1. New Air Quality General Permit G70-A Overview WVONGA Air Permitting Issues Seminar September 12, 2013 Oglebay Resort, Wheeling, WV Laura Jennings Engineer DEP – Division of Air Quality 09/12/2013

2. Air quality permits are required when any of the following are triggered:  Criteria pollutants (CO, NO X, SO 2, PM, VOC): potential to emit (PTE) of 6 lbs/hr and 10 tpy or 144 lb/day of any criteria pollutant  Hazardous air pollutants: PTE of 2 lb/hr or 5 tpy of HAPs on an aggregated basis  Toxic air pollutants: Any TAP with PTE in amount greater than shown in Table 45-13A (formaldehyde limit is 1,000 lb/yr)  Subject to any substantive requirement 09/12/2013 45CSR 13 Permit Thresholds

3.  The maximum design capacity of a stationary source or emissions unit to emit a pollutant under its physical and operational design.  Air pollution control equipment is treated as part of its design if the effect it would have on emissions is enforceable in any permit. 09/12/2013 Potential to Emit (PTE)

4.  Any NG compressor equipped with a catalytic converter that is integral to the unit shall have PTE determined taking into reductions achieved by the catalytic converter.  The catalytic converter must be interlocked in such a way as to not allow operation of the engine without operation of the catalytic converter.  The catalytic converter shall have the catalyst replaced every 45,000 hours of operation or every ten (10) years, whichever is earlier. 09/12/2013 Potential to Emit (PTE)

5. What is an Air Quality General Permit?  General permits are authorized under 45CSR13 for the construction, modification or relocation of a category of sources by the same owner or operator or involving the same or similar processes or pollutants upon the terms and conditions specified in the general permit  Other Existing DAQ General Permits: Coal (G10), Asphalt (G20), NG Compressor Stations (G30, G33), NG Compressor Station w/ Dehydration (G35), Materials Handling (G40), Concrete (G50), Emergency Generators (G60, G65) 09/12/2013 General Permits Program

6.  Prevention and Control of Air Pollution in regard to the construction, modification, relocation, administrative update and operation of oil and natural gas production facilities located at the well site 09/12/2013 General Permit G70-A

7.  Draft G70-A went to public notice on March 29, 2013  Public notice period was extended from April 29, 2013 to May 17, 2013 upon request  Public comments received by May 17, 2013 were accepted  DAQ has reviewed the public comments and continues to address DAQ’s response to comments  DAQ has not yet issued the final version of G70-A 9/12/2013 G70-A Status:

8.  EPA proposed amendments following reconsideration of certain aspects of the August 12, 2012 final standards of the NSPS, Subpart OOOO on April 12, 2013  EPA finalized the proposed amendments on August 2, 2013  The final amendments become effective the date they are published in the Federal Register  The Federal Register publication is the official version of the final amendments  The final amendments have not yet been published in the Federal Register 09/12/2013 G70-A Status:

9.  All oil and natural gas production facilities included in NAICS Code 21111 (Crude Petroleum and Natural Gas Exploration) and SIC Code 1311 (Crude Petroleum and Natural Gas) are eligible for the G70-A General Permit except as identified on the following slides 09/12/2013 G70-A Applicability

10.  Any facility that is a “major source” “major source” defined by 45CSR14, 19, or 30. PTE 100 tpy of any criteria pollutant, or 10 tpy individual HAP, or 25 tpy aggregate HAPs, or 100,000 tpy CO2e  Any facility requiring a RACT analysis (R21)  Any facility using fuel other than NG (for fuel burning units or engines) 09/12/2013 G70-A Applicability Exclusions

11.  Any NG processing plant (defined by 40 CFR 60.5430)  Any NG sweetening plant  Any NG transmission compressor station  Any facility subject to NSPS, Subpart Kb  Any facility that will require individual permit review process or provisions or to incorporate requirement other than established in G70-A 09/12/2013 G70-A Applicability Exclusions

12. Applicable State Rules:  45CSR2 (PM & opacity from fuel burning units)  45CSR4 (objectionable odor)  45CSR6 (PM & opacity from enclosed combustion devices)  45CSR10 (SO2 from fuel burning units)  45CSR13 (Permitting requirements)  45CSR16 (NSPS requirements)  45CSR22 (Fee program)  45CSR34 (NESHAP requirements) G70-A Regulatory Applicability 09/12/2013

13. Applicable Federal NSPS Regulations:  40CFR60, Subpart OOOO (Standards of Performance for Crude Oil and Natural Gas Production, Transmission & Distribution)  Natural Gas Wells  Storage Vessels  Pneumatic Controllers  40CFR60, Subpart JJJJ (Standards of Performance for Stationary Spark Ignition Internal Combustion Engines) G70-A Regulatory Applicability 09/12/2013

