Written by Chloe Marie – Research Fellow
On June 9, 2018, the Pennsylvania Department of Environmental Protection
(DEP) published Final General Permits 5 and 5A,
respectively for natural gas compression stations, processing plants and
transmission stations (GP-5), and for unconventional natural gas well site
operations and remote pigging stations (GP-5A). These general permits will
become effective on August 8, 2018, and are part of the state Methane Reduction
Strategy that has been implemented over the last two years by the
administration of Governor Tom Wolf.
In January 2016, Governor Wolf launched the Methane Reduction Strategy designed to
reduce methane emissions that are contributing to climate change. The
Pennsylvania DEP initially proposed to review the existing GP-5 applicable to
sources located at natural gas compressor stations and/or processing facilities
and expand its applicability to cover sources located at natural gas
transmission stations. DEP also proposed to create a new Air Quality General
Permit for unconventional natural gas wells, known as GP-5A. Prior to the
promulgation of GP-5A, methane emissions at unconventional well sites had been
addressed through a Category No. 38 exemption. Leading up to the publication of
the final version of the general permits, Pennsylvania DEP issued draft permits,
and received public comment, on two prior occasions.
The Final GP-5 applies to thirteen operations or emissions sources
located at natural gas compression stations, processing plants and
transmissions stations, and the new final GP-5A applies to eleven sources
located at unconventional natural gas well site operations and remote pigging
stations. Exceptions are made for certain air contamination sources regulated
by 25 Pa. Code Chapter 127, Subchapter D, E, F and G. A Technical Support Document, however,
specifies that GP-5 is no longer just eligible for sources located at non-major
facilities; now both GP-5 and GP-5A also are eligible for sources located at
Title V facilities provided that they are adding a specific type of source to
the facility.
Both general permits establish new requirements relating to Best
Available Technology (BAT), air emissions standards, air quality source testing
and monitoring, recordkeeping and reporting for all applicable air
contamination sources. According to the Technical Support Document, the
Pennsylvania DEP “determined that BAT for certain new sources is more stringent
than the applicable NSPS limit for certain new sources.” Certain changes have
been made to the ownership transfer procedure and now a new procedure is
applicable to both GP-5 and GP-5A addressing transfer of ownership that does
not modify any existing source, is not adding a new source, and is not subject
to a new Single Source Determination; otherwise, permit applicants must file
for an Authorization to Use the General Permit.
In addition, both general permits would apply only to emissions from all
sources and associated air pollution control equipment provided that they do
not exceed major source thresholds calculated on the basis of a rolling
12-month average. GP-5 and GP-5A holders also must conduct source testing at a
frequency determined by federal and state requirements. As for recordkeeping
and reporting requirements, permit holders are required to maintain records in
electronic format on-site or near site for a five-year period and submit annual
emissions inventory to the Pennsylvania DEP on March 1 of each year.
The Pennsylvania DEP also amended the Air
Quality Permit Exemptions document, the latest version of which was dated
August 10, 2013, which provides for exemptions from plan approval and
permitting requirements under 25 Pa. Code Chapter 125. The Pennsylvania DEP
clarified that these exemptions only apply to new or modified sources
constructed after August 8, 2018.
This material is based upon work supported by the National Agricultural Library, Agricultural Research Service, U.S. Department of Agriculture.
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