WVDEP Division of Air Quality’s Draft of the Natural Gas Facility Class II General Permit G80-A Open for Public Comment Until March 30, 2015


By: Amanda L. Fitzhugh Porter, Esq.

The West Virginia Department of Environmental Protection (“WV DEP”) Division of Air Quality has drafted a Natural Gas Facility Class II General Permit G80-A which is now available for public comment until March 30, 2015. This General Permit “address[es] the prevention and control of regulated air pollutants from eligible natural gas production, compressor and/or dehydration facilities[,]” and combines all related air quality regulations into a single permit. It will allow applicants to “install and operate specified equipment, air pollution control devices and/or emission reduction devices to control emissions of regulated pollutants into the air.” The following activities may be included in the General Permit G80-A:

  • Natural Gas production facility activities are:
    • Natural gas well completion operations;
    • Separation of the condensate,
    • Natural gas and water in gas production units;
    • Additional separation of the natural gas, condensate and water emulsion in heater treaters;
    • Compression of the natural gas;
    • Dehydration of the natural gas;
    • Storage of the condensate and produced water; and
    • Loading of tanker trucks to transport condensate and produced water from the facility.
  • Natural gas compressor station activities are reciprocating internal combustion engine driven compressor(s) or combination of equipment (including but not limited to compressor engines, emergency standby generators, engine driven air compressors, boilers, line heaters, tanks, glycol dehydration units, air pollution control devices, etc.) that supplies energy to move natural gas at increased pressure from gathering systems, in transmission pipelines or into storage.

Currently, there are three general permits used for air quality control: G30-D and G35-A which cover natural gas compressor facilities while G70-A permits include oil and natural gas production facilities designed and operated for the purpose of oil and natural gas production located at the well site. The G80-A will replace these three former general permits. In doing so, G30-D, G35-A and G70-A will continue to exist, however, any modifications, amendments or revisions, will only be allowed under General Permit G80-A. Please note, General Permit G80-A does not include approval for Gas Well Drilling. Such approval is still handled by the WV DEP, Office of Oil and Gas.

For additional information, including the draft of the General Permit G80-A, please visit the Division of Air Quality (“DAQ”) website at http://www.dep.wv.gov/daq.Pages/default.apsx. DAQ is accepting public comments via email at DEPG80A@wv.gov until March 30, 2015. A public hearing is scheduled for March 16, 2015 from 6:00 p.m. to 8:00 p.m. EST at WV DEP headquarters in Charleston, WV. The public hearing will be available, in real-time, via YouTube.

Amanda L. Fitzhugh Porter is an associate in the Energy Practice Group in Leech Tishman’s Pittsburgh office. If you would like more information on this subject, please contact Amanda at (412) 261-1600 or aporter@leechtishman.com. Learn more about Leech Tishman’s Energy Practice Group here.


Leech Tishman’s Facebook Page: https://www.facebook.com/leechtishman

Leech Tishman’s Energy Group Twitter: https://twitter.com/LTEnergyGroup

Leech Tishman’s Company Page on LinkedIn: https://www.linkedin.com/company/leech-tishman

Leech Tishman is a firm dedicated to providing full-service commercial legal services to individuals, businesses, and institutions. We combine a deep understanding of our clients and their businesses with skilled legal counsel to find solutions. Leech Tishman offers legal services in alternative dispute resolution, bankruptcy & creditors’ rights, construction, corporate, employment, energy, environmental, safety & toxic torts, estates & trusts, government relations, insurance coverage & corporate risk mitigation, intellectual property, international legal matters, litigation, real estate, and taxation. Headquartered in Pittsburgh, PA, Leech Tishman also has offices in Chicago, Los Angeles, New York and Wilmington, DE. For more information call 412.261.1600 or visit us at www.leechtishman.com.