14. Applicable Federal NESHAP Regulations:  40CFR63, Subpart ZZZZ Area Source Requirements (National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines)  40CFR63, Subpart HH Area Source Requirements (National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities) 09/12/2013 G70-A Regulatory Applicability

15.  1.0 Emission Units  2.0 General Conditions  3.0 Facility-Wide Requirements Source Specific Requirements:  4.0 Units listed in GP Registration  5.0 Natural Gas Well Affected Facility  6.0 Storage Vessels  7.0 Fuel burning units: Gas Production Units, In-line Heaters, Heater Treaters, and Reboilers  8.0 Pneumatic Controllers Affected Facility 09/12/2013 G70-A Overview

16.  9.0 (Reserved Section)  10.0 Natural Gas-Fired Compressor Engine (RICE)  11.0 Tank Truck Loading Facility  12.0 NSPS, Subpart OOOO Requirements for Storage Vessel Affected Facilities  13.0 NSPS, Subpart JJJJ Requirements for RICE  14.0 Control Devices not subject to NSPS, Subpart OOOO Requirements 09/12/2013 G70-A Overview

17.  15.0 NESHAP, Subpart ZZZZ Areas Source Requirements for RICE  16.0Dehydration Units  17.0NESHAP, Subpart HH Area Source Requirements for Dehydration Units with exemption from § 63.764(d)  18.0NESHAP, Subpart HH Area Source Requirements for Dehydration Units Not Located within an UA/UC  19.0NESHAP, Subpart HH Area Source Requirements for Dehydration Units Located within an UA/UC 09/12/2013 G70-A Overview

18. Emission Units:  Only emission units identified in G70-A Registration are authorized at the facility  Equipment installed, maintained, & operated to minimize fugitive emissions  Shall not exceed the maximum design capacities  Shall use control devices listed in Registration  Shall not exceed emission limits listed in Registration 09/12/2013 G70-A Section 1.0

19. Summary:  A summary of each section of the G70-A is provided on the following slides. This summary is not intended to be a complete set of requirements for each section, rather an overview  The summary provided is subject to revision pending final DAQ response to public comments received for the G70-A draft permit.  The complete requirements will be in the final version of G70-A when it is issued. 09/12/2013 G70-A Overview

20. 2.0 General Conditions:  Standard boilerplate language  Applicability and non-applicability conditions for sources seeking registration to G70-A  Definition section includes NSPS, Subparts OOOO and JJJJ and NESHAP, Subparts HH and ZZZZ definitions 3.0 Facility Wide Requirements:  Standard boilerplate language  Siting Criteria for emission units 09/12/2013 G70-A Sections 2.0 and 3.0

21. Units listed in the General Permit Registration:  Minor source emission limits  NSPS, Subpart OOOO applicability  NSPS, Subpart OOOO compliance date  NSPS, Subpart OOOO start-up, shutdown, malfunction  Standard language for recordkeeping and operation and maintenance of control equipment 09/12/2013 G70-A Section 4.0

22. 5.0 - Natural Gas Well Affected Facility:  NSPS, Subpart OOOO language  45CSR6 language for completion combustion device 6.0 – Storage Vessels:  Throughput limitation per registration  Emissions limitation per registration  Emissions determination (per NSPS, Subpart OOOO)  Control device requirements dependent on NSPS, Subpart OOOO applicability  Uncontrolled storage tanks (site specific sampling, T/P monthly monitoring) 09/12/2013 G70-A Sections 5.0 & 6.0

23. Fuel Burning Units - GPU’s, In-line heaters, Heater Treaters, and Glycol Dehydration Reboilers:  MDHI per registration  Emission limit per registration  NG throughput per registration  Opacity limit 09/12/2013 G70-A Section 7.0

24. 8.0 - Pneumatic Controllers:  NSPS, Subpart OOOO Requirements Only  Individual controllers are not listed in the registration  G70-A section applicability in the registration will indicate whether or not pneumatic controllers are affected facilities per NSPS, Subpart OOOO 9.0 - Reserved 09/12/2013 G70-A Section 8.0 & 9.0

25. 10.0 - NG-fired compressor engines (RICE):  Emission limit per registration  Fuel consumption per registration  Requirements for Catalytic Reduction Devices 11.0 – Tank truck loading facility:  Emission limits per registration  Throughput limits per registration  Control devices per registration 09/12/2013 G70-A Sections 10.0 & 11.0

26. 12.0 - Storage Vessel Affected Facilities:  NSPS, Subpart OOOO Requirements  Storage vessels are also subject to Section 6.0 13.0 – Spark Ignition Internal Combustion Engines:  NSPS, Subpart JJJJ requirements for non-emergency stationary spark ignition (SI) internal combustion engines (ICE)  Engines are also subject to Section 10.0  Engines may also be subject to Section 15.0 09/12/2013 G70-A Sections 12.0 & 13.0

