Pennsylvania DEP revised the General Plan Approval and/or General Operating Permit, commonly known as the GPA/GP-1, for Natural Gas and and No. 2 Oil Fired Small Combustion Units. The issuance of the new permit took effect upon publication of the January 28, 2023 version of the Pennsylvania Bulletin.
The primary change of the GPA/GP-1 was to increase the size or rated capacity of the combustion units covered by the general permit from 50 million Btu per hour to 100 million Btu per hour. This new rated capacity of 100 million Btu/hr widens the size range of small combustion units allowed for GPA/GP-1 applications and helps modernize the emissions acceptable under the permitting process.
Small business can find copies of the new GP-1 general permit applications, instructions, and additional information here.
UPDATE: Effective on August 20, 2022, Pennsylvania DEP is suspending the enforcement of a specific monitoring requirement – the inspection of the gasoline storage tank automatic tank gauge (ATG) cap. The reason for the suspension is that after a review of the rule’s requirements it was determined that the likelihood of the ATG being compromised is very low and the verification of the ATG status after every gasoline truck delivery can be problematic and difficult to access. Please note that the suspension of this specific monitoring requirement does not affect owners or operators of gasoline dispensing facilities relief from other Stage I & Stage II requirements. Additional information can found in the August 20, 2022 issue of the Pennsylvania Bulletin which can be found here.
About the Stage I & Stage II Rulemaking
The Pennsylvania Environmental Quality Board finalized a final-form rulemaking that amends air quality regulations related to the control of VOC emissions at gasoline dispensing facilities. The rulemaking went into effect on March 26th, 2022 and targets Volatile Organic Compound (VOC) emissions during the following situations:
Loading of underground gasoline storage tanks (or Stage I vapor recovery)
Filling of motor vehicles at the pump (or Stage II vapor recovery)
During and after decommissioning of Stage II vapor recovery equipment from gasoline dispensing pumps.
The final-form rulemaking also adds and amends definitions related to Stage I and Stage II vapor recovery systems. A copy of the final preamble and regulation can be accessed here.
What is Stage I Vapor Recovery Systems?
“Stage I” refers to a vapor recovery system that controls the emission of gasoline vapors into the atmosphere during the transfer of gas from a gasoline tank truck to a gasoline storage tank at a Gasoline Dispensing Facility (GDF).
A properly operating Stage I vapor recovery system returns vapors to the gasoline tank truck. The equipment and controls of a Stage I system also control the emission of gasoline vapors during the storage of gasoline vapors at a GDF.
What is Stage II Vapor Recovery Systems?
“Stage II” refers to the vapor recovery system that controls the emission of vapors during the transfer of gasoline from a gasoline storage tank at a GDF to a motor vehicle fuel tank. A Stage II vapor recovery system also controls emissions into the the atmosphere of vapors during the storage of gasoline at a GDF.
Stage II vapor recovery technology uses special refueling nozzles, dispensing hoses and a system that draws refueling vapors in the Underground Storage Tank (UST). A properly operating Stage II system moves the gasoline vapors from the motor vehicle fuel tank druing the refueling of the vehicle into the UST at the GDF.
Who is Affected by This Rulemaking?
The Pennsylvania Department of Environmental Protection (DEP) has finalized regulatory requirements for GDF owners and operators to decommission their Stage II vapor recovery system in 12 counties in the Philadelphia and Pittsburgh areas. The compliance date for the decommissioning of Stage II systems is December 31, 2022.
The 12 Pennsylvania counties include: Allegheny, Armstrong, Beaver, Bucks, Butler, Chester, Delaware, Fayette, Montgomery, Philadelphia, Washington, and Westmoreland.
Owners and operators are those with gasoline throughputs that exceed at anytime >10,000 gallons per month (or 120,000 gallons per year) and independent small business marketers of gasoline that have a monthly throughput >50,000 gallons per month (or 600,000 gallons per year) in the above mentioned 12 Pennsylvania counties.
Persons performing decommissioning procedures, leak testing, and repairs at gasoline dispensing facilities.
What Happens After Decommissioning Takes Place?
For those entities that need to decommission their Stage II vapor recovery system by December 31, 2022, a notification form needs to be completed and submitted to the appropriate DEP regional office, Allegheny County Health Department, or Philadelphia Air Management Services.
The Inflation Reduction Act of 2022 is set to address climate change and other environmental issues that could benefit small businesses. $369 billion in incentives is dedicated to target areas of renewable energy, energy efficient products, and electric vehicles over the next ten years.
While the bill is still waiting final approval, you can find summaries of the legislation as well as a summary of investments in climate and equity.
Jeremy Hancher is the EMAP Program Manager located at the Widener University SBDC. He holds over 15 years of experience in environmental compliance, environmental policy, and program management. He is proud to be the team lead of the award-winning EMAP program which provides free and confidential environmental assistance to the Pennsylvania small business community in fulfillment of the requirements of the Pennsylvania Air Pollution Control Act and Section 507 of the federal Clean Air Act.
In 2015, Jeremy was part of the team effort when EMAP was recognized by US EPA Administrator Gina McCarthy for Outstanding Accomplishments by a State Small Business Environmental Assistance Provider in Providing Technical Environmental Assistance to the Small Business Community. Jeremy holds a Bachelor’s degree from the University of Pittsburgh, a Master’s degree from the University of Pennsylvania, and a certificate from the Wharton School.