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immediately report any release of a hazardous substance greater than its reportable quantity (RQ)
to the National Response Center (NRC). Reporting of CERCLA releases was intended to
provide the public with information regarding releases of the identified compounds in their
communities, and to assist the EPA in determining the need for additional regulations. The
CERCLA rules include a list of chemicals and classes of chemicals that must be reported, many
of which may be present in cooling water systems. For affected facilities, monitoring and
assessing cooling tower emissions is required to maintain compliance with the CERCLA rules.

Enforcement Provisions: The Clean Air Act Amendments of 1990 included new, enhanced
enforcement provisions for implementing the Clean Air Act. This includes civil penalties of up
to $25,000 per day per violation and Criminal Penalties of up to 5 years in jail, for knowingly
violating a provision of the Act.

Present Monitoring

Due to increasing of environmental concerns and impacts of the inherent cooling tower
problems, air and water discharge permits have become more stringent, and more online and in
situ continuous monitoring and sampling systems to reduce potential hydrocarbon leakage, pH
upset, excessive residual chlorine, temperature and organic discharge may be required.

A review of a recent air permit granted for a new petrochemical plant located in a non-
attainment area, the State of Texas (TNRCC) required that the plant's cooling water system must
be monitored for benzene and total organic carbon concentrations in the return cooling water.
The Operator has committed in the permit application that all exchangers containing cooling
water/hydrocarbons will use welded tube sheet construction to minimize possible leakage as
compared to potential leakage from the bolted flanges. This additional heat exchanger design
requirement thus became one of the special conditions and requirements in the approved permit.

Additionally the Operator is required to perform sampling of the cooling tower using an air
stripping device and other testing as necessary to establish the pounds per hour (lb/hr) of VOC
being emitted into the atmosphere from the cooling tower. The sample must be collected in a
sample bag (Tedlar bag) and analyzed by gas chromatography within 24 hours of sample
collection. The Permit has set a minimum detection level of the testing system, which is
equivalent to 0.015 ppmw concentration in water.

The VOC concentration (ppmv) in the exhaust from the air stripping testing system or equivalent
testing system and the corresponding pounds of strippable VOC per gallon of cooling water
should be reported. These will be used to determine the level (either ppmv or lb/VOC/gal) at
which a leak into cooling water will be assumed in the ongoing monitoring program. The
appropriate equipment must be maintained so as to minimize fugitive VOC emissions from the
cooling tower. The results of the monitoring and maintenance efforts must be recorded, and such
records must be maintained for a period of two years. The leak shall be repaired as soon as
practical but not later than 45 calendar days after the owner or operator receives results of
monitoring tests indicating a leak.

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