EP04 – What Every Oil & Gas Producer Needs To Know About SB181

In this episode, we interview Sean Hacket, the industry liaison for CDPHE & COGCC.

We discuss the new regulations that WILL impact all oil & gas operators in Colorado.

Sean also outlines multiple resources for follow-up or to become a stakeholder in the regulation rule making process.

CDPHE Resources Mentioned

Regulation 7 (emission rules)

It’s a somewhat lengthy read, but pages 246-265 of Regulation Number 7 discuss the statement of basis and purpose for all of the rules adopted by AQCC on December 19, 2019, including the tank gauging requirements (https://drive.google.com/file/d/16qTQLSTX1T49DYWp3voXRNl4_g-vbhQT/view). 

How to Get Involved in the Rule making Process

At 31:50 in the video, I ask Sean how an interested party can get involved in the rule-making process.

This document outlines the process of becoming a stakeholder (“a rule-making party” vs. a spectator).

Introduction to Continuous Monitoring

These videos were from air monitoring event held at Colorado School of Mines on April 7, 2020 that was cancelled and held online:

Worker Safety Rules

Regarding worker safety rules, while worker safety is certainly important to CDPHE and while some Air Quality Control Commission or Oil and Gas Conservation Commission rules may touch upon worker safety issues (e.g. the automated tank gauging requirement might provide for a safer work environment because it allows companies to measure tank levels without having to send personnel on top of a tank to open a thief hatch and potentially expose them to emissions), worker safety issues are generally overseen by OSHA (https://www.osha.gov/SLTC/oilgaswelldrilling/standards.html).

To my knowledge the only reference to worker safety issues in SB19-181 is in 34-60-106(20), which requires COGCC to adopt rules requiring certain certifications for workers, including OSHA standards (page 22 of SB19-181, which can be found here: https://leg.colorado.gov/sites/default/files/2019a_181_signed.pdf). 

Method 21 – Volatile Organic Compound Leaks

Colorado follows EPA’s Method 21 for measuring VOC leaks. Method 21 is the standard used to measure leaks (i.e. methane) using a handheld cooled camera (i.e. FLIR), for example. This is the typical method used by LDAR (leak detection and repair) teams.

Additional CDPHE Resources

– APCD Email Lists (contains oil and gas list): https://www.colorado.gov/pacific/cdphe/air-mailing-lists

– APCD Contact Information- 303-692-3100 cdphe.commentsapcd@state.co.us

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