ENV-16-4 Application of RTR Rule Changes to Storage Vessels and Best Practices for Implementation

Description:

On September 29, 2015, the EPA issued a rule revision with potentially severe, widereaching consequences for the refinery sector. The Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards rule, made two significant changes impacting storage vessel applicability and compliance. First, it expanded the applicability of the Group 1 storage vessel classification. Second, and more importantly, the rule mandated new inspection requirements for storage vessels. While certain elements of the rule are clear and affect all facilities similarly, other requirements can only be implemented on a case-by-case basis, making it difficult to establish industrywide best practices. It has been left to facilities to choose which technologies and protocols are best suited to their particular case. This paper will first examine how the rule applies to storage vessels at all refineries, then move on to a case study review of the various tank types, fittings, and units impacted by the new rule. Lastly, we will present a decision-making tool to identify the most applicable maximum achievable control technologies (MACTs) for storage vessels and aid in quicker implementation.