Pennsylvania to Issue Oil and Gas Emissions Aggregation Guidance

The Pennsylvania Department of Environmental Protection (PADEP) intends to develop technical guidance for performing single stationary source determinations for operations in the oil and gas industry. Currently, there are significant gas exploration and extraction activities occurring in Pennsylvania, mostly related to the development of the Marcellus Shale formation. As a result, air quality permitting issues have arisen related to the “aggregation” of the air emissions associated with exploration, extraction, or production activities to determine whether the emissions from these sources constitute a single “major stationary source” or “major facility” for purposes of New Source Review (NSR) and/or Title V permitting programs. Source aggregation is an important concept that could significantly impact the air quality permitting requirements that are associated with operations in the oil and gas industry in Pennsylvania. The Draft Technical Guidance Document is expected to be published during the summer of 2011.