Proposed Changes to the Oil & Gas Air Pollution General Permit

Michael Hopkins, P.E., Assistant Chief, DAPC614-644-3611, Mike.Hopkins@epa.state.oh.us

Revisions to Oil & Gas GP Revisions to the Unpaved

Roadways GP Proposed PBR Timing issues Aggregation Other issues

Topics

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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 Criteria3

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)

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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

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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

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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

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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

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What alternative is there to a PBR?

Incorporate flowback into GP Simpler approach but: Need GP before flowback

Does this work?

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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

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Where do I get Copies?

Ohio EPA Oil & Gas GP web page http://www.epa.ohio.gov/dapc/genpermit/g

enpermits.aspx

Ohio EPA Oil & Gas PBR web page http://epa.ohio.gov/dapc/pbr/permitbyrule.

aspx

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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

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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

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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

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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

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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

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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?

Wrap-up

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