1

Addressing Air Quality Impacts from Oil and Gas Development in

Colorado

WESTAR ConferenceOctober 23, 2008

Rose WaldmanColorado Air Pollution Control Division

2

3

Current Rule Requirements Condensate Tanks (VOCs) Ozone Control Area (OCA)

– System-wide control by company at 75% (from 5/1 to 9/30); at 70% (rest of year)

– Control device at 95%– Control not required at tank/batteries with ≤ 730 bbls/yr

(~ 5 tpy)– Exemption for companies with total operations of < 30

tpy (uncontrolled)

Statewide– Control at 95% required at tank/batteries with ≥ 20 tpy

(uncontrolled)

4

Current Rule Requirements (cont.)

Gas Processing Plants in OCA (VOCs) – LDAR, NSPS Subpart KKK applies regardless of

construction date

– Condensate tanks must be controlled at 95% if not stabilized and if ≥ 1 tpy (uncontrolled)

Glycol Dehydrators in OCA & Statewide (VOCs) – Control vents at 90% ≥ 15 tpy (uncontrolled)

5

Current Rule Requirements (cont.) RICE Statewide (NOx, CO, & VOCs)

Maximum Engine HP

Construction or Relocation

Date

Emission Standards (G/hp-hr)

NOx CO VOC

100<HP<500 1/1/081/1/11

2.01.0

4.02.0

1.00.7

500<HP 7/1/077/1/10

2.01.0

4.02.0

1.00.7

6

Ozone Non-Attainment Status Denver Metro North Front Range 9-county area

became non-attainment on 11/20/07

APEN threshold reduced from 2 tpy to 1 tpy

Permit threshold reduced from 5 tpy to 2 tpy (VOCs), 10 tpy to 5 tpy (NOx)

SIP Development Proposing new rules/regulations Possible implementation date 2/1/09

7

Proposed Rule Changes

Condensate Tanks (NAA) Move from system-wide to threshold approach New/modified tanks ≥ 2 tpy at 95% by 2/1/09 Existing tanks ≥ 10 tpy at 95% by 5/1/10 Existing tanks ≥ 5 tpy at 95% by 5/1/2011 Existing tanks ≥ 2 tpy at 95% by 5/1/2012 Control all tanks at 95% 1st 90 days (new/modified) Auto-ignitor and electronic surveillance at controlled

locations (new, modified, existing) Removing 30 tpy exemption Increase ozone season control from 75% to 80% (last

season of system-wide approach) Statewide rules may be proposed next spring

8

Proposed Rule Changes (cont.)

Pneumatic Controllers (NAA) 1st time source being regulated Most controllers must be low-bleed

(new: 2/1/09, existing: 5/1/09) Enhanced maintenance, inspection, and

recordkeeping for remaining high-bleeds Statewide rules may be proposed next

spring

9

Proposed Rule Changes (cont.)

Statewide RICE (existing) Install controls if >500 hp Rich burn: NSCR and air fuel controller by

5/12/2010 Lean burn: oxidation catalyst by 5/1/2010 Not required at ≥ $5,000 per ton reductions

10

Potential future strategies

Leak detection/maintenance at E&P sites and compressor stations

Drill rigs (NOx)

Miscellaneous oil and gas equipment

11

House Bill 1341 – Enforced by COGCC

Condensate/produced water/crude oil tanks - located in 3 counties within ¼ mile of affected buildings - control at 95% if source ≥ 5 tpy Glycol dehydrators

- located in 3 counties within ¼ mile of affected buildings - control at 90% if source ≥ 5 tpy Production Pits

- located in 3 counties within ¼ mile of affected buildings - control at 95% if source > 5 tpy Pneumatic devices shall be low-bleed if technically feasible

(new/modified Statewide) Green completions

- Statewide, unless exempt due to field conditions Control requirements will be reflected in an APCD-issued permit

12

House Bill 1341 - continued

COGCC hearing: Dec. 9-11, 2008

Implementation date: Feb. 1, 2009 (pending)

Compliance date: Oct. 1, 2009, for most air related rules (pending)

COGCC and CDPHE interaction– Revises permitting process for COGCC and adds

a consultation component