Applicability issues and compliance strategies for the proposed oil and gas industry hazardous air pollutant standards
The US Environmental Protection Agency (US EPA) has targeted oil and natural gas transmission and storage facilities located across the United States for regulation under the National Emission Standards for Hazardous Air Pollutants (NESHAP) program (proposed in Title 40, Code of Federal Regulations, Part 63 [40 CFR 63], Subparts HH and HHH). The proposed NESHAP were published in the February 6, 1998 Federal Register and are expected to be promulgated in May 1999. These rules are intended to reduce Hazardous Air Pollutants (HAP) emitted from oil and gas facilities. It is expected that these rules will require more than 400 major sources and more than 500 non-major sources (also referred to as area sources) to meet maximum achievable control technology (MACT) standards defined in the NESHAP. The rules would regulate HAP emission from glycol dehydration units, storage vessels and various fugitive leak sources. This technical paper addresses the applicability issues and compliance strategies related to the proposed NESHAP. The applicability criteria for both rules differ from those promulgated for other source categories under 40 CFR 63. For example, individual unit throughput and/or HAP emission thresholds may exempt specific units from the MACT standards in the NESHAP. The proposed Subpart HH would apply not only to major sources, but also to triethylene glycol (TEC) dehydration units at area sources located in urban areas. For both proposed NESHAP all 199 HAP must be considered for the major source determinations, but only 15 specific HAP are targeted for control under the proposed standards. An overview of the HAP control requirements, exemption criteria, as well as initial and continued compliance determination strategies are presented. Several industry examples are included to assist industry develop compliance strategies.
- Research Organization:
- Trinity Consultants, Dallas, TX (US)
- OSTI ID:
- 20000903
- Report Number(s):
- CONF-990331-
- Resource Relation:
- Conference: Gas Processors Association Seventy-Eighth Annual Convention, Nashville, TN (US), 03/01/1999--03/03/1999; Other Information: PBD: 1999; Related Information: In: Gas Processors Association seventy-eighth annual convention, proceedings, 393 pages.
- Country of Publication:
- United States
- Language:
- English
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