Updates to Colorado's Regulations for Well Production Facilities

​Updates to Colorado's Regulation 3 and Regulation 7 are scheduled for December and, although not yet finalized, are summarized for well production facilities below. These changes are a direct result of SB-19181 and the re-designation of the Denver Metro/North Front Range ozone non-attainment area.

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​Updates to Regulation 3
Stationary Source Permitting and Air Pollutant Emission Notice Requirements

• Removed 90-day permitting deferral period for new E&P facilities
  • Operators will need to apply for a pre-construction permit (GP09 or GP10)
• New requirement for E&P facilities to submit a notice of startup at least 15 days before well completions
• Removed APEN and permitting exemptions for wastewater vessels that contain less than 1% crude

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​Updates to Regulation 7
Control of Ozone via Ozone Precursors and Control of Hydrocarbons via Oil and Gas Emissions

Updated Storage Tank Control

• Updated to include crude and water tanks (not just condensate)
• Lowered emissions thresholds for all tanks (for new and existing tanks)
  • By May 1, 2020, controls will be required on tanks with VOC emissions 4 tons per year or more in the non-attainment area
  • By March 1, 2021, controls will be required on tanks with VOC emissions 2 tons per year or more statewide
• Weekly inspections required for all tanks
• Automatic gauging systems for new tanks/facilities

New Truck Load-Out Control
Liquid load-out to trucks must be controlled (using submerged fill and vapor collection system)

Increased Leak Detection and Repair (LDAR) Frequency

• At least semi-annual LDAR at well production facilities with VOC emissions over 2 tons per year statewide
  • ​Maintain more frequent (quarterly or monthly) LDAR, if applicable
• Alternative methods for LDAR may be used if demonstrated to be as effective as current methods

Updated Well Unloading Requirements

• Best management practices and additional recordkeeping requirements during plugging and abandonment statewide

New Pneumatic Controller Inspection and Reporting

• Pneumatics inspections at the same frequency as LDAR statewide
• Annual report documenting inspections

New Annual Emission Report

• New requirement for operators to provide an annual emission report for all Colorado facilities statewide
  • ​Must include VOC, NOx, methane, ethane, carbon monoxide
  • Must include emissions from drilling/fracking/completion, separator venting, flaring, storage tanks, dehydrators, engines, component leaks, pneumatic devices, equipment blow-downs, well unloading, produced water handling

Updates to Reasonably Available Control Technology (RACT)
​Major sources (50 tons per year or more of controlled NOx or VOC) will have expanded combustion equipment requirements as well as NSPS and NESHAP requirements (incorporated by reference) and a RACT for general solvent use.

If you have questions or need help navigating these proposed changes, please contact us.