Where There's Smoke There's Fire? – How it Just Got Harder for Colorado Oil and Gas Operators to Meet Air Emissions Requirements
The Air Pollution Control Division (Division) has again revised its P.S. Memo 10-02: "Oil & Gas Atmospheric Condensate Storage Tank Batteries System Reporting Guidance (P.S. Memo)" to make several significant changes regarding reportable air emissions under Air Quality Control Commission Regulation No. 7, § XII. The revised P.S. Memo likely will make it more difficult for oil and gas owners and operators to comply with the system-wide volatile organic compound (VOC) emission reduction requirements applicable to condensate storage tanks in the Denver-Metropolitan Area and North Front Range 8-Hour Ozone Nonattainment Area (Nonattainment Area).
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