Clarification on "New Glycol Dehydrators"

Definition of a "New Glycol Dehydrator":

Clarification of definition under LAC 33:III.2116


The following three cases were proposed with the question "Does this meet the definition of 'new glycol dehydrator' as noted in LAC 33:III.2116.B.2?":

Case One        A glycol dehydrator was originally manufactured prior to October 20, 1994, but refurbished and installed in a production facility after October 20, 1994.

Case Two        A glycol dehydrator was originally manufactured prior to October 20, 1994, but transferred to a production facility after October 20, 1994.

Case Three     A glycol dehydrator was originally manufactured prior to October 20, 1994, but refurbished after October 20, 1994 and used within an existing production facility.

It does not matter when a particular dehydrator was refurbished or modified, LAC 33:III.2116 only mentions construction. LAC 33:III.111 defines construction as fabrication, erection, or installation of an affected facility.  Affected facility is defined as any apparatus to which a standard is applicable, in this case the dehydrator.

In cases one and two, the dehydrators were installed in a new location.  This meets the definition of "new glycol dehydrator."  In case three, the existing dehydrator was refurbished, but this does not meet the definition of construction.  The dehydrator must meet the standard of LAC 33:III.2116.B.1 for existing glycol dehydrators.  To rigidly follow the definitions, the dehydrator in case three would have to be refurbished on site and not require installation or reinstallation.

 

Louisiana Department of Environmental Quality 602 N. Fifth Street Baton Rouge, LA 70802
Call or e-mail a hotline · Office Address/Phone listing · Locate a DEQ employee
Call 1-866-896-LDEQ or e-mail our Customer Service Center with questions or comments