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Colorad o Reg. 7 2014 Revisions

Colorad o Reg. 7 2014 Revisions. Jul 10 | 2014 Marley Bain. Storage Tank Emission Management. Reg. 7 Revisions – Overview . Revisions to Reg. 7 adopted February 2014, effective April 2014

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Colorad o Reg. 7 2014 Revisions

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  1. Colorado Reg. 7 2014 Revisions Jul 10 | 2014 Marley Bain Storage Tank Emission Management

  2. Reg. 7 Revisions – Overview • Revisions to Reg. 7 adopted February 2014, effective April 2014 • AQCC Regulation Number 7 – Control of Ozone Via Ozone Precursors and Control of Hydrocarbons Via Oil and Gas Emissions (VOC regulation) • Section XII and XVII focus on Oil and Gas emissions • XII: Ozone non-attainment area • XVII: State-wide • Enforced by CDPHE

  3. Reg. 7 Revisions - Outcome • Expansion of several non-attainment area requirements statewide • Low bleed or intermittent bleed pneumatics • Control of storage tank emissions at lower thresholds • New requirements not previously included in Section XII • Definition of ‘hydrocarbon’ includes methane/ethane • Leak detection and repair (LDAR) requirements • Audio, visual, olfactory (AVO) checks • Well unloading and maintenance • Storage tank emission management (STEM)

  4. STEM Overview Purpose: Develop a Plan(s) to meet the storage tank “without venting” requirements. • Required for storage tanks with VOC emissions > 6tpy (rolling 12-month uncontrolled actuals) • NOT required for storage tanks containing stabilized liquids or tanks controlled during the first 90 days of production • Implementation of STEM Plan

  5. STEM Plan (XVII.C.2.b.(i)) • Selected control technologies • Monitoring practices • Operational practices and/or other strategies • Procedures for evaluating ongoing storage tank emission capture performance • Monitoring with “Approved Instrument Monitoring Method” (AIMM) • Specific implementation schedule for AIMM • Certification by the owner or operator that the STEM strategies are designed to minimize emissions from storage tanks and associated equipment • Additional requirements in Statement of Basis and Purpose

  6. AIMM Frequency – new tanks • AIMM is a defined term in the rule

  7. AIMM Frequency – new tanks • AIMM is a defined term in the rule

  8. Recordkeeping (XVII.C.3) • STEM Plan, updates, and certification • Records of monitoring (kept for 2 years) • Tank AIRS ID • Date and duration of any period of thief hatch, prv, or other access point venting (except as allowed) • Date and duration of periods when control equipment is not operating • Timing of and efforts made to eliminate venting, restore operation of control equipment, and mitigate visible emissions • List of equipment associated with tank that is designated as unsafe, difficult, or inaccessible to monitor – including explanation of designation and monitoring plan

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