Facility application closed on technicality

This major operator's sulphur recovery plant amendment application was refused for a technicality. If she'd know the simple instructions the regulator later gave to her, the operator could have saved the application.

Closed applications are a big problem. For example, Husky, Penn West and Apache have each faced rejection over fifteen hundred times. If each application costs only $15k to submit, this is a waste of over $60million.

Applications are closed for two reasons: technical and technicality.

If closed for a technical reason, the regulator might be saying, "No, I'm sorry. We don't agree that you should flare acid gas at this location and quantity."

An example of closure on a technicality: "Sorry, you notified the wrong parties."

Read closed applications

The best way to prevent closure is to read other closed applications. At Proven, we read five closed applications for every application we submit. Closed applications clearly show what the regulator rejects and why they reject it.

On three quarters of submitted applications, the regulator calls or writes with questions and concerns. Handling these is like handling horses. If you know what you're doing and how to handle them, you get a smooth ride. If you don't know how to handle them, you can get kicked and thrown -- your application could be closed and you could end up on the noncompliance list.

Because regulations change, you really need to look at recent applications as well as the guidelines and checklists. Otherwise, you're likely to get a surprising application closure.

Subscribers can view this application by pasting the following link into their browser after logging into AppIntel. http://app.appintel.info/AOW.php?pxnrg=44426n3835383o343431366363

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Tags: AER application, Closure, Facilities

  8 Jun 2016

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