New Tank Regulations

On September 30th, 2022, the United States Environmental Protection Agency (EPA) published its Limited Approval, Limited Disapproval of the California Air Plan Revisions issued by the California Air Resources Board (CARB). The EPA has rejected CARB’s demonstrations of reasonably available control technology (RACT) for the 2008 and 2015 ozone National Ambient Air Quality Standards (NAAQS) for tanks subject to U.S. EPA’s 2016 Oil and Gas Control Techniques Guidelines (CTG). The demonstrations relied on South Coast AQMD Rules 463 – Organic Liquid Storage and 1178 – Further Reductions of VOC Emissions from Storage Tanks at Petroleum Facilities to demonstrate compliance. However, RACT deficiencies were identified in both rules with respect to their alignment with the U.S. EPA’s Oil and Gas CTG.

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