UPDATE: The Air Quality Division of the Oklahoma Department of Environmental Quality issued an updated General Permit for Oil and Gas Facilities (GP-OGF) on July 1st, 2022.
This new permit will be required for facilities operating under the previous version of the GP-OGF. All facilities either under construction or in operation under the current authority must transition to comply with the standards set within the new permit within the next two years. Currently, there is a 24 month transition period that will expire on July 1st, 2024.
During the 24-month transition period, the NOM (Notice of Modification) for the existing GP-OGF may be used for those facilities wanting to maintain coverage under the existing GP-OGF. Using the NOM from the new GP-OGF (DEQ Form 100-306-D) automatically subjects the facility to the new GP-OGF upon submission.
For facilities that have conditions in their current authorization that conflict with the requirements with the new GP-OGF, these facilities must obtain an individual minor source construction permit and then incorporate these conditions into a subsequently issued Authorization to Operate.
These updates were made in order to incorporate current criteria for EPA enforceability. The new permit will allow for more flexibility for the regulated than the previous. There are several changes in the new GP-OGF that may affect eligibility to use the new permit.
As per Form 100-306, under the new permit, eligible facilities are those designed and operated for the production, gathering, processing, storage, or transportation of crude oil, natural gas, and natural gas liquids (NGL), including condensate, that meet the requirements defined within the eligibility checklist. Each of these have been updated from the previous GP-OGF in order to satisfy EPA regulation. The new eligibility checklist is outlined in DEQ Form 100-306 A. \
Lastly, note that the AQD has created a new mailbox: (AQDPermitsOGGPandOGPBRNotifications@deq.ok.gov) for facilities to submit notices of modification under the GP-OGF and notices of enforceability under the Permit by Rule for Oil and Gas Facilities (PBR-OGF). The email box may be used to submit:
- Notice of Modification for facilities covered under the new GP-OGF,
- Notice of Modification for facilities seeking to transfer coverage from the former GP-OGF to the new GP-OGF,
- Notice of Modification for facilities which remain covered under the former GP-OGF through the transition period
- Notice of Enforceability (NOE) under the PBR-OGF.
Please, do not hesitate to contact our team if you have any questions or would like additional information. #NTGEnviromental