Pennsylvania General Permits For Natural Gas Facilities Air Emissions
Pennsylvania’s unconventional natural gas producers and mid-stream operators have been operating in the “Twilight Zone” when it comes to having clear and concise guidance from the Pennsylvania DEP relative to general permits for emissions from well pad sources (Exemption 38) or gathering, compression and processing facilities (GP-5).
As background, Exemption 38 exempts well head and well pad sources from plan approval and operating permit requirements. The specific limits for exempted emissions at these sites are:
Combined VOC emissions must be less than 2.7 tons on a 12month rolling basis
NOx emissions from stationary engines must be less than 100 lbs per hour, 1000 lbs per day, 2.75 tons per ozone season and 6.6 tons on a 12 month rolling basis
Combined Hazardous Air Pollutant emissions must be less than 1000 lbs of a single HAP or 2000 lbs of a combination of HAPs in a 12 month period
Additional criteria and reporting requirements apply for sources at these sites with an annual report due on March 1st of every year.
In the absence of any DEP guidelines, operators submitted a number of Compliance Demonstrations to comply with the 30 day deadline. Unfortunately, DEP returned most with deficiencies. Any attempts to secure an industry-wide extension on the 30 day deadline were rejected by DEP and operators have been told to make individual requests to regional air quality offices. These requests must justify why the extension is needed and for what length of time. A complete list of the wells covered by the request must be included. Any well not on the extension request list may be issued a Notice of Violation.
The lack of guidance from the DEP has been frustrating for many operators. Many of those who had their Compliance Demonstrations returned were not given any feedback on why they were deficient.
The revised GP-5 form was published in the Pennsylvania Bulletin on November 15th. As noted above, this general permit is for gathering lines, compressor and processing facilities. It establishes Best Available Technology requirements and other federal and state requirements for the covered facilities. This permit can only be used for facilities that are not major sources and quarterly leak detection and repair requirements, recordkeeping and reporting will apply. Engines on a well pad can be included in the GP-5 if they are aggregated as part of a single facility with compression units. Process heaters, tanks and dehydrators can all be included under the GP-5 although some specific requirements may apply.
The revised GP-5 is available for review and comment. Written comments must be submitted to the DEP by January 6, 2015.
The DEP has released a 9 page “Frequently Asked Questions” document on both Exemption 38 and the GP-5. This can be helpful in providing some guidance on what requirements must be met to qualify under either of these programs. This document can be found on the DEP’s website here.