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DEP Clarifies Exemption For Oil And Gas Well Drilling
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On May 29, the Department of Environmental Protection published notice in the Pennsylvania Bulletin of substantive revisions to the Air Quality Permit Exemptions Technical Guidance Document or Exemption List (DEP ID. 275-2101-003). Pa Bulletin. page 2822).
In addition to other recommended revisions, the Department is proposing changes that will revoke the existing “automatic” exemption for oil and gas exploration and production facilities and operations (Category No. 38).
Currently, an exemption from plan approval and operating permit requirements is provided for the following oil and gas exploration and production facilities and operations that include wells and associated equipment and processes used to: (a) drill or alter oil and gas wells; b) extract, process and deliver crude oil and natural gas to the point of lease custody transfer; (c) plug abandoned wells and restore well sites, or (d) treat and dispose of associated wastes.
Proposed revisions to the Exemption List establish Category No. 38, a conditional exemption for certain oil and gas exploration and production facilities and operations.
Air quality plan approval and operating permits will not be required if nitrogen oxide (NOx) emissions from all of the sources including internal combustion engines at a single facility are less than or equal to 100 lbs/hr, 1000 lbs/day, 2.75 tons during the ozone season (period beginning May 1 of each year and ending on September 30 of the same year). Annual NOx emissions at the facility must not exceed 6.6 tons on a 12-month rolling basis.
In addition, the proposed revisions to the Exemption List provide a conditional exemption for uncontrolled volatile organic compound (VOC) emissions at a single facility less than or equal to 2.7 tons per year (tpy). However, VOC emissions containing hazardous air pollutants (HAPs) at the facility must be less than 1,000 lbs/yr of a single HAP or one tpy of a combination of HAPs.
VOC emissions from sources containing HAPs including polychlorobiphenols, Chromium, Mercury, Lead, Polycyclic Organic Matter or dioxins and furans will not be eligible for the limited VOC exemption. The NOx and VOC emission thresholds will also apply to all other source categories on the Exemption List.
The proposed revisions to the Exemption List also require that a Request for Determination (RFD) be submitted to the Department if the NOx and VOC emissions exceed the minor significance thresholds specified in Category No. 38.
If the RFD is not approved by the DEP, a Plan Approval Application or an application seeking authorization to use a general plan approval or general permit must be submitted to the appropriate DEP regional office.
The gas dehydration and compression facilities will continue to be subject to applicable plan approval, operating permit or general plan approval and operating permit programs. The 30-day comment period will end on June 28, 2010.
However, in response to several requests, the DEP intends to publish a notice in the Pa. Bulletin to extend the public comment period for the proposed revisions to the Air Quality Permit Exemptions Technical Guidance Document (DEP ID. 275-2101-003) from June 28, 2010 to July 18, 2010.
A copy of the proposed exemption is available online. For additional information contact Jeanette Van Skike by sending email to: jvanskike@state.pa.us or by telephone at 717-787-4325.
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6/28/2010 |
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