Continuous Emissions Monitoring Systems
Bring Your VRU Into Compliance With EPA Regulations
On July 8, 2024, new and modified EPA rules were finalized that require bulk gasoline terminals with vapor recovery units (VRUs) to install and operate continuous emissions monitoring systems (CEMS) that meet strict performance standards and emissions limits. Non-compliance isn't just costly, it can shut down operations. Zeeco helps you act now with expert CEMS retrofit solutions engineered for rapid deployment and guaranteed regulatory alignment. From TOC monitoring and performance spec compliance to turnkey system integration, Zeeco gives you the technical edge to stay ahead of enforcement deadlines and avoid penalties.
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Subpart XXa CEMS Requirements for VRUs
- Compliance Date: Affected facilities must be in compliance now
- Applies to: bulk gasoline terminals constructed, modified, or reconstructed after June 10, 2022.
- Installation and Operation: Facilities using VRUs must install, calibrate, operate, and maintain a CEMS to measure the concentration of TOCs in the atmospheric vent from the VRU
- Performance Specifications: The CEMS must comply with Performance Specification 8 and 8(a) of appendix B, quality assurance requirements in Procedure 1 of appendix F, and procedures under §60.13
- Monitoring Location: The sampling probe or other interface must be located at a measurement location that provides representative measurements of emissions from the VRU
- Emissions Limitations: Newly constructed gasoline loading rack affected facilities must maintain VRU atmospheric emissions at or below 550 ppmv of TOC as propane, determined on a 3-hour rolling average. Modified or reconstructed gasoline loading rack affected facilities must maintain VRU atmospheric emissions at or below 5,550 ppmv of TOC as propane, determined on a 3-hour rolling average.
Subpart BBBBBB CEMS Requirements for VRUs
- Compliance Date: May 8, 2027
- Applies to: Carbon adsorption vapor recovery systems at bulk gasoline terminals
- Installation and Operation: Facilities must install, operate, and maintain a CEMS to measure TOC concentrations in the exhaust air stream. The CEMS must comply with the performance specifications of Subpart XXa.
- Emissions Limitations: Facilities with carbon adsorption systems, refrigerated condensers, or other vapor recovery systems must reduce TOC emissions to less than or equal to 19,200 ppmv as propane, determined on a 3-hour rolling average. This measurement should encompass all periods when the vapor recovery system is capable of processing gasoline vapors.
Subpart R CEMS Requirements for VRUs
- Compliance Date: May 8, 2027
- Applies to: Bulk gasoline terminals with carbon adsorption systems and refrigeration condenser systems
- Monitoring Requirements: Facilities must implement continuous emissions monitoring systems in the exhaust air stream
- Emissions Limitations: VRUs must keep emissions at or below 5,500 ppmv of TOC as propane, determined on a 3-hour rolling average when the system is operating.
- Recordkeeping and Reporting: Facilities must maintain records and submit reports detailing CEMS data and any excess emissions events