Houston/Galveston, Texas is the Front and Center Genesis in Highly Reactive Volatile Organic Compound (HRVOC) Emissions Reduction Spending

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Written by William Whitney, Senior Correspondent for Industrialinfo.com (Industrial Information Resources, Incorporated; Houston, Texas). Highly Reactive Volatile Organic Compounds (HRVOC) emissions have in recent years become a widespread industrial and legislative concern, relegated to individual state governments by the federal Environmental Protection Agency's (EPA) National Ambient Air Quality mandates. In the most simplistic form, these related air quality issues and monitoring processes strive to reduce ground level ozone.

And that's where the simplicity stops. While there is very little, if any, overlap between the individual states’ and federal government’s roles, the initial activity is driven by the EPA in identifying "non-attainment" areas that have tested with unsatisfactory levels of identified pollutants. Interestingly enough, as a result of the individual states' autonomy to prescribe compliance methods (to the EPA levels), the solutions may be somewhat unique from state to state - as in the case of high level non-attainment zones such as Houston/Galveston, Texas, moderated by the Texas Commission on Environmental Quality (TCEQ) and Baton Rouge, Louisiana. Seemingly, the end justifies the means.

Pollutants are measured against the EPA standard PM-10 (Particulate Matter), so-called, as it refers to matter measuring 10 micrometers or more in width (about one-seventh of a human hair).

The Texas case study is notable, with some 23 designated non-attainment counties, ranked by severity, as marginal, moderate, serious, severe, and extreme. In fact, there are presently well over 450 such designated counties in 31 U.S. states. It is, as well, big business for engineering firms, equipment purveyors, and contractors.

The Texas Administrative Code might generally be considered both the beginning and the end of all things HRVOC – most notably, Title 30, Chapter 115, et al. The "rules" process is not for the faint of heart, as they are under continuous scrutiny, revision, and adaptation, in an effort to firmly establish workable and effective testing, monitoring, and reporting directives. The ongoing recordkeeping and validation addressing permitting, licensing, compliance verification, and dispute resolution can make ISO 14000 look like a stroll in the park.

According to Ashley Forbes, TCEQ Air Quality Planning Section, Policy Coordinator with the HRVOC…” Monitor testing compliance deadlines for flares, cooling towers, and vent gas controls are 31 December 2005, while the testing compliance deadline for fugitive emissions passed in March 2004.

Modern technology has a big footprint in the century old refining, manufacturing, and generation industries. Eclectic scientific formulas drive a myriad of sophisticated equipment required for HRVOC emissions monitoring, such as flow monitors that measure flow rate, velocity, ambient temperature, and pressure. New acronyms, such as CEMS (Continuous Emissions Monitoring Systems), CEIS (Computerized Emissions Inventory Systems), CFMS (Continuous Flow Monitoring Systems), now join Online Analyzers and the like in the new world of old industry.

Industrialinfo.com has identified 127 plant sites in the Houston/Galveston eight county region, which will be impacted by the HRVOC rulings. Each site could have multiple applications. Capital spending in the Houston/Galveston area for HRVOC compliance easily surpasses tens of millions of dollars, and could approach hundreds of millions over the course of time.

Click on the image at right to view the Houston-Galveston Area Industrial Plant HRVOC Emissions Reduction Map.

To obtain a list of these 127 plant sites including plant contact names, addresses, and phone numbers, contact Industrialinfo.com’s Member Center at 1-800-762-3361.

TCEQ's Ms. Forbes is equally positive with regard to the stakeholder process saying, "We have cast a wide net in using these open public meetings – the first of their kind, resulting in cutting-edge regulation that has and is being developed from the input of industry, vendors, private citizens, and the environmental community."

And it would appear to be working with more than one hundred participants from environmental groups, the general public, and big players you would expect to see, such as BASF (NYSE: BF) (Mount Olive, New Jersey), Goodyear (NYSE:GT) (Akron, Ohio), BP (NYSE:BP) (Chicago, Illinois), Texas Petrochemical (PNK:TXPI.PK) (Houston, Texas), and ExxonMobil (NYSE:OXM) (Fort Worth, Texas).

So, what are all these little nasties, and how do they get into our air. In the case of HRVOCs, the primary culprits are ethylene, propylene, 1,3 butadiene, and a group consisting of butane isomers – not exactly household words. There is a dichotomy, in that Harris County (Houston) identifies all four pollutants, while the remaining counties (Brazoria, Chambers, Fort Bend, Galveston, Liberty, Montgomery, and Waller) in the Houston/Galveston case study identify only ethylene and propylene – according to informed sources.

The major sources of discharges come from flares, cooling towers, vent gas streams, and fugitive emissions (valves, pumps, connections, etc.). This is where the highly reactive (HR) comes into play with the volatile organic compounds (VOC) in a catalytic mix in the air - exacerbated by Mother Nature and sunlight. This unhealthy potion is often generically called NOx, which refers to gases of a mixture of nitrogen oxides.

Senior Engineer Chris Bauer, CSP, P.E., at the Austin, Texas, based environmental compliancy firm of Waid & Associates, has a cat bird seat, as his firm specializes in both permitting and compliance, as well as several other environmental areas. Queried about the Stakeholder provision, which allows industry, the general public, and the regulators themselves to participate in the overall TCEQ rules process, he observes, "It is successful in that it allows a point of view to arise in the initial pre-regulation process – not as an after the fact issue."

Additionally, Mr. Bauer points to a somewhat unique proposed provision within the TCEQ program called Mass Cap & Trade Program (administered by TCEQ Emission Banking & Trading Team), which will allow offending plants to buy additional compliance tonnage from other entities. In example, while still in the proposal stage, the general rule of thumb is widely held at ten tons of discharge being allowable per year, dependant upon the individual site, with final regulatory approval. Under the trade program it will be possible for a facility with a compliance problem (anticipated overage) to acquire (purchase) additional overage units without affecting the overall total emissions, which is almost always a regional issue. The end justifies the means – again!

This much is sure – the landscape isn't changing all that much, but the way we collectively deal with HRVOC, NOx, and near ground ozone is likely to become a continued heavy expense for industry and an increasing growth market for purveyors seeking new-found sales revenues in allotted capital spending.