Toxic Air Contaminants Reporting

Challenge

In June 2022, House Bill 22-1244: The Public Protection from Toxic Air Contaminants Act was made law. This law required emissions inventories to be reported for 477 Toxic Air Contaminants (TACs) across assets in synthetic-minor and major source classifications as part of Colorado’s Oil & Natural Gas Air Emissions Inventory (ONGAEIR).

Our clients, major energy companies residing in Colorado, faced the following needs:

• Identification of TACs emitted from upstream and midstream Oil & Gas production segments
• Compilation of emission factors applicable to TAC emissions at oil and gas emission source types
• Calculate TAC emissions
• Data aggregation services to report TAC emissions at the facility level

With knowledge and acumen accrued working closely with both operators and the state on permitting initiatives, SLR was most able to fulfill these needs within the timeline set forth by the state and federal governments.

Solution

SLR has managed diverse reporting initiatives for operators in basins across Colorado for many years and has expertise in both Colorado and Federal permit programs affecting operators in the area. With this experience, we were able to utilize that expertise to compile a 3-part action plan to perform the necessary permitting support.

Step 1: Assessment against TAC requirements
SLR began the process by first ascertaining a list of TACs specific to Oil and Gas operators and performing a baseline assessment to understand the missing components needed by our client to meet regulatory standards.

Step 2: Due diligence in reviewing operator production records
Next, SLR reviewed the client’s production records and created a cross-referenced document that allowed for the creation of TAC inventories through numerous, pollutant-specific calculations, including TAC information by facility.

Step 3: Confirmation of findings and preparation of contaminants reporting for federal and state approval
Once SLR confirmed through multiple data audits that the emission inventories reported were accurate and met the needs of minor and major source classifications, we supported the clients in the development of their report to be submitted to the state of Colorado.

Impact

Our clients were able to report their emission inventory documentation with confidence that their TAC footprint was accurate and met all necessary requirements. Their reporting was submitted on schedule. The client remains compliant with their reporting responsibilities.

SLR has compiled TAC reports for over 400 facilities across the state of Colorado and completed these new ONGAEIR reporting requirements in stride.