(72c) How Facilities in Harris County, Texas Are Using Point Source Monitoring to Identify and Reduce Emissions of Highly Reactive Volatile Organic Compounds

In 2002, the Texas Commission on Environmental Quality (TCEQ) established regulations limiting emissions of highly reactive volatile organic compounds (HRVOC) via both long-term cap and short-term emission limit. Modified in 2004, this program limits emissions from 51 affected facilities in Harris County, Texas, to collectively no more than 3,451.5 tons of HRVOC annually. It also limits emissions of HRVOC from a facility to no more than 1,200 pounds in any one hour. Compliance with these limits is demonstrated primarily through installation and operation of continuous emission monitor systems (CEMS) on flares and cooling towers. In May 2006, the Houston Advanced Research Center (HARC) authorized ENVIRON to investigate the effectiveness of HRVOC monitoring as a control measure. Designated Project H76, the work involved a comprehensive quantitative and qualitative review and analysis of HRVOC emissions monitoring data for representative Harris County facilities that are subject to both short- and long-term HRVOC emission limits. Nine facilities representing eight companies participated in this study. Collectively, these facilities represent 67.5% of the HRVOC allowances allocated and they continuously monitor 41 flares and 50 cooling towers. Study participants provided both quantitative monitoring data and qualitative HRVOC program implementation information in support of this study. This data and information were evaluated with respect to, among other items: monitoring implementation schedule and difficulties, actual emissions in comparison to HECT program allowance allocations, actual flare and cooling tower emissions in comparison to historical reported values, use of monitors to eliminate/reduce sources of HRVOC emissions, changes in practices resulting from use of HRVOC monitors, HRVOC emission control projects, costs, and use of remote sensing technologies. This paper will present an overview of study methodology, key findings, identified best management practices, conclusions and recommendations for additional investigation.