Planning for Severe Nonattainment
Colorado's air regulations are constantly changing. One anticipated change is going further into ozone nonattainment (because monitored ozone was higher than the NAAQS). Colorado's ozone nonattainment is expected to be re-designated from serious to severe, in early 2022. This will again halve the major source threshold from 50 to 25 tons per year. Below are some ways oil and gas facilities may achieve compliance.
REDUCING VOC EMISSIONS
Controlling VOC emissions has become more and more important, but with the expected further re-designation it will be even more important to reduce emissions. Simple and relatively low-cost changes to process equipment can have large impacts. Electrifying engines and utilizing liquid and gas pipelines, if possible, are a good start. Additional hydrocarbon separation, vapor recovery units, and internal tank modifications are some other common methods that don't require existing infrastructure.
CLAIMING HIGHER CONTROL EFFICIENCIES
Using an appropriate enclosed combustor can reduce emissions by 95% or more and many manufacturers of enclosed combustors guarantee a control efficiency of up to 99%! Our experienced staff has learned to navigate permitting with the state so clients have the option of claiming a higher combustor control efficiency. Often, this can be the difference between a synthetic minor source and a major source (and Title V permitting), especially at the expected major source threshold of 25 tons per year.