The Environmental Protection Agency (EPA) updated its requirements on August 2, 2013, for Volatile Organic Compounds (VOCs) emissions from storage tanks, which are primarily used by the oil and natural gas industry.

This update is a part of the VOC performance standards for storage tanks, which was published in 2012. A key component of the 2012 rules mandates hydraulically fractured wells undergo “reduced emissions completion” or “green completion” by 2015 in order to capture gas that generally escapes into the atmosphere during drilling.

Additionally, the 2012 rules stipulated certain storage vessels reduce VOC emissions by 95 percent by October 15, 2013. Based on supplemental information received after adoption of the 2012 ruling, the EPA does not think there will be sufficient control equipment to meet this deadline and have therefore, revised and updated the rules. Some major revisions include:

Clarifying the types of storage tanks that are subject to the rule. Tanks are considered “affected facilities” if they:

  • Were constructed after August 23, 2011
  • Have potential VOC emissions of six tons or more per year
  • Are used to store crude oil, condensate, unrefined petroleum liquids, or produced water

Phasing in the date of compliance

  • April 15, 2014 for tanks that come online after April 12, 2013, or within 60 days after startup
  • April 15, 2015 for tanks constructed between August 23, 2011 and April 12, 2013

Providing alternative emissions limits

  • If reducing VOC emissions by 95 percent, or
  • If demonstrating emissions from a tank have dropped to less than four tons per year of VOCs without emission controls.

This new ruling, as well as other changes concerning air emissions can be found at: http://www.epa.gov/airquality/oilandgas/actions.html

As with most rules and regulations, there are many more details that cannot be briefly summarized. We encourage you to research these new rulings and determine how they may impact your operations. As always, feel free to contact RS&H with any questions regarding these or any other environmental related concerns.

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Kate Lindekugel

Kate Lindekugel

Environmental Specialist II at RS&H, Inc.

As an environmental scientist, Kate has more than 13 years of experience including ecological surveys and field studies, functional assessments, preparing environmental reports and permits, data management, stream channel and wetland restoration, peer reviewed research, and coordinating with local, state, and federal regulatory agencies, as well as public and private stakeholders.

Contact Kate: Kate.Lindekugel@rsandh.com

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