What Is It?: The rules and regulations governing oil & gas operations (PA Code) include a list of kinds of facilities that are exempt from needing an Air Quality Permit. B 38 is the exemption for an oil & gas well. (The complete list of exemptions is contained in a DEP Technical Guidance Document which is here.)

Why Does It Matter?: An unconventional gas well can cause air pollution in several ways. If wells are exempt from needing an air quality permit then:

• There is no evaluation of whether they are following the rules.
  
  
• There are no inspections, and hence no violations that will ever happen.
  
  
• There is no documentation for data reporting or aggregation into area sources of air pollution.
  

Where Can I Find It?: 25 PA Code § 127.14. Exemptions

What’s been said about it?: For a Fayette County public comment on B 38 look here.