Today, U.S. Environmental Protection Agency (EPA) Administrator Andrew Wheeler announced a proposal that offers regulatory flexibility to petroleum, chemical, and coal products manufacturing facilities, as well as petroleum bulk stations and terminals by amending Clean Air Act regulations to allow an alternate, less cumbersome mode of inspection for certain liquid storage vessels (tanks). This proposal would offer flexibility for more than 3,500 storage vessels to conduct “in-service” rather than out-of-service inspections. The Agency estimates this proposal could save $768,000 – $1,091,000 in regulatory costs annually and reduce emissions of volatile organic compounds by as much as 83-tons per year.
“This commonsense method of inspection not only reduces emissions of air pollutants, it also saves our vital domestic energy industry valuable time and resources,” said EPA Administrator Andrew Wheeler. “This action by EPA further demonstrates President Trump’s commitment to environmental protection while promoting America’s energy dominance.”
“The EPA rule announced today is a common-sense solution that will lower emissions, ensure safety and provide operators with increased regulatory flexibility. By allowing greater use of a well-established, safe and effective inspection method, this new policy is a meaningful contribution to our shared goal of environmentally responsible facility management,” said ITLA President Kathryn Clay. “ILTA and its members appreciate EPA’s efforts to address an issue that became especially challenging in recent months due to the pandemic-related imbalances in petroleum and fuels markets that constrained the storage sector.”
The current inspection method sometimes required under New Source Performance Standards (NSPS) Subpart Kb is expensive, labor intensive, and results in volatile organic compound air emissions and other pollutants from venting and flaring. The proposed amendments will both reduce burdens for these businesses and reduce emissions.
The proposal would allow owner/operators of certain large tanks known as Volatile Organic Liquid Storage Vessels to conduct less cumbersome “in-service” inspections of the tanks, without emptying and degassing the storage tank. Since 2018, EPA has received more than 300 requests from facilities seeking permission to conduct roof-top, also known as in-service, inspections to demonstrate compliance with a 1987 Clean Air Act regulation. These one-off requests are time consuming and burdensome for both tank owners and operators and for EPA. Further, EPA understands that in recent months inspecting these large tanks from the inside has become more challenging because there is a significant increase in the need for liquid storage capacity (particularly crude and petroleum products), due to slower consumer demand.
In 1987, EPA promulgated New Source Performance Standards Subpart Kb which applies to large storage tanks that store volatile organic liquids across a variety of industries, such as petroleum refineries, chemical plants and portions of the oil and gas industry. To reduce volatile organic compound emissions from storage vessels, NSPS Kb specifies, for certain tanks in certain circumstances, out of service inspections for holes and tears at least once every 10 years, as well as monitoring, recordkeeping, reporting, and other requirements to ensure compliance with the standards. In 1999, EPA finalized the National Emission Standards for Hazardous Air Pollutants (NESHAP) WW for storage vessels that, in certain circumstances, allow for less cumbersome in-service inspections, without emptying and degassing the storage tank. This proposal would allow compliance with NESHAP WW in lieu of compliance with NSPS Kb for storage tank inspection.
More information, including pre-publication versions of the Federal Register notices and related fact sheet, is available at https://www.epa.gov/stationary-sources-air-pollution/volatile-organic-liquid-storage-vessels-including-petroleum-storage