The State of Texas has recently stepped up enforcement of existing air pollution regulations concerning the control of emissions due to degassing or cleaning of stationary, marine and transport vessels (which includes storage tanks), as specified in 30TAC 115, Subchapter F. The degassing / cleaning rules are contained in Section 115.541, and require companies which perform these tasks to verify and to provide documentation that their vapor control systems maintain a 90% volatile organic hydrocarbon vapor destruction removal efficiency (VOC DRE).
In addition, there are pending new Maintenance, Startup, Shutdown (MSS) permit conditions which may further regulate control of VOCs to a DRE of 99%.
In light of the current rules, plus the potential MSS permit conditions, Stork's Air Emissions Services (AES) Division based in Houston, Texas has performed emission studies of several mobile internal combustion engine (I.C.E.) systems which our clients use in degassing operations at various petrochemical sites across the state. To date, seven (7) engines have been tested, with each one exhibiting a VOC DRE of greater than 99%, thereby meeting both the existing Rule 115 criteria as well as the more strict MSS draft permit criteria. In addition to engines, other equipment such as mobile thermal oxidizers can be used for this service. Stork currently has scheduled testing of two (2) such units for the latter part of November.
As the units are mobile rather than a stationary source, Stork worked closely with clients to develop an acceptable emissions test. The work was performed at the Cavalcade Street facility using one of the laboratory's state-of-the-art emission test trailers. Both Inlet loading as well as the Outlet emissions were measured, with a rapid turnaround of the samples and data in order to enable our client's to be able to get their mobile units back on to jobsites. In addition, Stork staff met with the local regulatory agency office to present the data on behalf of their clients.
The Texas Commission on Environmental Quality (TCEQ) has also recently announced that the Rule 115 is subject to revision and has established stakeholder meetings to provide an open forum for the public, end users, and companies providing these services in order to discuss potential revisions to the rule.
Stork Testing & Metallurgical Consulting, a member of the Stork Materials Group of companies, is a nationally and internationally recognized engineering and testing company, offering services ranging from metallurgical analysis to product testing. Stork's Air Emissions Services Division was created in 1970 to assist our Petrochemical, Refining and Manufacturing clients in complying with their air permits.We maintain NELAC based accreditations for emissions testing operated by both the states of Texas and Louisiana.