Texas Facilities Subject to New HRVOC Rules

For more information, contact Ed Fiesinger at 713.977.8787. 

The Texas Commission for Environmental Quality (TCEQ) recently promulgated rules that will require facilities in the Houston/Galveston nonattainment area that emit, or have the potential to emit, a highly reactive VOC (HRVOC) to submit quality assurance plans (QAP) by April 30, 2005. Companies with these facilities will be required to continuously monitor their systems for flow and composition.

Any TCEQ account in the Houston/Galveston area with a vent gas stream, flare, or cooling tower heat exchange system that emits or has the potential to emit a HRVOC will have to comply with this rule. Ethylene, propylene, and various C4's are currently on the HRVOC list but this could change due to ongoing review of air modeling results.

QAPs are due by April 30, 2005, for systems existing on or before December 31, 2004. Plans for new systems that become subject to this rule after December 31, 2004, must be approved at least 60 days before the new systems are put into HRVOC service.

What do you need to submit?

To make sure such monitoring is done correctly, the TCEQ is requiring that affected companies submit a QAP for the required monitoring. Such plans should cover:

1) routine training procedures and/or evaluation of sampling personnel,

2) routine monitoring of the variables and/or parameters which may have a significant effect on data quality,

3) techniques to detect defects,

4) methods and written procedures to qualify data, and

5) strategies to increase the level of precision in the reported data and/or to detect equipment defects or degradation in equipment performance.

By its nature, a QAP is a very detailed and rigorous document to develop. As TCEQ reviews each QAP, facilities will be notified of any deficiencies and will have 60 days to respond.