general plan approval and/or general operating permit (gp
TRANSCRIPT
General Plan Approval and/or General Operating Permit (GP-5)
and Air Quality Permit Exemption Criteria
SWEP Capital Chapter’s Annual Regulatory Update Seminar
Oct. 31, 2013
• GP-5 is the permit for the sources located at natural gas compression and/or processing facilities
• The current GP-5 became effective on Feb. 1, 2013.
• GP-5 Permit conditions and the application forms may be accessed at: http://www.dep.state.pa.us/dep/deputate/airwaste/aq/permits/gp.htm
GP-5 General Information
Sources Regulated:
Previous GP-5 vs. Revised GP-5
Previous GP-5 Revised GP-5
NG-fired engines ≥100 HP to < 1500 HP
All size NG-fired engines located at a non-major facility
Glycol Dehydrator Glycol Dehydrator and associated equipment (excluding re-boiler)
- Natural gas-fired simple cycle turbines - Centrifugal compressors - Natural gas fractionation process units
(such as De-propanizer, De-ethanizer, De-butanizer)
- Storage vessels/tanks - Pneumatic controllers - Sweetening Units - Equipment leaks
Only minor sources/facilities can use GP-5: • NOX, CO, SOX, PM10 or PM2.5 – 100 tons • VOCs – 50 tons • Any individual Hazardous Air Pollutant (HAP) –
10 tons • Total HAPs – 25 tons • Greenhouse gases, expressed as carbon
dioxide equivalent (CO2e) – 100,000 tons
Minor Facility Permit Limits
• Compliance with minor source permit limits is based on the facility's actual emissions
• Actual emissions must not exceed any of the major facility thresholds on a 12-month rolling basis
• Individual sources cannot exceed any source specific emission limitation included in the GP-5
How the Minor Source Permit Works
• Effective emission limits
• LDAR required over the entire facility
• Companies can use lower emitting equipment and process more gas
• Companies can operate in a fashion that matches their risk profile
• Ability to optimize their strategic investments
GP-5
• Exemption 38 for conventional and unconventional wells, wellheads and all other associated equipment (i.e., non-road engines, storage vessels/tanks, tanker truck loading and flaring activities)
• Exemption 38 became effective on Aug. 10, 2013
Exemption Category No. 38
• Conventional wellheads are exempted consistent with the previous exemption
• An unconventional wellhead and associated equipment can be exempted from permitting under Exemption 38, provided the specified criteria are all met
Exemption 38
• While a source may be exempt from permitting requirements, that source is still subject to all applicable commonwealth and federal regulations
• The criteria that must be met for a well pad to be exempted from permitting requirements are cost effective and protective of the public and environment
Exemption 38
• The entire well pad/facility is subject to a leak detection and repair (LDAR) program
• Storage vessels/tanks containing VOCs being controlled to a minimum of 95 percent emissions reduction
• Permanent flares must be enclosed
Exemption 38
• Only sources of minor significance can be exempted from permitting
• The department has developed more detailed Internal Implementation Instructions for consistent implementation of Exemption 38
• The Internal Implementation Instructions document is available at: http://www.dep.state.pa.us/dep/deputate/airwaste/aq/permits/gp.htm
Exemption 38
• Inadequate information to make single source determination – Not including information about associated wells
• Applications seeking authorization to use GP-5 for sources located only at the well pad – Well pad sources are largely governed by Exemption 38
• Inadequate information about HAPs other than formaldehyde VOC – EPA Test Method 25A is less sensitive to oxygenated and
chlorinated organic compounds
GP-5 Application Common Deficiencies
• 501 compressor stations • 13 processing plants and metering stations
Natural gas compression and processing facilities
0
100
200
300
400
500
600
North Central Northeast Southwest Northwest Total
Series1 151 64 178 121 514
151
64
178 121
514
Nu
mb
er o
f fa
cilit
ies
Natural gas compression and processing facilities
North Central 29%
Northeast 12%
Southwest 35%
Northwest 24%
• Distribution of facilities in the state
Natural gas compression and processing facilities
• Top five counties
Natural Gas Compression Facility –
• Clean Air Council of Philadelphia funded NO2 modeling of Barto Compressor Station impacts.
• Results from AERMOD modeling indicated that
100 ppb NO2 NAAQS exceeded by 278%.
• DEP conducted short-term sampling of ambient NO2.
• Sampling measured a maximum 1-hour average NO2 concentration of 5.9 ppb and a maximum 5-minute average of 20.4 ppb – well below the NAAQS limit.
Ambient Air Impact- Compressor Station
• Unconventional natural gas facilities began reporting emissions in 2012 for calendar year 2011.
• Sources and activities subject to reporting requirement include gas drilling; compression; dehydration; and gas processing operations.
Air Emissions Inventory – Natural Gas Production
• Net SO2 Emission Reduction of 511,309 tons equates to $14.8 to $37.3 billion of annual monetized health benefits computed using EPA’s benefit-per-ton (BPT) factors.
Air Emissions Inventory – Natural Gas Production
Category Year CO NOx PM10 SOx VOC
All Point Sources 2008 94,409 235,485 30,719 864,789 24,671
All Point Sources 2011 85,990 192,275 22,588 353,480 20,363
Difference (8,419) (43,210) (8,131) (511,309) (4,308)
Unconventional Gas 2011 6,852 16,542 577 122 2,820
Questions?
