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• <br />The oxidizer will utilize propane as a supplemental fuel (stand-by mode) and also <br />to bring the oxidizer to the proper operating temperature before retort products are routed <br />to the unit (start-up and shutdown). Besides sulfur compounds, combustion at the thermal <br />oxidizer will result in emissions of nitrogen oxides (NOx), carbon monoxide (CO) and <br />other combustion products. <br />Combustion emissions for the oxidizer were based on the expected volumes for <br />propane, production gas and production oil (naptha and gas oil) over the R&D test period. <br />Propane will be used intermittently (start-up, shutdown, and standby operation), and the <br />estimated propane consumption factors in the expected use over these operating periods. <br />The produced oil and gas combustion enissions were calculated based on the expected <br />evolution of retort products for 4,200 tons of shale. Please refer to the attached electronic <br />spreadsheet for data on the fuel volumes used for the emission calculations. <br />Combustion emissions (except for SO2 which was covered earlier) were estimated <br />using relevant emission factors from AP-42. For propane, these emission factors were <br />from AP-42, Section 1.5 (LPG Combustion). For the produced oil, emission factors were <br />taken from AP-42, Section 1.3 (Fuel Oil Combustion). Data on #6 fuel oil were used as <br />the produced oil is expected to more closely represent this fuel compared to other liquid <br />fuel oil choices within AP-42. Also, #6 fuel oil tends to have higher emissions compared <br />to other liquid fiiels, snaking emission estimates using these factors conservative. For <br />produced gas, enuission factors from AP-42 Section 1.4 (Natural Gas Combustion) were <br />selected. Based on engineering data, the produced gas will have an energy value similar <br />to that of natural gas (about 1,000 Btu/scf). <br />Total oxidizer combustion emissions were calculated based on the sum of the <br />emissions from each combustion fuel. Emissions were calculated for the following <br />pollutants: PM/PM-10, NOx, volatile organic compounds (VOC), and CO. <br />Fugitive Component Leak Emissions <br />VOC emissions and associated hazardous au- pollutant (HAP) emissions were <br />calculated utilizing the oil and gas production operations average emission factors listed <br />in Table 2-4 from the "Protocol for Equipment Leak Emission Estimates" <br />(EPA-453/R-95-017, November 1995) and the VOC content of each stream (where <br />appropriate). <br />Speciation profiles for each product stream have been developed by AMSO based <br />on engineering projections of the various retort products (See Attachment 5). These <br />profiles were used to select the appropriate service for each stream as well as obtain the <br />VOC content and HAP content for each stream. The appropriate service and VOC <br />content for each product stream is summarized in the table below. <br />Page 21 of 46