On August 2, 2013, the U.S. Environmental Protection Agency (USEPA) issued updates to the April 2012 oil and natural gas standards for storage tanks. The rule applies to storage tanks constructed after Aug. 23, 2011 and are used to store crude oil, condensate, unrefined petroleum liquids known as “intermediate hydrocarbon liquids,” or produced water. Storage tanks subject to NSPS (have a potential to emit six or more tons of volatile organic compounds [VOC] a year) must reduce emissions by 95 percent. The updates include the following:
- Phase in the date by which storage tanks must install VOC controls
- Establish alternative emission limits for tanks where emissions have declined
- Clarify test protocols for control equipment
- Clarify the types of tanks subject to the rule
- Streamline compliance monitoring requirements to ensure leaks are repaired while USEPA addresses monitoring issues raised in reconsideration petitions
- Adjust requirements for submitting annual reports.
Compliance deadlines include the following:
- Tanks that come online after April 12, 2013 are likely to have higher emissions and must control VOC emissions within 60 days or by April 15, 2014, whichever is later
- Tanks that came online before April 12, 2013 are likely to have lower emissions and must control VOC emissions by April 15, 2015.
Additional standards of the rule also allow an alternative emissions limit that would permit owners/operators to remove controls from tanks if they can demonstrate that the tanks emit less than four tons per year of VOC emissions without controls for twelve consecutive months. Owners are still required to evaluate emissions monthly to ensure emissions are below four tons.
The docket for this rule is Docket ID No. EPA-HQ-OAR-2010-0505 and can be accessed at http://www.regulations.gov. For more information about this rule, go to http://www.epa.gov/airquality/oilandgas/actions.html.
EHS Support can help your company by providing expertise for air permit applications, technical support, or auditing. Please contact our Technical Expert, Peter Okonski at peter.okonski@ehs-support.com or (225)324-1309.
