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DEP contends rules protect people and the environment okay

~ Public comment on Lockney compressor station raises questions ~

Government has been called a "necessary evil" by many citizens over the years, but the majority try to believe that all the rules and regulations really are to protect the "common good." The WV DEP stands by that notion when issuing air quality permits across the state.

In recent months, newspapers across Central WV have received numerous legal advertisements from the Department of Environmental Protection (DEP) in connection with the natural gas boom this area is seeing. On Aug. 15, this paper ran an Air Quality Permit Notice for the compressor station that is being constructed at Lockney, just west of Normantown.

The advertisement told the exact coordinates of the station, the permit number, the "potential emissions authorized by this permit action" and information to submit public comment. At least one Gilmer County resident did submit a comment as follows:
"I am concerned that the approval of this permit is not taking into consideration the total emissions that will be present in the area. There is another compressor station situated right beside the location that is now under construction for Cone Gathering's station.

"I feel it should be considered collectively with the existing compressor station to estimate the total potential emissions to ensure the safety of the residents of Lockney."

DEP Engineer Jill Harris responded to the comment in writing, explaining that "Cone Gathering, LLC is installing a new natural gas compressor station with three natural gas fired compressor engines, one diesel fired generator, one TEG dehydration unit, one vapor recovery unit and associated engine, multiple storage tanks and loadout operations."

Her letter went on to explain how the determination is made as to whether a facility's emissions is considered in combination with other nearby facilities. EPA definitions require that aggregation is appropriate only if the separate emission sources meet the following "three-prong test":

The sources belong to a single major industrial grouping (same two-digit major SIC code);
The sources are located on one or more "contiguous or adjacent" properties; and
The sources are under common control of the same person (or persons under common control).

In the case of CONE Gathering's compressor station at Lockney, only two of the three indicators are met.

While the other facility does share the single major industrial grouping code, and they are adjacent to each other, they are not owned by the same person or company. The existing compressor station is owned by Dominion.

"Since all 'three prongs' are not met, the sources will not be aggregated in determining applicable rules, regulation and public notice reporting. The DAQ has decided to issue permit R13-3099 to CONE Gathering, LLC. Upon review of the permit application, it was decided that the facility will meet all rules and regulations of the state of West Virginia and of the US EPA as they apply to air quality.

The state rules and federal regulations are designed to ensure human health and safety and environmental welfare."
While safe levels of toxins like Sulfur Dioxide, Carbon Monoxide, Benzene, Toluene and Oxides of Nitrogen have been established, gas companies should be doing what they can to monitor the total emissions when they have facilities so close together.

Jill Harris can be contacted at 304-904-0499, ext. 1203, for questions.