FLIR technology helps identify emissions at fuel facilities
When regulating authorities enlist high-tech equipment to identify emissions, the best and perhaps only way to respond is with that same equipment and a contractor that not only knows how to use it, but also knows how to deliver solutions.
In 2019, the Colorado Department of Public Health and Environment (CDPHE) Air Quality Control Division (AQCD) amped up its enforcement at gasoline-dispensing facilities (GDFs) using Forward-Looking InfraRed (FLIR) cameras. Since then, the U.S. Environmental Protection Agency (EPA) has reclassified the Denver Metro Northern Front Range (DMNFR) as “Serious” non-attainment after ozone data between 2015 and 2017 failed to show attainment of the 2008 8-hour Ozone National Ambient Air Quality Standard (NAAQS) of 75 parts per billion (ppb).
CDPHE estimates 2,200 tons of volatile organic compounds (VOCs) are released into Colorado’s air annually when petroleum is improperly transferred from transport trucks to fueling facilities’ USTs. To combat this issue, CDPHE started using FLIR cameras in the spring of 2019 to observe emissions during the transfer of fuel. This resulted in the issuance of numerous violations for GDF owners/operators and/or transport companies not in compliance with the state’s air quality regulations.
Regulation 7 changes
On Dec. 19, revisions to sections of Colorado Regulation 7 were made in an effort to align with current federal requirements and clean up the state implementation plan (SIP). The goal is to improve Colorado’s air quality and meet the 2008 and 2015 NAAQS. Highlights of the revisions which apply to GDFs include:
- Vapor collection system is now defined as “a vapor transport system which uses direct displacement by the gasoline being transferred to force vapors from the vessel being loaded into either a vessel being unloaded or a vapor holding tank (Part B, Section IV.A.2.j).”
- Provisions that prohibit the transfer of petroleum from “any delivery vessel into any tank unless the tank is equipped with a submerged fill pipe and all vapors displaced in the tank are transferred to the delivery vessel being unloaded using a properly maintained, functioning, and leak-tight collection system (Part B, Section IV.B3.b).”
- All avoidable liquid and vapor leaks during petroleum transfers are prohibited (Part B, Section VII.B.1.c), which turns any emissions at a GDF into a violation fairly quickly.
Call a CGRS Expert:
An expert response
In response to increased enforcement and regulatory revisions, CGRS Environmental and Compliance Services have collaborated to help GDF owners/operators address fugitive emissions during fuel transfers. CGRS Environmental Services has inspected oil and gas facilities for fugitive emissions for years, while Compliance Services provides testing, repairs, and services for USTs and fuel systems. Our certified thermographers are equipped with the same FLIR technology as the AQCD and work with compliance experts armed with extensive knowledge of fuel systems and the ability to make repairs.
CGRS can help GDF owners/operators:
- Verify that they are in compliance with air quality regulations;
- Identify where leaks are coming from;
- Make the necessary repairs;
- Provide visual documentation that their vapor-control systems are functioning properly after repairs;
- Develop site-specific operating procedures for fuel transfer from transportation trucks to USTs;
- Properly maintain their fuel systems;
- Perform pre-CDPHE inspection services to ensure customers’ fuel systems are leak-tight during gasoline transfers and avoid potential violations and fines.
If equipment is properly maintained and the transfer of fuel is performed correctly, GDFs can avoid potential violations. Contact CGRS at 800.288.2657 to schedule a FLIR inspection for your GDF today!