EPA testing has suggested that actual storage tank emissions are higher than reported. As a result, the EPA has proposed the Next Generation Compliance document that has significant impacts on hazardous air pollutant (HAP) storage tanks in a wide range of industries.
The Next Generation Compliance document presents areas in which the EPA will focus their attention to strengthen compliance strategies by means of regulatory overhaul, increased monitoring programs, and innovative enforcement strategies. The EPA's focus on tanks has been spurred by violations resulting from design flaws, inadequate maintenance procedures and emission controls, and deficient monitoring techniques. Recent enforcement settlements have resulted in multi-million dollar fines for these facilities and have required costly equipment modifications. With such high potential settlement costs, it has become more important than ever to have a robust compliance program.
The upstream, midstream, and downstream sectors of the oil and gas industry all include storage tanks containing HAPs. The EPA's Next Generation Compliance plan will scrutinize sites with HAPs storage tanks and will disproportionately affect the oil and gas industry due to its relatively large number of storage tanks. Consequently, it is important for these sites to ensure storage tank emissions are accurately estimated and in compliance. This paper will investigate strategies and present methods for sites with storage tanks to ensure compliance.