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Olsson can help oil and gas operators navigate stricter air pollution regulations

Thursday, March 20, 2014

Tony Barlage, Air Consulting

With sweeping new regulations put in place last month by the Colorado Air Quality Control Commission (AQCC), oil and gas operators will need to intensify their compliance efforts to meet the requirements of the stricter regulations. In response, Olsson Associates has added staff members, training, and equipment to respond to these new regulatory requirements.

Tougher regulations to address issues

In February, the AQCC adopted tougher air pollution regulations regarding volatile organic compound emissions. Colorado also became the first state to directly regulate methane emissions from oil and gas production. The new regulations address a variety of issues, including stricter control requirements, increased emissions monitoring, leak detection and repair, and associated record keeping and reporting requirements. Implementation dates range from May 2014 for new operations to January 2016 for existing sites.

Leak detection and repair inspections

One new regulatory provision establishes leak detection and repair (LDAR) program requirements for components at oil and gas facilities upstream of natural gas processing plants, including compressor stations and well production facilities. Inspection frequency will be based on actual uncontrolled emissions at exploration and production sites. Olsson has equipment, such as optical gas imaging cameras, and trained staff members to perform inspections and handle reporting requirements for the LDAR program.

Other key aspects of the stricter air pollution regulations include the following:

  • Limiting “venting” and establishing a storage tank emissions monitoring system. These actions will require operators to evaluate and use appropriate control technologies, monitoring practices, and operational practices to eliminate leaks and venting.
  • Establishing new and expanding recordkeeping and reporting requirements associated with required inspections and maintenance, including a two-year time period to keep records and an annual report submittal to the AQCC.
  • Expanding storage tank control requirements to hydrocarbon liquid storage tanks covered by New Source Performance Standard OOOO regulations with emissions over newly defined levels.
  • Creating new glycol dehydrator control requirements and adding control requirements for new and existing dehydrators based on their proximities to buildings and/or designated outdoor activity areas.
  • Creating more stringent air pollution control practices, expanding pneumatic device requirements, and instituting an eventual phase out and replacement of high bleed pneumatic devices statewide, as well as requiring the use of auto-igniters on combustors statewide.

Olsson can help

Olsson was directly involved with the Colorado Oil and Gas Association, the Colorado Petroleum Association, and the Joint Industry Workgroup as a stakeholder in the development process for the new regulations. Further, Olsson has a strong air quality team that provides full-service compliance support to small and mid-sized oil and gas operators. Olsson can also supplement in-house compliance and field service teams at larger firms. If you have any questions about the new air quality regulations, please contact Olsson at 303.237.2072.

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