On December 17, the Environmental Quality Board is scheduled to consider proposed regulations to control methane emissions from existing oil and gas operations and setting a new numeric human health criterion for manganese.
Methane Controls
The proposed regulation controls methane emissions by setting volatile organic compound (VOC) emissions from existing oil and gas operations.
The approach used in the regulation is based on a federal Control Technique Guideline for oil and gas facilities which will be used to develop a RACT standard. RACT is defined as the lowest emission limitation that a particular source is capable of meeting with economically feasible, reasonably available emissions control technology.
Generally, the regulation 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 estimates there are approximately 435 midstream compressor stations, 120 transmission compressor stations and 10 natural gas processing facilities whose owners and operators may be subject to the proposed VOC emission reduction measures, work practice standards, and reporting and recordkeeping requirements.
In addition, an estimated 8,403 unconventional natural gas wells, as 303 of the 71,229 conventional natural gas wells that are above the 15 barrel of oil equivalent per production threshold would be covered by the regulation
[A report by the Environmental Defense Fund in February of 2018 on methane emissions from oil and gas wells in Pennsylvania, however, found about 50 percent of those emissions come from conventional oil and gas wells (268,900 tons) and about 50 percent from unconventional gas wells (253,500 tons).
[Conventional gas wells are treated is in reporting methane emissions. Conventional oil and gas wells are not required to report their methane emissions to DEP, while unconventional wells are, even though they make up about half the methane emissions.]
DEP consulted with the Air Quality Technical Advisory Committee, the Small Business Compliance Advisory Committee and the Citizens Advisory Council in the development of this proposed rulemaking.
DEP is recommending a 60-day public comment period and 3 public hearings.
Copies of the regulatory package are available-- Executive Summary; Preamble; Annex A -The Regulation; Regulatory Analysis Form; Citizens Advisory Council Letter June 18, 2019; Small Business Compliance Advisory Committee Letter April 17, 2019; Air Quality Technical Advisory Committee Letter April 11, 2019.
Manganese - Background
A 2017 change in state law directed the Environmental Quality Board to adopt a proposed manganese standard within 90 days that includes the 1 milligram/liter manganese standard established under 25 Pa Code Chapter 93.7 and changed the point of compliance from the point pollution enters a stream to the point where it is taken out by a water user (25 Pa Code Chapter 96.3)
The 1 milligram/liter standard is 20 times the level of manganese that water suppliers are allowed to have in their water supplies, according to EPA’s secondary maximum contaminant level. Click Here for more.
Local government groups, drinking water suppliers and many other groups opposed the amendment. Click Here for more.
The last minute as a favor to the coal industry and shifts the burden for treating manganese discharges from abandoned mine sites and other sources from those who pollute the water to those using the water, like public water suppliers.
The change in law swept away nearly 30 years of environmental protection for Pennsylvania waterways impacted by the consequences of acid mine drainage, and imposes additional testing, monitoring and treatment at public water supply operations along these waterways.
Current science shows manganese is harmful to human health as a possible nervous system toxin with implications to early childhood development at levels that are less than the threshold levels that impact aquatic life.
In a related action, on November 12, Commonwealth Court ruled Senate President Pro Tempore Joe Scarnati (R-Jefferson) and Sen. Gene Yaw (R-Lycoming), Majority Chair of the Senate Environmental Resources and Energy Committee, lacked standing to file a petition for mandamus relief to compel DEP and the Environmental Quality Board to propose a change in the manganese standard as required by the 2017 law. Click Here for more.
Manganese - Proposal
In January of 2018, DEP published an advance notice of proposed rulemaking requesting information on changing the water quality standard to gather more information on manganese impacts and setting a 1 mg/L standard as part of the regulation development process.
DEP also consulted with the Small Water Systems Technical Assistance Center, the Agricultural Advisory Board and the Water Resources Advisory Committee.
DEP is proposing the EQB adopt a proposed regulation for comment proposing a new numeric human health criterion for manganese of 0.3 mg/L in Chapter 93.8 - Water Quality Criteria For Toxic Substances, and deleting the 1 mg/L standard because it is not protective of human health.
DEP, however, is proposing alternative language for public comment which would make the point of compliance at the discharge point or the point at which water is taken from a stream consistent with the 2017 law.
DEP is proposing a 45-day public comment period and one public hearing.
Copies of the regulatory package are available-- Executive Summary; Preamble; Annex A - The Regulation; Regulatory Analysis Form; and Human Health Rationale.
The meeting will be held in Room 105 of the Rachel Carson Building in Harrisburg starting at 9:00.
For more information and available handouts, visit the Environmental Quality Board webpage. Questions should be directed to Laura Edinger by calling 717-772-3277 or send email to: ledinger@pa.gov.
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[Posted: December 4, 2019] www.PaEnvironmentDigest.com
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