2017 Alliance Expo and Annual Meeting

April 25 - 26, 2017 Wichita Falls

TCEQ Clarifies NSPS OOOO Requirements

After further evaluation and review of 40 CFR 60.5365(e) and EPA’s Response to Comments on the amendment to NSPS OOOO regarding storage vessel affected facilities, if an owner or operator complies with the specific rule requirements* and determines that the emissions from a tank (uncontrolled) are less than 6 tpy, the tanks would not be subject to NSPS OOOO requirements.  No certification of the tank emissions is required, however it is recommended that owners and operators maintain a copy of the calculations as documentation.

When tanks are authorized by a PBR, and controls (flare, combustor, etc.) are used to limit tank emissions so that they are below the 6 tpy threshold for NSPS OOOO applicability, certification is required consistent with 30 TAC section 106.6.  An APD certification may be filed to establish the federally enforceable limit in compliance with 40 CFR 60.5365.

In addition, when a VRU is being used to recover VOC emissions from the tanks and this results in tank emissions below 6 tpy, no certification is required; however, all monitoring and recordkeeping requirements must be met as stated in 60.5365(e)(1-4).

*Specific Rule Requirements: 40 CFR 60.5365 The potential for VOC emissions must be calculated using:

1. A generally accepted model or calculation methodology, and site specific or equivalent product composition. TCEQ calculation methodologies can be found by following these links:

a. Emissions Calculation Spreadsheet
b. Representative Analysis Criteria
c. Air PBR 106.352: Oil & Gas Handling and Production Facilities

2. Be based on the maximum average daily throughput determined for a 30-day period of production prior to the applicable emission determination deadline specified in this section.

Editor’s Note: The preceding information was sent to the Texas Alliance by the TCEQ.