27. Control devices not subject to NSPS, Subpart OOOO:  Includes devices to control VOC emissions from the storage tank. With permitted control requirements for the control devices listed in the registration, PTE calculations for determining applicability to NSPS, Subpart OOOO can be calculated based on controlled emissions.  Includes control devices used for tank truck loading operations if listed in the registration.  Includes control devices used to control VOC and HAP emissions from natural gas dehydration units if listed in the registration. 09/12/2013 G70-A Section 14.0

28. Reciprocating Internal Combustion Engines:  NESHAP, Subpart ZZZZ Area source requirements for non-emergency spark ignition engines.  DAQ has taken delegation of this area source GACT  Engines are also subject to Section 10.0  Engines may also be subject to Section 13.0 09/12/2013 G70-A Section 15.0

29. Dehydration Units:  Based on existing DAQ language for dehys  Throughput limit based on registration  Emission limits based on registration  Control devices per registration  TEG dehydration units may also be subject to Section 17.0, 18.0, or 19.0 09/12/2013 G70-A Section 16.0

30. Dehydration Units with exemption from § 63.764(d):  NESHAP, Subpart HH Area Source Requirements  DAQ has taken delegation of this area source GACT  Includes exceptions for both flowrate and for benzene emissions  The dehydration unit is also subject to Section 16.0  The dehydration re-boiler is also subject to Section 7.0 09/12/2013 G70-A Section 17.0

31. 18.0 – Dehydration units subject to NESHAP, Subpart HH and Not Located within an Urban Area/ Urban Cluster.  NESHAP, Subpart HH area source requirements limited to the titled scenario for sources that do not meet either the flowrate or benzene emission exceptions to § 63.764(d).  The dehydration unit is also subject to Section 16.0  The dehydration re-boiler is also subject to Section 7.0 09/12/2013 G70-A Section 18.0

32. 19.0 - Dehydration units subject to NESHAP, Subpart HH and Located within an Urban Area/ Urban Cluster.  NESHAP, Subpart HH requirements for sources located in an UA plus offset/ UC boundary that do not meet either the flowrate or benzene emission exceptions to § 63.764(d).  The dehydration unit is also subject to Section 16.0  The dehydration re-boiler is also subject to Section 7.0 09/12/20132 G70-A Section 19.0

33. G70-A Registrations will include facility specific information that was provided in the application including:  Registration number, company and facility name, ID number  G70-A permit section applicability based on the equipment that will be located at and operated at this facility  Emission units table  NG wells table  Emission limits table  Throughput limits table  Engine information table 09/12/2013 G70-A Registrations

34. Q1: Where will I find the final G70-A permit and the final application forms? A1: The final G70-A General Permit, G70-A Fact Sheet, G70-A Instructions and Forms,, G70-A Registration, General Permit Registration Application, and G70-A Response to Public Comment Document will be available on DAQ’s website: www/dep.wv.gov/daq/permitting/General Permit Registration 09/12/2013 G70-A Q & A:

35. Q2: If I want to submit an application for a G70-A permit registration after the G70-A is effective, what do I need to do? A2: After you verify that all eligibility requirements are met, complete and submit the following to DAQ:  General Permit Registration Application, along with all required attachments & support documents  Certification of Information (Signed by Responsible Official or Authorized Representative)  G70-A Application Fees  Publish Class I Legal Advertisement 09/12/2013 G70-A Q & A:

36. Q3: What are the fees associated with the G70-A? A3: The G70-A registration fees are as follows: $500 (Construction or Modification) $300 (Class II Administrative Update) $1,000 (NSPS fee for Subparts JJJJ or OOOO) $2,500 (NESHAP fee for Subparts ZZZZ* or HH) Note: only one NSPS or NESHAP fee applies * Waived for new engines that comply by NSPS, Sub JJJJ 09/12/2013 G70-A Q & A:

37. Q4: What is required in the public notice? A4: Accurate, & consistent information including: Directions must be specific and accurate Longitude & Latitude coordinates must be as accurate as possible (decimal format) Must be consistent with what was provided to OOG Emissions must be consistent with emissions provided in the application 09/12/2013 G70-A Q & A:

38. Q5:When is a G70-A permit required? A5:A G70-A permit is required any time the permit thresholds in 45CSR13 will be triggered. 09/12/2013 G70-A Q & A:

39. Q6: Is a permit required prior to the completion operation? A6:  Completion combustion operations ALONE typically do not trigger 45CSR13 permitting thresholds. Extended use of completion combustion devices however, may require permitting.  A two-day notification for completion operations is required for all NG well completion operations. Instructions and forms are on DAQ’s website: www/dep.wv.gov/daq G70-A Q & A: 09/12/2013

