Discussion needed here.

Discussion needed here. formaldehyde issues:

Products of fossil fuel combustion are exempted from Air Toxics analysis by3704(F)(4)(f)(i) (but the next paragraph, (f)(ii), effectively rescinds (f)(i)). Note that (F)(3) says that by Aug. 3, 2008 a rule shall be written that limits the substances which the Ohio EPA may regulate to NAAQS pollutants or precursors; contaminants issued by sources regulated by the CAA; listed Air Toxics compunds. What I'm getting at is: Does 3704 prohibit our regulating formaldehyde from these sources?

Colorado

Under the GP02 general permit,

(1)	Engines brought into the state after the 2010/2011 NSPS dates are required to meet those NSPS standards ("Table 2");
(2)	A table ("Table 1") of allowable NOx/CO/VOC rates is provided based on horsepower and rich/lean, but not date of manufacture. Most of the numbers correspond to to the 2007/2008 round of limits. Hence, relative to JJJJ, Colorado's limits are more strict than JJJJ if the engine was built prior to any NSPS, and less strict if the engine is subject to the 2010/2011 round of limits. There appear to be exceptions for NOx and CO for rich burn .GE.500 hp, which are more stringent than the 2010/2011 limits, and the CO and VOC limits for lean burn .GE.500 hp, which respectively are stricter than and equal to the 2010/2011 round of limits.
(3)	The NOx limit for a rich burn unit .GE.500 hp is 0.7 g/hp-hr, or 1.0 g/hp-hr if it is constructed or relocated to Colorado after July 1, 2010. I think they've made a muddle of it. Can they avoid that 0.7 limit if they go shopping out-of-state for their engine?

Wyoming (no page yet; may not need one)

A standard permit for existing natural gas facilities in the Green River Basin ozone non-attainment area went out for public comment with due date for comments to the WDEQ/AQD on April 13, 2015, and to the Environmental Quality Council on May 19, 2015. Wyoming Air Quality Standards and Regulations (WAQSR) Chapt. 8, Sec. 6 (p. 8-85) and Chapt. 6, Sec. __ address compressor stations, but the former goes into fugitive emissions and the latter, ____, and I haven't found anything about engines yet. Here is response to comments (Chapt. 8?), including lengthy and informative submittal by the American Lung Association, and here their draft permitting chapter. Fugitive emissions are the concern with compressor stations; I don't see anybody whining about the engines.

Texas

Discussion needed here.

West Virginia

Discussion needed here.

a
matrix

	pre-NSPS allowed?	stricter than NSPS?	depend on air quality attainment status?	special requirements for relocation from out of state?
Ohio (draft)
Pennsylvania		stricter NOx and Co limits (much stricter for rich burn); formaldehyde limit on certain lean burn
W.Va.
Texas		provides NOx limits on all but the smallest pre-1992 engines
Colorado		NOx and CO for large rich burn, and CO for large lean-burn all more stringent than 2010/2011 NSPS.		yes, although in some cases they may have failed in their intent
Wyoming			Green River Basin O3 nonattainment region of particular concern for compressor stations, but haven't found language addressing the engines.

(up a level)

dkt
4/29/15