

14 final judgment for purposes ofFederal Rules ofCivil Procedure 54 and 58.

15

16

17 IT IS SO ORDERED, this 7{/1

18

19

20

21

22

23

24

25

26

27

28

ORDE~

day of_-Jo..",o~-7--tr__, 2005.

30
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 .Page 33 of 35

1 FOR PLAINTIFF UNITED STATES OF AMERICA:

2

3 Dated: :$/zS-/OS4

5

6

7 Dated: 4- 1- -»:

8

9

10

11

12

13

14

15

16

17

18 .

19

20

21

22

23

24

25

26

27

28

By:TenJ

THOMAS L. SANSONETTI

~euJ/~.

Assistant Attorney General

Environment and Natural Resources Division

United States Department ofJustice

~~1),~ ROBERT D. MULLANEY

Trial Attorney

Environmental Enforcement Section

Environment and Natural Resources Division

United States Department ofJustice

301 Howard Street, Suite 1050 .

San Francisco, California 94105

Telephone: (415) 744-6491

PAUL M. WARNER

United States Attorney

JEANNETTE SWENT

Assistant United States Attorney

District ofUtah

185 South State Street, Suite 490

Salt Lake City, Utah 84111

31
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 34 of 35

1 FOR PLAINTIFF UNITED STATES OF AMERICA (continued):

2

3

4 Dated: t{ ·(P ·0r-

\

5

6

7

8

9

10 Dated: ;2,./1:>/6 J

11

12

13

14

15 OF COUNSEL:

16 THOMAS P. MINTZ

Assistant Regional Counsel

17 Office ofRegional Counsel

United States Environmental

18 Protection Agency, Region IX

75 Hawthorne Street

19 San Francisco, California 94105

20

21

22

23

24

25

26

27

28

"

/If... ~~--""

.

~~rNNER Acting Assistant Administrator for Enforcement

and Compliance Assurance

United States Environmental Protection Agency

32
Case 2:05-cv-00319-PGC Document 7 Filed 06/08/2005 Page 35 of 35

1 FOR DEFENDANT MOBIL EXPLORATION & PRODUCING U.S. INC.:

SARA N. ORTWEIN

Vice President

Mobil Exploration and Producing U.S., Inc.

396 West Greens Road

Houston, Texas 77067

~{i~~ Exon1~~r~~ 800 Bell Street

Houston, Texas 77002-7426

Telephone: (713) 656-3429

Attorney for Defendant .

20

21

22

23

24

25

26

27

28 33
APPENDIX'B

SCREEN3 MODELING INPUT AND OUTPUT RESULTS
02/22/05

11:00:38 *** SCREEN3 MODEL RUN *** *** VERSION DATED 96043 ***

McELMO MAIN FLARE -- NOx DISPERSION, 618,104 SCF/.HR, 300 BTUISCF

SIMPLE TERRAIN INPUTS:

SOURCE TYPE

EMISSION RATE (GIS) = FLARE STACK HEIGHT (M)

TOT HEAT RLS (CALIS)

RECEPTOR HEIGHT (M)

URBANIRURAL OPTION

EFF RELEASE HEIGHT (M)

BUILDING HEIGHT (M)

MIN HORIZ BLDG DIM (M)

MAX HORIZ BLDG DIM (M)

FLARE

1.50000

59.4500

.129887E+08

.0000

RURAL

70.9117

'.0000

.0000

.0000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED.

THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 215.356 M**4/S**3; MOM. FLUX = 131.320 M**4/S**2.

*** FULL METEOROLOGY ***

**********************************

*** SCREEN AUTOMATED DISTANCES ***

**********************************

*** TERRAIN HEIGHT OF O. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES ***

DIST

(M)

CONC

(UG/M**3 )

U10M USTK MIX HT PLUME

STAB (MIS) (MIS) (M) HT (M)

SIGMA

Y (M)

SIGMA

Z (M) DWASH

200.

300.

400.

500.

600.

700.

800.

900.

1000.

1100.

1200.

1300.

1400.

1500.

1600.

1700.

1800.

1900.

2000.

2100.

2200.

2300.

2400.

2500.

2600.

2700.

2800.

