I added this comment to my post. "The Achilles heel of the proposed amendments shows up under the paragraph on page 6 titled REDUCING COMPLIANCE BURDENS. “The proposed exemption would apply to sources covered by the NSPS that are not major sources and that do not obtain Title V permits for another reason….. VOC sources are considered “non-major” if they emit less than 100 tons per year…..That emissions threshold is lower in certain nonattainment areas, however.” The Wetzel County Action Group filed a legal appeal to the WV Air Quality Board (AQB)to consider compressors and gas wells collectively so as to be covered by Clean Air Act rules. From the FrackCheckWV post by Duane Nichols on May 21, “The AQB said that insufficient evidence had been presented to support a claim that the new compressors stations and/or the wells feeding them were in fact “contiguous or adjacent”, as defined by the legal definitions of these terms under the Clean Air Act in spite of existing pipelines interconnecting them.” Here is what that paragraph, REDUCING COMPLIANCE BURDENS SAYS:
REDUCING COMPLIANCE BURDENS To reduce the compliance burden to industry, state and local governments and tribes, EPA also is proposing to exempt certain sources from Title V permitting requirements that would be triggered by the proposed rule. The proposed exemption would apply only to sources covered by the NSPS that are not major sources and that do not have to obtain Title V permits for another reason. EPA believes the recordkeeping and reporting requirements included in the proposed standards are sufficient to assure compliance. VOC sources generally are considered “non-major” if they emit less than 100 tons per year. That emissions threshold is lower in certain nonattainment areas, however. EPA also is seeking comment on additional approaches to provide the industry and regulatory agencies with more efficient and effective tools for maximizing transparency compliance with the proposed regulations. These include submitting performance test results to an EPA electronic database, and third-party compliance verification.
HOW TO COMMENT Comments, identified by Docket ID Number EPA-HQ-OAR-2010-0505, may be submitted by one of the following methods: www.regulations.gov: follow the on-line instructions for submitting comments. E-mail: Comments may be sent by electronic mail (e-mail) to a-and-r-Docket@epa.gov. Fax: Fax your comments to: (202) 566-9744.
Mail: Send your comments to: Air and Radiation Docket and Information Center, Environmental Protection Agency, Mail Code: 2822T, 1200 Pennsylvania Ave., NW, Washington, DC 20460. Hand Delivery or Courier: Deliver your comments to: EPA Docket Center, 1301 Constitution Ave., NW, Room 3334, Washington, D.C. 20004. Such deliveries are only accepted during the Docket’s normal hours of operation, and special arrangements should be made for deliveries of boxed information. FOR MORE INFORMATION Today’s proposed rule and other background information is available http://www.epa.gov/airquality/oilandgas. Information also is available at EPA’s electronic public docket and comment system (http://www.regulations.gov,) using Docket ID Number EPA-HQ-OAR- 2010-0505.