1 

# GP 12.1/ 12.2 Air Permitting of Oil and Gas

Well Site Production Operations in Ohio JO H N S CH M EL Z L E | M A Y 13 , 2 0 142 

# RETTEW

▶ 

### Civil, environmental, transportation, and structural engineering; surveying; safety consulting; and w ater t reatment ▶ 

### 350 employees ▶ 

### Offices in:  Pennsylvania  Ohio  New York  Colorado3 

# Topics

▶ 

## Background: Ohio EPA ▶ 

## Preparing the Application ▶ 

## Compliance and Resources4 

# Background: Ohio EPA5 

# Background

▶ Oil and gas well site production operations in Ohio are permitted under two general permits
▶ GP 12.1/ 12.2 for the well site production operations
▶ GP 5.1 for the unpaved roadways/ parking areas
▶ Initial GP 12.1 issued in 20 11
▶ Aggregate natural gas engine horsepower ≤ 1,800 BHP
▶ Combustor/ flare heat input capacity ≤ 10 MMBTU / hr6 

# Background
▶ 

### Revised GP 12.1 and new GP 12.2 issued in April 20 14 ▶ 

### GP 12.1 ▶ 

### Aggregate natural gas engine horsepower ≤ 1,80 0 BHP ▶ 

### Combustor/ flare heat input capacity ≤ 10 MMBTU / hr ▶ 

### GP 12.2 ▶ 

### Aggregate natural gas engine horsepower ≤ 1,0 0 0 BHP ▶ 

### Combustor/ flare heat input capacity ≤ 32 MMBTU / hr7 

# Background

▶ 

### Other changes include: ▶ 

### Incorporation of NSPS 40 CFR Part 60 Subpart OOOO applicable requirements ▶ 

### Revised LDAR requirements ▶ 

### Revised GP 5.1 (unpaved roadways/ parking areas) inspection/ monitoring requirements8 

# Preparing the Application9 

# Preparing the Application

▶ 

### Potential emissions calculations for all sources at the site
▶ Natural gas - fired reciprocating internal combustion engines (RICE)
▶ Diesel - fired reciprocating internal combustion engines (RICE)
▶ Storage tanks and truck loading for liquids
▶ Dehydration ( Dehy ) units/ reboilers
▶ Flare/ combustor
▶ Ancillary equipment/ components
▶ Unpaved roadways Potential Emissions Calculations Natural Gas-Fired Compressor Engine - CAT G3516 with Oxidation Catalyst Catalyst Minimum Maximum Maximum Uncontrolled Uncontrolled Control Controlled Engine Hours of Uncontrolled Controlled Emission Factor Emission Factor Efficiency Emission Factor Horsepower Operation Emission Rate Emission Rate Pollutant (g/bhp-hr) (lb/MMBTU) Source (%) (g/bhp-hr) (lb/MMBTU) (bhp) (hrs/yr) (lbs/hr) (tons/yr) (lbs/hr) (tons/yr) NOx 0.50 --- Manufacturer 0% 0.50 --- 1,380 8,760 1.52 6.66 1.52 6.66 VOC (NMNEHC) 0.55 --- Manufacturer 50% 0.275 --- 1,380 8,760 1.67 7.33 0.84 3.66 CO 2.85 --- Manufacturer 93% 0.200 --- 1,380 8,760 8.67 37.98 0.61 2.66 SOx --- 5.88E-04 AP-42, Table 3.2-2 0% --- 5.88E-04 1,380 8,760 0.0059 0.026 0.0059 0.026 PM10 --- 9.9871E-03 AP-42, Table 3.2-2 0% --- 9.9871E-03 1,380 8,760 0.10 0.44 0.10 0.44 PM10 (filterable) 7 71E 05 AP 42 Table 3 2 2 0% 7 71E 05 1 380 8 760 0 00078 0 0034 0 00078 0 003410 

# Preparing the Application

▶ 

### P rocess flow diagram of well site production operations ▶ 

### Indicate each air emission source and emission point ▶ 

### Site layout showing unpaved roadways/ parking areas ▶ 

### Indicate travel segment(s) and associated travel distances11 

# Preparing the Application

GP12.1 PTIO Application - Process Flow Diagram Gas Pipeline Sales
PM, SOx, NOx, CO, VOC, HAPs PM, SOx, NOx, CO, VOC, HAPs Lean Glycol 5 MMCFD Glycol Dehydration Unit (P001) Compressor Engine (P002) w/BTEX Condenser Wet Gas Stream from Well Low Pressure Inlet Separator & Gas CAT G3516B, 1,380 bhp Gas and Flash Separator (2) Heater Treater (1.5 MMBTU/hr) (1) with Oxidation Catalyst PM, SOx, NOx, CO, VOC, HAPs
PM, SOx, NOx, CO, VOC, HAPs Oil Water Rich Glycol Dehy Reboiler (0.5 MMBTU/hr) VOC, HAPs Flare (P004) Two (2) One (1) One (1) 500-bbl 500-bbl 500-bbl Oil Tanks Water Tank Slop Tank Slop liquid (predominantly condensate (some water) from various equipment, such as the

(T001) (T001) (T001) compressor blowcase, flare knockout, etc.)

