Applewood is pleased to announce that Bethany Moffat received her Method 9 Certification on October 21st, 2021.
If you have need for opacity observation or a Method 9 report, please reach out!
The Air Pollution Control Division (APCD) is working on a Greenhouse Gas (GHG) Audit Program that will focus on reducing GHG emissions from manufacturing facilities. The program has been created in response to Colorado Revised Statute Section 25-7-102(2(g) which set the following goals for GHG reduction in the state:
The audit program will be based on manufacturing facilities’ relative contribution, so large contributors to GHG emissions will be the focus of the program in the beginning. Manufacturing facilities with direct emissions of equal to or more than 50,000 metric tons of CO2e per year through 2019 will be the affected facilities at first. It is expected that the applicability will be lowered to smaller contributors in the future. Facilities that will be excluded will be Oil and Gas, Landfills, Underground Coal Mines, Electric Generating Units and Food Processing Facilities. Most of those types of sources are covered under separate regulations.
The audit program will require energy and emission control audits addressing GHG emissions from energy-intensive, trade exposed manufacturing facilities (EITEs) as well as non EITE facilities. For EITEs it will require that the audit be done by a 3rd party every 5 years through 2035. Non EITE facilities will be required to implement management systems for energy and GHG emission reductions over a 5-year period. APCD wants facilities to help decide what sources should be included in their own audit, with the focus being on the sources that have the most emissions.
The audit will help to establish GHG Best Available Control Technologies (BACT) and Best Available Energy Efficiency Practices (BAEEP). These will likely be set per facility instead of per industry. The audit report should recommend a compliance process. If sources do not meet GHG BACT and BAEEP, the commission will consider the regulatory requirements to further mitigate the costs of reducing emissions and provide incentives to reduce emissions. APCD would also like to utilize existing programs like ISO.
APCD expects to have draft language for the audit program out by mid-February 2021. In April there will be a request for a rulemaking and a rulemaking hearing in July. For more information on the upcoming GHG audit program for Colorado manufacturer’s, go to the CDPHE website for the program:
On December 15, 2020 Governor Polis released a statement about his intentions to push for a downgrade for the Denver Metropolitan/North Front Range Area from serious to severe non-attainment for the area’s ozone levels. The area has been unable to achieve a ground-level ozone standard of 75 ppb. The statement said that state agencies and stakeholders should plan for the downgrade in 2022.
Currently, sources that have a potential to emit (PTE) over 50 tons per year of VOC and NOx need to have Title V permits. However, this will likely soon change again. The major source level was only recently moved down from 100 tons per year in January of 2020. Sources that have air permits with VOC or NOx emissions between 25 and 50 tons per year are going to have to either limit their emissions to less than 25 tons per year or apply for a Title V permit within 1 year of the severe designation.
If a source intends to submit a synthetic minor permit, which would limit their emissions to less than 25 tons per year, then the permit needs to be ISSUED by the Air Pollution Control Division within the 12-month period after the change to avoid Title V permit application requirements. Often permits take several (4-18) months to be issued by the Air Pollution Control Division, so applications for synthetic minor permits need to be submitted in the upcoming months.
If a source intends to submit a Title V permit application, the application will need to be submitted within 12 months of the redesignation date, so likely in 2023.
Sources should now be looking at their PTE accounting and deciding what will work best for them.
To help sources decide which direction to go with their air permit, Applewood has assembled the following table that outlines the benefits and disadvantages of each type of air permit: Benefits and Drawbacks of Major or Minor Source Permits
My son has asthma and the wildfire smoke has been making him cough. It is a nasty, goopy cough, which has garnered some fun stares in COVID times. His asthma specialist recommended that we purchase HEPA air purifiers and place them in our home. This is also the best way to deal with wildfire smoke even if you do not have asthma. However, if you do not want to go out and buy expensive HEPA filters, check out this great video from the University of Michigan on how to make a HEPA air purifier yourself! https://www.youtube.com/watch?v=kH5APw_SLUU