Pennsylvania AQTAC Discusses Oil and Gas Related Topics at June 14, 2012 Meeting

The Pennsylvania Air Quality Technical Advisory Committee (AQTAC) met on Thursday June 14, 2012 at the Pennsylvania Department of Environmental Protection (PADEP) Rachel Carson building in Harrisburg, Pennsylvania.  Among many important agenda items, two key topics that were discussed related directly to Pennsylvania’s growing oil and gas industry; a review of public comments regarding the proposed revisions to GP-5 for Natural Gas Production and Processing Facilities and a review of public comments regarding the Interim Final Guidance for Performing Stationary Source Determinations for Oil and Gas Industries.  The presentations did not get into the “weeds,” but provided a general flavor of the comments submitted by the general public, industry, environmental interest groups, and U.S. EPA.  A summary of the comments related to GP-5 is presented below.  The comments related to the Interim Final Guidance for Performing Stationary Source Determinations for Oil and Gas Industries will be provided in a later blog.   

For the proposed GP-5 revisions, PADEP received comments from 296 commentators, with multiple duplicate submittals. A copy of the PADEP presentation can be viewed here. The comments provided by the general public expressed concerns associated with the lack of public participation for individual GPs issued to sources, the lack of source specific best available technology requirements for each individual GP-5 permit issued, and suggestion that regional public hearings be conducted to present the impacts of the revised GP-5.  As anticipated, U.S. EPA provided numerous comments that weighed in on the proposed revisions and identified significant concerns with federal enforceability of emission unit specific voluntary GP-5 permit limits, suggested that a provision be included to allow PADEP to request an air quality impact analysis (e.g. modeling study) to evaluate a source’s impact on a National Ambient Air Quality Standard (NAAQS), suggested that GP-5 address emissions of PM₁₀, PM_2.5, VOC, and GHG from all GP-5 sources, and suggested that applicants provide more detail for compliance demonstration methods.  Affected industries provided substantial comments suggesting GP-5 exemptions (e.g., well heads, vehicle idling, well completions, and fugitive dust), the incorporation of federal NSPs and NESHAP requirements by reference (versus specific inclusion of such requirements), revisions to emission limits for reciprocating internal combustion engines (RICE), and suggesting that PADEP scale back the broad definition of “Natural Gas Production and Processing Facilities” of GP-5 to be more consistent with the intent of a General Permit.  Several oil and gas equipment vendors expressed concern with the specified catalyst monitoring requirements as being overly burdensome, burdensome site specific record storage requirements, suggested removal of the SO₂, particulate, and formaldehyde limits for engines, and expressed concern with the proposed GP-5 RICE emission limits as being unattainable. Finally, several environmental groups provide comments that requested clarification of GP-5’s non-applicability to landfill gas compression, suggested inclusion of all applicable regulatory requirements for the source, and suggested replacing the stated 85% VOC control standard with a 98 to 99% VOC control requirement.  PADEP indicated that final amendments will be available “this fall” with a response to comment document. PADEP also hinted that the GP-5 proposal may be revised, along with a revised permit exemption list, and both of these could go through public notice again.