EPA Updates Storage Tank Emissions Requirements
The U.S. Environmental Protection Agency (EPA) has recently released updates and clarifications of the cost-effective regulations and standards to reduce air pollution from oil and gas storage tanks used in many industries like oil and natural gas.
The proposed updates in this blog include the first federal air standards released for natural gas wells that are hydraulically fractured, along with requirements for storage tanks and other standard equipment.
On July 1, 2014, the U.S. Environmental Protection Agency (EPA) proposed clarifications and updates to New Source Performance Standards for the oil and natural gas industry laid out in 2012. The proposal responds to many requests for clarification and issues raised in administration petitions for reconsideration. The updates will take place over a period of time and will begin with high-emitting tanks first, which will provide needed time to prepare for new production and installations.
The proposed Oil & Gas Tank updates are:
- Provide additional details about the requirements needed for handling of liquids during well completion operations
- Clarify requirements for storage tanks
- Define low-pressure wells
- Clarify the critical requirements for leak detection at natural gas processing plants
- Update the requirements for reciprocating compressors
- Update the definition of “responsible official.”
Before moving towards the EPA’s new proposed rules let’s take a step back and look at the previous regulations laid out for federal air standards.
- On April 17, 2012, as per the Clean Air Act – EPA issued many cost-effective regulations to reduce harmful and poisonous air polluting gases from the oil and natural gas industry, while allowing responsible and continued growth in U.S. oil and natural gas production. The final set of rules included several of other sources of pollution in the oil and gas industry that were not previously regulated at the federal level, and the first federal air standard for natural gas wells that are hydraulically fractured.
- On August 2, 2013, EPA updated the standards for storage tanks to ensure that the tanks should control the highest emissions first, while providing tank owners and operators time to purchase and install Volatile Organic Compound (VOC) controls.
Updates and clarifications to storage tanks requirements
EPA has proposed several new updates and clarifications for the storage tanks requirements in the oil and gas industry. They are:
- Determining potential emissions: The proposal would clarify that the Volatile Organic Compound (VOC) emissions that are captured as a result of permit requirements do not count towards determining whether a tank is subject to emission control requirements under these air regulations.
- Thief hatch requirements: EPA is proposing to allow other mechanisms besides weighted thief hatches to ensure that the hatch lids remain properly sealed.
- Notification requirements: EPA has also proposed that the dates of a storage tank to be included in the notification requirement when it is removed and added in the field of service, and it should also be included in the operator’s annual report.
The EPA has created a five page “fact sheet” as a quick reference guide for the updated tank emissions requirements. The agency has also stated that the EPA “received several petitions asking that the agency reconsider this requirement, based on the large number of storage tanks affected each year and the remoteness of many of the well sites where the tanks are located. EPA is continuing to evaluate this issue and will address it by the end of 2014.”
The proposal and additional information for EPA’s air regulations for the oil and natural gas industry are available at http://www.epa.gov/airquality/oilandgas.
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