ENV-11-41 Quantifying Inaccuracies and Categorizing Risk for TANKS4.0 Errors in Organic Liquid Storage Tanks Emissions Estimation

Description:

Guidance for Component II of the recent US Environmental Protection Agency (EPA) Section 114 Information Collection Request (ICR) demonstrated a new level of sophistication from the agency in terms of their understanding the weaknesses and inaccuracies associated with the EPA TANKS 4.09d (TANKS) program. Specifically, the EPA has now set the precedent of actively disallowing the use of TANKS for demonstrating compliance with vapor pressure requirements, calculating monthly emission rates, and calculating emissions from tanks storing heated products. This paper will quantify the differences between TANKS and AP-42 calculation methods for a series of representative tanks and their corresponding products for both monthly emissions and emissions from heated products. The reader should be able to intuitively rank these differences in terms of enforcement risk for a typical refinery tank farm.