On April 11, DEP’s Air Quality Technical Advisory Committee voted to recommend DEP move ahead with a proposed regulation to control volatile organic compound emissions, with a “co-benefit” of reducing methane emissions from existing oil and gas operations.
It was the first time the full text of the proposal was discussed and the recommendation was made in a split vote by the Committee after a lively conversation during which environmental group representatives questioned whether the scope of the regulation was adequate to the task.
Generally, the draft regulation outline calls for a 95 percent reduction in VOC emissions, however, some equipment-specific requirements call for less or more. For example, natural gas processing plants are required to have zero VOC emissions.
DEP said the regulation, as drafted, would exempt the “lion’s share” of conventional oil and gas wells (perhaps 80 percent or more) and roughly 6 percent of unconventional gas wells in Pennsylvania from the leak detection and repair requirements due to the threshold emission limits.
There are now about 80,000 conventional oil and gas wells and about 10,651 active unconventional gas wells in Pennsylvania.
Andrew Williams from the Environmental Defense Fund issued a statement Thursday saying DEP needed to make changes to the proposed rule. “...[If] not fixed, [the rule] will be the least protective methane rule in the country.”
“The rule as currently drafted would capture only 21 percent of methane emissions. A 2018 report by Environmental Defense Fund estimated that emissions of methane, a potent climate forcing agent, from Pennsylvania’s oil and gas industry are up to five times higher than what is reported to DEP, or potentially 520,000 tons per year. DEP’s current draft focuses almost entirely on volatile organic compounds (VOCs), not methane.
“The scope of DEP’s air emissions rule needs to be expanded – capturing only 21 percent of methane emissions leaves far too much pollution on the table and in our air. Simply removing the threshold for low-producing wells will allow for much more methane capture. DEP has got to get this right if Pennsylvania is to meaningfully reduce greenhouse gas emissions and tackle climate change as directed by Gov. Wolf in his executive order earlier this year.”
Click Here for a copy of the regulation. Click Here for a copy of DEP’s presentation.
DEP’s Small Business Compliance Advisory Committee is scheduled to discuss the VOC/methane control regulation at its meeting on April 17. DEP’s Citizens Advisory Council is also part of the review process.
DEP already had meetings with the Oil and Gas Technical Advisory Board on March 21 and a prior meeting with the Air Quality Technical Advisory Committee on December 13 to discuss the content of the regulation.
After these initial reviews are completed, DEP will prepare the regulation to go before the Environmental Quality Board for consideration as a proposed regulation.
Stage II
The Air Quality Technical Advisory Committee also recommended DEP move forward with a proposed regulation phasing out Stage II VOC controls at gasoline service stations because that early technology has been overtaken by better controls on vehicles themselves.
For more information and available handouts, visit the DEP Air Quality Technical Advisory Committee webpage. Questions should be directed to Kirit Dalal, 717-772-3436 or send email to: kdalal@pa.gov.
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