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PADEP Publishes Guidance on Erosion and Sediment Control, Emission and Source Reporting

The Pennsylvania Department of Environmental Protection recently published three important notices in the Pennsylvania Bulletin affecting the oil and gas industry.  They are:

  1. The final Erosion and Sediment Control General Permit-2 (ESCGP-2) for Earth Disturbance Associated with Oil and Gas Exploration, Production, Processing or Treatment Operations or Transmission Facilities, which includes several supporting documents and a policy document.
  2. final technical guidance document regarding the Department’s “Policy for NPDES Permits for Stormwater Discharges Associated with Construction Activities at Oil and Gas Wells (Document No. 550-2100-008)”).
  3. A notification regarding “Emissions and Source Reporting Requirements for Natural Gas Operations” pursuant to the Pennsylvania Air Pollution Control Act.

The ESCGP-2 notice includes detailed information regarding the DEP’s plan for the proposed transition from the current ESCGP-1 (which expires on April 12, 2013) to the new ESCGP-2.  In the notice regarding emissions and source reporting requirements for unconventional natural gas operations, the DEP identified sources subject to reporting, which include: “compressor stations; dehydration units; drill rigs; fugitives, such as connectors, flanges, pump lines, pump seals and valves; heaters; pneumatic controllers and pumps; stationary engines; tanks, pressurized vessels and impoundments; venting and blow down systems; well heads; and well completions.”  Complete source reports are due by March 1, 2013, and annually on March 1 thereafter.