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Published byJoy joyce Divine Modified over 10 years ago
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Michael Hopkins, P.E., Assistant Chief, DAPC 614-644-3611, Mike.Hopkins@epa.state.oh.us
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Revisions to Oil & Gas GP Revisions to the Unpaved Roadways GP Proposed PBR Timing issues Aggregation Other issues 2
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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
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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
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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
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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
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Qualifying criteria PBR adds tons/yr limits for flowback for BAT PBR references NSPS sections Require for each well? - still undecided 7
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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 http://epa.ohio.gov/dapc/pbr/permitbyrule. aspx 8
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Incorporate flowback into GP Simpler approach but: Need GP before flowback Does this work? 9
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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
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Ohio EPA Oil & Gas GP web page http://www.epa.ohio.gov/dapc/genpermit/g enpermits.aspx 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 http://epa.ohio.gov/dapc/pbr/permitbyrule. aspx 11
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Comments are due by March 22 nd 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
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Summit Petroleum 6 th 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
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U.S. EPA says Summit Petroleum decision applies in 6 th 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
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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
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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
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Information Locations: Answer Place ▪http://ohioepa.custhelp.com/app/homehttp://ohioepa.custhelp.com/app/home Ohio EPA Web ▪http://epa.ohio.gov/http://epa.ohio.gov/ District Offices/Local Air Agencies ▪http://epa.ohio.gov/dapc/general/dolaa.aspxhttp://epa.ohio.gov/dapc/general/dolaa.aspx Questions? 17
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