The Air Quality Control Commission of the Colorado Department of Public Health and Environment (CDPHE) formally adopted Regulation 7 on December 18, 2020 and it goes into effect on February 14, 2021.
Regulation 7, named Control of Ozone via Ozone Precursors and Control of Hydrocarbons via Oil and Gas Emissions (Emissions of Volatile Organic Compounds and Nitrogen Oxides), mandates stringent air emissions and monitoring requirements for operators at multiple phases of a well’s lifecycle.
In this piece we cover the continuous monitoring aspect of Regulation 7 changes, not the entire regulation, which includes other restrictions on RICE engines, new controls for pneumatic pumps, etc. Our focus is on the overall requirements for air quality monitoring, what needs to be in your air quality monitoring plan and some considerations for evaluating and choosing a monitoring system. As a result, this is not intended to be a comprehensive guide to compliance, but rather a useful reference for helping you meet air monitoring compliance objectives with solutions that generate incremental benefits.
Air Quality Monitoring Requirements
Regulation 7 mandates that drilling operations beginning on or after May 1, 2021 are required to monitor air quality at and/or around the pre-production and early production operations. This requirement has “before,” “during” and “after” phases. Operators must monitor air quality for at least ten days before initiating pre-production operations, during all pre-production operations and then for at least six months after the well is capable of consistently producing either separable gas or salable liquid hydrocarbons (“early production”).
Regulation 7 defines “pre-production operations” as “…the drilling through the hydrocarbon bearing zones hydraulic fracturing or refracturing, drill-out, and flowback of an oil and/or natural gas well.” This implies that spudding the well is the event triggering the start of the pre-production period.
At least 60 days before beginning air quality monitoring, operators must submit an air quality monitoring plan to the CDPHE and the local government with jurisdiction over the location and any other local government unit, within 2,000 feet of the proposed operations. This requirement means that operators must submit their plans at least 70 days before spudding a well.
Local governments have 14 days from receiving the plan to consult with CDPHE, and municipal governments will have the opportunity to take part in the approval process. Submitting a plan does not ensure compliance, as the plan must be approved by the CDPHE before beginning air quality monitoring. Of course, once the air quality monitoring plan is approved, then the operator must comply with it.
What Needs to be in Your Air Quality Monitoring Plan
CDPHE’s air quality monitoring plan requirements are comprehensive and summarized below:
- Owner or operator name and the contact information of the owner or operator representative for monitoring purposes.
- The planned schedule for drilling and pre-production operations.
- The operations to be monitored including the API number of the well(s), location of the operations including latitude and longitude coordinates, and any associated facility or equipment AIRS number(s).
- Whether the local government with jurisdiction over the location of the operations has air quality monitoring requirements applicable to pre-production and/or early production operations, a description of those requirements, and a local government contact for air quality monitoring purposes.
- The monitoring objective(s), which must include one or more of the following (and may include additional objectives such as field-testing new air quality monitoring technologies or improving emissions inventories): (a) detect, evaluate, and reduce as necessary hazardous air pollutant emissions, (b) detect, evaluate, and reduce as necessary methane emissions, and (c) detect, evaluate, and reduce as necessary ozone precursor emissions.
- The air pollutant(s) and other parameters to be monitored. Pollutants must include at least one of the following: total VOCs, methane, benzene or BTEX (benzene, toluene, ethyl benzene and xylenes) or other indicator of hydrocarbon emissions.
- A description of the monitoring equipment to be deployed, including the manufacturer and model information and any manufacturer specifications for the monitoring equipment and data systems.
- A description of the meteorological monitoring equipment to be deployed.
- A monitor siting plan specifying: (a) the number of monitors, (b) the location and height of the monitoring equipment, including for each phase of operations if location and height of the equipment will change, (c) a topographic map and plan of the site.
- The map must indicate: (i) any obstructions to air flow, (b) all roads and access ways within a half-mile of the facility and (ii) any contiguous structures, whether or not they are part of the production operations.
- A description of how the placement of monitoring equipment minimizes surface disturbances
- An explanation of how the number and placement of monitoring equipment will be adequate to achieve the desired air quality monitoring objectives.
- A description of the Standard Operating Procedures to Be Used, including: (a) the sampling and/or measurement interval, averaging times, minimum detection concentration or level, expected precision, and confidence level at which pollutant data will be reported, (b) the response level for each pollutant or indicator monitored and/or sampled and the response procedures or actions that will be taken if elevated levels are observed, (c) the data quality indicators for precision and bias of the monitoring equipment, (d) the quality control and quality assurance procedures, including calibration intervals and frequency, (e) a discussion of known limitations of the pollutant monitoring equipment, (f) the protocol that will be used for acquiring, processing, and recording relevant meteorological data, (g) the data system and operating protocol to be used for data collection, including, but not limited to, data logging, data processing, recording, downloading, backup and storage, and reporting, and (h) the methods for collecting and analyzing speciated or other samples of chemical constituents identified by the Division when indicated necessary based on site-specific concentration thresholds.
- A description of how the monitoring equipment, pollutant(s) monitored, and siting plan are expected to detect elevated emissions and achieve at least one of the monitoring objectives.
Best Practices for Air Quality Monitoring Solutions
We suggest operators consider the following criteria for evaluating and choosing an air quality monitoring system.
- Continuous monitoring. APCD expects continuous monitoring solutions to report data at around a frequency of at least one reading every fifteen minutes, but has indicated interest in increasing the reporting frequency. Choosing a monitoring solution with better fidelity will give you more actionable data, and will be the gold standard for Reg 7 reporting.
- Objective provider. Choosing an independent, third-party provider of the monitoring solution builds and maintains trust with key stakeholders, including regulatory agencies, communities, employees and investors.
- Cloud-based. A cloud-based solution makes installation simple, easy and cost-effective.
- Cost. Cost is always a consideration, but ideally, your monitoring solution should generate benefits over and above merely meeting regulatory compliance.
- Data platform. A cloud-based environmental data platform is essential to operationalizing and benefitting from an air quality monitoring system.
- Sensors. The best solution providers will offer sensors that not only continuously monitor for methane, VOCs and particulates, but will also record necessary meteorological information, such as wind speed and direction.
- Redundant. Sensor batteries should be able to recharge using on-board solar panels to ensure reliability, even during a series of cloudy days.
Solutions with these best practices attributes can help you not only meet compliance objectives, but have the potential to deliver incremental benefits, such as gold standard ESG reporting, operational improvements and capitalizing on the emerging market for Responsibly Sourced Natural Gas (RSG).
How We Can Help – We Know Colorado
Project Canary’s continuous monitoring solutions are in use today by several leading E&P operators in Colorado and other states.
“Project Canary is an evolution in the field of emissions monitoring and data.”
– Dr. Morgan Bazilian Ph.D., Director of the Payne Institute for Public Policy at Colorado School of Mines
Not only do our solutions meet Regulation 7 requirements, but they have proven their value in helping operators generate operational efficiencies, reduce overall costs and increase environmental performance.
Importantly, our Canary S sensor takes samples every second and reports data every minute, giving operators the highest possible level of data fidelity in near real-time.
Contact us today to learn more about how Project Canary can help you Collect, Manage, Operationalize and Benefit from real-time, independent environmental data.