The BTEXs and hexane are of special concern because they are on the Federal list of hazardous air pollutants (HAPs). Current regulations by many states will only allow 15 Tons per Year (TPY) of VOCs per individual well location and 5 TPY of HAPs per individual well location.
Title V was passed as the enforcement arm of the Clean Air Act and applies to all sites that are “Major” sources of emissions as defined by the law. The law requires that all sites that are “Major” sources of emissions have a permit certifying they are in compliance with all Federal, state, and local laws that apply to the facility.
The standard or average emissions from the glycol regeneration system of a single dehydration unit, in most parts of Wyoming, calculated using the accepted equation for determining emissions, GRI-GLYCalc, (flow rate of gas at 6 MMSCF/D, 319 PSIG, utilizing a single 10015 sc Kimray glycol pump) reveals: VOCs = 51 TPY and HAPs = 19 TPY. This exceeds the Federal, state, and local requirements under Title V of the Clean Air Act. Due to the rate of harmful emissions, an emissions control device must be used.
If a site is not in compliance, corrective action must be taken. Violators of Title V are potentially liable for heavy penalties, including $10,000 per day per violation, civil and criminal fines and jail time for the responsible person(s). There is compelling incentive for all sites that are “Major” sources to fully comply with all environmental regulations and reporting requirements. This is also the right thing to do for our environment and protecting our earth.
There are significant costs associated with applying for a Title V “Major” source permit. Also, there are ongoing costs associated with reporting and permit renewal, in addition to the potential civil and criminal penalties for non-compliance. Many companies prefer to install an emissions control/destruction device if such action will allow the site to operate as a minor source of harmful emissions.