## Evaluating Well Pad Permitting in the Appalachian Basin

A&WMA Oil & Gas Environmental Compliance Conference Washington, PA ♦ May 13, 2014

Tom Muscenti Trinity Consultants Manager of Consulting Services

### ˃ 

## Permit Paths

˃ 

## State implementation of well pad permitting

 

### Pennsylvania

– Exemption 38

 

### West Virginia

– G

- 70A

 

### Ohio

– GP12 series



### ˃ 

## Comparing and contrasting requirements for identical operations 

# Presentation Overview

# Available Permitting Paths

˃ 

### Exemptions

 No permits required

 Limited scope and emissions



### ˃ 

### General Permits

 Facility/operation must meet qualifying criteria to be authorized to use

 Standardized set of terms and conditions



### ˃ 

### Site

- Specific Permits

 Unique set of terms and conditions

 Lengthiest times for preparation and review

 Applicable if other options are not valid

# PADEP’s Exemption 38

˃ 

### Limited to well

- site operations

˃ 

### Conditional exemption for unconventional operations

 Work practices

 Emission limitations (source and facility)

 Compliance demonstration



### ˃ 

### No capacity limitations for equipment

˃ 

### References applicable Federal rules

˃ 

### Eliminates requirement for site

- specific Plan Approval (~6 months)

˃ 

### No application, no fee

# WVDEP’s G

- 70A

˃ 

### Limited to well

- site operations

˃ 

### Includes siting criteria

˃ 

### Public notice period for application

˃ 

### Emission limitations and throughput restrictions
are source

- specific as registered by applicant

˃ 

### Incorporates Federal rules into permit

˃ 

### Reduces permit issuance to 45 days

˃ 

### Application fee required

– amount depends on equipment proposed

# OEPA’s GP12.1, 12.2

˃ 

### Limited to well

- site operations

˃ 

### Includes qualifying criteria

 Engine stack requirements

 Size limitations (engine horsepower, storage capacity, flare capacity)



### ˃ 

### Emission unit

- specific control requirements and emission limitations

˃ 

### References Federal rules and includes some specific requirements

˃ 

### Reduces permit issuance to 45 days

˃ 

### Application fee required

– amount depends on equipment proposed

## Example Equipment

– Storage Tanks*

* Exclusive of Federal requirements PA WV OH Limits/Controls Control VOC emissions >95% if over 2.7 tons per year (otherwise meet facility

- wide limit) Comply with potential emissions as registered Control VOC emissions to meet General Permit limits (51.3 tons per year)

Qualifying criteria (size/capacity): None Not subject to NSPS Kb Each tank < 950 barrels, total < 6,000 barrels

## Example Equipment

– Glycol Dehydration Units*

* Exclusive of Federal requirements PA WV OH Limits/Controls Control VOC emissions >95% if over 2.7 tons per year (otherwise meet facility

- wide limit) Comply with potential emissions as registered Control VOC emissions to meet annual General Permit limits (5.0 tons per year)

Qualifying criteria (size/capacity): None None No more than two

## Example Equipment

– Engines*

* Exclusive of Federal requirements PA WV OH Limits/Controls Facility

- wide 2.7 tons per year VOC limit, NO X emission limitations (e.g., 6.6 tons per year) for all exempt engines on site Comply with potential emissions as registered Maintain total engine emissions below general permit limits depending on fuel type

Qualifying criteria (size/capacity): None Natural gas fired only Facility

- wide horsepower restrictions for natural gas and diesel fired engines

## Compliance Requirements

– Leak Detection and Repair (LDAR)*

˃ 

### PA: Initial and annual LDAR using FLIR camera or gas leak detector on equipment in natural gas or hydrocarbon liquid service

˃ 

### WV: Initial and annual LDAR using audio, visual, olfactory means on control device closed vent systems

˃ 

### OH: Initial and quarterly LDAR using FLIR
camera or U.S. EPA Method 21 (subsequent frequency can be reduced)

* Exclusive of Federal requirements

## Compliance Requirements

– Emissions Documentation*

PA WV OH Annual Emissions Reporting Annual PA oil and gas emissions report (includes more than just permanent equipment) None Annual emissions reported every two years

Permit Compliance Tracking Rolling 12

- month facility

- wide calculations and engine calculations, if applicable Rolling 12

- month calculations for specific equipment Rolling 12

- month calculations for specific equipment

* Exclusive of Federal requirements

## Compliance Requirements

– Compliance Reporting*

˃ 

## PA: Initial compliance evaluation within 180 days of installation

˃ 

## WV: Immediate reports due when emissions or throughputs in registration are exceeded

˃ 

## OH: Annual permit evaluation report

* Exclusive of Federal requirements

# Commonalities

˃ 

## No specific methane emission limits

˃ 

## Option to obtain site

- specific permit

˃ 

## Limited to minor sources (e.g., non

Title V and non HAP major)

˃ 

## Do not regulate drilling activities under these permits/exemptions

## Conclusions

˃ 

### Agencies are working within framework of state regulations to streamline review

˃ 

### Criteria and requirements are unique to each state as well as conditions at the site

˃ 

### Regardless of where the well pad is located, the permitting evaluation typically needs the following information:

 

### Estimate of number, capacity, and throughput of each piece of equipment

 

### Analysis of natural gas and/or liquids from the well or surrounding area

 

### When production will begin

# Questions?

Tom Muscenti Trinity Consultants 724

- 935

- 2611 tmuscenti@trinityconsultants.com