Comparison of Air Emission Standards for the Oil & Gas ...

Comparison of Air Emission Standards for the Oil &
Gas Industry

(Well Pad Operations, Natural Gas Compressor Stations, and Natural Gas Processing Facilities)

The Pennsylvania Department of Environmental Protection issued a General Permit, General Plan Approval and/or General Operating Permit (BAQ-GPA/GP-5) to authorize the construction,
modification, and/or operation of natural gas compression and/or natural gas processing facilities. Plan Approval and Operating Permit Exemption Category #38 (Well Pad Operations) was amended on
August 10, 2013.
The Center for Sustainable Shale Development (CSSD) is an independent nonprofit organization based in Pittsburgh, Pennsylvania. The Center provides a forum for a diverse group of stakeholders to
share expertise with the common objective of developing solutions and serving as a center of excellence for shale gas development. CSSD’s mission is to support continuous improvement and
innovative practices through performance standards and third-party certification. CSSD has developed initial performance standards for operators engaged in unconventional exploration, development,
and gathering activities including site construction, drilling, hydraulic fracturing and production in the Appalachian Basin. These standards represent consensus on what is achievable and protective of
human health and the environment.
Colorado Department of Public Health and Environment, Air Quality Control Commission has promulgated air emissions regulations 3, 6, & 7 (adopted 23-Feb-2014) impacting oil and gas (O&G)
exploration and production (E&P) activities in Colorado.
EPA has promulgated New Source Performance Standards at 40 CFR Part 60, Subpart OOOO (Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution).
West Virginia and Ohio have issued General Air Permits for Natural Gas Production facilities.
This document provides a comparison of the requirements in these air standards. The information highlighted in blue was compiled by CSSD.

Pennsylvania Department of Environmental Protection, Bureau of Air Quality

5/23/2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia
Well Site
Exemption Category No. 381 Performance Standard No. 9 NSPS Subpart OOOO Regulation Nos. 6 & 7: Current  No state-specific REC
requirements in addition
 Requires compliance with NSPS  Beginning on 1/1/14 – direct all  Beginning 10/15/12:  Requires compliance with NSPS  No state-specific REC to NSPS Subpart OOOO
requirements in 40 CFR Part 60, Subpart pipeline-quality gas during completion requirements in 40 CFR Part 60, Subpart requirements in addition to NSPS
OOOO. of development wells and re- o Must capture and direct OOOO. Subpart OOOO.  Compliance with NSPS
completion or workover of any well into flowback emissions to a Subpart OOOO
 Beginning 10/15/12 - No venting allowed a pipeline for sales. completion combustion  If a combustion device is used to control  Flaring required except for gas requirements is required
– must capture and direct flowback device, except in conditions emissions of VOCs and other releases by a properly functioning by General Permit G70-
emissions to a completion combustion  No venting allowed – must be flared in that may result in a fire hydrocarbons, it shall be enclosed. relief device and gas released by A9; (however, permit is
device, except in conditions that may accordance with CSSD Performance hazard or explosion.2 controlled venting for testing, not required to be
result in a fire hazard or explosion. Standard No. 10.  Alternative emissions control equipment blowing down and cleaning out obtained prior to well
 Beginning 1/1/15: shall qualify as air pollution control wells.7 completion activities.)10
 Beginning on 1/1/15 – direct all pipeline-  Acceptable reasons for flaring – low equipment, and may be used if the Division
quality gas during completion of content of flammable gas and safety o REC equipment required approves the equipment, device or Proposed
development wells and re-completion or reasons. for all wells besides those process.
workover of any well into a pipeline for classified as wildcat,  Natural Gas Completion Permit-
sales.  Unacceptable reasons for flaring – i) delineation or low by-Rule8 – requires compliance
lack of pipeline connection except for pressure.3 with NSPS Subpart OOOO.
 Open Flaring is only allowed under the exploratory or extension wells; ii)
following circumstances: inadequate water disposal capacity; iii) o Salable quality gas must be
inadequate or lack of flowback routed to the gas flow line
o used at exploration wells to equipment or operating personnel. “as soon as practicable.”4
determine whether oil and/or
gas exists in geological o Emissions that cannot be
formations or to appraise the directed to the gas flow
physical extent, reserves and must be directed to a
likely production rate of an oil or completion combustion
gas field. device (e.g., flare) with a
continuous ignition source
o Flaring used for repair, except in conditions that
maintenance, emergency or may result in a fire hazard
safety purposes. or explosion.5

o Flaring used for other o General duty to safely
operations at a wellhead or maximize resource
facility to comply with 40 CFR recovery and minimize
releases to the atmosphere
during flowback and
subsequent recovery.6

1 49Pennsylvania’s Air Quality Permit Exemptions Page 1 of 23
2 40 C.F.R. § 60.5375(a)
3 40 C.F.R. § 60.5375(a)
4 40 C.F.R. § 60.5375(a)(2)
5 40 C.F.R. § 60.5375(a)(3)
6 40 C.F.R. § 60.5375(a)(4)
7 Ohio Admin. Code § 1501:9-9-05(B)
8 Ohio’s Draft Natural Gas Completion Draft Permit-by-Rule

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia
Flaring
Part 60, Subpart OOOO

requirements.

 Enclosed combustion device including
enclosed flare must be used for all
permanent flaring operations at a
wellhead or facility. These flaring
operations will be designed and operated
in accordance with the requirements of 40
CFR § 60.18.

Exemption Category No. 38 11 Performance Standard No. 10 NSPS Subpart OOOO Regulation No. 7: Current

 Flaring during completions as allowed by  Raised/elevated flares or engineered  Completion combustion  If a combustion device is used to control  Requires “properly functioning relief  “Temporary” flaring
NSPS Subpart OOOO. combustion device with a reliable devices (e.g. flares) are emissions of VOCs and other device”13 allowed for 30-days
continuous ignition source. required to have a hydrocarbons, it shall be enclosed. before a permit is
Post Completion Requirements: continuous ignition Proposed Natural Gas Completion Permit- required.15
 98% destruction efficiency. source.12  Have no visible emissions during normal by-Rule14
 Enclosed flare (Raised/elevated flares or operations o 20% opacity
engineered combustion device) must be  Development well: flaring no more than  Emissions limitations for completion limitation and
used for permanent installations. 14-days (for life of well).  Be designed so than that an observer can operations: PM emissions
determine whether it is operating properly. limit set
 All permanent enclosed flaring operations  Exploratory/Extension wells: Flaring no o 34 tons/yr VOCs. according to a
must be designed and operated in more than 30-days (for life of well).  Auto-igniters: All combustion devices used o 1.7 tons/yr NOx. formula16
accordance with 40 CFR § 60.18. to control emissions of hydrocarbons must o 9.3 tons/yr CO.
 No visible emissions from flares except be equipped with and operate an auto- o 0.82 tons/yr HAP.  General Permit G70A:
20% opacity limitation

9 WVDEP General Permit G70-A, Section 5.1 Page 2 of 23
10 WVDEP Response to Public Comment #33 on General Permit G70-A
11Pennsylvania’s Air Quality Permit Exemptions
12 40 C.F.R § 60.5375(a)(3)
13 Ohio Admin. Code § 1501:9-9-05(B)
14 Ohio’s Proposed Natural Gas Completion Permit-by-Rule
15 W. Va. Code R. § 45-6-6.1a
16 W. Va. Code R. § 45-6-4.1, 4.3

