In a news release, the Texas Chemical Council announced the following:
“TCEQ has notified TCC that beginning June 20, 2022, the agency will include new cooling tower boilerplate language in newly drafted special conditions for projects with affected cooling towers. The clarification is a result of multiple requests received during permit draft negotiations with applicants to clarify the sampling location.
Under the prior condition, TCEQ used the following language: “Cooling water sampling shall be representative of the cooling tower feed water and shall be conducted using approved methods.” The revised language clarifies the sampling point location to be taken from the stream entering the cooling tower which was the intent of the prior condition, but was not listed specifically.
The following is the new boilerplate condition for TDS:
A sample of cooling tower water shall be taken from the circulated water stream(s) entering the cooling tower. The analysis shall be conducted using the approved methods below:
(1) The analysis method for TDS shall be EPA Method 160.1, ASTM D5907, or SM 2540 C [SM – 19th edition of Standard Methods for Examination of Water]. Water samples should be capped upon collection, and transferred to a laboratory area for analysis.
(2) The analysis method for conductivity shall be either ASTM D1125-14 Test Method A (field or routine laboratory testing) or ASTM D1125-14 Test Method B (continuous monitor). The analysis may be conducted at the sample site or with a calibrated process conductivity meter. If a conductivity meter is used, it shall be calibrated at least annually. Documentation of the method and any associated calibration records shall be maintained.
(3) Alternate sampling and analysis methods may be used to comply with D(1) and D(2) with written approval from the TCEQ Regional Director. If approved by the TCEQ Regional Director, the permit holder shall submit a permit application to incorporate the alternative sampling and analysis method into the permit within 2 months of the date of written approval.
(4) Records of all instrument calibrations and test results and process measurements used for the emission calculations shall be retained.
Per TCEQ, the new clarified language notes that it should be the “circulated” water stream(s) entering the cooling tower. If the incoming make-up water stream is not a “circulated water stream,” then a sample is not expected. The incoming process water stream, prior to the point of any make-up water, is what should be sampled. Additionally, TCEQ clarified that in specific instances where the make-up water is coming from a source which would be expected to contribute significantly to the TDS in the cooling water system, the condition may be adjusted to include sampling it and will be discussed through the draft negotiation process on a case-by-case basis.”