Evaluating Well Pad Permitting 

in the Appalachian Basin

A&WMA Oil & Gas Environmental 

Compliance Conference

Washington, PA ♦ May 13, 2014

Tom Muscenti

Trinity Consultants

Manager of Consulting Services
˃ Permit Paths

˃ State implementation of well pad 

permitting

 Pennsylvania – Exemption 38

 West Virginia – G-70A

 Ohio – GP12 series

˃ Comparing and contrasting 

requirements for identical operations

Presentation Overview
Available Permitting Paths

˃ Exemptions

 No permits required

 Limited scope and emissions

˃ General Permits

 Facility/operation must meet qualifying criteria to 

be authorized to use

 Standardized set of terms and conditions

˃ Site-Specific Permits

 Unique set of terms and conditions

 Lengthiest times for preparation and review

 Applicable if other options are not valid
PADEP’s Exemption 38

˃ Limited to well-site operations

˃ Conditional exemption for unconventional 

operations

 Work practices

 Emission limitations (source and facility)

 Compliance demonstration

˃ No capacity limitations for equipment

˃ References applicable Federal rules

˃ Eliminates requirement for site-specific Plan 

Approval (~6 months)

˃ No application, no fee
WVDEP’s G-70A

˃ Limited to well-site operations

˃ Includes siting criteria

˃ Public notice period for application

˃ Emission limitations and throughput restrictions 

are source-specific as registered by applicant

˃ Incorporates Federal rules into permit

˃ Reduces permit issuance to 45 days

˃ Application fee required – amount depends on 

equipment proposed 
OEPA’s GP12.1, 12.2

˃ Limited to well-site operations

˃ Includes qualifying criteria

 Engine stack requirements

 Size limitations (engine horsepower, storage 

capacity, flare capacity)

˃ Emission unit-specific control requirements and 

emission limitations

˃ References Federal rules and includes some 

specific requirements

˃ Reduces permit issuance to 45 days 

˃ Application fee required – amount depends on 

equipment proposed 
Example Equipment –

Storage Tanks*

* Exclusive of Federal requirements

PA WV OH

Limits/Controls Control VOC 

emissions >95% if 

over 2.7 tons per 

year (otherwise 

meet facility-wide 

limit)

Comply with 

potential 

emissions as 

registered

Control VOC emissions 

to meet General 

Permit limits (51.3 

tons per year)

Qualifying 

criteria 

(size/capacity):

None Not subject to 

NSPS Kb

Each tank < 950 

barrels, total < 6,000 

barrels
Example Equipment –

Glycol Dehydration Units*

* Exclusive of Federal requirements

PA WV OH

Limits/Controls Control VOC 

emissions >95% if 

over 2.7 tons per 

year (otherwise 

meet facility-wide 

limit)

Comply with 

potential 

emissions as 

registered

Control VOC emissions 

to meet annual 

General Permit limits 

(5.0 tons per year)

Qualifying 

criteria 

(size/capacity):

None None No more than two
Example Equipment –

Engines*

* Exclusive of Federal requirements

PA WV OH

Limits/Controls Facility-wide 2.7 

tons per year VOC 

limit, NOX

emission 

limitations (e.g., 

6.6 tons per year) 

for all exempt 

engines on site

Comply with 

potential 

emissions as 

registered

Maintain total engine 

emissions below 

general permit limits 

depending on fuel 

type

Qualifying 

criteria 

(size/capacity):

None Natural gas fired 

only

Facility-wide 

horsepower 

restrictions for natural 

gas and diesel fired 

engines
Compliance Requirements –

Leak Detection and Repair (LDAR)*

˃ PA: Initial and annual LDAR using FLIR camera 

or gas leak detector on equipment in natural 

gas or hydrocarbon liquid service

˃ WV: Initial and annual LDAR using audio, visual, 

olfactory means on control device closed vent 

systems

˃ OH: Initial and quarterly LDAR using FLIR 

camera or U.S. EPA Method 21 (subsequent 

frequency can be reduced)

* Exclusive of Federal requirements
Compliance Requirements –

Emissions Documentation*

PA WV OH

Annual 

Emissions 

Reporting

Annual PA oil and 

gas emissions 

report (includes 

more than just 

permanent 

equipment)

None Annual emissions 

reported every two 

years

Permit 

Compliance

Tracking

Rolling 12-month 

facility-wide 

calculations and 

engine 

calculations, if 

applicable

Rolling 12-month 

calculations for 

specific equipment

Rolling 12-month 

calculations for 

specific equipment

* Exclusive of Federal requirements
Compliance Requirements –

Compliance Reporting*

˃ PA: Initial compliance evaluation within 

180 days of installation

˃ WV: Immediate reports due when 

emissions or throughputs in registration 

are exceeded

˃ OH: Annual permit evaluation report

* Exclusive of Federal requirements
Commonalities

˃ No specific methane emission limits

˃ Option to obtain site-specific permit

˃ Limited to minor sources (e.g., nonTitle V and non HAP major)

˃ Do not regulate drilling activities 

under these permits/exemptions
Conclusions

˃ Agencies are working within framework of 

state regulations to streamline review

˃ Criteria and requirements are unique to 

each state as well as conditions at the site

˃ Regardless of where the well pad is located, 

the permitting evaluation typically needs 

the following information:

 Estimate of number, capacity, and throughput 

of each piece of equipment

 Analysis of natural gas and/or liquids from the 

well or surrounding area

 When production will begin
Questions?

TomMuscenti

Trinity Consultants

724-935-2611

tmuscenti@trinityconsultants.com