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 p arti Cipan . t s: 

Na.-ne E~A ·office. •·; ~. 

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. 

2 
Agency 

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-Enforcea

O&G Sites Citation Construction Approval Timeline Options 

General Air Permit for Reg. 26.705 Construction may begin 30 days after Yes, listed in confirm

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 Sou

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 requeste

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 e

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 requeste

Shale construction followed by full 

application within 90/180 days after 

s!art of operation. -----

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Agency 

TCEQ TCEQ TCEQ 

UDAQ 

WVDEP 

WDEQ 

Comparison of Commonly Used Permitting Options for Midstream Sites 

DRAFT- FOR DISCUSSION PURPOSES 

Permit Commonly Used by Federally-Enforcea

O&G Sites Citation Construction Approval Timeline Options 

O&G Permit by Rule - non- 30 TAC 106.352 & Registration required to be submitted Yes, can be requeste

Barnett Shale 106.512 10 days after start of construction if 

installing natural gas engine> 240 hp. 

Registration required to be submitted 

prior to start of construction if sour gas 

(> 24 ppmv sulfur). Otherwise, no 

registration required. 

O&G Standard Permit 30 TAC 116.620 Construction may begin 45 days after Yes, can be requeste

application submittal or receipt of 

written notification from TCEQ, whichever is earlier. 

O&G Standard Permit - Non-Rule Standard Notification prior to start of Yes, can be requeste

Barnett Shale Permit construction followed by full 

application within 90 days after start of 

operation. 

Approval Order - Certification R307-120-4 Within 120 days of the filing date of Yes, can be requeste

the application, 

General Permit G35- Natural CSR 45-13-5.7.b. WVDEP must issue registration with Yes, can be requeste

Gas Facility 45 days after application is determined 

complete. 

Site Specific, Pre-Construction Chapter 6, Section 120-180 days; with or without Yes, can be requeste

Permits 2 modeling (inclusive of public 

comments) 

Median Construction Approval Timeline (days)- 30 

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