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

 Open Flaring is only allowed under the for periods not to exceed a total of five igniter as follows: GP-12.119 and PM emissions limit
following circumstances: set according to a
minutes during any two consecutive o All combustion devices installed Enclosed or Open Flare(s)/Combustion formula.17
o Flaring used at exploration wells on or after May 1, 2014, must be Device(s) with a maximum combined
to determine whether oil and/or hours. equipped with an operational capacity heat input of no more than 250  However, permit is not
gas exists in geological auto-igniter upon installation of MMBtu/hr and operated at no more than 10 required to be obtained
formations or to appraise the the combustion device. MMBtu per hour combined heat input from prior to well completion
physical extent, reserves and all the sources vented to the combustion activities.18
likely production rate of an oil or o All combustion devices installed device(s), except during an emergency.
gas field. before May 1, 2014, must be
equipped with an operational o For VOC and where applicable,
o Flaring used for repair, auto-igniter by or before May 1, compliance with the applicable
maintenance, emergency or 2016, or after the next control requirements of 40 CFR
safety purposes. combustion device planned Part 60, Subpart OOOO, by having
shutdown, whichever comes first. a designed minimum control
o Flaring used for other efficiency of 95% for an enclosed
operations at a wellhead or  Alternative emissions control equipment flare/combustor.
facility to comply with 40 CFR shall qualify as air pollution control
Part 60, Subpart OOOO equipment, and may be used if the Division o Carbon monoxide (CO) emissions
requirements. approves the equipment, device or shall not exceed 1.35 tons per
process. month averaged over a 12-month
rolling period.
 Opacity is limited to 20% or greater for an
aggregated 3 min period in any 1 hour, o Nitrogen Oxide (NOx) emissions
but cannot be equal to or greater than shall not exceed 0.25 ton per
60% opacity at any time. month averaged over a 12-month
rolling period.

o Sulfur Dioxide (SO2) emissions
shall not exceed 0.15 ton per
month averaged over a 12-month
rolling period.

GP-12.220

Enclosed or Open Flare(s)/Combustion
Device(s) with a maximum combined
capacity heat input of no more than 250
MMBtu/hr and operated at no more than 32
MMBtu per hour combined heat input from
all the sources vented to the combustion
device(s), except during an emergency.

19 Ohio General Permit 12.1, Condition 4 Page 3 of 23
20 Ohio General Permit 12.2, Condition 4
17 WVDEP General Permit G70-A, Section 5.1.5
18 WVDEP Response to Public Comment #33 on General Permit G70-A

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

o For VOC and where applicable,
compliance with the applicable
control requirements of 40 CFR
Part 60, Subpart OOOO, by having
a designed minimum control
efficiency of 95% for an enclosed
flare/combustor.

Diesel Nonroad  States including Pennsylvania are Performance Standard No. 11  U.S. EPA regulates  States are precluded from establishing any o Carbon monoxide (CO) emissions  States are precluded
Drilling Rig precluded from establishing any emissions from non-road emissions limitations other than those shall not exceed 4.32 tons per from establishing
Engines emissions limitations other than those  Meet EPA Tier 2 standards by March diesel engines according to required by 40 CFR Part 89. month averaged over a 12-month any emissions
required by 40 CFR Part 89. 20, 2013. varying “tiered” levels based rolling period. limitations other than
on the engine’s those required by 40
 Non-road engines are exempt from  25% of owner/operator engine manufacturing date.22 o Nitrogen Oxide (NOx) emissions CFR Part 89.
permitting requirements under Exemption utilization (hp) meeting EPA Tier 4 shall not exceed 0.79 ton per
Category No. 38.21 standards for PM by March 20, 2015.  Starting in 2010, diesel month averaged over a 12-month
produced for use in non- rolling period.
 All non-road engines must comply with  75% of owner/operator engine road engines required to
federal emission standards found in 40 utilization (hp) meeting EPA Tier 4 meet ultra-low sulfur (15 o Sulfur Dioxide (SO2) emissions
CFR Part 89, Subpart B or 40 CFR Part standards for PM by September 24, ppm of sulfur) shall not exceed 0.48 ton per
1039, Subpart B, based upon the engine’s 2015. requirement.23 month averaged over a 12-month
model year. rolling period.
 95% of owner/operator engine
 Only ultra-low sulfur diesel fuel will be utilization meeting EPA Tier 4  States are precluded from
available. standards for PM by September 24, establishing any emissions
2016. limitations other than those
required by 40 CFR Part 89.
 Use ultra-low sulfur diesel (15ppm of

21Pennsylvania’s Air Quality Permit Exemptions Page 4 of 23
22 40 C.F.R. Part 89; 40 C.F.R. Part 1039
23 40 C.F.R. Part 80

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

sulfur) at all times.  States are precluded
from establishing
Diesel Nonroad  States including Pennsylvania are Performance Standard No. 11.1  U.S. EPA regulates  States are precluded from establishing any  States are precluded from any emissions
Fracturing precluded from establishing any emissions from non-road emissions limitations other than those establishing any emissions limitations other than
Pump Engines emissions limitations other than those  Meet EPA Tier 2 standards by diesel engines according to required by 40 CFR Part 89. limitations other than those those required by 40
required by 40 CFR Part 89. March 20, 2014. varying “tiered” levels based required by 40 CFR Part 89. CFR Part 89.
Diesel Heavy- on the engine’s  States are precluded from establishing any
Duty Vehicle  Non-road engines are exempt from  25% of owner/operator engine manufacturing date24 emissions limitations other than those  States are precluded from  States are precluded
Fracturing permitting requirements under Exemption utilization (hp) meeting EPA Tier 4 required by 40 CFR Part 89. establishing any emissions from establishing
Pump Engines Category No. 38. standards for PM by September  Starting in 2010, diesel limitations other than those any emissions
24, 2015/ March 20, 2016. produced for use in non- required by 40 CFR Part 89. limitations other than
 All non-road engines must comply with road engines required to those required by 40
federal emission standards found in 40  75% of owner/operator engine meet ultra-low sulfur (15 CFR Part 89.
CFR Part 89, Subpart B or 40 CFR Part utilization (hp) meeting EPA Tier 4 ppm of sulfur)
1039, Subpart B based upon the engine’s standards for PM by September requirement.25
model year. 24, 2016.
 U.S. EPA regulates engine
 Only ultra-low sulfur diesel fuel will be  95% of owner/operator engine emissions from highway
available. utilization meeting EPA Tier 4 heavy-duty vehicles based
standards for PM by September on the vehicle’s model year.
24, 2017.
 Starting in 2006, highway
 Use ultra-low sulfur diesel (15ppm diesel fuel required to meet
of sulfur) at all times. ultra-low sulfur (15 ppm of
sulfur) requirement.
 States including Pennsylvania are Performance Standard No. 11.2
precluded from establishing any
emissions limitations other than those  50% of engines meeting EPA 2007
required by 40 CFR Part 86. and Later Model Year Highway Heavy-
Duty Vehicles and Engines emissions
 Heavy duty vehicle engines are exempt standards for PM by September24,
from permitting requirements under 2017.
Exemption Category No. 38.
 80% of engines meeting EPA 2007
 All Heavy Duty vehicle engines must and Later Model Year Highway Heavy-
comply with federal emission standards Duty Vehicles and Engines emissions
found in 40 CFR Part 86. standards for PM by September 24,
2014.
 Only ultra-low sulfur diesel fuel will be
available.  Use ultra-low sulfur diesel (15ppm of
sulfur) at all times.

