What Colorado’s Regulation 7 Continuous Monitoring Reporting Requirements Mean for Your Team

In September of 2020 the Colorado Department of Public Health and Environment (CDPHE) updated their Regulation 7 to require continuous monitoring around upstream oil and gas facilities during pre-production and early production.  The first reports will be due at the end of June to cover any monitoring done in May. With these being the first reports submitted for a new monitoring requirement there has been some confusion as to what they mean for facilities’ current air monitoring programs and what you need to successfully write an acceptable report.

What Are the Updated Requirements?

Section VI.C.2. (Recordkeeping and Reporting) of Regulation 7 requires monthly reports be submitted to the CDPHE by the last day of the month following the previous month of monitoring and indicates a variety of considerations in reporting done by operators that could impact the compliance of facilities. This necessary recordkeeping includes:

• The month and year of the monitoring period, a description of the monitoring equipment and the pollutant(s) monitored.
• A description of the monitored operations including the phase of operation and activities occurring during the monitored period, API number of the well(s), location of the operations,  any associated facility or equipment AIRS number(s), the date, time, and duration of any monitoring equipment downtime, the date, time, and duration of operations malfunctions and shut-in periods or other events investigated for influence on monitoring.
• A summary of monitored air quality results by phase of operation, including time series plots as hourly or higher time resolution and a statistical summary including number of observations, maximum concentrations or levels, periodic averages, and date distributions including 5th, 25th, median, 75th and 95 percentile values.
• A description of responsive action(s) taken as a result of monitoring results, including the date; concentration or level measured; correlations with specific events, activities, and/or monitoring thresholds; and any additional steps taken as a result of the responsive action.
• The results of any speciated or other samples of chemical constituents identified by the Division and collected when site-specific concentrations indicate such samples are necessary.
• A summary of meteorological data, including in the time intervals identified for concentration readings in the air quality monitoring plan during the time period of responsive action(s). If meteorological data is collected on-site, the meteorological data assessed in as close to the sampling and/or measurement intervals as possible.
• A description of how data will be processed, if available from the manufacturer, and summarized for purposes of fulfilling monthly reporting requirements, including whether and how data will be corrected, and how missing data and values that are below detection limits will be treated in statistical summaries.
• In the last monthly report, a certification by the company representative that supervised the development and submission of the monitoring reports that, based on information and belief formed after reasonable inquiry, the statements and information in the monthly reports are true, accurate, and complete.

The Key Factors to An Acceptable Report

How can you be sure your reports will be accepted and in compliance with these new regulations? Montrose has already submitted compliance level reports for these programs and we have received feedback from CDPHE for additional document formats that weren’t initially made explicit in the CDPHE’s regulation. These additional requests are:

• All data provided to be in an excel form, including final data, data distribution tables, wind rose tables, and calibration files

While CDPHE has offered a template for submitting monthly data, we’ve found that building our own template to meet the specificities of the regulation is more effective in:

• visualizing the data, by having the option to include a multitude of graphs and roses
• providing more flexibility for explaining the data, site activities, and quality assurance results
• allows for automating reports to be built into the same data platform that hosts the monitoring data

The amount monthly reporting facilities will need to document due to these updates may overwhelm operators, which is why automating reports with Montrose will end up saving you time and money. By cutting on a majority of the writing, it will leave with more time for review and quality assurance of the reports.

For More Information

For additional information on these regulations visit the Colorado Department of Public Health and Environment Website.

If you would like to learn more about Montrose’s services and how they can help you save time and money with your reporting, reach out today and speak to one of our experts.