Trinity Consultants

Shooting a Moving Target - Permitting Fugitive Volatile Organic Compound (VOC) Emissions

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Fugitive emissions from components at chemical processing facilities often appear as allowable emission limits in construction (New Source Review) and operating (Title V) permits issued by state permitting authorities – a subtle contradiction to the federal and state level regulations that regulate those very emissions.

Both federal (New Source Performance Standards (NSPSs), Maximum Achievable Control Technology (MACT) standards) as well as state regulations require targeted industries to control fugitive VOC emissions through the implementation of Leak Detection and Repair (LDAR) programs. Unlike other regulations, LDAR requirements are work practice standards with no set emission standards to be achieved.

However, chemical processing facilities, being on the NSR “List of 28”, must also include fugitive emissions when determining net emissions increases of new or modified sources for New Source Review analyses. Therefore, these facilities are required to determine potential fugitive VOC emissions when evaluating new construction and process modification projects.

A background on the most common methods of estimating fugitive VOC emissions is provided including an explanation of the underlying piping component counts and various sets of emission factors available to environmental professionals. The possibility of having a fluctuating potential to emit (PTE) from groups of such sources is illustrated.

To illustrate the difficulties faced by both agency and facility, a case study is presented including the following:
• The motives behind the limits as explained by the agency
• Possible alternatives considered by one regulated entity to avoid such limits

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