EPA released new proposed rules for VOC Performance Standards for storage tanks used in oil and gas production. The VOC Rules issued in 2012 came under attack from industry as not feasible or unreasonable. The proposed rule issued on March 28, 2013 addresses some of those concerns. EPA stated it plans to continue revisions during 2014.
What’s important to know is that the proposed rules are scheduled for final action by the end of July, and we now have until April 28, 2013 to make any comments on the current proposal.
Changes in the oil and gas industry have stimulated this re-look at requirements. Basically, EPA has realized that the intense growth in production and increase in storage tank numbers and size will result in a shortage of control equipment that had been called for by the 2012 rules. The changed approach creates two tracks for compliance, based on when a tank comes into service. There is also an alternative compliance demonstration available. Initially tanks had to demonstrate that VOC emissions were reduced by 95%. Now owners or operators can demonstrate that emissions from a tank have been reduced to less than 4 tons per year of VOCs without emission controls for at least the prior 12 months.
Other adjustments include lengthening the period for preparation of an annual report of well completions and storage tanks to 90 days from the initial 30 day period and developing an inspection protocol for tanks with controls.
Aspects not yet addressed include the requirement that owners/operators use a continuous parametric monitoring system (CPMS) to demonstrate compliance.
Action to review and comment on the proposed changes must happen NOW! And stay tuned for the 2014 revisions as well.