proposed revisions to colorado air quality control commission regulation no. 7 garry kaufman air...

Proposed Revisions to Colorado Air Quality Proposed Revisions to Colorado Air Quality Control Commission Regulation No. 7Control Commission Regulation No. 7

Garry KaufmanGarry Kaufman

Air Pollution Control DivisionAir Pollution Control Division

Introduction

The Colorado Air Pollution Control The Colorado Air Pollution Control Division is proposing two separate sets of Division is proposing two separate sets of revisions to Colorado Air Quality Control revisions to Colorado Air Quality Control Commission Regulation No. 7 for the Commission Regulation No. 7 for the control of air emissions from oil and gas control of air emissions from oil and gas operations in Coloradooperations in Colorado

Introduction

The first set of revisions tightens existing emission The first set of revisions tightens existing emission control requirements set forth in Regulation No. 7, control requirements set forth in Regulation No. 7, Section XII for condensate tanks located in the 8-Section XII for condensate tanks located in the 8-Hour Ozone Control AreaHour Ozone Control Area The existing requirements were adopted in The existing requirements were adopted in

connection with the Early Action Compact connection with the Early Action Compact Ozone Action Plan (“EAC”) entered into Ozone Action Plan (“EAC”) entered into between the State of Colorado and EPAbetween the State of Colorado and EPA

Introduction

The second set of revisions establishes The second set of revisions establishes statewide controls for condensate tanks, statewide controls for condensate tanks, natural gas fired engines and natural gas natural gas fired engines and natural gas dehydratorsdehydrators

EAC Revisions: Background

Colorado and EPA entered into the EAC as a means of Colorado and EPA entered into the EAC as a means of deferring an ozone non-attainment designation for Adams, deferring an ozone non-attainment designation for Adams, Arapahoe, Boulder, Douglas and Jefferson Counties, the Arapahoe, Boulder, Douglas and Jefferson Counties, the Cities and Counties of Denver and Broomfield and parts of Cities and Counties of Denver and Broomfield and parts of Larimer and Weld Counties (“8-Hour Ozone Control Area’)Larimer and Weld Counties (“8-Hour Ozone Control Area’)

The EAC was a response to monitoring data along the front The EAC was a response to monitoring data along the front range showing exceedances of the federal 8-Hour ozone range showing exceedances of the federal 8-Hour ozone standardstandard

As part of the EAC process, the AQCC promulgated As part of the EAC process, the AQCC promulgated Regulation No. 7, Section XII requiring controls for Regulation No. 7, Section XII requiring controls for condensate tanks, natural gas dehydrators and certain natural condensate tanks, natural gas dehydrators and certain natural gas fired engines located in the 8-Hour Ozone Control Areagas fired engines located in the 8-Hour Ozone Control Area


The EAC approach requires cleaner air The EAC approach requires cleaner air faster than standard air quality requirementsfaster than standard air quality requirements

There are incentives for the StateThere are incentives for the State No nonattainment designationNo nonattainment designation Lesser permitting requirementsLesser permitting requirements No transportation conformityNo transportation conformity


As part of the milestones set forth in the EAC , VOC As part of the milestones set forth in the EAC , VOC emissions from condensate tanks in the 8-Hour Ozone emissions from condensate tanks in the 8-Hour Ozone Control Area were not to exceed 91.3 tons per day for Control Area were not to exceed 91.3 tons per day for the period from May 1 through September 30 (‘Ozone the period from May 1 through September 30 (‘Ozone Season) 2007, and were not to exceed 100.9 tpd for the Season) 2007, and were not to exceed 100.9 tpd for the ozone season 2012ozone season 2012

To achieve these numbers, Regulation No. 7, Section XII To achieve these numbers, Regulation No. 7, Section XII provides, in part that owners and operators of condensate provides, in part that owners and operators of condensate tanks in the 8-Hour Ozone Control Area achieve an tanks in the 8-Hour Ozone Control Area achieve an overall VOC emission reduction of 47.5% during the overall VOC emission reduction of 47.5% during the Ozone Seasons for the years 2006 and beyondOzone Seasons for the years 2006 and beyond


The 47.5% reduction requirements was premised The 47.5% reduction requirements was premised on growth projections that indicated that on growth projections that indicated that uncontrolled VOC emissions from condensate uncontrolled VOC emissions from condensate tanks in the 8-Hour Ozone Control area would be tanks in the 8-Hour Ozone Control area would be 146.1 tpd in 2007146.1 tpd in 2007

Actual data shows that uncontrolled emissions Actual data shows that uncontrolled emissions from condensate tanks in 2005 totaled 195.3 tpdfrom condensate tanks in 2005 totaled 195.3 tpd

Current growth projections forecast 236.4 tpd Current growth projections forecast 236.4 tpd during 2007during 2007


