Developing effective strategies for complying with the oil and gas MACT
- Trinity Consultants, Inc., Baton Rouge, LA (United States)
- NorAm Gas Transmission, Shreveport, LA (United States)
The 1990 Clean Air Act Amendments (CAAA), enacted on November 15, 1990, represent landmark legislation which provides the US Environmental Protection Agency with unprecedented authority to promulgate regulations affecting air pollution. Title 3 of the 1990 CAAA focuses on the emissions of hazardous air pollutants (HAP) from the sources of concern. The HAP affected by Title 3 are identified in Section 112(b) of the Clean Air Act (CAA). The industry specific regulations promulgated for major industrial source categories under Section 112(d) and Section 112(g) of the CAA are referred to as the Maximum Achievable Control Technology (MACT). In order to maximize operational flexibility and optimize costs of compliance, facilities must develop a plan to identify methods to comply with the area source provisions of the regulations by becoming a minor source/synthetic minor source or to comply with the major source requirements of the regulations in the most cost effective manner. Area source requirements are generally less stringent as compared to the major source requirements. This paper outlines the fundamental aspects of Title 3 as they impact the upstream oil and gas industry. The paper provides guidelines to the potentially affected facilities in determining applicability of the MACT rules based on emission inventories, potential to emit (PTE), and latest guidance from the EPA. The paper finally provides strategies to comply with the requirements of the regulations and discusses the advantages and disadvantages associated with using specific strategies.
- OSTI ID:
- 418192
- Report Number(s):
- CONF-960348-; TRN: IM9705%%570
- Resource Relation:
- Conference: 75. Annual convention of the Gas Processors Association, Denver, CO (United States), 11-13 Mar 1996; Other Information: PBD: 1996; Related Information: Is Part Of Seventy-fifth Gas Processors Association annual convention: Proceedings; PB: 325 p.
- Country of Publication:
- United States
- Language:
- English
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