2900.

.1976E-03

.2504E-03

.1994E-02

.9364E-01

.5748

1.071

1.236

1. 570

1. 831

1. 893

1. 849

1.769

1. 687

1.611

1.541

1.477

1.417

1.363

1.312

1.265

1.221

1.181

1.143

1.107

1.074

1.042

1.013

.9848

5

5

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1.0

1.0

3.0

3.0

3.0

3.0

3.0

1.5

1.5

1. 5'

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

2.0 10000.0

2.0 10000.0

3:4 960.0

3.4 960.0

3.4 960.0

3.4 960.0

3.4 960.0

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

1.7 636.9

212.67

212.67

353.43

353.43

353.43

353.43

353.43

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

42,.14 40.98

43.89 41.43

102.30 83.27

123.67 116.05

144.45 164.03

164.74 222.37

184.62 291. 21

241. 27 392.31

262.53 480.98

278.55 578.29

293.46 686.83

308.54 807.14

323.75 939.12

339.05 1082.70

354.42 1237.88

369.84 1404.65

385.28 1583.04

400.74 1773.09

416.20 1974.82

431.66 2188.30

447.11 2413.56

462.53 2650.65

477.94 2899.62

493.32 '3160.53

508.66 3433.41

523.98 3718.32

539.26 4015.30

554.51 4324.41

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO
3000. .9585 1 1.5 1.7 636.9 635.95 569.72 4645.68 NO

3500. .. 9357 2 1.5 1.7 636.9 635.95 495.84 461. 21 NO

4000. .9215 2 1.5 1.7 636.9 635.95 551.47 525.60 NO

. MAXIMUM 1-HR CONCENTRATION AT OR BEYOND 200. M:

1097. 1.893 1 1.5 1.7 636.9 635.95 277.95 574.19 NO

DWASH= MEANS NO CALC MADE (CONC = 0.0)

DWASH=NO MEANS NO BUILDING DOWNWASH USED

DWASH=HS MEANS HUBER-SNYDER DOWNWASH USED

DWASH=SS MEANS SCHULMAN-SCIRE DOWNWASH USED

DWASH=NA MEANS DOWNWASH NOT APPLICABLE, X<3*LB

************************************~**

*** SUMMARY OF SCREEN MODEL RESULTS ***

***************************************

CALCULATION

PROCEDURE

SIMPLE TERRAIN

MAX CONC

(UG/M**3)

1. 893

DISTTO

MAX (M)

1097.

TERRAIN

HT (M)

o.

***************************************************

** REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS **

***************************************************
02/18/05

09:42:13

*** SCREEN3 MODEL RUN ***

*** VERSION DATED 96043 ***

MeELMO MAIN FLARE-- NOx DISPERSION, 618,104 SCF/HR, 443 BTUISCF

SIMPLE TERRAIN INPUTS:

SOURCE TYPE =

EMISSION RATE (GIS)

FLARE STACK HEIGHT (M) =

TOT HEAT RLS (CALIS)

RECEPTOR HEIGHT (M)

URBANIRURAL OPTION

EFF RELEASE HEIGHT (M) =

BUILDING HEIGHT (M)

MIN HORIZ BLDG DIM (M) =

MAX HORIZ BLDG DIM (M)

FLARE

2 :21000

59.4500

.191799E+08

.0000

RURAL

73.2591

.. 0000

.0000

.0000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED.

THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 318.009 M**4/S**3j MOM. FLUX = 193.915 M**4/S**2.

*** FULL METEOROLOGY ***

**********************************

*** SCREEN AUTOMATED DISTANCES ***

**********************************

*** TERRAIN HEIGHT OF O. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES ***

DIST

(M)

CONC

(UG/M**3)

UI0M USTK MIX HT PLUME

STAB (MIS) (MIS) (M) HT (M)

SIGMA

Y (M)

SIGMA

Z (M) DWASH

200.

300.

400.

500.

600.

700.

800.

900.

1000.

1100.

1200.

1300.

1400.

1500.

1600.

1700.

1800.

1900.

2000.

2100.

2200.

2300.

2400.

2500.

2600.

2700.

2800.

2900.