133.7

154.2

195.3

215.8

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236.4

256.9

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2001 2002 2003 2004 2005 2006 2007 2008

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Inventoried Emissions Modeled Emissions

Projected Uncontrolled Annual Daily Average VOC Growth Rate = 20.5 tons/day


The Division is required to periodically The Division is required to periodically assess the underlying assumptions of assess the underlying assumptions of the Ozone Action Planthe Ozone Action Plan The overarching goal is to maintain The overarching goal is to maintain

the integrity of the EAC and avoid a the integrity of the EAC and avoid a nonattainment designationnonattainment designation

EPA’s next scheduled date to decide EPA’s next scheduled date to decide whether to defer the NAA designation whether to defer the NAA designation is Sept 2006is Sept 2006


EPA has indicated that unless new control EPA has indicated that unless new control strategies that reduce condensate tank strategies that reduce condensate tank emissions to 91.3 tpd are put in place by emissions to 91.3 tpd are put in place by May 1, 2007, the EAC will be retracted and May 1, 2007, the EAC will be retracted and the area will be designated as a non-the area will be designated as a non-attainment areaattainment area

EAC Area: Proposed Revisions

The proposed revisions are intended to The proposed revisions are intended to accomplish two objectives:accomplish two objectives: Ratchet down control requirements in Ratchet down control requirements in

order to meet the 2007 and 2012 order to meet the 2007 and 2012 milestones in the EACmilestones in the EAC

Simplify the rule by eliminating Simplify the rule by eliminating burdensome recordkeeping and reporting burdensome recordkeeping and reporting requirementsrequirements


The current rule requires companies to attain a The current rule requires companies to attain a 47.5% reduction in VOC emissions from 47.5% reduction in VOC emissions from condensate tanks in the 8-Hour Ozone Area during condensate tanks in the 8-Hour Ozone Area during ozone season (May-September) and a 37.5% ozone season (May-September) and a 37.5% reduction during non-ozone seasonreduction during non-ozone season

Because reductions are only required system-wide Because reductions are only required system-wide and do not apply to individual units the regulation and do not apply to individual units the regulation requires detailed record-keeping in order to verify requires detailed record-keeping in order to verify compliance with the reduction requirementscompliance with the reduction requirements


The proposed regulation will replace the system The proposed regulation will replace the system wide reduction requirement with an emission wide reduction requirement with an emission threshold control requirement that will apply to threshold control requirement that will apply to individual unitsindividual units

In conjunction with this change, the proposed In conjunction with this change, the proposed revisions eliminate the extensive record-keeping, revisions eliminate the extensive record-keeping, requiring instead that operators track condensate requiring instead that operators track condensate production from each tank and maintain records of production from each tank and maintain records of any period where a required control device is not any period where a required control device is not operatingoperating


The emission control threshold will be set at The emission control threshold will be set at a level that will allow the area to meet the a level that will allow the area to meet the 91.3 tpd milestone set forth in the EAC. 91.3 tpd milestone set forth in the EAC.

The proposed revisions currently set the The proposed revisions currently set the threshold at 11 tons of VOC emissions per threshold at 11 tons of VOC emissions per yearyear

EAC Area: Emission Control Threshold The 11 tpy threshold was determined using The 11 tpy threshold was determined using

the following methodology:the following methodology: Calculation of projected emissions in Calculation of projected emissions in

2007 based on a straight line projection 2007 based on a straight line projection using actual data from 2003-2005using actual data from 2003-2005

calculation of of the distribution of 2005 calculation of of the distribution of 2005 emissions based on emission magnitudes emissions based on emission magnitudes

EAC Area: Emission Control Threshold

Use of these two data sets to project Use of these two data sets to project distribution of 2007 emissions based on distribution of 2007 emissions based on emission magnitudesemission magnitudes

Application of a 76% control factor based Application of a 76% control factor based on 95% control efficiency and 80% rule on 95% control efficiency and 80% rule effectivenesseffectiveness


133.7

154.2

195.3

215.8

174.8

236.4

256.9

100

120

140

160

180

200

220

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260

2001 2002 2003 2004 2005 2006 2007 2008

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Inventoried Emissions Modeled Emissions

Projected Uncontrolled Annual Daily Average VOC Growth Rate = 20.5 tons/day


EAC 2005 Condensate Tank VOC Emission Distribution

8

4 5 5 5 5 6 5 6 5 5 5 5 5 5 4

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Total Uncontrolled VOC Emissions = 195.3 Tons/Day

EAC Area: Emission Control ThresholdTank Battery Category

(Tank Size TPY) % of 2005 Daily

Emissions Projected 2007 Uncontrolled VOC Emissions (Tons/Day)

