Trinity Consultants

Air Quality Permitting & Compliance for Natural Gas Operations in the Appalachian Basin

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This 1-day course is for environmental/project engineering staff responsible for air permitting of natural gas operations in PA, OH, and WV. Those new to air permitting in these states as well as veterans benefit from the dynamic discussion of recent developments in evolving state-specific requirements. This course covers all segments of natural gas operations (production, processing, gathering, and transmission) in the Marcellus and Utica Shale plays. Case studies illustrate the intricacies of operating in the Appalachian Basin.

Attendees learn about:

  • Documenting eligibility with permit exemptions (e.g., PA Exemption 38)
  • Evaluating qualifying criteria and preparing applications for General Permits (e.g., PA GP-5, WV G-70, OH GP-12, etc.)
  • Preparing applications when “traditional” air permitting may be necessary or advantageous (e.g., PA Plan Approval, WV R-13, OH PTIO)
  • Strategies for streamlining the permitting process and enhancing compliance

Course Topics

Basic Air Quality Permitting and Compliance Concepts
Pennsylvania Air Quality Compliance & Permitting

  • Overview of PA DEP – Regional Structure
  • Potentially Applicable Pennsylvania SIP Requirements
  • PA Air Permitting Processes for Natural Gas Operations
    • Request for Determination (RFD) Process
    • Exemption 38 Criteria and Compliance
    • General Permit GP-5 Requirements
    • Plan Approval Requirements
    • Major New Source Review Permitting in PA
    • State-Only and Title V Operating Permit Requirements
    • Changes in Ownership
  • PA Marcellus Shale Emissions Inventory Requirements
  • Hot Topics for Oil & Gas in Pennsylvania
    • Source and Project Aggregation Issues
    • Enforcement Activities

Exercise:  Permitting Scenarios in PA

West Virginia Air Quality Compliance & Permitting

  • Overview of WV DEP – AQ Division
  • Potentially Applicable West Virginia SIP Requirements
  • WV Air Permitting Processes for Natural Gas Operations
    • Permit Determination Form (PDF) Process
    • General Permit Registrations (G30-D, G33-A, G35-A, G-70)
    • Minor New Source Review (R13) Process
    • Major New Source Review (R14/R15) Process
    • Title V Permitting Process
    • Changes in Ownership
  • Hot Topics in Oil & Gas in West Virginia
    • Source and Project Aggregation Issues
    • Enforcement Activities

Exercise:  Permitting Scenarios in WV

Ohio Air Quality Compliance & Permitting

  • Overview of OH EPA Division of Air Pollution
  • Potentially Applicable Ohio SIP Requirements
  • OH Air Permitting Process
    • Exemptions
    • Permits-by-Rule (PBRs)
    • General Permits (GP 5, GP 6, GP 12)
    • Permits to Install (PTI)
    • Permits to Install & Operate (PTIO)
    • Title V Operating Permits
  • Hot Topics for Oil & Gas in Ohio
  • Overview of Air Services System

Exercise:  Permitting Scenarios in OH

Potentially Applicable Federal Emission Standards

  • Overview of Each State’s Implementation of Federal Rules
    • NSPS Subparts IIII/JJJJ – Reciprocating Engine Rules
    • NSPS Subpart KKK – Gas Processing Plant Requirements
    • NSPS OOOO – Oil and Natural Gas Systems
    • NESHAP Subparts HH/HHH – Dehydration Unit Requirements
    • NESHAP Subpart ZZZZ - Reciprocating Engine (RICE) MACT

Permitting Case Studies

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