Updates from Ohio EPA DAPC A&WMA’s All-Ohio Meeting August 10, 2017 Michael E. Hopkins, P.E. Assistant Chief, Permitting Ohio Environmental Protection Agency Division of Air Pollution Control 50 West Town Street, Suite 700 Columbus, OH 43216-1049 614-644-2270

Permitting Update Where we have been Current Status of Permitting Permitting Goals GP Updates Recent Updates 2

Where Have We Been

Installation Permit Workload 4

Title V Renewal Workload 5

Non-Title V Renewal Workload 6

Improvement Projects Streamline CO review New exemptions for insignificant sources 1996 – 40; 2017 - 64 Development of permit-by-rule program 1996 – 0; 2017 - 12 Development of General Permit program 1996 – 0; 2017 - 72 7

Improvement Projects Development of PTIO program Meant ½ the number of permits needed Stars2/Air Services system development Huge difference in our ability to manage work Multiple layers of improved guidance Engineering Guides Terms and Conditions Library 8

Improvement Projects Assist DO/LAA projects Move work from one DO/LAA to another Multiple other improvement projects 40 – 50 improvement projects Continuous Improvement Always have process improvement projects underway All improvements done while staff shrinking 9

Where are we Today?

Permitting 570 TV Facilities; 6000 NTV facilities; 50,000 operating emissions units Issuing 2700 final permits, 8800 emissions units/yr 90+% installation permits issued w/in 180 days 11

Installation Permit Issuance Times 12

Current Status 8 late installation permits pending 72 late Title V renewals pending Very few late PTIO renewals SEDO has about 40% of the late ones 13

Current Plans Process late installation permits if possible Title V Renewal Goals Late utility/refinery TV renewals final by 12/31/17 Other TV renewals final by 7/31/17 DO/Laas helping SEDO Several rounds of SEDO installation permits to others Current round of TV Renewals to others 14

Bottom Line Backlogs better than the past 20 years Close to “nirvana” – no backlogs / no late permits 15

RECENT changes

GP Updates 17

Ohio’s General Permits Pre-written permit for specific size and type of equipment Qualifying criteria must be met Company must agree to the qualifying criteria and terms Company submits application 18

Ohio’s General Permits Staff checks to see if they qualify No detailed review, no calculations, no writing terms If meets qualifying criteria – issue permit Average permit issuance time: 18 days 19

Current List of GPs 20 Aggregate Processing Miscellaneous Metal Parts and Products Coating Lines Boilers Oil and Gas Well-site Production Operations Diesel Engines (Compression Ignition Internal Combustion Engine) Paved and Unpaved Roadways and Parking Areas Digester Operations Paved Roadways and Parking Areas Dry-cleaning Operation Ready Mix Concrete Batch Plants Mid-Stream Compressor Equipment Storage Piles Updated Mineral Extraction Tub Grinder 20

Mid-Stream Compressor GPs Issued new GPs for equipment at mid-stream compressor stations Typically take “wet” gas from wells, dry it, and then compress the gas to put it into transmission pipeline. Draft – April 2016; Final – February 2017 22 new GPs, 120+ documents… lots of work 21

Compressor Station GPs 5 Lean Burn NG-Fired Spark Engines (100-3800 HP) 5 Rich Burn NG-Fired Spark Engines (100-3800 HP) 2 Diesel Engines (175-750 HP) 2 Glycol Dehydrators (90 – 150 MMscfd) 3 Flares (1 MMBtu/hr open, 10 MMBtu/hr enclosed, 20 MMBtu/hr enclosed) 1 Reciprocating Compressor 1 Equipment Leaks 1 Flash Vessel/Storage Tanks (21,000 gal) 1 Condensate Truck Loading Operation (32 mm gal/yr) 1 Pipeline Pigging Operation 22

Key Features Available for Title V and non-Title V facilities Incorporates NSPS Subpart OOOOa Most popular lean burn and Rich burn engines covered (100 to 3800 HP) Emission limits similar to PA Requires compressor maintenance blow-down to be controlled by routing to low pressure line 23

Key Features Uses OOOOa leak detection program Zero bleed controllers must be included in leak detection Requires flash vessel/storage vessel to vent to control (except produced water) Requires tank truck loading to be controlled (except produced water) 24

Key Features Requires controls on pigging if >3.24 ton/yr Will need to show project does not trip major NSR Will need to provide modeling if over thresholds Especially concerned about formaldehyde 25

Compressor Station GPs Now can be used Designed for mid-stream compressors but can be used for other operations Ohio GP web site: http://www.epa.ohio.gov/dapc/genpermit/genpermits.aspx 26

Next up w/ GPs? Will need to revise the well-site GPs Need to incorporate OOOOa requirements Feds put OOOOa on hold – must wait 27

Possible New Exemptions Issued a bunch of new exemptions in 2016 Beginning work on new group now Just starting rule process – pre-interested party started Need suggestions first Draft rules for comment next 28

Possible New Exemptions Natural gas transmission valve sites, and metering and regulating sites. Portable flares for burning natural gas from maintenance activities at natural gas facilities Restaurant grills and ovens used for food preparation Portable turbine for power 29

Possible New Exemptions Small cooling towers Temporary fuel burning equipment Small woodworking operations Battery charging operations Also – updating Permit-by-rules 30

Wrap-up The work goes on… Ohio EPA: http://epa.ohio.gov/home.aspx DAPC: http://epa.ohio.gov/dapc/AirPollutionControl.aspx Questions??? 31