40. Q7: Are there plans to update the other NG General Permits? A7: Yes, DAQ’s future plans include:  Updating G-35A (NG compressor stations with Glycol dehydration units) to include NSPS, Subpart OOOO language and amended MACT, Subpart HH language  Updating G-30D (NG compressor stations) to include NSPS, Subpart OOOO language  Updating G-33A (engines > 25HP and < 500 HP)to include NSPS, Subpart OOOO language G70-A Q & A: 09/12/2013

41. Common permit application mistakes WVONGA Air Permitting Issues Seminar September 12, 2013 Oglebay Resort, Wheeling, WV Jerry Williams, PE Engineer DEP, Division of Air Quality 9/12/2013

42.  Do they exist?  What needs to be included?  What are common mistakes?  How can you make sure everything is included? 09/12/2013 A “Perfect” Permit Application

43.  Yes. Although rarely seen, like Sasquatch, there are people who say they exist. 09/12/2013 Do they exist?

44.  Application forms signed by the Responsible Official in blue ink.  All applicable attachments as listed on Page 4 of the R13 Permit Application and General Permit Application.  All necessary permit application fees. 09/12/2013 What needs to be included?

45.  Permit application not signed by the Responsible Official (including not being signed in blue ink)  Failure to include required attachments that are completed in their entirety  Inclusion of all equipment data  Inclusion of all engine data (type, date of manufacture, is it EPA certified (include EPA certificate of conformity))  Utilization of manufacturer’s data 09/12/2013 Common Mistakes

46.  Failure to include all necessary emission calculations  Storage tank flashing emissions (utilization of acceptable test sample and an appropriate methodology)  Utilization of manufacturers data  Fugitive/SSM/Blowdown emissions  GHG emissions  All necessary supporting documentation (emission models, Gly-Calc, manufacturers information, etc.) 09/12/2013 Common Mistakes

47.  Submittal of appropriate application fees  Application fee, NSPS, NESHAP  $1,000 Permit Application Fee  $1,000 Applicable NSPS Fee  $2,500 Applicable NESHAP Fee 09/12/2013 Common Mistakes

48.  $1,000 Applicable NSPS Fee  40CFR60 Subpart Kb, IIII, JJJJ, OOOO, etc.  $2,500 Applicable NESHAP Fee  40CFR63 Subpart HH, ZZZZ  40CFR63 Subpart HH (If you have a applicable glycol dehydration unit, this fee must be paid)  40CFR63 Subpart ZZZZ (If you have an engine that is deemed ‘existing’ as an area source under this rule, this fee must be paid) 09/12/2013 Common Mistakes

49.  40CFR63 Subpart ZZZZ  For stationary RICE located at an area source of HAP emissions, an engine is considered ‘existing’ if you commenced construction or reconstruction before June 12, 2006. 09/12/2013 Common Mistakes

50.  Failure to submit a Source Aggregation Analysis  What does this mean?  “Building, structure, facility, or installation” is defined as all the pollutant emitting activities which belong to the same industrial grouping, are located on one or more contiguous or adjacent properties, and are under the control of the same person  If a facility meets all of these criteria, emissions from all applicable sources must be aggregated in order to determine the facility’s total emissions in regards to Title V major source or PSD status 09/12/2013 Common Mistakes

51.  How is Source Aggregation determined?  Same Industrial Grouping (common SIC code)  Contiguous or adjacent  Under common control (Permitting collocated facilities complicates this issue) 09/12/2013 Common Mistakes

52.  What can you do for Source Aggregation Analysis?  Provide as much information as possible to support your aggregation determination  This includes:  SIC code of facility  Ownership issues  Contiguous or adjacent issues  Proximity  Operational dependence or lack thereof  What equipment is in question  Why you made the aggregation decision 09/12/2013 Common Mistakes

53.  This industry is very dynamic  Applicants are seeking permits more than ever  Everybody wants their permit ASAP  Applicants are not including the necessary information to make aggregation determinations.  This will result in a permit review delay  We will ask these questions  Therefore, it is imperative that you are proactive and include this information with every air permit application 09/12/2013 Common Mistakes

54.  Follow the steps above and if there are questions, please feel free to contact the DAQ 09/12/2013 How can you make sure everything is included?

55. Laura Jennings Phone: 304-926-0499 ext. 1217 E-mail: Laura.M.Jennings@wv.govLaura.M.Jennings@wv.gov Jerry Williams Phone: 304-926-0499 ext. 1223 E-mail: Jerry.Williams@wv.govJerry.Williams@wv.gov 09/12/2013 Questions?