State Issues

State Issues - Texas

Texas

IF MEMBERS WOULD LIKE TO RESPOND TO THIS PROPOSED RULE, THERE ARE FEWER THAN FOUR WEEKS TO SUBMIT COMMENTS.

Texas Commission on Environmental Quality (TCEQ) recently issued a proposed rulemaking to subject volatile organic compound (VOC) storage tanks in the Houston-Galveston-Brazoria (HGB) metropolitan area to more stringent control and monitoring requirements.

The proposed rule, published in the Texas Register on Dec. 29, 2006 (p.10525 - 10535), would, among other things:

Prohibit floating roof landings, except for inspection and maintenance purposes or for change of product service. An option to maintain total tank emissions (including landings) below a permitted cap would be allowed as an alternative to the prohibition; and
Require more stringent controls for tank fittings on floating roofs, including slotted guide poles and other openings.

A public comment period ends February 12. Public hearings have been proposed, including two in Houston on January 29th. The proposed rule adoption date is May 23, 2007 with a required implementation date of January 1, 2009.

An Executive Summary of the proposed rule is attached. This, plus the proposed rule and details on five public hearings may be found under

Rule Project Number 2006-038-115-EN (Approval Date 12/13/06) at the following website: http://www.tceq.state.tx.us/rules/prop.html.

TCEQ REQUEST FOR COMMENTS:

Comments have been requested on these issues within this proposed rule, among others:

The rule would specify that a floating roof must be kept floating on the liquid surface at all times except when it must be supported by its leg during initial fill and other limited circumstances. Such circumstances would include required inspections or maintenance, or for a change in service between incompatible liquids. The term incompatible is to describe to "a material that would be contaminated by the previously stored material." Thus, per TCEQ, one gasoline with a lower Reid vapor pressure (RVP) in compliance with applicable fuel requirements would be considered incompatible with a higher, noncompliant, RVP gasoline." The commission seeks comment on this definition. In particular, TCEQ seeks comment on how to address "compatibility" switching between materials owned by different entities.
An alternative to the proposed "landing ban" requirements would provide a compliance option where a site-wide floating roof emissions cap could be established. TCEQ seeks comment on whether this is appropriate for the purpose of reducing roof landing emissions. TCEQ also seeks comment on additional exemptions to the proposed ban on convenience landings, and on other approaches to decrease emissions from tank landings.

Texas Emissions Reduction Plan (TERP)

TexAQS II 2006 Emission Fly-Over

RELATED ILTA ARTICLES

ILTA provides a monthly newsletter to its membership. Members may log in to the Member Resources page to access archived newsletters. The following is a list of articles ILTA has published in its newsletter relating to state issues in Texas.

May 2006

TCEQ to Engage in Emission tracking Fly-Over Activities (p.3)

September 2005

TCEQ Conducts Air-Quality Research Using Infrared Cameras in Houston Area (p.5)