24 40 C.F.R. Part 89; 40 C.F.R. Part 1039 Page 5 of 23
25 40 C.F.R. Part 80

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia
Existing
Compressor Previous Exemption Category No. 38 Performance Standard No. 12 NSPS Subpart JJJJ (Standards of Existing Natural Gas Fired Reciprocating Internal Natural Gas Compressor
Engines Performance for Stationary Spark Combustion Engines: Station General Permit
 Existing compressor engines (those  By March 20, 2014 – 1.5 g/hphr NOx Ignition Internal Combustion Engines) Number G33-A29
installed prior to August 10, 2013) – emission limitation for existing Rich Burn Reciprocating Internal Combustion Engines over 100 HP -
exempt from any permitting or emission compressor engines greater than 100  Applies to constructed, Engines: compliance with NSPS
limitation requirements if less than 100 hp. reconstructed, and modified Subpart JJJJ.
hp. engines after June 12,  Rich Burn Engines greater than 500
o CO – None 2006.26 horsepower, constructed or modified Page 6 of 23
Previous GP-5 before February 1, 2009 - shall install
o VOC – None  Emissions limitations for NSCR and an air fuel controller by July 1,
 Prior to February 2013 - existing engines manufactured 2010.
compressor engines greater than or equal between 2007/2008 and
to 100 hp and less than 1500 hp were 2010/2011 greater than 100  Any rich burn reciprocating internal
subject to the previous GP-5 emissions hp:27 combustion engine constructed or modified
limitations: o 2.0 g/hp-hr for before February 1, 2009, for which the
NOx. owner or operator demonstrates to the
o 2.0 g/hp-hr NOx. Division that retrofit technology cannot be
o 4.0 g/hp-hr for installed at a cost of less than $ 5,000 per
o 2.0 g/hp-hr CO. CO. ton of combined volatile organic compound
and nitrogen oxides emission reductions
o 2.0 g/hp-hr VOCs. o 1.0 g/hp-hr for (this value shall be adjusted for future
VOCs. applications according to the current day
 Emission test results indicate that the consumer price index) is exempt complying
existing compressor engines authorized under  Compressor engines are with Section XVII.E.3.a.
the previous GP-5 are generally meeting the also subject to the National
CCSD performance standard of 1.5 g/bhp-hr Emission Standards for Lean Burn Reciprocating Internal Combustion
of NOx. Hazardous Air Pollutants Engines:
(NESHAP) for Stationary
Reciprocating Internal  All lean burn reciprocating internal
Combustion Engines (RICE) combustion engines rated greater than 500
at 40 C.F.R. 63, Subpart horsepower - install and operate an
ZZZZ (i.e., the “RICE oxidation catalyst by July 1, 2010.
MACT”)28

 Any lean burn reciprocating internal
combustion engine constructed or modified
before February 1, 2009, for which the
owner or operator demonstrates to the
Division that retrofit technology cannot be
installed at a cost of less than $ 5,000 per
ton of volatile organic compound emission
reduction (this value shall be adjusted for
future applications according to the current

26 40 C.F.R. § 60.4230
27 40 C.F.R. Part 60, Subpart JJJJ, Table 1
28 40 C.F.R. Part 63, Subpart ZZZZ
29 WVDEP General Permit G33-A, Section 6.0

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

“New” Lean- day consumer price index) is exempt from
Burn
Compressor complying with the requirement to install an
Engines
oxidation catalyst.

Exemption Category No. 38 (Compressor Engines Performance Standard No. 12.1 NSPS Subpart JJJJ (Standards of  No emission standards for engines rated Oil and Gas Well-Site Production Natural Gas Production
at the Wellpad)30 Performance for Stationary Spark less than 100 HP Operations, General Permit 12 Facility Class II General
 Emissions limitations for new, Ignition Internal Combustion Engines) Permit G70-A
 Lean-Burn compressor engines at the purchased, replacement,  Engines must comply with NSPS
wellpad (those installed on or after August reconstructed, or relocated lean-burn  Emissions limitations for engines Regulation No. 7: Subpart JJJJ standards. Requires compliance with
10, 2013) are exempt from permitting engines greater than 100 hp: manufactured on or after NSPS Subpart JJJJ.33
requirements provided that: 2010/2011 greater than 100 hp  Specific emissions limitations:
o NOx emissions from stationary o 0.5 g/hp-hr NOx. engine models (depending on  Actual emissions from natural gas fired
internal combustion engines at o 2.0 g/hp-hr CO. engine size)31: o 20% opacity, 6-min average.
the wells, and wellheads are o 0.7 g/hp-hr VOCs. reciprocating internal combustion engines
less than 100 lbs/hr, 1000 o Formaldehyde – None o 1.0 g/hp-hr for NOx. o Particulate Emissions (PE):
lbs/day, 2.75 tons per ozone o HAPS – No facility wide limit shall not exceed the emission performance
season (May 1 to September o 2.0 g/hp-hr for CO. 0.310 lb/MMBtu for engines ≤ 600
30); and 6.6. tons per year on a standards in table below as expressed in hp.
12-month rolling basis. o 0.7 g/hp-hr for VOCs.
units of grams per horsepower-hour (g/hp- 0.062 lb/MMBtu for engines > 600
Compressor engines are also subject hp.
to the National Emission Standards for hr)
Hazardous Air Pollutants (NESHAP) o 2.6 tons of SO2/year.
for Stationary Reciprocating Internal Maximum Construction
Combustion Engines (RICE) at 40  Total combined engine power less than
C.F.R. 63, Subpart ZZZZ (i.e., the Engine or Emission or equal to 1,300 hp:
“RICE MACT”)32
HP Relocation Standards is g/hp- o 2.0 g/hp-hr NOx or 160 ppmvd at
15% O2 for engines ≥ 100 hp.
o VOC emissions from facility is Date hr
less than 2.7 tpy, VOC from o 4.0 g/hp-hr CO or 540 ppmvd at
facility is exempted. If the NOx CO VOC 15% O2 for engines ≥ 100 hp.
VOCs include HAPs, the HAP
exemption criteria in this < 100 HP Any NA NA NA o 1.0 g/hp-hr VOCs or 86 ppmvd at
paragraph will be met. 15% O2 for engines ≥ 100 hp.
Combined HAP emissions at ≥100 HP On or after 2.0 4.0 1.0
the facility less than 1000 lbs of  Total combined engine power greater
a single HAP or one ton of a and < January 1, than 1,300 hp:
combination of HAPs in any
consecutive 12-month period. 500 HP 2008

≥500 Hp On or after 1.0 2.0 0.7
January 1,
o If the exemption criteria cannot 2011 2.0 4.0 1.0
be met, then a case-by-case On or after July 1.0 2.0 0.7
plan approval is required. 1, 2007
On or after July
1, 2010

o Formaldehyde – None

GP-5 (Compressor Engines at Natural Gas o 1.0 g/hp-hr NOx /or 82 ppmvd at
Compression and/or Processing Facilities) (Feb. 15% O2 for engines ≥ 100 hp.
2013)
o 2.0 g/hp-hr CO/or 270 ppmvd at
 The facility emissions are limited to non- 15% O2 for engines ≥ 100 hp.
major emission thresholds. (Synthetic
Minor)

30 Pennsylvania’s Air Quality Permit Exemptions Page 7 of 23
31 40 C.F.R. Part 60, Subpart JJJJ, Table 1
32 40 C.F.R. Part 63, Subpart ZZZZ
33 WVDEP General Permit G70-A, Section 13

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

“New” Rich-  Natural gas fired lean burn less than 100 o 0.7 g/hp-hr VOCs or 60 ppmvd at
Burn hp
Compressor o 2.0 g/hp-hr for NOx. 15% O2 for engines ≥ 100 hp.
Engines o 2.0 g/hp-hr for CO.

 Natural gas lean burn greater than 100 hp
and less than or equal to 500 hp
o 1.0 g/hp-hr for NOx.
o 2.0 g/hp-hr for CO.
o 0.7 g/hp-hr for non-
methane/non-ethane
hydrocarbons (except
formaldehyde).

 Natural gas lean burn greater than 500 hp
o 0.5 g/hp-hr for NOx.
o 93% reduction for CO or
47ppm@15% oxygen.
o 0.25 g/hp-hr for non-methane/non-
ethane hydrocarbons (except
formaldehyde).
o 0.05 g/hp-hr for formaldehyde.

