Mike Riedel attended an API Workshop recently that included EPA presenters. 
EPA has changed their interpretation of the E& P, T & S MACT regulations that 
would have an impact on the registrations required in June of this year. The 
API representatives apparently agreed with the EPA interpretations. The 
Environmental Notice on the intranet will be changed to reflect these 
changes. 

Dehys  that are Major Sources for HAPs must be registered with EPA on June 
17, 2000. Previously it was understood that your Major Source status on June 
17, 2000 would determine if you register a facility. EPA has indicated that 
your status on June 17, 1999 would determine whether or not a site is 
registered.

For dehys regulated under the E & P MACT regulations (this does not impact 
the T & S MACT), you determine your major source status by first determining 
if the dehys at a location exceed 10 tons/year of any one HAP or 25 tons/year 
of all HAPs. If they do you must register the location with EPA. If not a 
Major Source because of dehys, you must then determine the HAP emissions from 
the greatest non-dehy source of HAP emissions (typically a recip engine). If 
the HAP emissions from this source alone exceed 10/25 tons/year, the location 
must be registered with EPA. If not you do not need to register. You no 
longer need to determine HAP emissions from the entire site to determine 
Major Source status.

If you have any questions, give me call at 713-646-7646.

Marc