Permits-to-Install and Operate for Dehydration Facilities


EQM Gathering OPCO, LLC


Belmont and Monroe counties, OH

CEC Services

  • Air Compliance and Permitting

Owner Objective

EQM Gathering OPCO, LLC is a midstream natural gas company operating in the Appalachian Basin. Following a discussion about permit exemption rules between EQM Gathering OPCO and The Ohio Environmental Protection Agency (Ohio EPA), the Ohio EPA requested applications for Permits-to-Install and Operate (PTIOs) for EQM Gathering OPCO dehydration facilities. An emission unit cannot be exempt from permitting requirements under the de minimis exemption if that source is subject to a federal rule, even if the source is exempt from the requirements within that rule. In these cases, the dehydrators are subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart HH but are exempt from all control requirements within that rule due to their low emissions. Some of the dehydration facilities were proposed and some were already operating.

CEC Approach

In order to streamline the process, to reduce cost, and to ensure consistency, the CEC team developed an initial permit application and used it to model all remaining applications. CEC performed quality assurance on all aspects of each application in order to ensure the correct site-specific details were used. The list of facilities was in constant flux; at one point, 22 facilities were expected and at least 14 were partially completed before being taken off the list immediately prior to submittal. Instead of using the standard software, GRI GlyCalc, CEC identified ProMax® 5.0 modelling software as the best tool for calculating the emissions due to how ProMax® allows for multiple models to be run simultaneously.

CEC’s team included a former Ohio EPA member who provided additional insight into the permitting process from the regulator’s perspective.

To date, CEC has submitted 11 applications with two more anticipated.