On October 12, 2024, the Pennsylvania Department of Environmental Protection (PADEP) announced that there will be a new General Plan Approval and/or Operating Permit available for owners and operators of gaseous fuel-fired spark ignition internal combustion engines (BAQ-GPA/GP-16). This BAQ-GPA/GP-16 was developed 25 Pa. Code Chapter 127, Subchapter H and is limited to gaseous fuel-fired spark ignition internal combustion engines. The application of the BAQ-GPA/GP-16 would be limited to engines proposed at new or existing minor sources, as defined under 25 Pa. Code Chapter 121.1
The proposed BAQ-GPA/GP-16 contains Best Available Technology (BAT) emission limits shown in the table below. Please note that these BAT limits are generally more stringent than the limits in Table 1 of 40 CFR Part 60 Subpart JJJJ Standards of Performance for Stationary Spark Ignition Internal Combustion Engines.
Table 1.
| Engine Type | Engine Rating (hp) | Emission Standards |
| (g/hp-hr) | ppmvd @15%O2 |
| NOx | CO | VOC (as propane) | HCHO | NOx | CO | VOC (as propane) | HCHO |
| Lean-Burn | ≥100 and ≤500 | 1.0 | 0.70 | 0.30 | – | 82 | 95 | 26 | – |
| Lean-Burn | >500 and <2,370 | 0.50 | 0.25 | 0.25 | 0.05 | 41 | 34 | 21 | 6 |
| Lean-Burn | ≥2,370 | 0.30 uncontrolled | >0.25 | >0.25 | >0.05 | 25 uncontrolled | >34 | >21 | >6 |
| 0.05 with control | 4 with control |
| Rich- Burn | >100 and <500 | 0.25 | 0.30 | 0.20 | – | 21 | 41 | 17 | – |
| Rich-Burn | >500 | 0.20 | 0.30 | 0.20 | 76% reduction | 16 | 41 | 17 | 2.7 |
In order to comply with the new BAQ-GPA/GP-16 the owner and/or operator must comply with the above limits set forth for the spark ignition combustion engine(s) they plan to permit. Additionally, as part of the BAQ-GPA/GP-16, there are monitoring, recordkeeping and reporting requirements designed to keep the facility operating within applicable Federal and State air quality requirements. Some of these records include maintenance performed, malfunction reporting and annual facility emissions inventory (AEI) reporting. The required records must be maintained onsite or at the nearest local field office for 5 years and an annual emissions report is required to be submitted to the Department by March 1st of every year.
Prior to this proposed BAQ-GPA/GP-16, sources seeking authorization for spark ignition engines were limited to certain exemption criteria or full Plan Approval permitting was necessary. The proposed permit allows operators and/or owners to more easily navigate obtaining authorization for spark ignition engines at their facilities in Pennsylvania.
Permitting Fees
- Fees proposed are as follows:
- General Plan Approval Application Fee ($2,100)
- General Operating Permit Application/Renewal Fee ($750)
- Annual Operating Permit Maintenance Fee ($500)
- Transfer of Ownership Fee ($500)
- Administrative Amendment Fee ($500)
As with other General Plan Approvals and Operating Permits the term for this proposed general permit is 5 years and an approved authorization can be renewed before the expiration date.
If you would like to provide comments on the proposed GP-16, comments are being accepted through November 25, 2024. Comments must include the originator’s name and address and should be submitted using either the Department’s eComment system at www.ahs.dep.pa.gov/eComment or by email to [email protected]. Any written comments should use ”Proposed Revised GP-16” as the subject line and may be mailed to the Policy Office, Department of Environmental Protection, Rachel Carson State Office Building, P.O. Box 2063, Harrisburg, PA 17105-2063.
If you would like to discuss this new General Plan Approval and/or General Operating Permit and how they may impact your facility or any upcoming projects you may have, please contact Trinity’s Philadelphia or Pittsburgh office.
