Airborne Emissions from Storage Tanks: What's New on the Regulatory Front and How to Cope with the Changes

Abstract

The U.S. EPA is developing new maximum achievable control technology (MACT) rules, which include provisions for aboveground storage tanks (AST's). While each industry category will have its own MACT rule, the trend for storage tank requirements is evident in rules recently promulgated for the chemical manufacturing (1), petroleum refining (2), and gasoline distribution industries (3). In addition to the new MACT rules, EPA is requiring new permits. The long-standing construction permit program was only triggered by new construction, but major sources (as defined by EPA) will be required to obtain the new permits just to operate. The application for these operating permits must include an estimate of air emissions, and EPA has released new equations and loss factors for estimating storage tank emissions. This paper will address the storage tank provisions of these new rules, as well as the new methods of estimating emissions from storage tanks.