Exemption Category No. 38 (Compressor Engines Performance Standard No. 12.2 NSPS Subpart JJJJ (Standards of Regulation No. 7: Oil and Gas Well-Site Production Natural Gas Production
at the Wellpad)34 Performance for Stationary Spark Operations, General Permit 12 Facility Class II General
 Emissions limitations for new, Ignition Internal Combustion Engines)  Actual emissions from natural gas fired Permit G70-A
 Rich Burn compressor engines at the purchased, replacement, reciprocating internal combustion engines Engines must comply with NSPS Subpart
wellpad (those installed on or after August reconstructed, or relocated rich-burn  Emissions limitations for engines shall not exceed the emission performance JJJJ standards.37 Compliance with NSPS
10, 2013) exempt from permitting where: engines greater than 100 hp: manufactured on or after 2010/2011 standards in table below as expressed in Subpart JJJJ.40
greater than 100 hp engine models units of grams per horsepower-hour (g/hp-  Specific emissions limitations:38
o NOX emissions from stationary o 0.3 g/hp-hr NOx. (depending on engine size):35 hr)
internal combustion engines at o 2.0 g/hp-hr CO. o 20% opacity, 6-min average.
the wells, and wellheads are o 0.7 g/hp-hr VOCSs. o 1.0 g/hp-hr for NOx. Maximum Construction Emission
less than 100 lbs/hr, 1000 o Formaldehyde - None Engine or Standards is g/hp- o Particulate Emissions (PE):
lbs/day, 2.75 tons per ozone o 2.0 g/hp-hr for CO. HP Relocation hr
season (May 1 to September Date NOx CO VOC  0.310 lb/MMBtu for engines ≤ 600
30); and 6.6 tons per year on a o 0.7 g/hp-hr for VOCs. NA NA NA hp.
12-month rolling basis. < 100 HP Any 2.0 4.0 1.0
Compressor engines are also subject ≥100 HP On or after  0.062 lb/MMBtu for engines > 600
o VOC emissions less than 2.7 to the National Emission Standards and < January 1, hp.
tpy, VOCs from facility are for Hazardous Air Pollutants 500 HP 2008
exempted. If the VOCs include (NESHAP) for Stationary o 2.6 tons of SO2/year.
HAPs, the HAP exemption Reciprocating Internal Combustion
criteria in this paragraph will be Engines (RICE) at 40 C.F.R. 63, o Total engine power less than or equal
Subpart ZZZZ (i.e., the “RICE to 1,300 hp:

34 Pennsylvania’s Air Quality Permit Exemptions Page 8 of 23
35 40 C.F.R. Part 60, Subpart JJJJ, Table 1

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

met. Combined HAP emissions MACT”)36 On or after 1.0 2.0 0.7  2.0 g/hp-hr NOx or 160 ppmvd at
at the facility less than 1000 lbs January 1,
of a single HAP or one ton of a 2011 2.0 4.0 1.0 15% O2 for engines ≥ 100 hp.
combination of HAPs in any 1.0 2.0 0.7
consecutive 12-month period. ≥500 Hp On or after July  4.0 g/hp-hr CO or 540 ppmvd at
1, 2007 15% O2 for engines ≥ 100 hp.

o If the exemption criteria cannot On or after July  1.0 g/hp-hr VOCs or 86 ppmvd at
be met, then a case-by-case 1, 2010 15% O2 for engines ≥ 100 hp.
plan approval is required.
o Total engine power greater than 1,300
o Formaldehyde - None hp:39

Coverage under GP-5 (Rich-Burn Compressor  1.0 g/hp-hr NOx /or 82 ppmvd at
Engines at Natural Gas Compression and/or 15% O2 for engines ≥ 100 hp.
Processing Facilities) (Feb. 2013)

 The facility emissions are limited to non-  2.0 g/hp-hr CO/or 270 ppmvd at
major emission thresholds. (Synthetic 15% O2 for engines ≥ 100 hp.
Minor)
 0.7 g/hp-hr VOCs or 60 ppmvd at
 Natural gas fired rich burn engines less 15% O2 for engines ≥ 100 hp.
than or equal to 100 hp:

 2.0 g/hp-hr NOx.
 2.0 g/hp-hr CO.

 Natural gas rich burn engines greater
than 100 hp and less than or equal to 500
hp:

 0.25 g/hp-hr NOx.
 0.30 g/hp-hr CO;
 0.2 g/hp-hr for non-methane/non-ethane

hydrocarbons (except formaldehyde).

 Natural gas rich burn engines greater
than 500 hp:

 0.20 g/hp-hr NOx.
 0.30 g/hp-hr CO.
 0.20 g/hp-hr for non-methane/non-ethane

hydrocarbons (except formaldehyde).
 76% reduction for formaldehyde or 2.7

ppmvd @ 15% oxygen

37 Ohio GP-12, at pp. 12-14
38 Ohio GP-12, at pp. 12-14

40 WVDEP General Permit G70-A, Section 13
36 40 C.F.R. Part 63, Subpart ZZZZ
39 The total combined total engine horsepower must also be no more than 1,800 hp for the site in order to qualify for Ohio’s GP-12. See Ohio GP-12, at pp. 12. Additionally, where the total combined engine power exceeds 1,300 hp the engines must have a manufacturing date of no earlier than January 1,

2011 for engines less than 500 HP or no earlier than July 1, 2010 for engines 500 hp or greater. Id.

Issued: May 23, 2014 Page 9 of 23

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia
Storage Vessels
Exemption Category No. 3841: Performance Standard No. 13 NSPS Subpart OOOO Regulation No. 7: Oil and Gas Well-Site Production Natural Gas Production
Operations, General Permit 12 Facility Class II General
 Storage vessels/storage tanks at the well  By October 15, 2013 – all existing or  “New” Group 1 storage vessels  Construction permits are now required for Permit G70-A
pad are exempt from permit requirements new individual storage vessels at the (constructed, modified, or all crude oil storage tanks (previously,  Total VOC emissions from all tanks
if they are equipped with VOC emission wellpad with VOC emissions equal to reconstructed after August 23, 2011 tanks with capacity < 40,000 gallons were combined at the site (including breathing  Requires compliance with
controls achieving emission reduction of and before April 12, 2013) that have exempt) losses, tank working losses, flash losses NSPS Subpart OOOO49
95% or greater. or greater than 6 tpy must install potential VOC emissions equal to or and truck loading losses) may not exceed
controls to achieve at least a 95% greater than 6 tons per year (tpy) -  Operating permits are now required for all 51.3 tons per rolling 12-month period.48
 Storage tanks at the well pad can qualify at least a 95% reduction in VOC crude oil storage tanks (previously, tanks
for the exemption if combined VOC reduction in VOC emissions. emissions by April 15, 2015.42 with capacity < 40,000 gallons were
emissions from all the sources at the exempt)
facility are less than 2.7 tons on a 12-  “New” Group 2 storage vessels
month rolling basis. Combined HAP (constructed, modified, or  For tanks projected to have > 1.5 tons
emissions at the facility must be less than reconstructed after April 12, 2013) VOC emissions in first 90 days of operation
1000 lbs of a single HAP or one ton of a that have potential VOC emissions
combination of HAPs in any consecutive equal to or greater than 6 tons per o Emissions controls must be
12-month period in order to qualify for the year (tpy) - at least a 95% reduction installed at date of first operation
exemption. If the VOCs emissions in VOC emissions by April 15, 2014 and must have 95% (98% if
include HAPs, this HAP exemption criteria or within 60-days of startup combustion device used)
is met. (whichever is later).43 efficiency

 No de minimis emission threshold per  6 tpy VOC determination may take o Controls can be removed after
tank as allowed in NSPS Subpart OOOO into account enforceable limits in an 90 days if VOC emissions are
(i.e., must reduce storage tank/storage operating permit or other projected to be <6 tons per year
vessel VOC emissions by 95% if requirement established under a
combined VOC emissions from storage Federal, State, local or tribal  Storage tank controls after 90 days:
vessels/storage tanks are above 2.7 tpy in authority.44
order to qualify for exemption).
 Emissions from a storage vessel  For tanks with VOC emissions less than 20
 Compliance with above criteria ensures that are recovered and routed to a TPY and equal to or greater than 6 TPY –
compliance with NSPS Subpart OOOO. process through a vapor recovery 95% control efficiency (98% if a
unit (VRU) can be excluded from combustion device is used).
GP-5 the 6 tpy VOC determination
provided certain requirements are  For tanks with VOC emissions greater than
met.45 20 TPY – 95% control efficiency.

