Colorado must revise state plan to include RACT requirements for VOCs covered by Control Technique Guideline. Source revisions include reciprocating compressors at gas processing plants.

July 26, 2017

The Denver Metro North Front Range (“DMNFR”) was reclassified to “Moderate” status in 2016, as it failed to attain the 2008 8 hr Ozone standard. As a Moderate nonattainment area, Colorado must revise its State Implementation Plan (SIP) to include Reasonably Available Control Technology (RACT) requirements for each category of volatile organic compound (VOC) sources covered by a Control Technique Guideline (CTG), according to a July 24, 2017 Trinity Consultants report.

The EPA finalized the Control Techniques Guidelines for the Oil and Natural Gas Industry (“Oil and Gas CTG”) on October 27, 2016, with a state SIP submittal deadline of October 27, 2018.

The Oil and Gas CTG acts a mechanism to provide recommendations that are useful in developing state RACT for specific sources. Note that Colorado has similar regulations comparable to the recommendations under the Oil and Gas CTG.

The Division compared the Oil and Gas CTG to existing requirements in its Regulation Number 7 (Reg 7) and proposed revisions to include RACT requirements for each category of sources covered by EPA’s Oil and Gas CTG in Colorado’s Ozone SIP. These proposed revisions include:

  • Duplicating existing State-Only requirements for inclusion in Colorado’s Ozone SIP,
  • Proposing new requirements for inclusion in Colorado’s Ozone SIP, and
  • Revising and/or clarify existing SIP and State-Only provisions.

For compressors as sources of VOC’s, CTG requirements are more stringent compared to Regulation 7 and include the following revisions:

  • Duplicate the centrifugal and reciprocating compressor provisions from existing Section XVII.B.3 in proposed Section XII.J in order to include the requirements in Colorado’s Ozone SIP.
  • Expand the reciprocating compressor requirements to reciprocating compressors located at natural gas processing plants.
  • Allow the option of reducing VOC emissions by routing compressor emissions to process or control.
  • Implement monitoring and recordkeeping requirements to demonstrate compliance with the control requirements.

Click here to view a table showing all revisions addressed on a source by source basis.

What this means to you.
Colorado must revise its state plan to include RACT requirements for VOCs covered by Control Technique Guidelines. Source revisions include reciprocating compressors at gas processing plants.

MIRATECH can help.
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