Delaware Riverkeeper Network Opposes
Pennsylvania’s Proposed Air Emissions Permit GP-5
Calls for addressing deposition of air pollutants from gas operations on water
Harrisburg, PA – Delaware
Riverkeeper Network submitted comments today to PA Department of
Environmental Protection’s (PADEP) Air Quality Bureau in Harrisburg
regarding PADEP’s proposed revisions to the General Plan Approval and/or
General Operating Permit for Natural Gas Production and Processing
Facilities, known as GP-5. PADEP noticed the proposed revisions in
March with a comment deadline of May 2 but then extended the comment
period to May 23. The revisions apply to natural gas operations
throughout the Commonwealth and were necessary to address changes in US
Environmental Protection Agency performance standards and national
emissions standards for hazardous air pollutants.
For a copy of DRN’s comments go to: http://www.delawareriverkeeper.org/resources/Comments/PADEP%20GP-5%20Comnt%205.23.12%20submitted.pdf
DRN’s
comment focuses on the issue of atmospheric deposition of airborne
pollutants from natural gas production and processing facilities. DRN
concludes that the proposed GP-5 is not effective for the protection of
human health or the environment and advocates that PADEP correct the
deficiencies in the proposed permit before moving ahead.
“The
deposition of pollutants emitted by natural gas operations on to water
will lead to water quality degradation and provides a substantial
pollution pathway that PADEP does not address in the proposed GP-5”,
said Maya van Rossum, the Delaware Riverkeeper. “This is a huge missing
piece of the air pollution
puzzle that faces all Pennsylvanians because of the dangerous
pollutants the gas industry emits. The problem must be solved by
addressing the whole picture, not just little bits. PADEP needs to fix
this and fix it now,” said van Rossum.
DRN
engaged an air expert, Cherelle Blazer, MESc, of Texas to conduct a
technical review of the GP-5 in regards to the issue of the deposition
of air pollution on water; her report is included in the link to DRN
comments above. Ms. Blazer found the proposed permit revisions to be
inadequate in protecting public health and the environment because it
does not go far enough in addressing the problem of deposition. Ms.
Blazer recommends action be taken to analyze cumulative effects and then
institute a plan to address them, to make more substantive cuts to
emissions and to explore ways to prevent emissions such as restricting
certain polluting activities (i.e. gas well flaring).
Ms.
Blazer reviewed the scientific literature on this issue and points out
that employing Best Available Control Technology (BACT), which is the
primary method used in the GP-5, is simply not enough to keep air
emissions from degrading the environment. In fact, the use of BACT in
other parts of the country where drilling has been occurring has not
resulted in effectively controlling Nitrogen and Sulfate, two of the
dangerous air pollutants emitted by gas facilities that are deposited on
to water. In Sublette County Wyoming where BACT is mandatory, Nitrate
and Sulfate emissions have actually increased and there is evidence of
atmospheric deposition in the water and on the land near gas fields
there. Ms. Blazer points out that the proposed GP-5 permit can result
in the same situation in Pennsylvania.
“Many
pollutants are released by natural gas activities and they all must be
stopped. Some of these toxics are deposited on land, vegetation, and
surface water, where they cause water quality pollution that affect
millions more people downstream as well as downwind. PADEP is proposing
to do the same old thing - a strictly technological fix. Well, this
isn’t working anywhere in the nation. PADEP needs a new model – they
need to prevent the pollution that is harming people and polluting our
air and water,” said Tracy Carluccio, Deputy Director, Delaware
Riverkeeper Network.
For more information on gas drilling go to http://www.delawareriverkeeper.org/act-now/urgent-details.aspx?Id=102
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