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Proposed Changes to the Oil & Gas Air Pollution General Permit

This document provides information on the proposed revisions to the Oil & Gas GP, Unpaved Roadways GP, and the proposed PBR, as well as timing issues, aggregation, and other related topics.

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Proposed Changes to the Oil & Gas Air Pollution General Permit

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  1. Michael Hopkins, P.E., Assistant Chief, DAPC 614-644-3611, Mike.Hopkins@epa.state.oh.us Proposed Changes to the Oil & Gas Air Pollution General Permit

  2. Topics • Revisions to Oil & Gas GP • Revisions to the Unpaved Roadways GP • Proposed PBR • Timing issues • Aggregation • Other issues 2

  3. What is being revised in the Oil & Gas GP? • Incorporate NSPS OOOO into the GP • Add a second Oil & Gas GP to enhance flexibility • Second GP = First GP except: • Flare size changed from 10 mmBtu to 32 mmBtu • NG engines maximum total HP changed from 1,800 HP to 1,000 HP • Same well-site emissions • Simplify the Qualifying Criteria 3

  4. What is being revised in the Unpaved Roadways GP? • Eliminate the need to do daily roadway inspections (for fugitive dust) on days that the roadway is not used. • Eliminates unnecessary inspections • Propose to change both the Title V and the Non Title V versions of the unpaved roadway GPs (GP 5.1 and GP 5.2) 4

  5. What is the Proposed PBR for? • Our current GP does not cover flowback operations • NSPS OOO now covers flowback • The PBR is designed to cover the NSPS flowback operations • Proposed to have Ohio EPA be the primary entity to regulate NSPS flowback requirements instead of U.S. EPA 5

  6. What is the Proposed PBR for? • Means all of the NSPS regulated by Ohio EPA • Means all of the NSPS reports go to Ohio EPA • U.S. EPA retains overall enforcement authority but Ohio EPA becomes the primary enforcement authority 6

  7. What Requirements are in the PBR? • Qualifying criteria • PBR adds tons/yr limits for flowback for BAT • PBR references NSPS sections • Require for each well? - still undecided 7

  8. What is the PBR process? • Review qualifying criteria • Review language of “permit” within rule • Submit application – coverage begins • Find approval on web page • http://epa.ohio.gov/dapc/pbr/permitbyrule.aspx 8

  9. What alternative is there to a PBR? • Incorporate flowback into GP • Simpler approach but: • Need GP before flowback • Does this work? 9

  10. What is in the interested party package? • Cover letter w/ common questions and answers • Draft Qualifying Criteria for both Oil & Gas GPs • Draft Model General Permit terms for the two oil & gas GPs • Proposed changes to the Roadway GP • Draft rule language for the flowback PBR 10

  11. Where do I get Copies? • Ohio EPA Oil & Gas GP web page • http://www.epa.ohio.gov/dapc/genpermit/genpermits.aspx • Ohio EPA Oil & Gas PBR web page • http://epa.ohio.gov/dapc/pbr/permitbyrule.aspx 11

  12. Timing Issues • Comments are due by March 22nd • Cheryl Suttman at: Ohio EPA Division of Air Pollution Control, 50 West Town Street, Suite 700, Columbus, OH 43215 or via e-mail: cheryl.suttman@epa.state.oh.us; or phone: 614-644-3617 • Ohio EPA will review comments • GPs might be available by the end of April • PBR will take about a year - rule process 12

  13. Aggregation Issues • Summit Petroleum 6th Circuit decision applies in Ohio • Applies when deciding on major source status for NSR or Title V • Court said that if two properties are not next to each other, then not adjacent and can’t be part of the same stationary source 13

  14. Aggregation Issues • U.S. EPA says Summit Petroleum decision applies in 6th Circuit states like Ohio • Ohio will follow this decision • Typically means most well sites are not to be grouped with each other because they are not adjacent • Still case-by-case analysis • We will need property lines/owners 14

  15. Flowback Reports • New NSPS flowback report submittal procedure • Need to send reports to U.S. EPA and Ohio EPA • Flowback reports to Ohio EPA can now go to a new e-mail address • OEPA_subpartOOOO_reports@epa.state.oh.us • No physical flowback reports are needed for Ohio EPA 15

  16. Other Issues • Inventory folks working with MARAMA Oil and Gas Workgroup • At some point, will need to develop a good emissions inventory – we are just starting that process • Make sure you have your GP prior to production 16

  17. Wrap-up • Information Locations: • Answer Place • http://ohioepa.custhelp.com/app/home • Ohio EPA Web • http://epa.ohio.gov/ • District Offices/Local Air Agencies • http://epa.ohio.gov/dapc/general/dolaa.aspx • Questions? 17

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