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Reficar Cartagena Refinery Expansion, Colombia - EKN

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vicinity of the existing refinery. It is impossible to reconcile these discrepancies without<br />

1101335.000 04F1 0611 MJ21<br />

41<br />

June 21, 2011<br />

additional information concerning the basis for emissions calculations for the Mamonal sources.<br />

It is also impossible to confirm whether the cumulative predicted impacts from the refinery and<br />

other sources in the Mamonal Industrial Area together would exceed applicable permissible<br />

standards without having modeled all sources together.<br />

There is no assessment of the impact of existing or proposed scenarios on ambient air pollutant<br />

concentrations for pollutants other than PM10, SO2, and NO2. Thus, it is impossible to<br />

determine whether or not the Project will create an issue with ozone, CO, heavy metals, or other<br />

pollutants (e.g., VOCs). The EIA also does not address the effect of the Project on greenhouse<br />

gas (GHG) emissions or global climate; however, an IDB study apparently estimated GHG<br />

emissions of approximately 100,000 tons/year. The modeling also does not address potential<br />

fugitive emissions of PM10 (e.g., coke and sulfur transfer) or VOCs (e.g., vents, floating roof<br />

storage tanks, pressure relief valves, and loading and unloading of raw materials [crude] or<br />

product).<br />

Air dispersion modeling for the Site will be performed to predict the maximum ground level<br />

concentration (GLCmax) of nitrogen oxides (NOX), sulfur dioxide (SO2), carbon monoxide (CO),<br />

and particulate matter (PM10) from the expanded refinery within and around the refinery fence<br />

line. The baseline emissions from current refinery operations plus the surrounding industrial<br />

facilities will be established by conducting real-time ambient air sampling with the refinery<br />

fence line, as well as at critical receptor locations (such as Membrillal, a restaurant,<br />

Pasacaballos) around the refinery fence line.<br />

New plant modifications will result in a reduction of air emissions from the new refinery and no<br />

net impact to the Mamonal Industrial Area airshed. NO2 total load will increase but the<br />

permissible limits will be met (Resolution 601, 2006, Tables 5 and 6). Confirmational air<br />

sampling and dispersion modeling will be performed at the Site to establish a baseline. This<br />

modeling program is designed to meet the issues listed in Table 7, using the following<br />

protocols:

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