Obama Drilling Expansion In Alaska Falls Short For Some

October 2012, Vol. 67 No. 10

The HAP control program -- this is called subpart HHH -- sets maximum technology control standards (MACT) for certain equipment in order to reduce HAP emissions. The final rule establishes MACT standards for small glycol dehydration units in the natural gas transmission and storage source category. This subcategory consists of glycol dehydrators with an actual annual average natural gas flow rate of less than 283,000 standard cubic meters per day (scmd) or actual average benzene emissions less than 0.9 Mg/yr. The final MACT standard for this subcategory of small dehydrators requires existing affected sources to meet a unit-specific BTEX emission limit of 3.01 x 10-4 grams BTEX/scm-ppmv (parts per million by volume) and new affected sources are required to meet a limit of 5.44 x 10-5 grams BTEX/scm-ppmv.

There are also some new administrative requirements for pipelines in subpart HHH regarding malfunctions, start-ups and shut downs of equipment. Specifically, facilities using carbon absorbers as a control device are required to keep records of their carbon replacement schedule and records for each carbon replacement. In addition, owners and operators are required to keep records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control equipment and monitoring equipment.