Oil & Gas Air Quality Exemption B 38
What?: The rules and
regulations governing oil & gas operations (
PA Code) include a list of kinds of
facilities that are
exempt
from needing an Air Quality Permit.
B 38 is the exemption for an oil
& gas well. DEP has an open public comment period on this exemption.
The PA Bulletin notice for this issue is
here.
Deadline: March 19, 2013.
Why Does It Matter?: An
unconventional gas well can cause air pollution in several ways. If wells are exempt from needing an air quality permit then:
- There is no evaluation
of whether they are following the rules.
- There are no inspections,
and hence no violations that will ever
happen.
- There is no documentation
for data reporting or aggregation into area sources of air pollution.
DEP is apparently responding to the air quality rule promulgated not
long ago by EPA for Oil & Gas — which does apply to wells. By
continuing the exemption they are leaving the industry
to regulate itself for Oil & Gas well air pollution. We need to tell DEP:
No air quality permit exemption for fracking!
How?:
E-mail: Krishnan Ramamurthy <
kramamurth@pa. gov>
US Mail: Krishnan Ramamurthy,Environmental Program Manager, Division of Permits,
Bureau of Air Quality, 12th Floor, Rachel Carson State Office Building,
P. O. Box 8468, Harrisburg, PA 17105-8468.
“Take-Action Button”: If you are looking for a click-here-to-take action button, you can use the one offered by
Clean Air Council. Click
here.
(DEP does have a tendency to lump together similar
click-button-to-take-action comments and treat them as one comment. If
you are writing your own comment from scratch — recommended! — it is
better to send it using your normal method of sending E-mail. That way
it will be in your sent items folder, you can use it as the basis for
writing future comments, and DEP will know that it came direct from
you.)
Background: For a Fayette County public comment on B 38 for this current public comment period look
here.