SHELL PRODUCES APPROXIMATELY 100,000 BARRELS PER DAY OF OIL FROM BELRIDGE FIELD. THE GROSS PRODUCTION FROM THE PRODUCTION WELLS ALSO CONTAINS 6 TO 8 MILLION STANDARD CUBIC FEET OF PRODUCED GAS, WHICH INCLUDES HYDROCARBONS AND H2S. THE PRODUCED GAS IS COLLECTED IN A VAPOR RECOVERY SYSTEM AT TWO DEHYDRATION PLANTS (DEHY PLANTS). THE AUTHORITY TO CONSTRUCT ( ATC ) FOR THE DEHY PLANTS REQUIRED THE COLLECTED PRODUCED GAS TO BE BURNED IN SCRUBBED STEAM GENERATORS, STATED THAT THE PRODUCED MUST NOT BE VENTED TO THE ATMOSPHERE, AND LIMITED THE USE OF FLARES TO BURN THE PRODUCED GAS TO NO MORE THAN 12 DAYS PER YEAR. SHELL VIOLATED ITS ATC CONDITIONS BY PERIODICALLY VENTING THE PRODUCED GAS TO THE ATMOSPHERE AND FREQUENTLY OPERATING ITS FLARES IN VIOLATION OF THE FEDERALLY ENFORCEABLE KCAPCD RULE 201 (ATC). SHELL ALSO SUBMITTED INACCURATE REPORTS IN VIOLATION OF FEDERALLY ENFORCEABLE RULE 111. THESE VIOLATIONS OF SECTION 110 OF THE CLEAN AIR ACT ARE THE BASIS OF THIS REFERRAL.