Oil & gas operating and maintenance plans

The Operating and Maintenance (O&M) Plan for oil and gas sources describes practices intended to ensure that process units and emission control devices operate satisfactorily so that actual emissions do not exceed permitted limits.

If required (see below), you must submit an O&M Plan along with the Construction Permit application. This will let you know what equipment monitoring requirements will apply to the emissions source before it is constructed. Once it is approved, we will issue the permit with a requirement to follow the plan from the date of equipment startup.

An O&M Plan may be modified without a permit modification, but you must continue to operate under the existing approved O&M Plan until you have received an approval letter for the modified plan. You may submit modified O&M Plans by mailing in a hard-copy, or by emailing to cdphe_oandm@state.co.us.

New standardized templates have been developed for certain common oil and gas process units, as listed below. You are required to use these templates to complete O&M Plans for these specific process units. Do not modify the structure of the template.

On November 14, 2022 the Air Pollution Control Division issued revised versions of Operating and Maintenance Plan Templates for the following sources: Amine Sweetening Systems; Condensate, Crude Oil, and/or Produced Water Storage Tanks; Glycol Dehydration Systems, Hydrocarbon Liquid Loadout, Natural Gas-driven Pneumatic Pumps, Process Flares or Emergency Flares, Natural Gas Fired Reciprocating Internal Combustion Engines, and Separators. 

The changes made to the Operating and Maintenance Plan Templates include, but are not limited to:

  • Consolidation of Forms APCD-304: Condensate Storage Tanks, APCD-307: Produced water storage tanks, and APCD-308: Crude oil storage tanks into a single template - APCD-304: Hydrocarbon liquid and/or Produced Water Storage Tanks.
  • Rendering obsolete and removing Form APCD-303: Fugitive component leaks.

If a template is not available for your process unit, you may develop your own company-specific O&M Plan. In the future, the Division will develop standardized templates for all common oil and gas process unit types.

When is an O&M Plan required?

In general, an O&M Plan is required for a process unit with emission controls at a synthetic minor or major stationary source.

  • If a process unit is not controlled, then an O&M Plan is not required.

  • If the facility is a minor source (as defined in Regulation No. 3, Part A, Section I.B.), then an O&M Plan is not required.

  • If the process unit is approved to operate under a general permit, a unit-specific O&M Plan is not required. The General Permit already contains O&M requirements.

Need assistance or clarification?

Call (303) 692-3150 and ask to speak to a permit engineer in the Oil & Gas Unit, or email questions to cdphe_oandm@state.co.us.