Key Takeaways from Colorado’s Regulation 7 Updates

In September, new updates were adopted to the Colorado Department of Public Health and Environment (CDPHE) Air Quality Control Commission’s Regulation 7 requirements.

These critical updates primarily affect continuous emissions monitoring around new oil and natural gas drilling operations.

What’s in the New Requirements?

These regulatory updates require all new Colorado drilling operations (beginning on or after May 1, 2021) to meet the following guidelines:

• Continuous monitoring must begin 10 days prior to the start of pre-production activities, during all pre-production operations, and for at least six months after the final well is producing.
• Operators must submit an air quality monitoring plan to the Air Pollution Control Division and any local government with jurisdiction over the location of operations at least 60 days prior to beginning air quality monitoring (or 70 days prior to pre-production operations).

What The Updates Mean for Your Program

Quality Data Management will be crucial. The sheer amount of data produced through upcoming programs will be unlike anything environmental departments and The CDPHE have seen before. While many existing data platforms can gather program data, few have built-in features to automate site specific monitoring plans and meet monthly reporting requirements for each multiwell pad. Automating this portion of the program can help minimize error and save hours of manual work preparing documents for CDPHE.

Monitoring Technology logistics will seem like a daunting task. But working with a technology consultant focused on agnostic solutions can help provide operators with vetted and credible tools to work alongside a Quality Assurance Plan. A well developed quality assurance plan should build confidence in the collected data and insights and minimize monitor downtime, which will save time troubleshooting in the field and drafting explanations for data gaps in monthly reports.

Choosing the right partner is key. Choosing a program management team with a great track record with industry and municipalities for managing large, high-quality monitoring networks puts your program in position for an effortless compliance. The right team will provide a trusted data management system, the appropriate monitoring technology, a thorough quality assurance plan, and the resources to meet the objectives of the operator-specific program.

Criteria for Your Air Quality Monitoring Plan

As a result of these new updates, your Air Quality Monitoring Plan must include the following:

• Operator and local government contact information
• All local government air quality monitoring requirements
• Planned schedule for drilling and pre-production operations, including API and AIRS numbers applicable to the site
• Details on whether monitored air pollutant(s) will be total volatile organic compounds, methane, benzene, or BTEX (benzene, toluene, ethylbenzene, and xylenes)
• Descriptions of the monitoring equipment, including purpose of selection, standard operating and quality assurance procedures, and data quality indicators
• Response levels based on preset thresholds, including at least one response level that will lead to notifying the Division and local government within 48 hours of the exceedance
• Proposed on-site meteorological equipment
• Details on how the number and location of monitors is adequate to achieve the desired air quality monitoring objectives (monitoring siting plan)

Additionally, all records from the Air Quality Monitoring Plan must be kept for a minimum of three years and monthly reports must be submitted by the end of the month following the sampling period.

Additional Information

You can access the specific updates to the regulation on the Colorado Department of Public Health and Environment Website.

If you have questions about the rule, or are interested in getting more information on how Montrose can support your team, reach out and connect with one of our subject matter experts.