 The owner or operator of each storage  Control devices (installed to achieve  AVO inspections of tanks and associated
vessel / storage tank shall also comply the 95% reduction in VOC equipment as frequent as every 7 days and
with the applicable requirements specified emissions discussed above) may be at least every 31 days.
in 40 CFR Part 60, Subparts Kb and removed if emissions from the
OOOO and 40 CFR Part 63, Subpart HH storage vessel have been below 4
(relating to national emission standards tpy on an uncontrolled basis for 12

41 Pennsylvania’s Air Quality Permit Exemptions Page 10 of 23
42 40 C.F.R. § 60.5395(b)
43 40 C.F.R. § 60.5395(c)
44 40 C.F.R. § 60.5365(e)
45 40 C.F.R. § 60.5365(e)

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

for hazardous Air pollutants from oil and consecutive months.46  Storage Tank Emission Management
(STEM) plan and inspections for tanks with
natural gas production facilities).  Control device must be reinstalled: non-stabilized liquids as follows:
(1) if a well feeding the storage
 In accordance with 25 Pa. Code §§ 127.1 vessel undergoes fracturing or Uncontrolled AIMM (Approved
and 127.12(a)(5), the owner or operator of refracturing; or (2) the monthly VOC Emissions Instrument Monitoring
each storage tank with a capacity greater emissions from the uncontrolled (tpy) Method)
than 40,000 gallons shall also comply with storage vessel increase to 4 tpy or Inspection
the requirements specified in 25 Pa. Code greater.47 >6 and <12 Frequency
§ 129.56. These storage tanks shall be >12 and <50 Annually
equipped with of the following vapor loss > 50 Quarterly
control devices: Monthly

o An external or internal floating
roof

o A vapor recovery system

 In accordance with 25 Pa. Code §§ 127.1
and 127.12(a) (5), the owner or operator
of each storage tank with a capacity less
than or equal to 40,000 gallons shall also
comply with the requirements in 25 Pa.
Code § 129.57.

 These storage tanks shall be equipped
with pressure relief valves.

Reciprocating GP-5/ NSPS Subpart OOOO Performance Standard No. 14.1 NSPS Subpart OOOO Regulation 6:
Compressors
 Federal Register regulations adopted by  No state-specific requirements.  No state-specific
 “New reciprocating compressors (those  Change rod packing at all reciprocating  “New” reciprocating compressors reference: Subpart OOOO, Standards of requirements.
Performance for Crude Oil and Natural
installed after August 23, 2011) – change compressors (both existing and new), (those installed after August 23, Gas Production, Transmission and Page 11 of 23
Distribution (40 CFR Part 60, Subpart
rod packing either every 26,000 hours of including those at the wellhead, either every 2011) – change rod packing either OOOOO, 01-Jul-2012 as amended by 78
Fed. Reg. 58416 on 23-Sep-2013).
operation or every 36 months as well as 26,000 hours of operation or after 36 every 26,000 hours of operation or
 NSPS OOOO applies to NG wells, storage
new reciprocating compressors. 50 months. every 36 months as well as new

reciprocating compressors.52

 Reciprocating compressors located at a  Reciprocating compressors located
well site or an adjacent well site and at a well site or an adjacent well site

48 Ohio GP-12, at p. 41
49 WVDEP General Permit G70-A, Section 12.1
46 40 C.F.R. § 60.5395(d)(2)
47 40 C.F.R. § 60.5395(d)(2)
50 40 C.F.R. §60.5385(a)

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

Pneumatic servicing more than one well site are and servicing more than one well vessels, centrifugal compressors with wet
Controllers seals, reciprocating compressors,
excluded from this requirement. 51 site are excluded from this pneumatic controllers, leaks and leaking
components at gas plants, sweetening
requirement.53 units, and NG well green completion
provisions.

 Affects all facilities regardless of emissions
levels.

GP-5/ NSPS Subpart OOOO Performance Standard No. 14.2 NSPS Subpart OOOO Regulation No. 7: Natural Gas Production
Facility Class II General
 “New” pneumatic controllers (those  By October 15, 2013, pneumatic  “New” pneumatic controllers  Controllers placed in service on or after 01-  No state-specific requirements. Permit G70-A
constructed (installed), modified or controllers (both existing and new): (those constructed May-2014 must
reconstructed on or after October 15, (installed), modified or  Proposed revisions to Ohio’s Oil and Gas  Requires
2013) located between the wellhead and o Low – bleed, with a natural reconstructed on or after compliance with
a natural gas processing plant: bleed rate gas bleed rate limit of 6.0 October 15, 2013) located o Emit in an amount less than or Well-Site Production Operations, General NSPS Subpart
of 6.0 scfh or less.54 scfh or less. between the wellhead and a equal to a low-bleed controller. Permit 12 require compliance with Subpart OOOO requirements
natural gas processing OOOO requirements for pneumatic for pneumatic
 Exception to 6.0 scfh bleed rate – where o Zero bleed when electricity plant: bleed rate of 6.0 scfh controllers.58
use of a greater bleed rate is required (3-phase electrical power) is or less.56 o Utilize no-bleed controller where controllers.
based on functional needs, including on-site.
response time, safety and positive on-site electrical grid power is
actuation. 55
accessible.
 The owner or operator of pneumatic
controllers shall also comply with the  Exception to 6.0 scfh bleed  High-bleed controllers in service prior to
applicable requirements specified in 40 rate – where use of a 01-May-2014 must be replaced or
CFR Part 60, Subpart OOOO. greater bleed rate is retrofitted such that emissions are less
required based on functional than or equal to a low-bleed controller.
needs, including response
time, safety and positive  All high-bleed controllers that must remain
actuation.57 in service must obtain State approval.

 Beginning 01-May-2015
o High-bleed controllers must be
tagged, and
o Must be inspected monthly with
attendant maintenance to
minimize emissions

52 40 C.F.R. § 60.5385(a) Page 12 of 23
51 40 C.F.R. §60.5365(c)
53 40 C.F.R. § 60.5365(c)
54 40 C.F.R. §60.5390(c)(1)
55 40 C.F.R. § 60.5390(a)

56 40 C.F.R. § 60.5390(c)(1)
57 40 C.F.R. § 60.5390(a)
58 WVDEP General Permit G70-A, Section 8

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

Centrifugal GP-5 -Natural Gas Compression and/or Processing Performance Standard No. 14.3 NSPS Subpart OOOO Regulation 6:  No state-specific requirements.  No state-specific
Compressors Facilities requirements.
 New centrifugal compressors may not  For centrifugal compressors  NSPS OOOO applies to NG wells, storage
LDAR  Compliance with NSPS Subpart OOOO vessels, centrifugal compressors with wet
requirements for centrifugal contain wet oil seals. installed after August 23, 2011 - seals, reciprocating compressors,
compressors.59 pneumatic controllers, leaks and leaking
must reduce VOC emissions from components at gas plants, sweetening
o Reduce VOC emissions from units, and NG well green completion
each centrifugal compressor  Replace worn out wet seals on existing each centrifugal compressor wet provisions.
wet seal fluid degassing system
by 95.0 percent or greater. centrifugal compressors with dry seals. seal fluid degassing system by 95 %

 If a control device is used to reduce or greater.60
emissions, you must equip the wet seal
fluid degassing system with a cover that o If a control device is used to
meets the requirements of §60.5411(b), reduce emissions, must equip
that is connected through a closed vent the wet seal fluid degassing
system that meets the requirements of system with a cover that
§60.5411(a) and routed to a control meets the requirements of 40
device that meets the conditions specified CFR §60.5411(b), that is
in §60.5412(a), (b) and (c). As an connected through a closed
alternative to routing the closed vent vent system that meets the
system to a control device, you may route requirements of 40 CFR
the closed vent system to a process. §60.5411(a) and routed to a
control device that meets the
conditions specified in 40
CFR §60.5412(a), (b) and (c).
As an alternative to routing
the closed vent system to a
control device, may route the
closed vent system to a
process.

