Odds and Ends Supplement, Archive 3

Sweet Smell of Success

1.       At 98% recovery, the annual production of citronellyl oxyacetaldehyde is approximately 6.4 pounds resulting in an annual revenue stream of a tad over $1 MM.

2.       The CDPHE would likely conduct an investigation, but would be unlikely to pursue any enforcement action. Regulation No. 2 (Odor) prohibits any odorous emission that is detectable in air diluted with either 7 or 15 volumes (depending on location) of odor-free air, but there is also the following provision:

When the source is a manufacturing process, the source shall have an affirmative defense to a violation of Sections I.A. and I.B., Part A, of this Regulation Number 2, provided that the source demonstrates that it is utilizing the best practical treatment, maintenance, and control currently available in order to maintain the lowest possible emission of odorous gases. In determining whether the source has met its burden of utilizing the best practical control methods, the source need not consider any method which would result in an arbitrary and unreasonable taking of property or in the practical closing of any lawful business or activity, if such would be without corresponding public benefit
 

Since GreenJeans maintains positive pressure and a Vapor Recovery system on the plant, I believe that would demonstrate the use of the best practical control to maintain the lowest possible emissions. (Assuming that at a dilution of 127:1, the odor is undetectable).

The COGCC new odor regulation (805 b.) requires control on produced water sources with a potential to emit 5 tons per year or more of volatile organic compounds. The COGCC could not pursue any enforcement action since the emission is well below the 5 tons per year (TPY) threshold. Even if the emission exceeded the 5 TPY limit, the tanks are ‘legal’ since they are controlled.