On Feb. 6, 2017 GASP submitted comments to the Pennsylvania Department of Environmental Protection (DEP) regarding a draft plan approval for the Blue Moon Compressor Station in West Pike Run Township, Washington County. A plan approval is a permit to install, construct, or modify a source of air pollution.
The facility’s operator applied for the draft plan approval that GASP commented on in March 2016. The draft plan approval would have authorized the installation of five compressor engines, two dehydrators, and associated water tanks and equipment. The facility had already installed and was operating five compressor engines, two dehydrators, and associated water tanks and equipment pursuant to a plan approval issued in May 2015.
When aggregated, emissions from the new equipment at the facility and the already-installed equipment would have exceeded major air pollution source thresholds for oxides of nitrogen (NOx), volatile organic compounds (VOCs), and formaldehyde, a hazardous air pollutant.
In our comments, we argued that the operator’s original plan to construct and operate a smaller facility did not excuse it from its obligation to comply with permitting requirements for major sources of air pollution when, as a matter of fact, it changed its plans within a year and essentially doubled the size of the facility to meet demand that it reasonably could have anticipated.
Specifically, we argued that the facility was subject to New Source Review (NSR) requirements, which, if applied, would have required the facility to: implement the Lowest Achievable Emission Rate, offset its potential emissions with Emission Reduction Credits, and conduct an alternatives analysis to demonstrate that the benefits produced by the facility will “significantly outweigh” the “environmental and social costs” that it imposes within Pennsylvania. Further, the facility’s operator would also have been required to show that its other facilities in Pennsylvania are being operated in compliance with applicable air pollution laws.
NSR requirements were established to ensure that new major sources of air pollution would not, at a minimum, detract from the attainment of the National Ambient Air Quality Standards, and compliance with NSR requirements is mandated by the Clean Air Act.
We are pleased to report that our comments found an audience. We have learned that the facility’s operator has revised its original plans and will install air pollution control devices and accept operating limitations so that it can operate the facility as a minor source of air pollution. As modified from the original plans, the facility will be permitted to emit 79 fewer tons per year of NOx, 23.63 fewer tons per year of VOCs, and 3.61 fewer tons per year of all hazardous air pollutants (including 3.43 tons of formaldehyde).
This is a victory for everyone who breathes the air in West Pike Run Township and areas downwind!
–John Baillie, Staff Attorney