GASP’s Recent Legal Actions Reduce Compressor Station Emissions
GASP’s legal team regularly comments on draft air permits and files appeals when necessary to reduce harmful emissions from natural gas compressor stations. Our recent work on two compressor stations in Southwestern Pennsylvania has helped limit air pollution from these sources and ensure that regulators are correctly applying air quality regulations.
Pa. DEP aggregates natural gas compressor station with nearby well pad
In response to comments submitted by GASP, the Pennsylvania Department of Environmental Protection (DEP) recently aggregated a natural gas compressor station with a nearby well site for purposes of air permitting.
The Jupiter Compressor Station is located in Greene County and operated by EQT Gathering, LLC. In April, GASP submitted comments on this station’s draft operating permit. Our comments pointed out that there are a number of facilities near Jupiter whose emissions should be grouped together, or “aggregated,” and treated as a single source for air permitting purposes. Under the Clean Air Act, sources of air pollution must be aggregated if they are contiguous or adjacent to each other, under common control, and share the same Standard Industrial Classification (SIC) code. This rule can be challenging to apply in the oil and natural gas industries, which often involve many relatively small sources spread out over a large area.
Last October, DEP issued a guidance document explaining its policy on how these single source determinations should be made for the oil and natural gas industries. In practice, DEP has applied this policy in an overly restrictive manner that is inconsistent with the definition of a “source” under the federal Clean Air Act. DEP’s policy states that sources located within 1/4 mile of each other are presumed to be “adjacent” to each other; sources located at a greater distance may be considered adjacent on a case-by-case basis. In practice, however, DEP has tended to ignore any sources located beyond 1/4 mile, even though U.S. EPA has clearly stated that there should be no bright-line rule concerning how far apart sources can be located and still be considered adjacent to each other.
In this case, the Jupiter station and the Pyles Well Pad are located within 1/4 mile of each other; as such, under DEP’s policy, these sources are presumed to be adjacent to each other. Jupiter is operated by EQT Gathering, LLC, and the Pyles Well Pad is operated by EQT Production; these are both wholly-owned subsidiaries of EQT Corporation, and thus Jupiter and the Pyles Well Pad are considered to be under common control. These facilities also share the same two digits of their SIC codes. GASP pointed out that all three aggregation requirements were met here, and DEP agreed. As a result, emissions from the Pyles Well Pad were considered in the Jupiter station’s operating permit.
This station is the first example we have seen where DEP has aggregated a compressor station with a nearby well site in response to public comments. GASP has argued many times in comments and in litigation that similar sources should be aggregated, but DEP has not agreed with those arguments in the past. Although the decision in this instance did not result in any significant changes to Jupiter’s permit, it provides a useful example of a case where DEP has correctly aggregated these sources.
GASP appeal of Kriebel Compressor Station results in emission reductions
In response to an appeal filed by GASP, the Allegheny County Health Department’s (ACHD) Air Quality Program and Kriebel Minerals, Inc. agreed to reduce nitrogen oxide (NOx) emissions from the Rostraver Rt. 51 Compressor Station by 87%.
Kriebel Minerals’ Rostraver Rt. 51 facility is located in Forward Township, Allegheny County. It compresses and dehydrates natural gas received from nearby conventional wells. GASP appealed the permit, arguing that greater engine emissions reductions were technically and economically feasible, and required as a matter of law.
Ultimately, Kriebel Minerals and ACHD agreed. Kriebel will install a more effective engine exhaust catalyst, and maximum allowable NOx emissions from the engine will be reduced from 5.12 tons per year to 0.66 tons per year. While engines like the one operating at the Kriebel facility are relatively small, emissions from this type of source are worth the attention because there are so many small stationary engines in operation, and add-on controls to reduce their emissions are incredibly cost-effective. Better controlling this category of sources has the potential to greatly improve air quality at minimal cost, and would be a wise approach for air pollution control agencies to consider as they work to meet revised National Ambient Air Quality Standards for NO2 and ozone.