AIR QUALITY: Plan Approval & Operating Permit Exemption, 25 Pa. Code Chapter 127.14(d) & Technical Guidance Document

HOWTO SHEET

This month, [due March 19th]  DEP is accepting comments regarding sources of pollution related to Oil & Gas operations that will be exempt from plan approval and permitting requirements of the PA Code [regulations].  The sources of pollution will still need to meet emission regulation thresholds.  Overall, this re-proposed document is reasonable, much of it codifying the adopted EPA regulations this past summer.

However, the time for exempting nonroad engines has passed.  Natural gas and dual fuel engines can replace virtually every kind and type of non-road engine.  The technology and fuel are available.  Encouraging the industry through regulation & policy will hasten our region in benefiting from the latest technologies.

 

The use of natural gas or dual fuel engines can reduce emissions by as much as 70% improving the air quality for nearby residents.  Add to that the low price of natural gas; such a change can benefit industry, shareholders, royalty owners and all Shalers alike.

Diesel engines are responsible for many pollutants including ground level ozone.  Main ingredients in ground level ozone are VOC’s and NOx.

The EPA reports these emissions can aggravate asthma, cause acute respiratory symptoms such as coughing, shortness of breath and chronic bronchitis.  Repeated exposures to ozone can make people more susceptible to respiratory infections, such as asthma.  The elderly, children and asthmatics are particularly susceptible to health problems caused by breathing in fine particles.

Air quality is affected by local conditions which determine where the ground level ozone goes and how bad it gets.  Much of rural Pennsylvania, now locations of nonroad engines – are areas that can have inversions and trap the ground level ozone.  Many areas along the Susquehanna River for example, are heavy fog areas which can also trap ground level ozone for extended periods of time.

Recently two announcements have indicated that folks in the gas fields have their air resources adequately protected.  But, we need to look closer.  First, it was reported that a new permit significantly reduced air emissions.  Reviewing the proposal with the approved permit shows that what was approved was similar to what we already had.  The proposal didn’t make the cut.  Secondly, it was announced that Pennsylvania’s air quality has significantly improved.  Overall that is true, but what was not emphasized was that there has been a tradeoff between Shale and beyond the Shale Counties.  While beyond the Shale Counties did indeed improve, many of the Shale Counties have increased in the amount of reported air emissions thus reducing the air quality in those areas.

 

Thus, we need to advocate that Nonroad engines are not exempt under the Category #38 viii. in order to ensure that our air resources are adequately protected.

Please send your email/letter acknowledging the topic below BEFORE MARCH 19TH  to DEP at the address/emails as below noted.

 

RE:  Plan Approval & Operating Permit Exemption, 25 Pa. Code Chapter 127.14(d) & Technical Guidance Document

 

WHERE TO SEND:

Krishnan Ramamurthy

Environmental Program Manager,

Division of Permits

Bureau of Air Quality

12th Floor, RCSOB

PO Box 8468

Harrisburg  PA  17105-8468

 

OR

 

kramamurth@pa.gov

 

Thank you for your participation.