With the regulations and requirements constantly changing, it is important to stay up to date with the latest rules to be in compliance. Have you considered adding a backup Vapor Recovery Unit (VRU) or Vapor Combustion Unit (VCU) to your facility? If not, take a look at some of the regulations and reasons this may be beneficial.
From the TCEQ, “Requirements of acceptable control efficiency: The unit cannot be down for more than an average of 5% of the time over a rolling 12 months or 432 hours per rolling 12 months and if possible during the downtime, the controlled waste streams should be redirected to another appropriate control device, unless the unit is certified for alternate operating hours. The unit must meet the requirements to be able to claim >95% and ≤99% control efficiency as listed above.”
If you were to get shut in by your gas provider, have problems with your VRU, etc., the allotted time can add up quickly so a backup unit would be extremely beneficial to stay in compliance. Having a second Vapor Recovery Unit could get pricey, so install a VCU on the same line and it will kick on should any issues arise. That way, it is still capturing and burning off your VOC’s to be under your 6 TPY limit. Not to mention, if the secondary control device is only in operation for < 480 hours a year is not required to be monitored, meaning the operator is not required to monitor the pilot, downtime, auto-ignite system, etc.
Having two units can also help in other situations if you have a lot of gas coming in and know that production will drop off, place 2 units and move one to your next location when the time comes. The EPA’s Quad O regulation also states that if you place a VRU and want to remove it, the owners/operators have to document that a tank’s monthly uncontrolled emissions have been below 4 tons per year for at least 12 consecutive months. So, place two units and move one to take to a new location when you are under your 4 tpy and leave the 2nd unit to stay in compliance.
As always, if you have any question or concerns, please contact the Account Manager for your area and let OTA take care of your needs.
