Air Permitting in Ohio
July 25, 2018

The Ohio Environmental Protection Agency (Ohio EPA) is the environmental agency that administers air quality regulations and permitting programs in Ohio. Oil and gas (O&G) production facilities are required to obtain, from the Ohio EPA, an air permit prior to construction and operation. The exception to this is that for some counties, the Local Air Pollution Control Agency (LAPCA) is the air permitting agency in lieu of Ohio EPA. Contact the Ohio EPA to determine the correct air permitting agency for the county. The LAPCAs work with the Ohio EPA on air permitting for O&G operations. The following link has a listing of: OH Regional Offices and LAPCs.  

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Below is a summary of some key things to know about the Ohio EPA air permitting process for O&G operations. Consult the Ohio EPA website and rules or contact the Division of Air Pollution Control (DAPC) for details for O&G air permitting. The focus of this article is minor source air permitting rules for oil and gas operations.

What requires an air permit?

In Ohio, air permits are required for O&G production facilities. Permits are issued for the construction and operation of facilities and equipment that emit regulated air contaminants. No air permits are required for drilling and completion operations.

Construction of Facility

The Ohio EPA requires an air permit prior to beginning construction. 

Construction is defined as any physical change or change in the method of operation (including fabrication, erection, installation, demolition or modification of an emissions unit) that would result in a change in emissions.

The following are some activities do not constitute beginning actual construction and may be undertaken prior to obtaining a final air.

  • Clearing the site of existing vegetation, old buildings, or old equipment.
  • Grading and clearing of land, stripping and stockpiling topsoil, earthwork cut and fill for foundations in preparation for construction.
  • Installing temporary site access roadways and parking areas.

For full list, review rules in OAC 3745-31-33 - Site preparation activities prior to obtaining a final permit-to-install or PTIO.

Types of Air Permits

The types of air permits for Ohio EPA can be divided into:

  • Major Sources – includes larger emitting facilities that would trigger Title V or Prevention of Significant Deterioration (PSD) permitting. For O&G operations, this would typically include larger compressor stations or gas processing facilities. No further discussion of these types of permit in this blog topic.
  • Minor Sources – includes smaller facilities that are “Non-Title V” or “Synthetic Minor Source Title V” sources (facilities). Most O&G tank batteries and smaller compressor stations can meet the minor source emission limits.

Major Sources (Title V, PSD)

The typical O&G production facility would not trigger major source permitting (Title V or PSD). Most operators will use enough emission controls to limit potential emissions to ensure the O&G facility can be permitted as a minor source. An exception to this that are larger compressor stations with a substantial number of large horsepower internal combustion engines might trigger major source permitting.

Title V permits are operating permits that are required under Title V of the Clean Air Act. PSD permits are new source review (NSR) permits that are required for the construction of a major source if the facility triggers the PSD emission threshold limits.

Typically, new major source facilities and modifications are required to first obtain a Permit-to-Install and then apply for a Title V Permit-to-Operate or obtain a Permit Revision if an effective Title V Permit-to-Operate has already been issued for the facility.

These permits are case-by-case permits that require individual permits; no general permits available for O&G facilities that trigger major source permitting. No further discussion of these permits given in this blog topic.

Ohio EPA Minor Source Air Permit Types for O&G

For minor source O&G operations, the Ohio EPA typically issues an air permit to install and operate (PTIO) in one permitting action. 

Minor source air permits include:

  • Individual permits – permit with greater operational flexibility and longer (up to 180 days) time to obtain permit approval. These are typically used if the facility cannot meet General Permit requirements.
  • General permits – used most often, especially if need quick approval and facility can comply with all General Permit requirements.

Ohio EPA Model General Permits

The following are general air permits available for O&G operations. If a facility cannot meet all requirements in the available Ohio EPA general permit, then an individual air permit would be required.

General permits are beneficial because approval can be granted by Ohio EPA within 45 days of application submittal. A traditional individual air permit can take up to 180 days for approval.

These O&G air permits are federally enforceable permits and can be used by and O&G facility to limit potential to emit (PTE) emissions from storage tanks (i.e., less than 6 tons VOCs per year/tank) such that NSPS OOOOa regulated emission controls are not required. This can substantially reduce costs and reduce testing, recordkeeping and reporting regulatory burdens.

