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Summary of substantial WVONGA/IOGA comments for the proposed G70

Summary of substantial WVONGA/IOGA comments for the proposed G70. GENERAL. Provide clarification of DAQ’s definition of processing plant which is excluded from eligibility. Incorporate by reference relevant sections of NSPS Subpart OOOO.

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Summary of substantial WVONGA/IOGA comments for the proposed G70

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  1. Summary of substantial WVONGA/IOGA comments for the proposed G70

  2. GENERAL • Provide clarification of DAQ’s definition of processing plant which is excluded from eligibility. Incorporate by reference relevant sections of NSPS Subpart OOOO. Broaden the scope to include dehydration units and diesel generators.

  3. NSPS, Subpart OOOO • Remove state regulatory requirements from sections said to incorporate a federal requirement. • Revise the requirement in Section 5 regarding digital photograph requirements to reflect the alternative method that is allowed by NSPS Subpart OOOO rather than having the stand alone requirement with no alternative. Remove VE checks requirement on well completion flares.

  4. Storage vessels not subject to NSPS, OOOO requirements • Requested clarification on the timing of sampling requirements. • Companies should be allowed to use a representative sample if one exists rather than having to do site-specific sampling • Concerns expressed over monitoring requirements – capabilities, overly burdensome, unnecessary for produced water tanks Unnecessary to perform additional sampling with each well brought on line.

  5. Natural gas-fired engines • Requested change in wording regarding the monitoring requirements for catalysts. • Include the requirement in Rule 13 regarding the frequency required for catalyst replacement.

  6. Storage vessels subject to NSPS, OOOO requirements • Inappropriate to replace fuel nozzles and burner tubes upon the first failure of a combustion control device. • Replace “incinerator” reference with “enclosed combustion device or flare.” • VRU’s should not be identified as a control device in this section.

  7. Control devices not subject to NSPS, Subpart OOOO • Low Pressure towers are not control devices. • VRUs should not be identified as control devices. • Require reporting of VRU downtime only if the emissions during the downtime were not controlled by a back-up control device, such as an enclosed combustion device.

  8. Reciprocating Internal Combustion Engines subject to NESHAP, Subpart ZZZZ • Provisions included for sources outside of the scope of the GP • Typographical issues.

  9. Forms/Instructions/Fees • Removal requested of the “Natural Gas Well Affected Facility Data Sheet.” • Substitute “Pollutant” for “Material Name and CAS No.” requested on the “Storage Vessel Affected Facility Data Sheet.” • Waive $2,500 NESHAP fee for facilities subject to the NESHAP, Subpart ZZZZ.

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