In use today for many analyzer applications is some type of fugitive emissions mitigation hardware. This hardware is used to eliminate fugitive hydrocarbon emissions after the sample passes through the analytical system before being introduced back into the environment. Very simply, this hardware is design to convert hydrocarbons into CO2 and Water vapor.
Depending on the service the emissions control hardware is used, periodic and frequent testing may be required. For example, per TCEQ Regulation 115, emissions control hardware used to eliminate highly reactive volatile organic carbons (HROVC’s) after the analytical system must meet and satisfy VOC vent gas rule requirements, thus testing would need to comply with 30 TAC §115.125 test requirements. Testing must be done per EPA Test Methods 18, 25, 25A, and 25B. Minor modifications to the test methods can be approved by the TCEQ regional office. For emissions control hardware not used in TCEQ Regulation 115 service, an oxidizing control device placed on the analyzer vent gas stream would be an applicable unit in Chapter 117 in the Houston-Galveston-Brazoria and Dallas-Fort Worth ozone nonattainment areas and may be subject to testing.
To assist our Clients with the proper and correct testing of these engineered emissions control devices currently in service throughout the greater South Texas area, Smith Analytical is pleased to offer our Clients testing services on this hardware. Depending on the application and service of the existing emissions control hardware, the test could be as simple as measuring the effluent with a portable flame ionization detector or could involve collection of the sample from the emissions control hardware into a summa canister or Tedlar® bag in order that the required EPA test method be performed off-site. Testing of these devices is done from grade using proprietary collection hardware designed and tested by Smith Analytical. As each unit is tested during the first step of the testing process, we can determine immediately if the vent control device is working properly with EPA / TCEQ approved equipment. If no emissions are observed, then no additional action is required. If the vent control device is in an HRVOC service and hydrocarbon emissions are seen with the portable instrument, then additional offsite testing must be done to comply with TCEQ Regulation 115. If the system is found to be inoperable, improperly installed or the design parameters exceeded, Smith Analytical can assist with repairs or proper installation of the hardware.