GASP to DEP: Revolution Cryogenic Plant Draft Plan Needs Stronger Controls to Protect Public Health

As part of our ongoing watchdog work, GASP this week took formal action to protect public health in Washington County: Our Senior Attorney John Baillie submitted written comments to the Pennsylvania Department of Environmental Protection (DEP) regarding the draft Plan Approval for ETC Northeast Pipeline’s Revolution Cryogenic Plant in Smith Township.

Here’s what’s going on: Currently, the Revolution Cryogenic Plant is classified as a natural minor source of air pollution. However, with the addition of the new Cryo II Unit, its potential to emit air pollutants would exceed major source thresholds.

To avoid being regulated as a major pollution source, the facility is aiming for synthetic minor status. To qualify for this, a facility must follow strict operating conditions that keep its emissions below certain thresholds.

According to the DEP’s Review Memo, the facility can only stay below major pollution thresholds if it relies heavily on two specific pollution controls:

• A Vapor Recovery Unit (VRU) operating at a 99.9% control efficiency.

• A Thermal Oxidizer operating at a 99% control efficiency.

Here is the catch: While DEP based its math on these high efficiencies, the draft Plan Approval does not actually legally mandate them.

In the comments submitted this week, GASP argued that if these exact control efficiencies are required to keep the plant from becoming a major polluter, they must be explicitly written into the permit.

GASP urged the DEP to revise the draft plan to:

1. Mandate the numbers: Explicitly require the facility to maintain a 99.9% control efficiency for the VRU and a 99% efficiency for the thermal oxidizer.

2. Prove compliance: Incorporate testing, monitoring, recordkeeping, and reporting requirements. Without them, there is no way for regulators—or the public—to know if the controls are actually working.

Stay tuned, we’ll keep you posted as the permitting process continues.