Truck Loadout (3) Notes: 1. Incoming well gas enters through inlet separator and then is heated indirectly by a heater treater to condition the gas. 2. Glycol dehydration unit still vent emissions are controlled by a BTEX Condenser and then routed to the reboiler for combustion. Flash separator emissions are controlled by the flare. 3. During truck loading, a vapor return line routes vapors back into the tanks that are controlled by the flare.12 

# Preparing the Application

▶ 

### Review and complete the GP 12.1/ 12.2 and GP 5.1 qualifying criteria documents – available online
▶ Will the facility meet site - wide emission limitations?
▶ Will sources meet the source - specific emission limits?
▶ Will each source meet applicable capacity limits?
▶ Will engine stacks meet the applicable height and location requirements?
▶ Will the facility meet the monitoring, record keeping, and reporting requirements?
▶ Will vehicle miles traveled on unpaved roadways be less than or equal to 120 ,0 0 0 miles/ year?13 

# Preparing the Application

▶ 

### If the facility will meet all of the qualifying criteria, be sure to check the yes box next to each question

√ √ √14 

# Preparing the Application

▶ 

### Complete the Emissions Activity Category ( EAC ) forms – available online ▶ 

### EAC 310 0 Dehy units (P0 0 1) ▶ 

### EAC 3862 Natural gas - fired internal combustion engines (P0 0 2) ▶ 

### EAC 3862 Diesel - fired internal combustion engines (P0 0 3) ▶ 

### EAC 310 1 Flare/ combustor (P0 0 4) ▶ 

### EAC 310 0 Ancillary equipment/ components (F0 0 1) ▶ 

### EAC 3111 Unpaved roadways/ parking areas (F0 0 2) ▶ 

### EAC 310 4 Storage tanks/ vessels (T0 0 1)15 

# Preparing the Application

▶ 

### Note that even if a certain air emission source that is contained in the GP (P0 0 1 through T0 0 1) will not be present at the facility, an EAC form must still be completed and included in the application – simply indicate NA; not planned for the site. Example: P0 0 3 diesel - fired internal combustion engines.16 

# Preparing the Application

▶ 

### Build the application within OEPA’s eBusiness Center – Air Services17 

# Preparing the Application

▶ 

### Facility profile ( eBusiness Center – Air Services) ▶ 

### Site name, location, SIC/ NAICS ▶ 

### Emission units, control devices, stacks ▶ 

### Emission units correspond to each of the pre established sources within the GP 12.1/ 12.2 and GP 5.118 

# Preparing the Application

▶ 

### Permit - to - Install and Operate ( PTIO ) Application ▶ 

### eBusiness Center – Air Services ▶ 

### Specify appropriate GP for which you are applying ▶ 

### Purpose of application ▶ 

### Permit Evaluation Report (PER) date ▶ 

### Applicable federal regulations ▶ 

### Permit application contact19 

# Preparing the Application

▶ 

### Assemble and submit the application ▶ 

### eBusiness Center – Air Services ▶ 

### Facility profile ▶ 

### PTIO application ▶ 

### Attachments ▶ Emissions calculations with supporting documentation (engine specs, TANKS reports) ▶ Process flow diagram (GP 12.1/ 12.2) and site layout for unpaved roadways (GP 5.1) ▶ Qualifying criteria documents ▶ Emissions Activity Category ( EAC ) forms ▶ 

### OEPA review time is typically < 45 days20 

# Compliance and Resources21 

# Complying with Your Permit

▶ 

### Single PTIO including the GP 12.1/ 12.2 and GP 5.1 standard permit conditions ▶ 

### PTIO is valid for 10 years ▶ 

### PTIO fee is invoiced after receipt of PTIO and due within 30 days ▶ 

### Annual Permit Evaluation Report (PER) – compliance assessment ▶ 

### LDAR requirements22 

# Complying with Your Permit

▶ 

### Leak Detection and Repair ( LDAR ) Program Requirements
▶ Develop and implement LDAR program for ancillary equipment (pumps, compressors, valves, flanges, etc.)
▶ Forward Looking Infra Red ( FLIR ) camera or analyzer meeting EPA Method 21
▶ Initial monitoring within 90 days of startup and then four consecutive quarters
▶ Provisions to reduce quarterly monitoring to semi - annual and then annual based on 2 percent equipment leak
▶ First attempt at leak repair within 5 calendar days, repaired within 30 calendar days
▶ Record keeping and reporting via Permit Evaluation Report (PER)23 

# Resources

▶ 

### GP 12.1/12.2 and GP 5.1 http ://www.epa.ohio.gov/dapc/genperm it/genpermits.aspx ▶ 

### Fact sheets ▶ 

### Instructions ▶ 

### Applications and forms ▶ 

### OEPA Business Center https://ebiz.epa.ohio.gov/PortalHelp.jsp24 

## Thank You! John Schmelzle, Project Manager RETTEW jschmelzle@rettew.com 717 - 697 - 3551