.4666E-03

.5548E-03

.6661E-03

.2049E-Ol

.3019

.8718

1.266

1.755

2.089

2.143

2.061

1. 969

1. 876

1. 800

1.731

1. 667

1. 606

1. 550

1.497

1.447

1.401

1.358

1.317

1.278

1. 242

1.207

1.175

1.144

5

5

5

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1.0

1.0

1.0

3.0

3.0

3.0

3.0

2.0

2.0

2.0

2.0

2.0

2.0

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

2.0

2.0

2.0

3.4

3.4

3.4

3.4

2.3

2.3

2.3

2.3

2.3

2.3

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

10000.0

10000.0

10000.0

960.0

960.0

960.0

960.0

640.0

640.0

640.0

640.0

640.0

640.0

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

234.08

234.08

234.08

429.40

429.40

429.40

429.40

607.47

607.47

607.47

607.47

607.47

607.47

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

47.40

48.96

50.95

126.59

147.64

168.18

188.30

228.42

248.95

269.15

288.71

304.03

1319.45

360.99

375.46

390.04

404.72

419.46

434.26

449.09

463.96

478.84

493.74

508.64

523.54

538.43

553.32

568.19

46.37

46.76

47.20

119.17

166.85

224.94

293.55

384.54

473.71

573.82

684.81

805.43

937.65

1089.77

1244.06

1410.10

1587.88

1777.41

1978.71

2191. 81

2416.74

2653.55

2902.27

3162.96

3435.64

3720.38

4017.22

4326.19

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO
3000. 1.115 1 1.5 1.7 786.5 785.55 583.04 4647.34 NO

3500. 1.024 2 2.0 2.3 640.0 607.47 493.05 458.20 NO

4000. 1. 012 2 2.0 2.3 640.0 607.47 548.96 522.97 NO

MAXIMUM 1-HR CONCENTRATION AT OR BEYOND 200. M:

1075. 2.148 1 2.0 2.3 640.0 607.47 263.93 546.73 NO

DWASH=

DWASH=NO

DWASH=HS

DWASH=SS

DWASH=NA

MEANS

MEANS

MEANS

MEANS

MEANS

NO CALC MADE (CONC = 0.0)

NO BUILDING DOWNWASH USED

HUBER-SNYDER DOWNWASH USED

SCHULMAN-SCIRE DOWNWASH USED

DOWNWASH NOr APPLICABLE, X<3*LB

. (

***************************************

*** SUMMARY OF SCREEN MODEL RESULTS ***

***************************************

CALCULATION

PROCEDURE

SIMPLE TERRAIN

MAX CONC

(UG/M**3)

2.148

DIST TO

MAX (M)

1075.

TERRAIN

HT (M)

o.

***************************************************

** REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS **

***************************************************
03/24/05

14:30:42

*** SCREEN3 MODEL RUN ***

*** VERSION DATED 96043 ***

McELMO MAIN FLARE -- S02 DISPERSION, 618,104 SCFIHR, 300 BTUISCF, H2S 700 PPM

SIMPLE TERRAIN INPUTS:

SOURCE TYPE

EMISSION RATE (GIS)

FLARE STACK HEIGHT (M)

TOT HEAT RLS (CALIS)

RECEPTOR HEIGHT (M)

URBANIRURAL OPTION =

EFF RELEASE HEIGHT (M)

BUILDING HEIGHT (M) =

MIN HORIZ BLDG DIM (M)

MAX HORIZ BLDG DIM (M)

FLARE·

9.21000

59.4500

.129887E+08

.0000

RURAL

70.9117

.0000

.0000

.0000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED.

THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 215.356 M**4/S**3; MOM. FLUX = 131.320 M**4/S**2.

*** FULL METEOROLOGY ***

**********************************

*** SCREEN AUTOMATED DISTANCES ***

**********************************

*** TERRAIN HEIGHT OF o. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES ***

DIST

(M)

CONC

(UG/M**3)

Ul0M USTK MIX HT PLUME

STAB (MIS) (MIS) (M) HT (M)

SIGMA

Y (M)

SIGMA

Z (M) DWASH

200 ..

300.

400.

500.

600.

700.

800.

