Skip Navigation Links
Agency Documents , Alerts, Comments
AGA/EPA Boiler MACT Letters re Sierra Club Petition for Reconsideration-July 2011
AGA-APGA Comments on EPA Proposed Rule: Boilers and Process Heaters (August 23, 2010)
AGA Alert - EPA Proposed Boiler MACT Rule (June 29, 2010)
AGA Alert - EPA Publishes Diesel Engine MACT Final Rule (Feb. 8, 2010)
Engine Air Toxics (RICE MACT) Final Rule Postponed (Nov. 9, 2009)
AGA Comments on EPA Proposed Hazardous Air Pollutant Standards for RICE Engines (June 4, 2009)
AGA Comments on EPA Proposed Hazardous Air Pollutant Standards for RICE Engines (June 3, 2009)
AGA Comments on EPA's Proposal to Drop the "Once-In-Always-In" MACT Policy (May 4, 2007)
AGA Comments on EPA Engine NSPS & NESHAP Proposed Rule (Oct. 11, 2006)
AGA Comments on Boiler MACT (March 14, 2003)
INGAA Detailed Comments on EPA's Hazardous Air Pollutant MACT Proposed Rule for Combustion Turbines (February 28, 2003)
AGA Comment Letter Supporting INGAA Turbine MACT Comments (February 28, 2003)
AGA Comments Supporting INGAA Comments on EPA's IC Engine MACT Proposed Rule (February 20, 2003)
INGAA Comments on EPA's IC Engine MACT Proposed Rule (February 19, 2003)
INGAA Cover Letter for Comments on EPA's IC Engine MACT Proposed Rule (February 19, 2003)
AGA Alert - MACT Hammer for Case-by-Case Hazardous Air Pollutant Permits Deadline Extended (March 12, 2002)
Final Technical Amendments Published: MACT for Oil & Gas Production and Natural Gas Transmission & Storage (June 29, 2001)
Transmission and Storage MACT (Part 63, Subpart HHH) Final Rule : Gas Utilities Are Exempt (June 17, 1999)
Photo Gallery
Presentations

 Transmission and Storage MACT (Part 63, Subpart HHH) Final Rule : Gas Utilities Are Exempt (June 17, 1999) 

On June 17, 1999, EPA published the final rules for hazardous air pollutant (HAP) emissions from the oil and gas production category and the natural gas transmission and storage category. In response to AGA's written comments and conversations with EPA, the final rule clearly exempts natural gas utility facilities. See 64 Fed. Reg. 32610, 32618, and 32649 (June 17, 1999) (clarifying definition of affected "Facility").

Background: Over the past 6 years, AGA has lobbied for member interests as EPA developed hazardous air pollutant standards for the oil and gas industry. Working with INGAA, we won several concessions along the way. First, we got EPA to create a separate category for natural gas transmission and storage facilities, rather than impose the same regulations as apply to oil and gas production. Second, we convinced EPA to focus the emission standards on just one type of unit - glycol dehydration units that are used to dehydrate natural gas. Fourth, we convinced EPA there was no need to regulate these units unless they were very large units located at very large "major sources" - e.g. large compressor stations. Fifth, we persuaded EPA to allow more flexibility in achieving the new standards for large glycol dehydration units.

Finally - the icing on the cake - AGA persuaded EPA to clarify the rule to exclude gas utilities!

Even for interstate pipelines, the final rule is far better than the original proposed rule. The final rule exempts small units that emit less than one ton of benzene per year, and it exempts units of any size that are located at small compressor or storage facilities that are not "major sources" of hazardous air pollutants. Even for affected units, the rule provides significant flexibility. The new 95% emission limit can be met using flares or other combustion devices. In the alternative, a company may use other modest measures to reduce benzene emissions just enough to get below the exemption threshold. Companies will have 3 years to achieve compliance.

 
 

Join the Energy Conversation