 Not applicable to centrifugal
compressors located at a well site
or at an adjacent well site and
servicing more than one well site.61

Exemption Category No. 3862 Performance Standard No. 14.4 NSPS Subpart OOOO Well Production Facilities: Oil and Gas Well-Site Production G70-A
Operations, General Permit 12.1 & 12.2
 Perform a leak detection and repair  By March 20, 2014 – implement a  Cover and closed vent inspections  AIMM (Approved Instrument Monitoring  Compliance with NSPS
(LDAR) program within 60 days after the Method) inspection must be initiated 15 to  Leaks shall be detected by the use Subpart OOOO
well is put into production and annually directed inspection and maintenance for “new” storage vessels with 30 days after unit commences operation of either a “Forward Looking Infra inspection requirements
thereafter. for units constructed on or after 15-Oct- Red” (FLIR) camera or an analyzer for storage vessels.65
o Use of optical gas imaging program (DI&M) for equipment leaks potential to emit VOC emissions 2014 meeting U.S. EPA Method 2164.

from all existing and new valves, pump equal to or greater than 6 tpy.63

seals, flanges, compressor seals, o Monthly olfactory, visual and

59 Pennsylvania’s GP-5 -Natural Gas Compression and/or Processing Facilities, Section D Page 13 of 23
60 40 C.F.R. § 60.5380(a)
61 40 C.F.R. § 60.5365(b)
62 Pennsylvania’s Air Quality Permit Exemptions
63 40 C.F.R. § 60.5416(c)
64 Ohio GP-12.1 & 12.2

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

camera (such as FLIR) or gas pressure relief valves, open-ended auditory inspections for defects  AIMM inspection must be initiated by the  2Initial monitoring within 90 days
leak detector. lines, tanks and other process and that could result in air phase-in schedule for units constructed of startup and quarterly thereafter
operation components that result in emissions. before 15-Oct-2014 for a period of four consecutive
o Conduct on valves, flanges, fugitive emissions. quarters (1 year).
connectors, storage o If leak detected:  AIMM inspections will continue as follows
vessels/storage tanks, and o Monitored by a weekly based on uncontrolled VOC emissions  If following the initial four
compressor seals. visual, auditory, and olfactory  Within 5 days – make first from the highest emitting storage tank or consecutive quarters, less than or
check. repair attempt. controlled VOC emissions from all equal to 2.0% of the ancillary
o If leak is discovered – repair permanent equipment: equipment are determined to be
within in 15 days unless facility o Yearly mechanical or  Complete repair within 30 leaking during the most recent
shutdown is required or instrument check to detect days. Well Production Facilities without Storage Tanks: quarterly monitoring event, then
ordering replacement parts are leaks. the frequency of monitoring can be
necessary for the repair.  Apply grease to Well AIMM AVO reduced to semi-annual.
o Repair detected significant deteriorating or cracked Production Inspection Inspection
 Upon written request documenting leaks in a timely manner. gaskets to improve the seal Facilities Frequency Frequency  If following two consecutive semi-
justification – DEP may grant extension while awaiting repair. WITHOUT annual periods, less than 2.0% of
for leak detection deadlines or repairs. o No leak repair quantification Storage Tanks One time Monthly the ancillary equipment are
Delay permissible if repair requires (tpy) Annually Monthly determined to be leaking during
 A leak is considered repaired if one of the o No FLIR or gas detector shutdown or if emissions during repair 0<x<6 Quarterly Monthly the most recent semi-annual
following can be demonstrated: would be greater than delay of repair 6 < x < 12 Monthly Monthly monitoring event, then the
until shutdown. 12 < x < 20 frequency of the monitoring can be
o No detectable emissions x > 20 reduced to annual.
consistent with EPA Method 21
specified in 40 CFR Part 60, Well Production Facilities with Storage Tanks:  If more than or equal to 2.0% of
Appendix A the ancillary equipment are
Well AIMM AVO determined to be leaking during
o A concentration of 2.5% Production Inspection Inspection any one of the semi-annual or
methane or less using a gas Facilities Frequency Frequency annual monitoring events, then the
leak detector and a VOC WITH frequency of monitoring shall be
concentration of 500 ppm or Storage Tanks One time Monthly returned to quarterly.
less (tpy) Annually Monthly
0<x<6 Quarterly Monthly  The program shall require the first
o No visible leak image when 6 < x < 12 Monthly Monthly attempt at repair within five (5)
using an optical gas imaging 12 < x < 50 calendar days of determining a
camera x > 50 leak.

o No bubbling at leak interface Natural Gas Compressor Stations:  The program shall require that the
using a soap solution bubble leaking component is repaired
test specified in EPA Method 21  AIMM inspections schedule for units within 30 calendar days after the
constructed on or after 01-Jan-2015 leak is detected.
o Any other method approved in o With fugitive VOC emissions <
writing by the Department 50 tons, must begin < 90 days  Leaks shall be measured by
o With fugitive VOC emissions > utilizing U.S. EPA Method 21 (40
CFR Part 60, Appendix A). All

potential leak interfaces shall be

traversed as close to the interface

65 WVDEP General Permit G70-A, Section 12 Page 14 of 23

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

GP-5 LDAR Program 50 tons, must begin < 30 days as possible. The arithmetic
difference between the maximum
 At a minimum, on a monthly basis  AIMM inspections will continue as follows: concentration indicated by the
perform a leak detection and repair instrument and the background
program that includes audible, visual, and Fugitive VOC Inspection Frequency level is compared with 500 ppm or
olfactory (“AVO”) inspections. 10,000 ppm (as applicable) for
Emissions (tpy) determining compliance.

>0 and < 12 Annually

 Within 180 days after initial startup and at > 12 and < 50 Quarterly  A component is considered to be
a minimum on a quarterly basis, use leaking if the instrument reading is
forward looking infrared (“FLIR”) cameras > 50 Monthly
or other leak detection monitoring devices equal to or greater than 500 ppm
approved by the Department for the or 10,000 ppm depending on the
detection of fugitive leaks. The
Department may grant an extension for component.
the use of FLIR camera upon receiving a
written request that documents the Repairing Leaks:
justification.
 Quantitative AIMM (EPA Method 21 or
 Repair detected leaks as soon as other Division approved method)
possible but no later than 15 days after
the leak is detected. o Units constructed on or after 01-
May-2014, a leak is anything >
 Records must be kept for a period of 5 500 ppm
years.
o Units constructed before 01-May-
 Operators are required to submit annual 2014, a leak is anything > 2,000
reports to the DEP. ppm

 For infra-red camera or AVO, a leak is any
detectable emission not associated with
normal operation.

