Goodbye Exemption No. 38, Hello GP-5A: Changes on the Horizon for the Pennsylvania Natural Gas Industry
Posted: March 23rd, 2017Authors: Christine C.
UPDATE (3/23/17): PADEP has posted drafts of the GP-5 and GP-5A permits for the natural gas industry. In addition, a draft of the revised Air Quality Permit Exemptions list with modifications to the Exemption Category No. 38 requirements has also been posted. The deadline to comment on the draft documents is June 5, 2017.
ORIGINAL (12/20/2016): On January 19, 2016, Governor Tom Wolf announced a four-point plan for reducing methane emissions from natural gas operations. At the December 8, 2016 Air Quality Technical Advisory Committee (AQTAC) meeting, the Pennsylvania Department of Environmental Protection (PADEP) took the first steps towards increased regulation of Pennsylvania’s natural gas industry in publishing a revised draft of General Plan Approval and/or General Operating Permit (GP)-5 and a draft of the new GP-5A. One of the more significant impacts of this action is that PADEP will revise Exemption Category No. 38 such that it will only apply to unconventional natural gas well sites constructed between August 10, 2013 and the effective date of PADEP’s revised Air Quality Permit Exemption List. All well sites installed or modified after the effective date will need to be permitted with a GP-5A.
Key revisions to certain general conditions of both permits include, but are not limited to:
- The newly promulgated 40 CFR Part 60, Subpart OOOOa regulations have been incorporated.
- Administrative amendments to the GP-5/5A permits will be allowed for minor administrative changes.
- A new requirement has been established to minimize noise.
- Some notifications are now required to be submitted through email rather than in writing.
- Emergency shutdowns and unscheduled blowdown or venting events must be reported to PADEP within 24 hours.
- Notification is required 24 hours before a scheduled blowdown or venting event.
- Source test protocols are required to be submitted 60 days before testing (previously they were required 30 days prior to testing).
The new GP-5A, which follows the same general format as GP-5, is applicable to unconventional natural gas well sites and remote pigging stations. Existing sources should continue to comply with the Exemption Category No. 38 emissions standards and the GP-5A emissions standards will apply only to new or modified sources. GP-5A includes requirements for the following emissions sources:
- Fugitive Particulate Matter
- Well Drilling and Hydraulic Fracturing Operations
- Well Completion Operations
- Natural Gas-Fired Combustion Units
- Glycol Dehydration Units
- Stationary Natural Gas-Fired Spark Ignition Internal Combustion Engines
- Reciprocating Compressors
- Storage Vessels
- Tanker Truck Load-Out Operations
- Fugitive Emissions Components
- Enclosed Flares and Other Emission Control Devices
- Pigging Operations
- Wellbore Liquids Unloading Operations
GP-5, which applies to natural gas compression stations, processing plants, and now transmission stations, has been reorganized for clarity and, in addition to expanding requirements for emissions sources included in the current GP-5, includes requirements for additional emissions sources. Specifically, GP-5 now includes requirements for fugitive particulate matter, natural gas-fired combustion units, tanker truck load-out operations, pumps, enclosed flares and other emissions control devices, and pigging operations. Existing sources that already operate under a GP-5 will continue to be subject to the requirements of the current GP-5, and the revised GP-5 will apply only to new sources.
ALL4 has been tracking the recent regulatory activity targeting methane emissions and the major takeaway is that change is on the horizon for the oil and gas industry. If you have questions about how these actions affect your operations or what your next steps should be, please reach out to me at (610) 933-5246, extension 155, or at firstname.lastname@example.org.