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Where There's Smoke There's Fire? – How it Just Got Harder for Colorado Oil and Gas Operators to Meet Air Emissions Requirements

October 20, 2013

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).