Colorado’s Regulation 7, enacted by the Air Quality Control Commission of the Colorado Department of Public Health and Environment (CDPHE), establishes stringent air quality regulations targeting the oil and gas industry to control ozone precursors and hydrocarbon emissions. The regulation has undergone several amendments to enhance environmental protection and public health. This page focuses specifically on the continuous air monitoring requirements within the broader regulatory changes.
Key Components of Regulation 7:
1. Air Quality Monitoring Requirements:
- Continuous Monitoring: Operators are mandated to implement continuous air quality monitoring during pre-production and early production phases. Monitoring must commence no later than 10 days before pre-production activities and continue for at least six months after the well begins producing saleable oil or gas.
- Monitoring Plans:Operators are required to submit comprehensive air quality monitoring plans to the CDPHE and relevant local governments at least 60 days prior to the commencement of monitoring. These plans must include detailed contact information, operational schedules, monitoring objectives (including specific pollutants like VOCs, BTEX compounds, and methane), equipment descriptions, siting plans, topographical maps, and operating procedures.
2. Recordkeeping and Reporting:
- Data Collection:Operators must collect and report data in one-minute intervals to ensure high-resolution monitoring.
- Monthly Reporting: Detailed monthly reports must be submitted in a format approved by the CDPHE, including summaries of air quality results by operational phase, data tags, statistical analyses, descriptions of responsive actions taken, and summaries of meteorological data.
3. Alert Level Responses and Actions
Regulation 7 mandates three levels of alert responses for elevated readings:
- Level 1: Personnel are notified of the alert and begin investigating potential causes.
- Level 2: All Level 1 actions are taken, and an LDAR technician must be sent to the site within 24 hours for further investigation.
- Level 3:
- All Level 2 actions are taken, and a response team is assembled to assess the cause and source of the elevated reading. The team must evaluate operations to determine if they can continue safely.
- Operators must notify the CDPHE, ECMC, and any local government with jurisdiction via the Event Notification feature in the APCD Submission App.
- For locations within 2000 feet of an RBU, if a 15-minute continuous total VOC (IB equivalent) concentration reaches or exceeds 7 ppm, a canister will trigger, collecting a sample for no more than one hour.
4. Performance Testing and Equipment Maintenance
- While our team does not provide services for this portion of Regulation 7, operators must ensure compliance with requirements for combustion control devices and pollution control equipment.
- Periodic performance testing is required for VOC emission control devices, with initial testing mandated as of May 1, 2023, and subsequent tests every 60 months.
- Regular inspections and maintenance of air pollution control equipment are also required to maintain compliance.
Implications of CO Reg 7:
Compliance Obligations:
Operators must adapt to stricter continuous air monitoring requirements, including higher data resolution and more frequent reporting. Sensible EDP’s platform can facilitate compliance by providing real-time data aggregation, alerts and visualization, simplifying the monitoring and reporting processes.
Enhanced Monitoring Capabilities:
With the emphasis on continuous monitoring and automated sampling, clients may need to upgrade their monitoring infrastructure. Sensible EDP’s sensor-agnostic platform can integrate with various air sensors, providing a unified dashboard for comprehensive environmental tracking.
Data Management and Reporting:
The increased volume and granularity of data necessitate robust data management solutions. Sensible EDP’s platform offers real-time controls and alerts, aiding clients in meeting the stringent data collection and reporting standards set by Regulation 7.
Proactive Response to Emission Events:
The regulation requires prompt reporting and responsive actions to any emission exceedances. Sensible EDP’s real-time alert system enables clients to swiftly address and mitigate potential compliance issues, thereby reducing the risk of penalties.
How Montrose Real-Time Air & Sensible EDP Can Help
Montrose’s Real-Time Air Monitoring Team has assisted multiple operators in Colorado and offers an end-to-end solution to help you meet the new continuous air monitoring requirements of Regulation 7 including:
- Comprehensive Air Monitoring Services – Our Denver-based team works closely with regulators to develop site-specific monitoring plans that meet compliance requirements.
- Continuous Sensor Monitoring & Compliance Management – We provide real-time alerts via text, email, and phone through the Sensible EDP™ platform, ensuring faster response times and uptime compliance.
- Automated Cannister Sampling & Laboratory Analysis – Montrose’s lab partner, Enthalpy Analytical, supports canister analysis for BTEX and other pollutants.
- Regulatory Reporting Support – Our team manages monthly reporting, ensuring all submissions meet the latest compliance standards.
- Additional Regulatory Support – Montrose’s stack testing and LDAR teams assist with other aspects of Regulation 7 compliance beyond continuous air monitoring.
Leveraging advanced monitoring solutions like those offered by Montrose and Sensible EDP can streamline compliance efforts, enhance operational efficiency, and contribute to sustainable environmental practices.
