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New EPA standards for oil and natural gas storage tank venting systems

October 2, 2024
New EPA standards for oil and natural gas storage tank venting systems

Part of our job as air quality consultants is keeping up with—and deciphering for our clients—the ever-expanding New Source Performance Standards (NSPS) and Emissions Guidelines (EG) under 40 CFR Part 60 regulating the oil and natural gas industry. The U.S. Environmental Protection Agency (EPA) regulates production and processing, as well as natural gas transmission and storage, through these rules.

A development catching our eye recently concerns closed vent systems (CVS), the infrastructure that captures and routes the dissolved gas that builds inside storage tanks. In two recent cases, the EPA issued consent decrees mandating that facility operators either prove the CVS is operating as required or make design changes to improve their performance. Additionally, standards for new facilities under Subpart OOOOb and existing facilities under Subpart OOOOc will soon expand requirements to all facilities that otherwise meet the applicability criteria of the rules.

The good news? Like many things involving environmental regulations, sound planning and good engineering can mitigate your compliance risk.

The evolving nature of federal standards combined with technological advances making it easier for the EPA to enforce these rules suggest that the industry will bear a greater burden to prove their CVS is meeting performance standards. It is also likely that consent decrees like the two recent ones will become more frequent as facilities get up to speed with the evolving regulations.

The good news? Like many things involving environmental regulations, sound planning and good engineering can mitigate your compliance risk.

While Subpart OOOOc and the recent consent decrees are relatively new developments, air quality compliance and permitting support is a foundational part of our work for oil and gas clients. Our air quality team of more than 70 professionals works across the U.S., and we offer staff to provide engineering design as well as environmental support for these projects, a rare combination for our industry. We have worked on behalf of the facility owner, performing CVS assessments and providing the resulting design. We’ve also provided third-party assessments to verify designs completed by others.

Regulatory background

Let’s take a step back and look at the chemical process and the regulations governing how to manage it.

When crude oil is extracted from a well field and moved to a storage tank, dissolved gas builds up and looks for a way out. Closed vent systems provide a safe escape hatch for those vapors, capturing them and routing them to a control device, where they are burned off.

Since September 18, 2015, NSPS Subparts OOOOa and OOOOb have required new facilities to have an engineering assessment of the closed vent system and verify that it is performing as needed. If this required one-time assessment finds deficiencies in the CVS’ performance, the rules mandate that the owner make the necessary design upgrades.

The upshot: Soon, many more facilities will need to assess their CVS design.

Subpart OOOOc broadens the requirement to certain existing facilities not subject to Subpart OOOOb. The upshot: Soon, whether to respond to a consent decree or to comply with Subpart OOOOc, many more facilities will need to assess their CVS design.

Beyond the design assessments required under Part 60, regulators are taking a more proactive approach to enforcement. In 2019, the EPA started performing flyovers of oil fields, using remote sensing technology to look for emissions. At facilities where gases were detected from the sky, the EPA provided the information to the owners as evidence that the CVS was not performing properly. This was the trigger for several recent consent decrees.

CVS design, evaluation, and certification

Barr works with facilities to take a proactive approach to facility design, evaluation, and certification.

Facility owners and operators are required to incorporate OOOOb compliance and certification into new facility designs and existing facility modifications. Barr has acted as a trusted resource to design and certify CVS with a variety of emission control devices. A systematic and detailed approach is essential to evaluation and certification. Barr’s process is a seamless transition from data gathering, to analysis and guidance, and through certification. Whether a facility has been in operation for decades or the facility has not yet been constructed, Barr has the expertise to assist with emission control concerns.

EPA enforcement actions

If your facility is found to have excess emissions, the path forward to a consent decree typically includes two components.

If you’re faced with a consent decree, be proactive and be thorough.

First, you will need to assess the cause of the CVS’ shortcomings and either improve or replace the system. Then, an engineer independent of the design verifies the assessment and reports the findings to the EPA.

While negotiation of a consent decree can take years, expect a relatively short timeline from lodging of the consent decree to completion. Based on the precedent set by the EPA, a typical time window is 12 to 24 months.

If you’re faced with a consent decree, be proactive and be thorough.

Lasting solutions with Barr

Responding to a consent decree or heading one off altogether is important work, but it needn’t be daunting. Helping clients respond and adapt to the ever-evolving regulatory landscape is a core mission at Barr. We began serving oil and gas clients nearly 60 years ago, and today we apply broad engineering and environmental capabilities to solve complex challenges across the industry—from oil and gas fields to pipelines to terminals to refineries.

Our breadth and depth of experience is based on decades of work in the oil and gas industry and the experience of many of our staff who have served petroleum clients for decades. Our ability to bring multidisciplinary approaches to complex problems is based on our staff’s broad range of disciplines in over 40 practice areas and our approach to staffing project teams without internal barriers or gatekeepers.

Wherever you are in your compliance journey, traveling that road with Barr will optimize your outcome because we’re built to address the present and solve for tomorrow. Contact our air quality compliance team to get started.

About the authors

Tony Shoberg, vice president, senior chemical engineer, has nearly 20 years of experience working for liquids terminals and other oil and gas clients. His work involves developing permitting strategies, preparing permit applications and notifications required to site and construct new facilities and expand existing facilities, performing audits, developing compliance management plans and systems, and preparing permit applications and notifications required to site and construct new facilities and expand existing facilities. He has also provided on-site multimedia environmental compliance support.

Rachele Emineth, senior mechanical engineer, leads and supports multidisciplinary natural gas pipeline gathering projects, feasibility studies for midstream and downstream companies, pipeline relocations, and maintenance projects. Her work has ranged from the installation of retrofit leak-detection systems to the installation of gathering-system pipelines that involved permitting of highway and railroad crossings. Rachele has worked with third-party verification of consent decrees and closed vent system certifications. She has also been involved in developing teams within Barr to address upcoming vapor control concerns.

Tags:

EPA Fuels Air Quality natural gas Compliance Oil Closed Vent Systems Tank Emissions

 

Tony Shoberg headshot
Tony Shoberg
Vice President, Senior Chemical Engineer

 

Rachele Emineth headshot
Rachele Emineth
Senior Mechanical Engineer
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