details of West Virginia's application of the general permit principal to reciprocating internal combustion engines installed at natural gas compressor stations

RICE at compressor stations are addressed under a number of existing or proposed GP's, viz.:

class(1)eff.?subject
G30-DIIy(4)Natural Gas Compressor Stations
G33-AIy"The SI ICE general permit benefits the natural gas industry by incorporating applicable air quality regulations from 40CFR 60 Subpart JJJJ into a Class I general permit."(3)
G35-AIIy(4)Natural Gas Compressor Station
G70-AIIy(4)well-site facilities; slide presentation for proposed rule
G80-AIIdraft(2),(4)Natural Gas Production, Compressor and/or Dehydration Facilities (webpage)
(1) Class II involves a higher permit processing fee than Class I, as well as public-noticing requirements.
(2) G80-A public hearing March 16, 2015; written comments due March 30, 2015.
(3) I forget just where.
(4) G80-A is intended to supersede G30-D, G35-A, and G70-A. Modifications and other updates to existing permits in those categories will be accomplished under G80-A.


comparison of G80-A (draft) vs. fed. RICE requirements
per sec. 13.1.1 of G80-A, "The registrant shall not cause, suffer, allow or permit emissions of PM, PM10, PM2.5, VOC, SO2, NOx , CO, and formaldehyde, from any registered RICE and/or generator to exceed the potential to emit (pounds per hour and tons per year) listed in the General Permit Registration without effecting a modification or administrative update." Also (per 13.1.3), engines with catalytic control devices must be equipped with closed-loop combustion controllers to maintain fuel ratios and ammonia slip within limits under conditions of varying load. The catalyst must be protected from damage with a high-temperature alarm and shutdown (13.1.3(d)). RICE sources are addressed in Attachment N of the GP Registration. Do the engine-control and catalyst-protection requirements surpass the federal requirements? Need to figure it out. Otherwise, I'll say that W.Va requirements match the feds.
G80-AJJJJ
NOx
COx
HCx
HCHOx
VEx

(up a level)



dkt
4/14/15