Colorado Air Quality Division requests adding RACT requirements for major sources of NOx and VOC for Denver and Northern Front Rage area.

October 1, 2020

Denver Metro – Northern Front Range serious non-attainment area.

Colorado’s CDPHE Air Quality Division (“Division”) is requesting the air quality control commission (AQCC) hold a rulemaking hearing this December for the Ozone State Implementation Plan (SIP) and proposed revisions to Regulation No. 3, Regulation No. 7, and the Air Quality Standards according to September 23, 2020 Trinity Consultants report.

These revisions are being proposed by the Division to address Serious ozone nonattainment area requirements for the Denver Metro Northern Front Range non-attainment area and the SB 19-181 legislative directive to the AQCC, and technical corrections to Regulation Number 3.

Currently, the Air Quality Standards Regulation reflects motor vehicle emission budgets (MVEBs) from the 2008 Ozone SIP for the “Moderate” classification. The Division is requesting to revise the Air Quality Standards Regulation to increase the stringency of the MVEBs in the proposed Serious SIP.

The Division is also requesting the following revisions to Regulation Number 7:

  • Add language that requires the implementation of reasonably available control technology (RACT) for major sources of VOC and/or NOx in the Denver and northern Front Range region. Note that a facility with NOx or VOC emissions of 50 tpy or more is considered a major source under the new major source threshold for serious ozone nonattainment area.
  • Incorporating specific emission limits for combustion turbines and landfill or biogas-fired engines
  • Incorporating additional wood furniture coating requirements
  • Proposing new VOC control requirements for foam manufacturing operations
  • Per the Pneumatic Controller Taskforce, add pneumatic device requirements specific to the oil and gas sector. This includes the requirement for non-emitting pneumatic controllers at facilities constructed on or after May 1, 2021.
  • Additional requirements to existing leak detection and repair (LDAR) recordkeeping requirements.
    Regarding the technical corrections to Regulation Number 3, the Division is requesting to propose minor revisions as follows:
  • Update the definition of carbon dioxide (CO2e) in Part A, to account for an update to the incorporation date and reflect EPA’s revisions to global warming potentials for fluorinated greenhouse gases in 40 CFR Part 98, Subpart A, Table A-1, made on December 11, 2014
  • Update and clarify public notice and comment provisions, allowing for access to digital copies on a website accessible to the public
  • Repealed Operating Permit exemption for engines that qualified under II.E.3.xxx
  • Other minor clean-up revisions.

The documents for the proposed revisions are online for Regulation 7, Regulation 3, and MVEBs. Please note that these proposed rule revisions are subject to change.

What this means to you.
Colorado’s Air Quality Division is requesting a December meeting to add language to the State Implementation plan to address serious ozone non-attainment. The plan includes requiring the implementation of reasonably available control technology (RACT) for major sources of VOC and/or NOx in the Denver and northern Front Range region. Note that a facility with NOx or VOC emissions of 50 tpy or more is considered a major source.

MIRATECH can help
Contact MIRATECH for stationary engine NOx and VOC emission control in Colorado.