  • Oil and Gas Well-site Production Operations with a Small Flare (GP 12.1) – for typical emission sources (e.g., storage tanks, engines, fugitive sources, and ancillary equipment) with natural gas engines limited to 1800 total horsepower and the flare limited to a nominal 10 mmBtu/hr.
  • Oil and Gas Well-site Production Operations with a Large Flare (GP 12.2) – for typical emission sources (e.g., storage tanks, engines, fugitive sources, and ancillary equipment) with natural gas engines limited to 1000 total horsepower and the flare limited to nominal 32 mmBtu/hr.
  • Natural Gas Compressor Stations and Similar Facilities – includes assorted general permits for various emission sources (e.g., engines, dehydrators, flares, storage tanks, truck loading, etc.) operating at oil and gas compressor stations.

General Permit for Roadways and Parking Areas – not specific to O&G

Roads and parking areas associated with drilling and production facilities may need this permit if the activity does meet the exemption. Exempt given in rules for roadways and parking areas (either paved or unpaved) with less than three thousand eight hundred vehicle miles traveled (VMT) per year, less than five tons particulate emissions (PE), and less than 1.45 tons PM10 per year (ref: OAC 3475-31-03(B)(1)(jjj).

The general permits available include: Paved and Unpaved Roadways and Parking Areas With a Maximum of 125,000 Vehicle Miles Traveled Per Year (GP 5.1); Paved and Unpaved Roadways and Parking Areas With Less Than or Equal to 320,000 Vehicle Miles Traveled Per Year (GP 5.2) -

O&G General Permits Steps

  1. Obtain an inventory of regulated emission sources (e.g., engines, tanks, dehydrators, heaters, fugitive sources, etc.) to determine whether an applicable general permit or individual permit is required.
  2. Based on the inventory, production rates and operating parameters, prepare calculations to determine equipment and facility potential to emit (PTE) emissions. These will set the permit limits. Use this calculations to determine if can quality for the general air permit or if an individual air permit is needed.
  3. Complete the application forms and the appropriate Model General Permit (MGP) Qualifying Criteria Document.
  4. Ensure the Responsible Official (RO) signs the application. For RO signatory guidance document go to link at http://epa.ohio.gov/dapc/permits/permits
  5. Submit a hardcopy of all documents to the District Office or Local Air Agency. As an option a company can use the Ohio EPA's online Air Services to submit the application online. This eliminates the need to sign and mail paper copies of these forms.
  6. No permit application fee (i.e., check) is required for application processing. Facilities with a General Permit will be required to submit an annual Fee Emissions Report (FER) and Emissions Inventory Summary (EIS) (due around April 15 each year for the previous year) based on actual operations. The reports are required to be filed electronically via the Ohio EPA’s online eBusiness Center: Air Services. Based on the reported emissions, an invoice for the fees will be sent in July to the company.
  7. Wait for approval from Ohio EPA prior to beginning construction for a new facility or initiation a modification.  Ohio EPA expect to be able to issue the model GP within 45 days of receipt of a complete application.
  8. Review the air permit to ensure continued compliance with all applicable requirements.

Individual PTIO Air Permits

If a facility cannot quality for a general permit, then the facility can apply for an. Steps include:

  1. Complete the appropriate individual Permit to Install / Permit to Install and Operate Application forms.
  2. Complete the Permit to Install / Permit to Install and Operate Application forms for the specific permit source types (e.g, internal combustion engine, storage tank, etc.)
  3. Calculate PTE emissions

Ohio EPA eBusiness Center

Title V and Synthetic Minor Title V facilities are required to use the eBusiness Center: Air Services for all emissions reporting, Title V Annual Compliance Certifications, all permit applications, and reports.

You can setup an account at the link: eBusiness Center.

HY-BON/EDI IQR Emissions Services (LDAR)

HY-BON/EDI can assist your company in routine compliance with State air regulations and NSPS OOOOa compliance. We have unrivaled experience and knowledge in Leak Detection (OGI) and measurement for the O&G Industry. 

We employ professionally certified technicians each with over 10 years of technical experience.  HY-BON/EDI offers a Leak Detection and Repair (LDAR) program that will keep your facility in compliance with the new regulations.  A part of our IQR service for NSPS OOOOa compliance includes first attempt to repair the source of fugitive emissions which gives the operator more time to finalize repairs if needed.

Contact us at [T1{hD\7i_ys]#[jbB&yXnCvl3$ or [T1{hD\7i_ysgXVB]#[O2xa\[E1qBibp8F+ for more information.