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The Importance Of Rule Revisions

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2. Proposed Revisions to Reg. No. 7 Related to Adoption of EPA’s Control Techniques Guidelines (CTG) for Oil and Gas – Chris Colclasure (Presentation) (Draft) a. Purpose of Rule Revisions i. Adopt reasonable available control technology requirements that are comparable to that of EPA’s CTG for oil and gas. 1. Support the implementation of these requirements in the current Denver Metro/North Front Range nonattainment area as proposed by the Division. ii. Have state only rules that improve ozone. 1. Will not be comprehensive ozone rule-making, since only looking at oil and gas and no other sources of volatile organic compounds (VOCs) and oxides of nitrogen (NOx). However, it is an opportunity to bring ozone numbers closer to attainment. …show more content…

This result was derived from all the sources, but we have not quantified what applying this statewide would get, but, I’m assuming pretty small. ii. Question: How has public input on the proposal been received so far? Answer: We have not gotten a lot of input from the general public however, we have gotten very good cooperation from stakeholders as well as environmental groups who would be affected by the rule. Also, they are the ones proposing that we make the rule statewide. iii. Question: What is the percentage of the VOCs inventory attributed to pneumatic whether in the North Front Range or statewide? Answer: I don’t know the exact number off the top of my head, but it’s real small. iv. Question: What is the Regional Air Quality Council’s (RAQC) proposed position on the rule in terms of where they think the board should go? Answer: We have three things that we found important for the RAQC to support or at least indicate: 1. Support for the increase of LDAR monitoring that would take the annual inspection up to semi- annual. 2. Also, support for pneumatic controller inspections to help identity any malfunctions that might arise. 3. Finally, this regulation will help deal with the ozone problem in the nonattainment area which we would support. Also, it was indicated that maybe there would be a proposal from others to expand this statewide. However, I don’t know whether we

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