Automatic Pressure Management and Pilot Light System (APMPLS)

The Air Pollution Control Division has published guidelines for an Automatic Pressure Management and Pilot Light System (APMPLS). The guidelines describe technical and practical considerations for design, operation, maintenance, and recordkeeping of APMPLS at Colorado well production facilities.  An APMPLS includes automatic pressure management, pilot light monitoring, and open thief hatch monitoring.

Participation in this program is optional for the owner or operator of a well production facility, but it does offer benefits.

Benefits of following the guidelines and notifying the division:

Potentially a less-frequent LDAR inspection schedule requirement for a well production facility that operates an APMPLS consistent with the guidelines.

  • By following the APMPLS guidelines and completing the prescribed notification and recordkeeping requirements at a facility, the owner or operator can conduct periodic inspections for leaks at that facility using an approved instrument monitoring method at the specified frequency stated in Regulation No. 7, Part D, Section II.E.4.f.  

Process for implementing and following the guidelines:

Step 1: Review the Automatic Pressure Management and Pilot Light System Guidelines.

Step 2: Notify the Division of your company's intention to follow the guidelines.

Step 3: Prepare your materials (as needed).

The following should be addressed by the materials developed in accordance with the guidelines.

  • Implementation plan, including:
    • Timeline and schedule for completing:
      • APMPLS installation and startup verification at existing facilities
      • Implementation of operation and maintenance changes
      • Revisions to Storage Tank Emission Management (STEM) plans, as needed (STEM Plans themselves do not need to be submitted to the Division)
    • The number of existing facilities affected (no names of facilities needed)
    • Whether APMPLS will be installed at future new facilities
  • Written procedures which address the following, consistent with the guidelines:
    • Whether the Division has previously granted approval of a plan for operating an automatic pressure management system
    • Procedure for determining the Leak Point for each tank system
    • If not previously approved by the Division, monitoring and response procedures for automatic pressure management system
    • Monitoring and response procedures for pilot light monitoring and open thief hatch monitoring, including the information specifically called for in the guidelines
    • Procedure for APMPLS verification after system startup
    • Operating and maintenance practices after startup, including how to manage malfunctions, emergency situations, and planned facility maintenance shutdowns
    • Recordkeeping practices, including a template of proposed recordkeeping forms
    • Other requirements as specified within the guidelines

Step 4: Submit your materials to the Division.

Directions on submitting your materials will be sent to you once you have notified the Division of your intent to follow the APMPLS Guidelines, as directed in Step 2.  Please be clear in your submittal if you are not following any part of the guidelines; benefits and protections offered will vary if the operator chooses not to follow the guidelines in full.


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