Air Quality Division Tank Degassing and Cleaning Rules; TSH :May 15, 2008 Page 1 Changes to Tank...
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Transcript of Air Quality Division Tank Degassing and Cleaning Rules; TSH :May 15, 2008 Page 1 Changes to Tank...
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 1
Changes to Tank Degassing and Cleaning Rules
Texas Association of Environmental Professionals
Air Quality Division • Teresa Hurley, P.E. • May 15, 2008
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 2
Tank Degassing and Cleaning Rules
• What are the current requirements?
• Why were the rules changed?
• What changed?
• When do changes take effect?
• Questions
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 3
What are the current requirements?
• 30 TAC Chapter 115 Subchapter F Division 3: Degassing or Cleaning of Stationary, Marine, or Transport Vessels
• Applicability:– Stationary tanks with capacity ≥ one million gallons
– Transport vessels with capacity ≥ 8,000 gallons
– Marine vessels with capacity ≥ 420,000 gallons
– Vapor space partial pressure ≥ 0.5 psia
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 4
What are the current requirements?
• Control Requirements:– 90% control of vapors
– No avoidable leaks
– Must use vapor-tight connections
– No intentional bypass of vapor control device
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 5
What are the current requirements?
• Vapors must be routed to control device until:– Partial vapor pressure < 0.5 psia; 19,000 ppm by weight;
34,000 ppm by volume as methane;
OR– Turnover of at least four vapor space volumes has
occurred
• Vapors can be vented to the atmosphere after any of the above conditions is satisfied
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 6
Why were the rules changed?
• Studies have indicated that VOC emissions in HGB area are under-reported in emissions inventories.
• Remote sensing study results have indicated that degassing emissions are under-reported.
• Rule changes were made to reduce the previously under-reported emissions.
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 7
What changed?
• Eliminated “four turnover” condition for allowing vent to atmosphere– Confusion over measurement: must be volume passing
through tank vapor space; not measured after combustion control
– Does not account for presence of residual liquid in the tank
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 8
Floating Roof Tank - Drain Dry
Source: API, 2004
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 9
Floating Roof Tank with a Liquid Heel
Source: API, 2004
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 10
What changed?
• Control degassing vapors until
– VOC concentration of vapors ≤ 34,000 ppmv as methane, or
– < 50% of lower explosive limit
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 11
What changed?
• Monitor VOC concentration of degassing vapors according to 115.545(11)– Allow flexibility in monitoring methods– Maintain records to demonstrate that method works for
compounds present
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 12
What changed?
• Specified monitoring methods:– Test Method 21 (40 CFR Part 60, Appendix A)– Test Method 18 (40 CFR Part 60, Appendix A)– Bag samples – Test Method 25A (40 CFR Part 60, Appendix A) – Portable hydrocarbon gas analyzer using appropriate
detector– Lower explosive limit detector calibrated and
maintained according to manufacturer's specifications
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 13
What changed?
• Monitoring must continue while vapors are vented to atmosphere:– At least once every 12 hours if ventilation is continuous– If ventilation ceases for more than 4 hours,
concentration must be rechecked before venting to atmosphere
– Monitoring can be discontinued after five consecutive readings less than 34,000 ppmv or 50% of LEL
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 14
What changed?
• Require control of vapors for smaller tanks:– Capacity ≥ 250,000 with vapor pressure ≥ 0.5 psia – Capacity ≥ 75,000 with vapor pressure > 2.6 psia
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 15
When do changes take effect?
• Compliance date for new requirements is January 1, 2009
Air Quality Division • Tank Degassing and Cleaning Rules; TSH :May 15, 2008 • Page 16
For more information
Teresa S. Hurley, P.E.
TCEQ Air Quality Planning Section
512-239-5316