 Leaks must be repaired within

o 5 days after discovery unless
parts are unavailable, equipment
requires shutdown, or other good
cause

o 15 days if parts need to be
ordered

o If shutdown required, leak must
be repaired at next scheduled
shutdown

o If other good cause, leak must be
repaired within 15 days good

Issued: May 23, 2014 Page 15 of 23

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

cause ceases

o Equipment must be re-monitored
within 15 days of repair

o Records must be kept for a
period of 2 years

o Operators are required to submit
annual reports to the State.

Well-bore freeze- Performance Standard No. 14.5

up emissions  Facility VOC emissions exceeding 2.7 tpy may  Eliminate VOC emissions associated with  None.  None.  None.
 None.  None.
require Plan Approval (case-by-case BAT). the prevention of well-bore freeze-up (only
de minimis emissions are permitted).

Blowdown Performance Standard No. 14.6
emissions
 Facility VOC emissions exceeding 2.7 tpy may  Existing and new compressors are required  None.
require Plan Approval (case-by-case BAT). to be pressurized when they are off-line for

operational reasons in order to reduce

blowdown emissions.

Truck Emission Performance Standard No. 15.1 and 15.2
Requirements
 States including Pennsylvania are precluded  U.S. EPA regulates engine  States including Pennsylvania are precluded  States including Pennsylvania are  States including
from establishing any emissions limitations  By March 20, 2014 -80% of all trucks emissions from highway from establishing any emissions limitations precluded from establishing any Pennsylvania are
other than those required by 40 CFR Part 86. used to transport fresh water or well heavy-duty vehicles based other than those required by 40 CFR Part 86. emissions limitations other than those precluded from
flowback water must meet U.S. EPA’s on the vehicle’s model required by 40 CFR Part 86. establishing any
 Heavy duty vehicle engines are exempt from Final Emission Standards for 2007 and emissions limitations
permitting requirements under Exemption Later Model Year Highway Heavy-Duty year.66 other than those required
Category No. 38. Vehicles and Engines for particulate by 40 CFR Part 86.
matter (PM) emissions.

 All non-road engines must comply with federal  By September 24, 2015 -95% of all
emission standards found in 40 CFR Part 86. trucks used to transport fresh water or
well flowback water must meet U.S.
 Only ultra-low sulfur diesel fuel will be EPA’s Final Emission Standards for
available. 2007 and Later Model Year Highway
Heavy-Duty Vehicles and Engines for
particulate matter (PM) emissions.

66 40 C.F.R. Part 86 Page 16 of 23

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

Truck Load-out Exemption Category No. 3867 Regulation No. 3: Natural Gas Production
Emissions Facility Class II General
 Exemption Category No. 38 requires  The following sources are exempt because by Permit G70-A
compliance with 95% VOC reduction  None themselves, or cumulatively as a category, they
requirements of other equipment such as are deemed to have a negligible impact on air Regulated Pollutant Limitation.
tanker truck load-outs, consistent with § quality: The registrant shall not cause,
60.5413 or alternate test methods as suffer, allow or permit
approved by the Department. o Crude oil truck loading equipment at emissions from any registered
exploration and production sites Tank Truck Loading Facility of
where the loading rate does not any regulated pollutant listed
exceed 10,000 gallons of crude oil per in the General Permit
day averaged on an annual basis. Registration to exceed the
potential to emit (pounds per
 Condensate truck loading equipment at hour and tons per year)
exploration and production sites that splash fill recorded with the registrant‘s
less than 6750 barrels of condensate per year General Permit Registration
or that submerge fill less than 16308 barrels of without effecting a modification
condensate per year. or administrative update.
To demonstrate compliance
with the tank truck loading
emissions in section 11.1.1,
the registrant shall not exceed
the maximum throughput limit
that was recorded with
registrant‘s General Permit
Registration without effecting a
modification or administrative
update. Compliance with the
Maximum Annual Throughput
Limitation shall be determined
using a twelve month rolling
total.

Glycol GP-5  None  The owner or operator of  For still vents and vents from any flash GP12.1 and GP 12.2 Natural Gas Production
Dehydrators each glycol dehydrator separator or flash tank, shall reduce Facility Class II General
 The owner or operator of each glycol located at natural gas hydrocarbon emissions by 95% (98% if  For Total Organic Compounds Permit G70-A
dehydrator located at natural gas compression and/or combustion device used) except where (TOC), total hazardous air
compression and/or processing facility processing facility shall o Combustion device was pollutants (total HAP), or benzene,  In addition to the
shall comply with the applicable comply with the applicable permitted prior to 01-May-2014, compliance with the applicable minimum
requirements established in 40 CFR Part requirements established in and control requirements of 40 CFR requirements in this
63, Subpart HH. 40 CFR Part 63, Subpart Part 63, Subpart HH. section, area source
HH. o Dehydrator is not within 1,320 TEG units may also
 The VOC emissions from the glycol feet of a building unit or  Emissions from a flare used to be subject to 40

67 Pennsylvania’s Air Quality Permit Exemptions Page 17 of 23

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

dehydrator still vent stream, which has a designated activity area  control emissions from the glycol CFR 63, Subpart
total uncontrolled potential emission rate dehydration unit shall not HH.
of VOC in excess of ten (10) tons per  Applies to units exceed:68
year, shall be controlled either by at least  Maximum
85% with a condenser, a flare or other air o Constructed on or after 01-May- o 0.25 ton Nitrogen Oxides Throughput
cleaning device, or any alternative 2015 with uncontrolled VOC (NOx) per month Limitation. The
methods as approved by the Department. emissions > 2 tons per year averaged over a 12- maximum wet
month rolling period; natural gas
o A glycol dehydrator using a o Constructed before 01-May-2015 throughput to the
condenser as an air cleaning with uncontrolled VOC emissions o 0.23 ton VOC per month glycol dehydration
device shall daily achieve an > 6 tons per year averaged over a 12- units/ still columns
average final exhaust month rolling period; and shall not exceed the
temperature of less than 110 o Constructed before 01-may-2015 throughput limit
degrees Fahrenheit (110 ºF). with uncontrolled VOC emissions o 0.15 ton Sulfur dioxide listed in the
> 2 tons per year if unit is within (SO2) per month registrant‘s G70-A
o (c) A glycol dehydrator using a 1,320 feet of a building unit or averaged over a 12- general permit
flare as an air cleaning device designated activity area. month rolling period. registration.
shall ensure destruction of VOC Compliance with the
emissions to the flare stack by o Carbon Monoxide (CO) Maximum
maintaining the heat content of emissions from a flare Throughput
the flare gas above 300 Btu/scf. used as a control device Limitation shall be
for the dehydrator shall determined using a
 Visible emissions from a glycol dehydrator not exceed 1.35 tons CO twelve month rolling
using a flare shall not exceed either of the per month averaged total.
following limitations: over a 12-month rolling
period.  Emission Limits. The
o Equal to or greater than 10% registrant shall not
for a period or periods o Emissions of Volatile cause, suffer, allow
aggregating more than 3 Organic Compounds or permit emissions
minutes in any one hour. (VOC) (excludes of hazardous air
methane and ethane) pollutants (HAPs)
o Equal to or greater than 30% at shall not exceed 5.0 and Volatile Organic
any time. tons/year. Compounds (VOCs)
to exceed the
 A glycol dehydrator shall not emit If a flare is used to control emission limits listed
malodorous air contaminants in such a emissions from the dehydrator: in the registrant‘s
manner that the malodors are detectable G70-A general
outside the facility property. o The flare shall be permit registration.
operated with a flame
 If a flare is used as an air cleaning device present at all times when  Control Devices.
for the glycol dehydrator, the owner or gases are vented to it. The following control
operator shall maintain a record of daily devices may be
visual observations of the continuous o An automatic flame used:
presence of a flame or a record of the ignition system shall be Flares
continuous recorder that indicates the installed. Enclosed

