PA Environment Digest Blog: Center For Coalfield Justice To DEP: Harmon Natural Gas Processing Plant Should Be Required To Apply For A Full Title V Air Quality Permit As They Originally Proposed In Washington County

This testimony was presented by Sarah Martik, Executive Director of the Center for Coalfield Justice based in Washington County, at a March 11 hearing by the DEP Office of Environmental Justice on an Air Quality Permit for the expansion of the MarkWest Energy's Harmon Creek Natural Gas Processing Plant in Smith Township, Washington County.

Hello, my name is Sarah Martik, and I am the executive director of The Center for Coalfield Justice (“CCJ”), which is a Pennsylvania-incorporated not-for-profit organization with federal Internal Revenue Service §501(c)(3)-status recognition located in Washington, PA.

Our mission is to “improve policy and regulations for the oversight of fossil fuel extraction and use; to educate, empower and organize coalfield citizens; and to protect public and environmental health.”

CCJ has over three thousand members and supporters and is governed by a volunteer Board of Directors.

Thank you for the opportunity to provide input on the expansion of MarkWest Liberty Midstream & Resources, LLC’s (“MarkWest”) Harmon Creek Gas Processing Plant (''Harmon Creek''), which adds several new air pollution sources in one of the most overburdened areas in Pennsylvania.

CCJ respectfully submits the following comments which will expand on the following:

1. MarkWest should be required to re-apply for a Title V permit,

2. MarkWest and the Department of Environmental Protection (“DEP”) must account for and consider all cumulative impacts (including the numerous existing facilities) in the project area to ensure that additional burdens will not be imposed on this overburdened community, and

3. The DEP must opt this permit into the Environmental Justice Policy.

MarkWest must reapply for a Title V permit.

MarkWest did not apply for a Title V permit because the expansion's emissions are estimated to be just below the threshold that would require it.

However, we understand that MarkWest initially planned to apply for a Title V permit but backtracked.

Given this context and past experience with operators in the region, and past experiences of violations at this specific facility, it is very likely that MarkWest will emit above the threshold of their proposed permit, and, therefore, would require a Title V permit.

Thus, the DEP should require MarkWest to apply for a Title V permit now rather than later to better protect this community.

The project area is one of the most overburdened in the state with many cumulative impacts, and this expansion must be opted into the Environmental Justice Policy.

The Harmon Creek plant is only one source of pollution within this community: there is another cryogenic plant, a [gas pipeline] compressor station, a number of unconventional well-pads and a number of abandoned/orphaned wells, in addition to the associated infrastructure like pipelines.

All of these sources contribute to this area’s significant environmental burden, and failing to consider this within the context of the Harmon Creek application puts people at increased exposure risk.

Here, PennEnviroScreen identifies three of the four census block groups within one mile of the project as EJ areas, including the block group (Block Group 1, Census Tract 7137) that contains the project, yet this permit was not opted into the full benefits of the Environmental Justice Policy. [Click Here to see graphic]

Block Group 1, Census Tract 7137, is disadvantaged to the 94th percentile for all block groups in Pennsylvania.

They received a score of 92 for toxic air emissions and a 96 for compressor stations - which approval of this application would only make worse.

Other indicators that affect living conditions where this block group received high scores include unconventional oil and gas wells (89), hazardous waste and storage sites (90), coal mining (85), and mining concerns (91).

This block group has a population with high incidents of heart disease.

Block Group 2, Census Tract 7140, ranks in the 96th percentile for disadvantaged block groups.

Again, they are disproportionately exposed to high levels of toxic air emissions (89) and compressor stations (89), but they are also exposed to high levels of traffic (96).

This block group received an environmental effect score of 100 due to the impact of unconventional gas wells (93), hazardous waste and storage sites (92), coal mining (84), and mining concerns (97).

There is also a high unemployment rate here, receiving a score of 91.

Block Group 2, Census Tract 7137, is one of the most disadvantaged block groups in the state, placed in the 99th percentile.

It received a score of 96 for both toxic air emissions and traffic while receiving scores of 90 for toxic water emissions and 86 for compressor stations.

This block group also received an environmental effects score of 100 since residents are affected by conventional gas wells (80), unconventional gas wells (87), hazardous waste and storage sites (91), and mining concerns (96).

In addition, there are many children under five in this block group (96), and there are high rates of heart disease (85).

The only block group within one mile of the project that is not an EJ area is Block Group 2, Census Tract 7110.

However, this block group still received high scores for toxic air emissions (92), conventional gas wells (86), and mining concerns (94).

Communities Near Bulger Compressor Station

The communities near the Bulger Creek Compressor station are already exposed to pollution.

Pollution from compressor stations can cause burning eyes and throat, skin irritation, headaches, nausea, vomiting, cancer, and cardiovascular and respiratory risks (which many people in these block groups already have).

Pipelines and unconventional gas wells, which are likely to increase in the area to feed the expansions, come with additional health impacts.

Unconventional gas wells increase the risk of groundwater contamination, exposing nearby residents to radioactivity, salts, and chemicals used in fracking fluid.

This means residents in these block groups are exposed through the air they breathe and the water they drink.

Additionally, pollutants from all the related infrastructure can have health impacts up to 10 miles.

Thus, it is evident that the communities near this project are already disproportionately burdened by numerous cumulative impacts, and additional burdens from expanding this facility must not be accepted or imposed, and at the bare minimum they should be required to apply for a Title V permit.

However, it is clear that additional burdens are likely to be imposed anyway, and the DEP did not choose to opt this permit into their Environmental Justice Policy, finalized in 2023.

The Environmental Justice meeting that was held just prior to this comment period did not give residents enough time to react to information and form comments to give at this hearing.

At the very least, the environmental justice meeting and the hearing should have been held on separate days.

The Environmental Justice Policy offers much more than one meeting to learn the basics about a project.

The Environmental Justice Policy recommends a tailored outreach approach for each community, easy-to-understand documents in an accessible place, enhanced inspection and enforcement, and more.

This community has not been given what they deserve from the DEP, and the DEP should rectify that.

Thank you for your consideration, please feel free to reach out with questions at any time.

Click Here for a copy of the hearing testimony.

Sarah Martik, Executive Director of the Center for Coalfield Justice, and can be contacted by email to: smartik@centerforcoalfieldjustice.org or 724-229-3550.

Visit DEP’s MarkWest Harmon Creek Natural Gas Processing Plant webpage for more information on DEP actions related to this facility.

(Photo: The Energy Age Blog - Marcellus Air.)

Resource Links - Harmon Creek Hearing:

-- Community Speaks Out Against Expansion Of Harmon Creek Natural Gas Processing Plant In Washington County [PaEN]

-- Washington County Resident To DEP: Harmon Creek Natural Gas Plant Expansion Will Result In A Huge Increase In Air Pollution, It Should Be Required To Have A Major Air Quality Permit, It Is Not A ‘Minor’ Source [PaEN]

-- Moms Clean Air Force To DEP: Families In Washington County Are Already Living In The Middle Of Major Natural Gas Industrial Sites - Do Not Expand The Harmon Creek Natural Gas Processing Plant And Make It Worse [PaEN]

-- Center For Coalfield Justice To DEP: Harmon Natural Gas Processing Plant Should Be Required To Apply For A Full Title V Air Quality Permit As They Originally Proposed In Washington County [PaEN]

-- Fact Sheet: How Oil and Gas Operations Impact Your Baby’s Health