# November 12, 2015

Memorandum

Subject: November 10, 2015 Meeting Between the Gas Processors Association (GPA) and its Members and the U.S. Environmental Protection Agency

From: 

# (EP~ · 

# - -

...

. 

# "-

. 

# Christopher



# ton~y Advisor Outreach and Information Division

, Office of Air Quality Planning and Standards (OAQPS)

To: Docket- EPA-HQ-OAR-2014-0606

This memorandum to docket provides a brief summary of the main discussion points made at the subject meeting for the proposed rulemaking: "Review ofNew

· Sources and Modifications in Indian Country: Federal Implementation Plan for Managing Air Emissions from True Minor Sources Engaged in Oil and Natural Gas Production in Indian Country," (80 Federal Register 56554, September 18, 2015)..

When: November 10, 2015; 1:00-3:30 p.m. ET Where: EPA Offices, RTP, NC EPA arti

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# p Cipan s: 

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# · office

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# Bruce Moore Office of Air Quality Planning and Standards Lisa Thompson Office of Air Quality Planning and Standards Charlene Spells Office of Air Quality Planning and Standards Amy Hambrick Office of Air Quality Planning and Standards Mattll.ew Witosky Office of Air Quality Planning and Standards Jodi Howard Office of Air Quali_ty Plannin_g and Standards Christopher Stoneman Office of Air Quality Planning and Standards Greg Nizich Office of Air Quali!J Planning and Standards Jameel Alsalam Office of Atmospheric Programs

GP A and -its Members:



# Name Company Melanie Roberts Targa Resources David Oldaker Enterprise Products
Jaron Hill Williams
Matt Hite GPA Claudio Galli Enbridge Adrienne Sandoval Tesoro Logistics Jeff Stovall Crestwood

# Other:

EC/R j 

# Name · 

# I CoJDpany

The EPA met with GPA and its members at the energy organization's request. During the meeting, several topics were discussed related to the proposed rulemaking. The topics

were:

• Creation of synthetic minor sources using streamlined permitting approaches (see attached);

• The EPA's rationale for why it has issued general permits for some categories of
minor sources and permits by rule for others;

• Coverage of gas processors plants under the proposed Federal Implementation
Plan (FIP);

• Transition for areas oflndian country under the proposed Federal Implementation
Plan from attainment to nonattainment; and

• How the proposed FIP would address minor modifications at major sources.

The EP.A answered basic questions clarifying its thinking on the proposed rule and
offered to be available for further discussions and/or exchanges of technical information.

This memorandum will be filed in the docket for the above actions and will be available
for public review.



# 2Agency ADEQ CDPHE NDDOH NDDOH NMED NMED ODEQ PADEP TCEQ Comparison of Commonly Used Permitting Options for Midstream Sites

DRAFT- FOR DISCUSSION PURPOSES

Permit Commonly Used by Federally-Enforceable Limit

O&G Sites Citation Construction Approval Timeline Options

General Air Permit for Reg

. 26.705 Construction may begin 30 days after Yes

, listed in confirmation letter.

Compression Stations submittal of complete NOI or receipt

of ADEQ Confirmation Letter,

whichever is earlier.

General Air Permit for RICE httgs: / / www.colora "Conditional certification of a Yes

(GP02) do.gov / Qacific / sites / registration under this general permit is

default / files / AP Ge effective from the date the complete

neral-Permit- registration request is received by the

GP02.Qdf APCD." Ifthe engines do not qualify

for registration

, the owner or operator

accepts liability.

Permit to Construct (PTC) and NDAC 33-15-14 Construction may begin upon receipt Synthetic Minor Source Permit option

Permit to Operate (PTO) of a PTC by NDDOH. Typical available

application processing time is 30-60

days.

Storage Tank Registration Guidance Policy / Tank registration due within 30 days Yes

NDAC 33-15-07 of start of operation.

GCP 1 Level One Oil and Gas NMAC NMED must grant or deny within 30 Yes

Installations 20

. 2.72.220 days after receiving an application

.

GCP4 Combustion Sources & NMAC NMED must grant or deny within 30 Yes

Related Equipment 20

. 2

. 72.220 days after receiving an application.

General Permit for Oil & Gas OAC 252:100-7- Construction may begin upon receipt Yes, can be requested in application.

Facilities 15(b)(2) of a Notice of Intent by ODEQ.

GP-5 Natural Gas 25 Pa. Code § § P ADEP will issue authorization within The GP-5 limits are enforceable

.

Compression

and/or 127.611 30 days after receipt.

Processing Facilities

O&G Permit by Rule

- Barnett 30 TAC 106.352 Notification prior to start of Yes, can be requested in application.

Shale construction followed b y full
application within 90 / 180 days after

s!art of operation.

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1 of2AgencyTCEQTCEQTCEQUDAQWVDEPWDEQComparisonofCommonlyUsedPermittingOptionsforMidstreamSitesDRAFT-FORDISCUSSIONPURPOSESPermitCommonlyUsedbyFederally-EnforceableLimitO&GSitesCitationConstructionApprovalTimelineOptionsO&GPermitbyRule-non-30TAC106.352&RegistrationrequiredtobesubmittedYes,canberequestedinapplication.BarnettShale106.51210daysafterstartofconstructionifinstallingnaturalgasengine>240hp.Registrationrequiredtobesubmittedpriortostartofconstructionifsourgas(>24ppmvsulfur).Otherwise,noregistrationrequired.O&GStandardPermit30TAC116.620Constructionmaybegin45daysafterYes,canberequestedinapplication.applicationsubmittalorreceiptofwrittennotificationfromTCEQ,whicheverisearlier.O&GStandardPermit-Non-RuleStandardNotificationpriortostartofYes,canberequestedinapplication.BarnettShalePermitconstructionfollowedbyfullapplicationwithin90daysafterstartofoperation.ApprovalOrder-CertificationR307-120-4Within120daysofthefilingdateofYes,canberequestedinapplication.theapplication,GeneralPermitG35-NaturalCSR45-13-5.7.b.WVDEPmustissueregistrationwithYes,canberequestedinapplication.GasFacility45daysafterapplicationisdeterminedcomplete.SiteSpecific,Pre-ConstructionChapter6,Section120-180days;withorwithoutYes,canberequestedinapplication.Permits2modeling(inclusiveofpubliccomments)MedianConstructionApprovalTimeline(days)-302of2