o If the permittee is using
a pilot flame ignition

68 OAC (Ohio Adminstrative Code) rule 3745-31-05(A)(3), as effective 11/30/01 Page 18 of 23

Issued: May 23, 2014

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

continuous ignition of the pilot flame.  system, the presence of Combustion Devices
a pilot flame shall be Closed Vent System
 The owner or operator of a new glycol monitored using a Carbon Adsorption
dehydrator, which is not subject to the thermocouple or other Systems
requirements established in 40 CFR Part equivalent device to Condensers
63, Subpart HH and has a total detect the presence of a
uncontrolled potential emission rate of flame. A pilot flame shall  The registrant shall
VOC in excess of five (5) tons per year be maintained at all comply with all
shall be controlled either by at least 95% times in the flare’s pilot applicable control
with a condenser, a flare or other air light burner. If the pilot device requirements.
cleaning device, or any alternative flame goes out and does
methods as approved by the Department. not relight, then an alarm Glycol Dehydration Units
shall sound. Recycling Back to Flame
Exemption Category No. 38 Zone of the Reboiler:
o If the permittee is using
 Combined VOC emissions from all the an electric arc ignition  If the registrant is
sources at the facility less than 2.7 tons system, the arcing of the reducing emissions
on a 12-month rolling basis. If the VOCs electric arc ignition by recycling the
include HAPs, the HAP exemption criteria system shall pulse glycol dehydration
in this paragraph will be met. Compliance continually and a device unit back to the
with this criterion is to be determined shall be installed and flame zone of the
using any generally accepted model or used to continuously reboiler, it shall be
calculation methodology. monitor the electric arc designed and
ignition system. operated in
 If the exemption criteria cannot be met, accordance with the
then a case-by-case plan approval is o Any flare, auto ignition following:
required. system, and recorder
shall be installed, a. The
calibrated, operated, and vapors/overheads
maintained in from the still column
accordance with the shall be routed
manufacturer’s through a condenser
recommendations, at all
instructions, and times when there is
operating manuals. a potential that
vapors (emissions)
If a condenser (or BTEX can be generated
elimination system) is used to from the still
control emissions from the column.
dehydrator:
b. The reboiler shall
o The condenser shall be only be fired with
operated at all times vapors from the still
when gases are vented column and flash
to it. tank, and natural
gas may be used as
o The condenser must be a supplemental fuel.
equipped with a
continuous temperature
monitoring device that
continuously monitors
and records the
dehydration still vent

Issued: May 23, 2014 Page 19 of 23

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

 temperature. c. The
vapors/overheads
o The condenser, from the still column
temperature monitoring shall be introduced
device and recorder into the flame zone
shall be installed, of the reboiler as the
calibrated, operated, and primary fuel or with
maintained in the primary fuel
accordance with the before the
manufacturer’s combustion
recommendations, chamber.
instructions, and
operating manuals. To demonstrate
compliance with the
Emission Limitation from a flare registrant shall
used to control the dehydrator: monitor the
throughput of wet
o 1.35 tons of CO per natural gas fed to
month averaged over a the dehydration
12-month rolling period. system on a monthly
basis for each glycol
o 0.23 ton of VOC per dehydration unit.
month averaged over a
12-month rolling period. Representative gas
sample collection
o 0.25 ton of NOx per and analysis
month averaged over a frequency for
12-month rolling period. dehydration units
shall be determined
o 0.15 ton of SO2 per based on the level of
month averaged over a HAP emissions from
12-month rolling period. the glycol
dehydration unit of
the facility as set
forth below:

Each dehydration
unit exempt from
§ 63.764(d)
requirements and
with
federally enforceable

controls - Upon

request by the

Director.

Issued: May 23, 2014 Each dehydration

Page 20 of 23

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

unit exempt from
§ 63.764(d)
requirements and
without
federally enforceable
control - (a) An
initial compliance
test within 180 days
of
permit issuance or
within 180 days of
start-up of
the dehydration unit,

whichever is later.

(b) Monitor and
record bi-monthly
the actual input
parameters for GRI
GLYCalc V3 or
higher.

Every dehydration
unit at or above 95%
of
HAPs major source
levels exempt from
§ 63.764(d)
requirements and
without federally
enforceable controls
- The registrant shall
sample and perform
a wet gas analysis at
least once each
year.

Natural Gas  In accordance with 25 Pa. Code §§  None  The owner or operator of a  Not Covered by Regulations 3, 6 and 7.  Not Covered by GP12.1 and  Not covered by
Processing Plants 127.11 and 127.12(a)(5), the owner or fractionation unit located at GP12.2. General Permit G-
operator of a fractionation unit located at an onshore natural gas 30D, G-35A, or G70-
an onshore natural gas processing plant processing plant shall A.
shall comply with 40 CFR Part 60, comply with 40 CFR Part
Subpart KKK – Standards of Performance 60, Subpart KKK – .
for Equipment Leaks of VOCs from Standards of Performance
Onshore Natural Gas Processing Plants. for Equipment Leaks of
VOCs from Onshore Natural
Gas Processing Plants.

Issued: May 23, 2014 Page 21 of 23

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia

Turbines Exemption Category No. 38:

 Combustion turbines rated at less than  None  The owner or operator of a  Not covered by Regulations 3, 6 and 7.  Micro turbines less than 200 kW are  Not covered by
GP-5 1,000 horsepower or 10.7 gigajoules per Turbine shall comply with exempt. General Permit G-
hour. emissions standards 30D, G-35A, or G70-
specified in 40 CFR Part 60,  Not Covered by GP12.1 and GP12.2. A
Subpart KKKK.

 The owner or operator of a new or
reconstructed turbine with a rated
capacity equal to or greater than 1000
bhp or 10.7 gigajoules per hour (10
MMBtu/ per hour), based on the higher
heating value (HHV) of the fuel that
commenced construction, modification, or
reconstruction after February 18, 2005,
shall comply with applicable requirements
specified in 40 CFR Part 60, Subpart
KKKK.

 In accordance with 25 Pa. Code §§ 127.1
and 127.12(a)(5), the owner or operator of
a new or reconstructed turbine shall not
exceed the following emissions
standards:

Turbine Size ≥1,000 BHP and
<5,000 BHP

NOx CO NMNEHC Total
ppmvd ppmvd (as Particulate
corrected corrected Propane) Matter
at at 15% ppmvd Lbs/MMBtu
15% O2 O2 corrected
at 15%
O2

25 25 9 0.03

Issued: May 23, 2014 Page 22 of 23

Comparison of Air Emission Standards for the Oil & Gas Industry

Item Pennsylvania CSSD Performance Standard Federal Colorado Ohio West Virginia
Page 23 of 23
Turbine Size ≥5,000 BHP and
<15,000 BHP

NOx CO NMNEHC Total
ppmvd ppmvd (as Particulate
corrected corrected Propane) Matter
at at 15% ppmvd Lbs/MMBtu
15% O2 O2 corrected
at 15%
O2

15 25 9 0.03

Turbine Size ≥15,000 BHP

NOx CO NMNEHC Total
ppmvd ppmvd (as Particulate
corrected corrected Propane) Matter
at at 15% ppmvd Lbs/MMBtu
15% O2 O2 corrected
at 15%
O2

15 10 ppm 5 ppm or 0.03
or 50%
93% reduction
reduction

 Compliance with the emissions standards
in this section shall be considered
compliance with the NSPS emissions
standards specified in 40 CFR Part 60,
Subpart KKKK and 25 Pa. Code Chapter
122 (relating to national standards of
performance for new stationary sources).

Issued: May 23, 2014