TexAQSII Remote Sensing VOC Project

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Information about TexAQSII Remote Sensing VOC Project
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Published on November 8, 2007

Author: Nikita

Source: authorstream.com

TexAQSII Remote Sensing VOC Project:  TexAQSII Remote Sensing VOC Project Russ Nettles Texas Commission on Environmental Quality Primary Goals:  Primary Goals Use the Hawk infrared camera to identify and characterize VOC emission sources that have possibly been unreported or under-reported in the agency’s emissions inventory Develop a corrective strategy plan to minimize VOC emissions from identified plumes Study Area and Types of Observation Platforms:  Study Area and Types of Observation Platforms Study area covered was the Houston Ship Channel, Texas City area, and the Beaumont area Observation platforms included the use of: Helicopter; Texas Parks and Wildlife boat; TCEQ vehicle; and San Jacinto Monument Summary of Results:  Summary of Results In two weeks of observation time, or 45 hours of flight time: In the Houston / Texas City area: 30 sites with noted visible IR plumes In the Beaumont / Port Arthur area: 11 sites with noted visible IR plumes Storage Tanks:  Storage Tanks 10,700 total storage tanks in the study area 5,400 were observed with the camera 71 noted with visible IR plumes Result: 1.3 percent of tanks with a visible IR plume Summary of Results (cont.):  Summary of Results (cont.) Visible IR plumes were also noted from barges that were either docked at one of the earlier noted facilities and being loaded or unloaded, in a barge parking lot, or in transit Plumes were primarily noted at the hatches and pressure relief vents Summary of Results (cont.):  Summary of Results (cont.) Approximately 50 visible IR plumes were noted from oil and gas production facilities during flights between the Beaumont and Houston areas. So, Roll the Clip:  So, Roll the Clip What Happens Now? :  What Happens Now? A voluntary “Find and Fix It” Program with point source industries Working with the barge owners Identification and discussion with oil and gas production companies Potential incentives for using the remote sensing technology Regulations??? An Initial Voluntary “Find it and Fix It” Program (non-enforcement) :  An Initial Voluntary “Find it and Fix It” Program (non-enforcement) All of the identified point sources have been contacted and provided with: A video clip of their release, and An aerial photo that pin points the suspected source Company responses are due back soon (45 days from contact), and should include a corrective strategy plan. Barge Owners and Operators:  Barge Owners and Operators The agency is working with the American Waterway Operators, the Coast Guard, and the Louisiana DEQ to address the problems noted with barges. LDEQ is involved, because their flyover study found similar problems. Oil and Gas Production Companies :  Oil and Gas Production Companies The agency is working to identify the owner/operators of the oil and gas production sites that had visible IR plumes The owner/operators will then be contacted and asked to participate in the “Find it and Fix it” program Incentives: Remote Sensing Technology Use:  Incentives: Remote Sensing Technology Use Initiate a long-term program where companies are encouraged to use the camera to identify leaks and make the appropriate repairs in an expeditious manner. A follow-up assessment using either the camera or conventional means (TVA, etc.) will be necessary to ensure that the leaks identified were repaired. Incentives: Compliance History:  Incentives: Compliance History Companies that opt to use a TCEQ approved infrared VOC imaging camera monitoring program to expeditiously identify and repair leaks could receive positive credit to the company’s compliance history. Incentives: External Floating Roof Tank:  Incentives: External Floating Roof Tank Use the IR VOC camera in lieu of the annual gap seal measurements However, use would not replace the 10 year shut-down and complete tank inspection requirements Incentives: Leak Detection and Repair Program:  Incentives: Leak Detection and Repair Program Use the IR VOC camera in conjunction with traditional VOC LDAR programs The use of the camera would be aimed at complementing the LDAR program, but would not replace the LDAR program Issue concerning undefined camera minimum detection limit (MDL) vs. current LDAR regulatory limits and method MDL IR VOC camera will allow more frequent and more inclusive monitoring of regulated and unregulated components Incentives: Leak Detection and Repair Program (cont.):  Incentives: Leak Detection and Repair Program (cont.) The use of the IR VOC camera may allow additional skip periods for routine Method 21 leak detection Difficult-to-Monitor components - Frequent use of the IR VOC camera may replace the annual monitoring requirement in Chapter 115 Incentives: Flexibility of State and Federal Regulations :  Incentives: Flexibility of State and Federal Regulations These incentives would require the flexible application of federal and state regulations and would need agreement by EPA Another key concern would be Title V deviation reporting. Some type of relief from deviation reporting would be needed for this type of voluntary program Regulations???:  Regulations??? Rule effectiveness review of storage tank rules New rules concerning loading and unloading of barges at regulated facilities ??????

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