**~** Fallon, Gail
From: Sent: To: Bachman, Tom A. [tbachman@nd.gov] Wednesday, February 05, 2014 7:38AM Fallon, Gail Subject: RE: Quick question and availability for SIP planning call


### Gail:

Your understanding is correct. However, it is unlikelythat a well site would have an engine (or multiple engines) above 500 Hp. The pumping unit is usually run by an electric motor. Forthe first year (or less) there may be a generator set (around 300 Hp) on site to run the electric motor until the Rural Electric Cooperative can get power to the site. Any compressor engines (usually not needed because ofthe high pressure ofthe gas from well) would be small for a single well. Onlywhen we get into multiple well pads will we have the possibility ofengine totals over 500 Hp. We believe VOC emissions ( 100 tpy or greater) from the operation ofa well will probably require a permit before the engine emissions. Regarding the call, my day is done at 4:00 CST (3:00 MST). Ifwe can finish the call is 30 minutes, that would work. If not, we need to reschedule.
Tom Bachman, P.E. Manager; AirQuality ImpactAnalysis Program NO Dept. ofHealth (701) 328-5188

From: Fallon, Gail [mailto:fallon.qail@epa.gov] Sent: Tuesday, February 04, 2014 5:12PM To: Bachman, Tom A. Subject: RE: Quick question and availability for SIP planning call

So Ithink I understand your discussion below. Just to be clear, as an example, an engine that emits over5 tpy at a minor source oil and gas well productionfacility is notcurrently being individually permitted; the hypothetical engine would only be included in a permit ifthere is some other requirement forthe facility as a whole to obtain a permit. As another example, a minorsource that is not an oil and gas well production facility with an engine that operates above the various exemption thresholds would generally be required to obtain a minorsource permitforthe individual engine or be included in a permitforthe facility as awhole.

1Regarding our call nextweek, I hope the 2:30-3:30 pm mountain time slot isn'ttoo late foryou. Ifit is too late,just_let me know and we will switch to adifferent day. Attached is aworksheet to guide our discussions. We will call you. •
Gail
Gail Fallon Environmental Engineer Air Quality Planning Unit US EPA, Region 8 Denver, CO (303) 312-6281

From: Bachman, Tom A. [mailto:tbachman@nd.gov] Sent: Monday, February 03, 2014 12:50 PM To: Fallon, Gail Subject: RE: Quick question and availability for SIP planning call 

### Gail:
The exemptions under 33-15-14-02.13(c)(1}, (2) and (3) are applicable to engines no matterwhere they are located or applicable emission standards. If an engine (or the total horsepower ofall engines on site) is lessthan 500 Hp, then they are exempt from permitting requirements. Ifany engine (ortotal ofall engines on site) is less than 1000 Hp and they operate less than 500 hours peryear, they are exempt. Finally, ifthe emissions of any NAAQS pollutant from any size engine is less than 5tons per year (tpy} orthe total for multiple engines on site is less than 5tpy, they are exempt. The source only has to meet one ofthese criteria to be exempt. Engines at an oil and gas facility with less than 5 tons/yr ofemissions would be exempt provided there is no other requirement for the facility (as a whole) to obtain a permit. We do not use a "nested source" process for permitting oil and gas well production facilities (well sites) that are minor sources. Engines that are part of an oil and gas well production facility would not need a permit until thefacility PTE equals 100 tpy ofcriteria pollutants or 10/25 tpy of HAPs (see 33-15-14-02.13.0). Ifthe facility needed a permit for some other reason, the engines would be included in the permit for the facility even though they would be exempt ifthey were the only source(s). Regarding the conference call on February 11 1 h, 

### I have a State Health Council meeting that morning to presentthe next round of rule revisions (public comment was held in October and November of last year). Ifwe could have the call in the afternoon, that would work for me. Ifyou have any questions, please contact me. Tom Bachman, P.E. Manager; AirQuality
2lmpf1clAnalysis Program NO Dept. ofHealth (701) 328-5188

From: Fallon, Gail [mailto:fallon.gail@epa.gov] Sent: Monday, February 03, 2014 12:31 PM To: Bachman, Tom A. Subject: Quick question and availability for SIP planning call
Hi Tom, I have aquick question on permittingfor engines forthe 110(1) analysis. Based on yourcurrent SIP approved rules, would engines with greaterthan 5tpy emissions at oil and gas facilities fall into the oil and gas permitting exemption or would these be subjectto minorsource permitting (trying to get ND's interpretation of33-15-14.13.c(3))?
Also, we are beginning planningforthe next fouryears and would like to have acall withyou sometime before the end ofthe month. I'm wondering ifyou would be available next week, Feb 11th, 9-10 am, mountain timeforacall. Kathy Ayala and Abby Fulton here would be involved in the call. Below is a rough agenda:

Thanks, Gail Give states a list ofcurrent outstanding SIPs and share with them which ones we intend towork on Ask states what SIPs will be submitted in the nextfouryears Ask states ifthey have priority SIPs (such as permits) outside ofconsent decrees

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