ENV-16-7 Hot, Heavy Breathing and Other Bad Tank Behavior

Description:

Since 2015, the United States Environmental Protection Agency (US EPA) has been investigating vapor pressure and emissions related to heated heavy fuel oil and asphalt storage tanks. US EPA asserts that emissions from heated heavy product storage tanks historically have been underestimated and is questioning its own methodology for estimating emissions from these tanks. In some cases, the US EPA’s TANKS 4.0.9d program1 can underestimate emissions from heated heavy product storage tanks by a factor of 300, as presented in the paper below. US EPA has asserted in some cases that properly estimated emissions would have triggered New Source Review (NSR) permitting and other regulatory burdens. This paper, and resulting poster session presentation, will discuss the current status of the enforcement initiative and concerns related to estimating emissions and determining vapor pressure in heated heavy product storage tanks. Specifically, this paper will discuss the following: 1. Estimating vapor pressure of heated heavy products; 2. Modeling emissions from heavy product storage tanks; 3. Insight from US EPA enforcement and Section 114 information requests; and 4. Future activities and considerations.