900.

1000.

1100.

1200.

1300.

1400.

1500.

1600.

1700.

1800.

1900.

2000.

2100.

2200.

2300.

2400.

2500.

2600.

2700.

2800.

2900.

.1213E-02

.1537E-02

.1224E-Ol

.5749

3.529

6.577

7.587

9.638

" 11. 24

11.63

11.35

10.86

10.36

9.889

9.460

9.066

8.703

8.367

8.056

7.768

7.499

7.249

7.015

6.797

6.592

6.399

6.218

6.047

5

5

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1.0

1.0

3.0

3.0

3.0

3.0

3.0

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

2.0

2.0

3.4

3,4

3.4

3.4

3.4

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

10000.0

10000.0

'960.0

960.0

960.0

960.0

960.0

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

212.67 42.14

212.67 43.89

353.43 102.30

353.43 123.67

353.43 144.45

353~43 164.74

353.43 184.62

635.95 - 241. 27

635.95 262.53

635.95 278.55

635.95 293.46

635.95 308.54

635.95 323.75

635.95 339.05

635.95 354.42

635.95 369.84

635.95 385.28

635.95. 400.74

635.95 416.20

635.95 431. 66

635.95 447.11

635.95 462.53

635.95 477.94

635.95 493.32

635.95 508.66

635.95 523.98

635.95 539.26

635.95 554.51

40.98

41.43

83.27

116.05

164.03

222.37

291.21

392.31

480.98

578.29

686.83

807.14

939.12

1082.70

1237.88

1404.65

1583.04

1773.09

1974.82

2188.30

2413.56

2650.65

2899.62

3160.53

3433.41

3718.32

4015.30

4324.41

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO
3000. 5.885 1 1.5 1.7 636.9 635.95 569.72 4645.68 NO

3500. 5.745 2 1.5 1.7 636.9 635.95 495.84 461. 21 NO

4000. 5.658 2 1.5 1.7 636.9 635.95 551.47 525.60 NO

Mf\XIMUM l-HR CONCENTRATION AT OR BEYOND 200. M:

1097. 11.63 1 1.5 1.7 636.9 635.95 277.95 574.19 NO

DWASH=

DWASH=NO

DWASH=HS

DWASH=SS

DWASH=NA

MEANS

MEANS

MEANS

MEANS

MEANS

NO CALC MADE (CONC = 0.0)

NO BUILDING DOWNWASH USED

HUBER-SNYDER DOWNWASH USED

SCHULMAN-SCIRE DOWNWASH USED

DOWNWASH NOT APPLICABLE, X<3*LB

***************************************

*** SUMMARY OF SCREEN MODEL RESULTS ***

***************************************

CALCULATION

PROCEDURE

SIMPLE TERRAIN

MAX CONC

(UG/M**3)

11.63

D:tST TO

MAX (M)

1097.

TERRAIN

HT (M)

o.

***************************************~***********

** REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS **

***************************************************
03/28/05

06:03:09

*** SCREEN3 MODEL RUN ***

*** VERSION DATED 96043 ***

MeELMO MAIN FLARE -- S02 DISPERSION, 618,104 SCF/HR, 443 BTU/SCF, H2S 700 PPM

SIMPLE TERRAIN INPUTS:

SOURCE TYPE = EMISSION RATE (G/S)

FLARE STACK HEIGHT (M)

TOT HEAT RLS (CAL!S)

RECEPTOR HEIGHT (M)

URBAN/RURAL OPTION

EFF RELEASE HEIGHT (M) =

BUILDING HEIGHT (M)

MIN HORIZ BLDG DIM (M)

MAX HORIZ BLDG DIM (M)

FLARE

9.21000

59.4500'

.191799E+08

.0000

RURA:J:,'

73.2591'

.0000,:

.0000

.0000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED.

THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT.~F 10.0 METERS WAS ENTERED.

