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Oil & Gas Industry Permitting
 

Oil & Gas Industry Emissions Source
Construction Permit Process

Permit applicants must submit:

• A “Construction Permit Application Completeness Checklist” (Form APCD-100);
• All APEN filing fees with the permit application;
• Equipment specific Air Pollutant Emissions Notice (APEN) forms when available (Form Series 200);
• A “Company Contact Information” form (Form APCD-101);
• A “Facility Wide Emissions Inventory” form (Form APCD-102);
• Supporting documentation of emissions calculations;
• An ambient air impact analysis (Unless a VOC only source);
• An Operating & Maintenance plan form (Form Series 300, if emissions source is synthetic minor or major)
• A process flow diagram (If more than one emissions point at facility)
• A “Regulatory Analysis” (Applicant may opt for APCD to complete this review)

The “Construction Permit Application Completeness Checklist” informs the permit applicant what information is required to submit a complete application. Please note, under some circumstances, certain attachments of the permit application may be excluded and the application will still be deemed administratively complete. Please follow the guidance contained on the checklist as well as the associated “Construction Permit Application Completeness Checklist” guidance document.

Submittal of a “Regulatory Analysis” along with the permit application may expedite the issuance of the permit. For an example “Regulatory Analysis” please visit the following link:

• Example of Regulatory Analysis

Please use the forms below to fulfill the requirements of the “Construction Permit Application Completeness Checklist”. Permit applications submitted without a “Construction Permit Application Completeness Checklist” and appropriate attachments will be deemed incomplete. The Air Pollution Control Division will not process incomplete permit applications.

Administrative Permit Application Forms
Form Description	Form #	Formats		Guidance
Construction Permit Application Completeness Checklist	APCD-100
Company Contact Information	APCD-101
Facility Wide Emissions Inventory	APCD-102
Equipment Notice of Startup (NOS) – 15-day Post Startup	APCD-103
Permit Transfer of Ownership	APCD-104
COGCC 805 Series Applicability Form	APCD-105

One element of the “Construction Permit Application Completeness Checklist” indicates the applicant must submit an ambient air impact analysis. The following table provides links to helpful guidance, produced by the Technical Services program, that may assist you in completing your ambient air impact analysis. Please note, ambient air impact analysis does not always involve a modeling based analysis. Please contact the Technical Services unit if you have specific questions after reviewing the guidance.

Technical Services Ambient Air Impact Analysis Guidance
Description	Guidance
Colorado Modeling Guideline for Air Quality Permits
Minor Source Modeling Checklist

If your source type is not listed below, please use the General APEN form. A guidance document is available for each APEN form.

Air Pollutant Emissions Notice(s) (APEN) Forms
Equipment Type	Form#	Formats		Guidance
General	APCD-200
Reciprocating Internal Combustion Engines	APCD-201
Glycol Dehydrators	APCD-202
Fugitive Component Leaks	APCD-203
Midstream Condensate Tanks	APCD-204
E&P Condensate Tanks	APCD-205
Amine Sweetening Units	APCD-206
Produced Water Tank	APCD-207
Hydrocarbon Liquid Loading	APCD-208

The Operating & Maintenance (O&M) plan must be submitted up front with the construction permit application. This will enable operator’s to know what equipment monitoring requirements will apply to the emissions source before it is constructed. Once approved, the permit will be issued to the operator with a requirement to follow the O&M plan from the date of equipment startup.

If your source contains unique operational characteristics, emission control equipment or the standard O&M plan forms do not cover your emissions source, please submit a case specific independent O&M plan for case-by-case approval by the APCD. If this approach is chosen, the O&M plan must still be submitted with the permit application. The APCD encourages the use of the O&M plan templates below to help expedite the permit approval process.

The O&M plan templates and a general guidance document explaining the use of the template forms are provided below.

Operating & Maintenance Plan Forms
Equipment Type	Form #	Formats		Guidance
Reciprocating Internal Combustion Engines	APCD-301
Glycol Dehydrators	APCD-302
Fugitive Component Leaks	APCD-303
Condensate & Mixed Liquid Storage Tanks	APCD-304
Amine Sweetening Units	APCD-306

After the construction permit is issued, operators must file a Notice of Startup (NOS) for the associated equipment and complete the self-certification process.

• The NOS must be submitted no more than 15 days after the equipment begins to operate.
• The NOS form must include the specific equipment details that were not provided with the permit application. This includes the make, model and serial number information for the emissions source and emissions control equipment.

The NOS form (Form APCD-103) is available in the “Administrative Permit Application Forms” table above.

Construction Permit Self-Certification

Issued permits are titled “Construction Permit”. Operators may determine if the permit is “Initial Approval” (i.e. needing self-certification) or “Final Approval” by reviewing the conditions contained in the permit under the heading “Requirements to Self-Certify for Final Authorization”. The conditions under this section of the permit indicate if the permit represents final authority to operate or if self-certification is required. If self-certification is required, the construction permit will be issued with a permit-specific self-certification document. The operator should follow the requirements of the self-certification document issued with the construction permit to complete the self-certification process.

Once self-certification is complete, the APCD will issue the operator a bill to cover the costs incurred by the APCD. The APCD will issue a “Final Authority to Operate” approval letter for the specific construction permit once the self-certification bill is paid.

Documents related to self-certification are contained in the table below. The “General Self-Certification Document” should only be used in cases where a permit-specific self-certification document was not provided by the APCD. Operators who have facility wide permits covering multiple emissions points that have phased construction and different startup dates must submit the “Self-Certification Timeline Table” each time a new emissions point is certified. Please see the guidance below for more information on this process.

Construction Permit Self-Certification Forms
Form Description	Form#	Formats		Guidance
Generic Self-Certification Document	APCD-400
Self-Certification Timeline Table	APCD-401

Operators with permits that authorize alternate operating scenarios (AOS) for natural gas fired reciprocating internal combustion engines (RICE) should complete and submit the “Applicability Reports” form contained below along with a revised APEN when reporting a permanent engine replacement. These forms are intended to communicate to the APCD the operator’s determination of applicable regulatory requirements (NSPS, MACT, Regulation 7) that apply to the replacement engine.

Please note, these forms are filled in with example content. Therefore, form fields should be overwritten with your specific source and equipment information. In addition, you must provide NSPS JJJJ and MACT ZZZZ regulatory requirement determinations that are specific to your case.

Alternate Operating Scenario (AOS) Reporting Forms
Form Description	Formats
Appendix A – Applicability Reports for PS Memo #98-006

If you have questions regarding the oil and gas industry permitting process, please contact the APCD at 303-692-3150 and ask for a member of the Oil & Gas permitting unit.

  Air Pollution Control Division

Suggestions and comments regarding the Air Quality Control Division can be forwarded to comments.apcd@state.co.us