1. 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

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

3. Where Have We Been

4. Installation Permit Workload4

5. Title V Renewal Workload5

6. Non-Title V Renewal Workload6

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

8. 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

9. 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

10. Where are we Today?

11. 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

12. Installation Permit Issuance Times12

13. 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

14. 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

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

16. RECENT changes

17. GP Updates 17

18. 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

19. 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

20. 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

21. 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

22. Compressor Station GPs
5 Lean Burn NG-Fired Spark Engines ( HP)
5 Rich Burn NG-Fired Spark Engines ( HP)
2 Diesel Engines ( 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

23. 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

24. 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

25. 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

26. Compressor Station GPs
Now can be used
Designed for mid-stream compressors but can be used for other operations
Ohio GP web site: 26

27. 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

28. 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

29. 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

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

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