Last month the Pennsylvania Department of Environmental Protection released long-awaited revised versions of two permitting proposals which are designed to help control methane emissions from new unconventional natural gas wells and their accompanying transmission infrastructure. At the moment, the Department is anticipating finalizing the proposals in early-to-mid 2018.
Perhaps the most substantial change to the proposals was to move what are considered “temporary activities” (such as well pad drilling operations) out of the permit itself and into an existing exemption category that still requires operators to meet certain performance standards, but not within the compliance and reporting context of the permit itself. This move was made in response to comments from industry that including these activities in the permit application created significant logistical challenges with respect to equipment identification and compliance.
These permits, once finalized, will address emissions from new operations and facilities.
The Department has also provided a brief concepts overview of pending rulemaking to address emissions from existing well production, as well as processing and transport infrastructure. These concepts are based on federal Control Technique Guidelines (CTGs) for Volatile Organic Compounds (VOCs). This approach is problematic for two reasons.
First, the Environmental Protection Agency has proposed withdrawing the CTGs, so the state would no longer have this basis to work from.
More importantly, the CTGs do not address methane directly and would be ineffective for comprehensively dealing with those emissions. The CTGs would have limited or no application for “dry gas” operations (where there are few VOC emission issues), and further do not cover many of the activities and equipment that have been identified as critical to reducing known and fugitive methane emissions.
DEP will be bringing a more fully-formed rulemaking proposal to the Air Quality Technical Advisory Committee next year, most likely in late Spring or Summer.
PEC will be submitting new comments to the Department, both on how to improve the permitting proposals, and how DEP should develop a more comprehensive hydrocarbon rulemaking to effectively address emissions from existing sources. Those comments will be posted on this site in early January 2018.