All 100% 236.4 >= 5 96% 226.5 >= 6 94% 221.2 >= 7 91% 215.7 >= 8 89% 209.8 >= 9 86% 203.4

>= 10 83% 197.3

>= 11 80% 190.2

>= 12 78% 183.7 >= 13 75% 177.0 >= 14 72% 170.4 >= 15 70% 164.9 >= 16 67% 158.5 >= 17 65% 152.8 >= 18 62% 147.3 >= 19 60% 141.6 >= 20 58% 136.6 >= 25 47% 111.8 >= 50 16% 38.1

>= 100 2% 4.5

EAC Area: Emission Control Threshold 2007 projected uncontrolled emissions for 2007 projected uncontrolled emissions for

tanks greater than 11tpy is 190.2 tpy and for tanks greater than 11tpy is 190.2 tpy and for tanks less than this magnitude emissions are tanks less than this magnitude emissions are 46.2 tpy (236.4-190.2=46.2)46.2 tpy (236.4-190.2=46.2)

Using a 76% control factor controlled tanks Using a 76% control factor controlled tanks of 11 tpy and greater will emit 45.6 tpy for of 11 tpy and greater will emit 45.6 tpy for a total emissions of 91.8 tpya total emissions of 91.8 tpy


In addition to the 11tpy threshold commencing in In addition to the 11tpy threshold commencing in May 2007, the proposed rule also sets a control May 2007, the proposed rule also sets a control threshold of 6tpd commencing in 2012 in order to threshold of 6tpd commencing in 2012 in order to meet the 100.9 tpd EAC milestone for the ozone meet the 100.9 tpd EAC milestone for the ozone season 2012season 2012

This number is pretty speculative and will This number is pretty speculative and will probably need to be revisited as 2012 approachesprobably need to be revisited as 2012 approaches


The proposed revisions also require tanks serving The proposed revisions also require tanks serving newly drilled, recompleted or restimulated wells newly drilled, recompleted or restimulated wells to employ control equipment during the first 90 to employ control equipment during the first 90 days of productiondays of production

This provision is intended to address the facts that This provision is intended to address the facts that emissions are greatest during this period and emissions are greatest during this period and actual production/emission levels are not known actual production/emission levels are not known prior to drillingprior to drilling

Proposed Statewide Regulation

The AQCC has requested that in addition to the The AQCC has requested that in addition to the EAC Area revisions, the Division propose EAC Area revisions, the Division propose statewide control requirements for oil and gas statewide control requirements for oil and gas operationsoperations

While for the most part statewide emissions don’t While for the most part statewide emissions don’t pose an immediate threat to ambient air quality pose an immediate threat to ambient air quality standards, given the expected growth of drilling in standards, given the expected growth of drilling in various parts of the state the Commission and various parts of the state the Commission and Division are concerned about possible future Division are concerned about possible future impactsimpacts


The current proposal includes controls for The current proposal includes controls for three types of equipmentthree types of equipment condensate tankscondensate tanks new enginesnew engines natural gas dehydratorsnatural gas dehydrators


The condensate requirements mirror those The condensate requirements mirror those proposed for the EAC area except the proposed for the EAC area except the threshold is set at 20 tpy or greaterthreshold is set at 20 tpy or greater

The 20tpy threshold would require controls The 20tpy threshold would require controls at 152 tanks and result in an annual at 152 tanks and result in an annual emission reduction of approximately 5000 emission reduction of approximately 5000 tpy of VOCstpy of VOCs


For engines, the Division is proposing emission For engines, the Division is proposing emission limits for new engineslimits for new engines starting July 1, 2007 engines over 500hp will starting July 1, 2007 engines over 500hp will

need to 2.0 g/hp-hr Nox, 4.0 g/hp-hr CO and need to 2.0 g/hp-hr Nox, 4.0 g/hp-hr CO and 1.0 g.hp-hr VOCs. These limits will drop to 1.0 g.hp-hr VOCs. These limits will drop to 1.0, 2.0 and 0.7 in 20101.0, 2.0 and 0.7 in 2010

The same limits will apply to engines between The same limits will apply to engines between 100 and 500 hp commencing in 2008 and 2011100 and 500 hp commencing in 2008 and 2011


Commencing on May 1, 2008, glycol Commencing on May 1, 2008, glycol natural gas dehydrators with a design rate of natural gas dehydrators with a design rate of 3MMscf per day or more will need to 3MMscf per day or more will need to achieve a control efficiency of 90% of achieve a control efficiency of 90% of emissions from the still vent and flash tankemissions from the still vent and flash tank

Conclusions

A new way of doing business?A new way of doing business?

proposed revisions to colorado air quality control commission regulation no. 7 garry kaufman air...

Documents

eac revisions

control of air emissions

hour ozone control area

colorado slide

set of revisions

hour ozone standard

cleaner air

eac approach