BUOY. FLUX = 318.009 M**4/S**3; MOM. FLUX = 193.915 M**4/S**2. '( ,-;

*** FULL METEOROLOGY ***

**********************************

*** SCREEN AUTOMATED DISTANCES ***

**********************************

*** TERRAIN HEIGHT OF O. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES ***

DIST

(M)

CONC

(UG/M**3)

U10M USTK MIX HT PLUME

STAB (M/S) (M/S) eM) HT (M)

SIGMA

Y (M)

SIGMA

Z (M) DWASH

10000.0

10000.0

100QO.0

, 96.0.0

96'0.0

960.0

96'.0.0.

6.40.0

6~O.0

640.0

640.0

64:0.0

:1640.0

) 786.5

786.5

.'786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

786.5

47.40

48.96

50.95

126.59

147.64

168.18

188.30

228.42

248.95

269.15'

288.71

304.03

319.45

360.99

375.46

390.04

404.72

419.46

434.26

449.09

463.96

478.84

493.74

508.64

523.54

538.43

553.32

568.19

200.

300.

400.

500.

600.

700.

800.

900.

1000.

1100.

1200.

1300.

1400.

1500.

1600.

1700.

1800.

1900.

2000.

2100.

2200.

2300.

2400.

2500.

2600.

2700.

2800.

2900.

.1945E-02

.2312E-02

.2776E-02

.8538E-01

1. 258

3.633

5.276

7.314

8.704

8.931

8.589

8.207

7.816

7.503

7.215

6.945

6.694

6.458

6.238

6.032

5.839

5.657

5.487

5.326

5.174

5.031

4.896

4.768

5

5

5

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1.0

1.0

1.0

3.0

3.0

3.0

3.0

2.0

2.0

2.0

2.0

2.0

2.0

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

2.0

2.0

2.0

3.4

3.4.,

3.4

3.4'

2.3

2.3

2.3

2.3

2.3

2.3'

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1,7

234 .~08

234.08

234.08

429.40

429.40

429.40

429.40

607.47

'607.47

607.47

607.47

607.47

607.47

78,5.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

46.37

46.76

47.20

119.17

166.85

224.94

293.55

384.54

473.71

573.82

684.81

805.43

937.65

1089.77

1244.06

1410.10

1587.88

1777.41

1978.71

2191.81

2416.74

2653.55

2902.27

3162.96

3435.64

3720.38

4017.22

4326.19

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO
3000. 4.646 1 1'.5 1.7 786.5 785.55 583.04 '4647.34 NO

3500. 4.268 2 2.0 2.3 640.0 607.47 493.05 458.20 NO

4000. 4.216 2 2. O. 2.3 640.0 607.47 548.96 522.97 NO

MAXIMUM 1-HR CONCENTRATION AT OR BEYOND 200. M:

1075. 8.951 1 2.0 2.3 640.0 607.47 263.93 546.73 NO

DWASH= MEANS NO CALC MADE (CONC = 0.0)

DWASH=NO MEANS NO BUILDING DOWNWASH USED

DWASH=HS MEANS HUBER-SNYDER DOWNWASH USED

DWASH=SS MEANS SCHULMAN-SCIRE DOWNWASH USED

DWASH=NA MEANS DOWNWASH NOT APPLICABLE, X<3*LB

***************************************

*** SUMMARY OF SCREEN MODEL RESULTS ***

********************~******************

CALCULATION

PROCEDURE

SIMPLE TERRAIN

MAX CONC

(UG/M**3)

8.951

DIST TO

MAX (M)

1075.

TERRAIN

HT (M)

o.

***************************************************

** REMEMBER TO INCLUDE BACKGROUND·CONCENTRATIONS **

***************************************************
02/22/05

11:05:15

*** SCREEN3 MODEL RUN *** *** VERSION DATED 96043 ***

MeELMO MAIN FLARE -- CO DISPERSION, 618,104 SCF/HR, 300 BTU/CF

SIMPLE TERRAIN INPUTS:

SOURCE TYPE

EMISSION RATE (G/S)

FLARE STACK HEIGHT (M)

TOT HEAT RLS (CAL/S) =

RECEPTOR HEIGHT (M)

URBAN/RURAL OPTION

EFF RELEASE HEIGHT (M) =

BUILDING HEIGHT (M)

MIN HORIZ BLDG DIM (M) =

MAX HORIZ BLDG DIM (M)

FLARE

12.8400

59.4500

.129887E+08

.0000

RURAL

70.9117

.0000

.0000

.0000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED.

THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 215.356 M**4/S**3; MOM. FLUX = 131.320 M**4/S**2.

*** FULL METEOROLOGY ***

*********************************.

*** SCREEN AUTOMATED DISTANCES ***

**********************************

*** TERRAIN HEIGHT OF O. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES ***

DIST

(M)

CONC

(UG/M**3 )

Ul0M USTK MIX HT PLUME

STAB (M/S) (M/S) (M) HT (M)

SIGMA

Y (M)

SIGMA

Z (M) DWASH

42.14

43.89

102.30

123.67

144.45

164.74

184.62

241. 27

262.53

278.55

293.46

308.54'

323.75

339.05

354.42

369.84

385.28

400.74

416.20

431. 66

447.11

462.53

477.94

493.32

508.66

523.98

539.26

554.51

200.

300.

400.

500.

600.

700.

800.

900.

1000.

1100.

1200.

1300.

1400.

1500.

1600.

1700.

1800.

1900.

2000.

2100.

2200.

2300.

2400.

2500.

2600.

2700.

2800.

2900.

.1691E-02

.2143E-02

.1707E-01

.8015

4.920

9.169

10.58

13 .44

15.67

16.21

15.83

15~14

14.44

13.79

13.19

12.64

12.13

11. 66

11.23

10.83

10.45

10.11

9.780

9.476

9.190

8.921

8.668

8.430

5

5

1

1

1

1

.1

1

1

1

1

1

1

1

1

1

1

1

1

1·

1

1

1

1

1

1

1

1

1.0

1.0

3.0

3.0

3.0

3.0

3.0

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

2.0

2.0

3.4

3.4

3.4

3.4

3.4

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1.7

1:7

1.7

1.7

1.7

10000.0

10000.0

960.0

960.0

960.0

960.0

960.0

636~9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636.9

636 ..9

636.9

636.9

212.67

212.67

353.43

353.43

353.43

353.43

353.43

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

635.95

40.98

41.43

83.27

116.05

164.03

222.37

291.21

392.31

480.98

578.29

686.83

807.14

939.12

1082.70

1237.88

1404.65

1583.04

1773.09

1974.82

2188.30

2413.56

2650.65

2899.62

3160.53

3433.41

3718.32

4015.30

4324.41

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO
, 3000. 8.205 1 L5 1.7 636.9 635.95 569.72 4645.68 NO

3500. 8.010 2 1.5 1.7 636.9 635.95 495.84 461. 21 NO

4000. 7.888 2 1.5 1.7 636.9 635.95 551.47 525.60 NO

MAXIMUM l-HR CONCENTRATION AT OR BEYOND 200. M:

1097. 16.21 1 1.5 1.7 636.9 635.95 277.95 574.19 NO

DWASH= MEANS NO CALC MADE (CONC = 0.0)

DWASH=NO MEANS NO BUILDING DOWNWASH USED

DWASH=HS MEANS HUBER-SNYDER DOWNWASH USED

DWASH=SS MEANS SCHULMAN-SCIRE DOWNWASH USED

DWASH=NA MEANS DOWNwASH NOT APPLICABLE, X<3*LB

***************************************

*** SUMMARY OF SCREEN MODEL RESULTS ***

***************************************

CALCULATION

PROCEDURE·

SIMPLE TERRAIN

MAX CONC

(UG/M**3)

16.21

DIST TO

MAX (M)

1097.

TERRAIN

HT (M)

o.

***************************************************

** REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS **

***************************************************
FLARE

18.9600

59.4500

.191799~+Q8

.0000

RUR.AI,

73.2591

.0000

.0000

.0000,

02/18/05

09:49:45

*** SCREEN3 MODEL RUN *** *** VERSION DATED 96043 ***

McELMO MAIN FLARE -- CO DISPERSION, 618,104 SCFIHR, 443 BTUISCF

SIMPLE TERRAIN INPUTS:

SOURCE TYPE = EMISSION RATE (GIS)

FLARE STACK HEIGHT (M)

TOT HEAT RLS (CALiS)

RECEPTOR HEIGHT (M) =

URBANIRURAL OPTION

EFF RELEASE HEIGHT (M)

BUILDING HEIGHT (M)

MIN HORIZ BLDG DIM (M)

MAX HORIZ BLDG DIM (M)

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED.

THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT',QF 10. 0 METERS WAS ENTERED.

BUOY. FLUX = 318.009 M**4/S**3;

*** FULL METEOROLOGY ***

MOM. FLUX = 193.915 M**4/S**2. , -,;

***********************~**********

*** SCREEN AUTOMATED DISTANCES ***

**********************************

***TERRAIN HEIGHT OF O. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES ***

DIST

(M)

CONC

(UG/M**3)

U10M USTK MIX HT PLUME

STAB (MiS) (MIS) (M) HT (M)

SIGMA

Y (M)

SIGMA

Z (M) DWASH

200.

300.

400.

500.

600.

700.

800.

900.

1000.

1100.

, 1200.

1300.

1400.

1500.

1600.

1700.

1800.

1900.

2000.

2100.

2200.

2300.

2400.

2500.

2600.

2700.

2800.

2900.

.4003E-02

.4760E-02

.5715E-02

.1758

2.590

7.479

10.86

15.06

17.92

18.39

17.68

16.89

16.09

15.45

14.85

14.30

13.78

13 .30

12.84

12.42

12.02

11.65

11. 30

10.96

10.65

10.36

10.08

9.815

5

5

5

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1.0

1.0

1.0

3.0

3.0

3.0

3.0

2.0

2.0

2.0

2.0

2.0

2.0

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

1.5

2.0 10000.0

2.0 10000.0

2.0 10000.0

3.4 960.0.

3.4.960.0

3.4 960.0

3.4' 960.0

2.3 6,40.0

2.3 640.0

2.3 640.0

2.3 640.0,

2.3 640.0

2 . 3'\ 6:.40. 0

1.7, 786.5

1.7 786.5

1.7 786.5

1.7 786.5

1.7 786.5

1.7 786.5

1.7 786.5

1.7 786.5

1.7 786.5

1.7 786.5

1.7 786.5

1.7 786.5

1.7 786.5

1.7 786.5

1.7 786.5

234.08

234.08

234.08

429.40

429.40

429.40

429.40

607.47

607.47

607.47

607.47

607.47

607.47

785.55

7'85.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

785.55

47.40

48.96

50.95

126.59

147.64

168.18

188.30

228.42

248.95

269.15

288.71

304.03

319.45

360.99

375.46

390.04

404.72

419.46

434.26

449.09

463.96

478.84

493.74

508.64

523.54

538.43

553.32

568.19

46.37

46.76

47.20

119.17

166.85

224.94

293.55

384.54

473.71

573.82

684.81

805.43

937.65

1089.77

1244.06

1410.10

1587.88

1777.41

1978.71

2191.81

2416.74

2653.55

2902.27

3162.96

3435.64

3720.38

4017.22

4326.19

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO
3000. 9.565 1 1.5 1.7 786.5 785.55 583.04 4647.34 NO

3500. 8.786 2 2.0 2.3 640.0 607.47 493.05 458.20 NO

4000. 8.679 2 2.0 2.3 640.0 607.47 548.96 522.97 NO

MAXIMUM 1-HR CONCENTRATION AT OR BEYOND 200. M:

1075. 18.43 1 2.0 2.3 640.0 607.47 263.93 546.73 NO

DWASH= MEANS NO CALC MADE (CONC = 0.0)

DWASH=NO MEANS NO BUILDING DOWNWASH USED

DWASH=HS MEANS HUBER-SNYDER DOWNWASH USED

DWASH=SS MEANS SCHULMAN-SCIRE DOWNWASH USED

DWASH=NA MEANS DOWNWASH NOT APPLICABLE, X<3*LB

***************************************

*** SUMMARY OF SCREEN MODEL RESULTS ***

***************************************

CALCULATION

PROCEDURE

SIMPLE TERRAIN

MAX CONC

(UG/M**3)

18.43

DIST TO

MAX (M)

1075.

TERRAIN

HT (M)

o.

***************************************************

. ** REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS **

***************************************************