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By Katerina E. Milenkovski, Of Counsel, Steptoe & Johnson PLLC
During the past several months, Ohio EPA has been working to determine what, if any, air pollution requirements apply to well-site operations in the oil and gas industry - in particular, in the Marcellus and Utica shale plays. Ohio EPA's analysis has determined that the following types of equipment and processes commonly found at well sites may need air permits:
• Dehydration systems (glycol dehydration units and gas condensate glycol separators)
• Spark ignition internal combustion engines
• Compression ignition (diesel) engines
• Unpaved roadways
• Truck loading racks
• Oil, condensate and water storage tanks
• Combustion devices/flares
• Equipment/pipeline leaks
In order to facilitate permitting for such equipment and processes, Ohio EPA has developed an "interested party" draft of a model general air permit. The "interested party" draft is a pre-proposal draft intended to gather input from the industry and other interested parties for inclusion into the official "proposed" general permit that will become the subject of formal rulemaking. A general permit is the same as any individual construction or operating permit that Ohio EPA issues except all the terms and conditions of the permit are established in advance, by rule, expediting the issuance of such permits.
At this time, stand-alone gathering stations, gas clean-up operations, gas compressor operations and other similar activities are not expected to be covered by the general permit and will continue to require case-by-case permitting, where applicable.
The proposed qualifying criteria document, which establishes eligibility for the general permit, is available for review, Ohio EPA Model General Permit (MGP) Qualifying Criteria Document.
The proposed model general permit terms and conditions themselves are available for review, Ohio EPA Draft Air Program Natural Gas Well Site General Permit Terms and Conditions.
After Ohio EPA reviews the interested party comments and incorporates any changes, there will be an additional opportunity for comment on the official proposed rule.
Please contact Kathy Milenkovski if you have questions or would like assistance in preparing comments on the proposal.
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