As rules change throughout the years, operators have a difficult time keeping up. In lieu with that comes enforcement. You might recall those TCEQ contracted helicopters that fly over production sites taking readings from emission plumes, as part of the state’s research. Recently, the TCEQ has purchased their own (red) helicopter to conduct similar surveys.
Quad OOOO states that if your single storage vessel has the potential for Volatile Organic Compounds (VOC) to emit equal to or greater than 6 tpy, 30 days after start up, then it is considered affected. The TCEQ has a specialized camera (FLIR) that can image the VOCs and other hydrocarbons invisible to the naked eye. If the camera detects these images, then it is noted the time and location and other information and sent to the operator. That owner of that facility must take immediate action to curb those leaks, prove whether their facilities are affected and not, and if affected, control those emissions with approved control technology. Maintaining your vapor recovery system on a monthly basis by cleaning and reseating thief hatches and configuring control technology to the application is a great first step to remaining under the radar. However, even if you are capturing flash gas and keeping leaks to a minimum, an air permit is still required through the state.
“When tanks are authorized by a PBR, and controls (flare, combustor, etc.) are used to limit tank emissions so that they are below the 6 tpy threshold for NSPS OOOO applicability, certification is required consistent with 30 TAC section 106.6. An APD certification may be filed to establish the federally enforceable limit in compliance with 40 CFR 60.5365. In addition, when a VRU is being used to recover VOC emissions from the tanks and this results in tank emissions below 6 tpy, no certification is required; however, all monitoring and recordkeeping requirements must be met as stated in 60.5365(e)(1-4).” – Any questions? Email our environmentalist at Enviro@otacompression.com.
OTA is here to help, so don’t hesitate and call your local Sales Rep today! Don’t get fined!