~ 

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 unlikely that a well site would have an 

engine (or multiple engines) above 500 Hp. The pumping unit is usually run by an 

electric motor. For the 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 of the high pressure 

of the gas from well) would be small for a single well. Only when we get into multiple 

well pads will we have the possibility of engine totals over 500 Hp. We believe VOC 

emissions ( 1 00 tpy or greater) from the operation of a well will probably require a 

permit before the engine emissions. 

Regarding the call, my day is done at 4:00 CST (3:00 MST). If we can finish the call is 

30 minutes, that would work. If not, we need to reschedule. 

Tom Bachman, P.E. 

Manager; Air Quality 

Impact Analysis Program 

NO Dept. of Health 

(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 I think I understand your discussion below. Just to be clear, as an example, an engine that emits over 5 tpy at a minor 

source oil and gas well production facility is not currently being individually permitted; the hypothetical engine would 

only be included in a permit if there is some other requirement for the facility as a whole to obtain a permit. As another 

example, a minor source 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 minor source permit for the individual engine or 

be included in a permit for the facility as a whole. 

1 
Regarding our call next week, I hope the 2:30-3:30 pm mountain time slot isn't too late for you. If it is too late, just_ let 

me know and we will switch to a different day. Attached is a worksheet 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 

matter where they are located or applicable emission standards. If an engine (or the 

total horsepower of all engines on site) is less than 500 Hp, then they are exempt from 

permitting requirements. If any engine (or total of all engines on site) is less than 1000 

Hp and they operate less than 500 hours per year, they are exempt. Finally, if the 

emissions of any NAAQS pollutant from any size engine is less than 5 tons per year 

(tpy} or the total for multiple engines on site is less than 5 tpy, they are exempt. The 

source only has to meet one of these criteria to be exempt. Engines at an oil and gas 

facility with less than 5 tons/yr of emissions 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 the facility PTE equals 1 00 tpy of criteria pollutants or 10/25 tpy 

of HAPs (see 33-15-14-02.13.0). If the 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 if they were the only source(s). 

Regarding the conference call on February 111

h, I have a State Health Council meeting 

that morning to present the next round of rule revisions (public comment was held in 

October and November of last year). If we could have the call in the afternoon, that 

would work for me. 

If you have any questions, please contact me. 

Tom Bachman, P.E. 

Manager; Air Quality 

2 
lmpf1cl Analysis Program 

NO Dept. of Health 

(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 a quick question on permitting for engines for the 110(1) analysis. Based on your current SIP approved rules, 

would engines with greater than 5 tpy emissions at oil and gas facilities fall into the oil and gas permitting exemption or 

would these be subject to minor source permitting (trying to get ND's interpretation of 33-15-14.13.c(3))? 

Also, we are beginning planning for the next four years and would like to have a call with you sometime before the end 

of the month. I'm wondering if you would be available next week, Feb 11th, 9-10 am, mountain time for a call. Kathy 

Ayala and Abby Fulton here would be involved in the call. Below is a rough agenda: 

Thanks, 

Gail 

Give states a list of current outstanding SIPs and share with them which ones we intend to work on 

Ask states what SIPs will be submitted in the next four years 

Ask states if they have priority SIPs (such as permits) outside of consent decrees 

3