BBBBBB Emissions Testing
This form of emission testing is named 40 CFR Subpart BBBBBB of the National Emissions Standards for Hazardous Air Pollutants (NESHAP). Let’s examine what this rule requires, who is subject to it, and how our experienced team at Erthwrks can provide the necessary testing procedures.
The rules and standards of Subpart BBBBBB apply to bulk gasoline plants and terminals, pipeline pumping stations, and pipeline breakout stations. It includes specific emission limits and management practices for dealing with equipment leaks, storage tanks, storage railcars and tank trucks. According to the EPA, these standards should result in an overall emissions reduction of 22 percent. Unfortunately, some 14,000 facilities that fall under the categories still need to take additional corrective measures to control their emissions.
The specific requirements for these operations depend on the operator’s daily storage and distribution. For instance, bulk gasoline plants that store or move less than 20,000 gallons per day must use submerged fill routines with discharge levels of either 6 inches or 12 inches from the bottom of the tank (depending on when the pipes were installed). Bulk gasoline terminals of over 75 cubic meters’ capacity must keep the HAP emissions of gas loaded into their cargo tanks at 80 milligrams or less per liter.
Erthwrks can help your organization bring itself into compliance and demonstrate continued compliance with 40 CFR Subpart BBBBBB. We can test your storage tanks’ closed vent systems and controls, monitor your operating parameters, test the loading rack controls to demonstrate their emission level compliance, and inspect structures such as storage tank roofs and seals for any leaks or other issues that require correction.
Stationary Engine Testing
- 40 CFR Part 60 Subpart JJJJ – NOx, CO, and VOC testing
- Pre and Post Catalyst testing for pollutant reduction usually via 40 CFR Part 63 Subpart ZZZZ – Formaldehyde (HCOH) and CO reduction efficiency
- Permit by Rule/Source Performance Guarantees
- Volatile Organic Compounds (VOCs) and Total Hydrocarbons (TOC) results via:
- EPA Method 7E: Nitrogen Oxides (NOx)
- EPA Method 10: Carbon Monoxide (CO)
- EPA Method 18: Gas Chromatograph (GC) Analysis
- EPA Method 25A: Flame Ionization Detection (FID) Analysis
- EPA Method 320 or ASTM D6348-12: Fourier Transform Infrared Spectroscopy Analysis
- EPA Method 323: Fourier Transform Infrared Spectroscopy (FTIR) (methods listed above)