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Michael Hopkins, P.E., Assistant Chief, DAPC 614-644-3611,

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Presentation on theme: "Michael Hopkins, P.E., Assistant Chief, DAPC 614-644-3611,"— Presentation transcript:

1 Michael Hopkins, P.E., Assistant Chief, DAPC ,

2  Revisions to Oil & Gas GP  Revisions to the Unpaved Roadways GP  Proposed PBR  Timing issues  Aggregation  Other issues 2

3  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

4  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

5  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

6  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

7  Qualifying criteria  PBR adds tons/yr limits for flowback for BAT  PBR references NSPS sections  Require for each well? - still undecided 7

8  Review qualifying criteria  Review language of “permit” within rule  Submit application – coverage begins  Find approval on web page  aspx aspx 8

9  Incorporate flowback into GP  Simpler approach but:  Need GP before flowback  Does this work? 9

10  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

11  Ohio EPA Oil & Gas GP web page  enpermits.aspx enpermits.aspx  Ohio EPA Oil & Gas PBR web page  aspx aspx 11

12  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 or via or phone:  Ohio EPA will review comments  GPs might be available by the end of April  PBR will take about a year - rule process 12

13  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

14  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

15  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 address   No physical flowback reports are needed for Ohio EPA 15

16  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

17  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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