                Control Device Requirements for Storage Vessels
                           Revised: October 8, 2015
                                       
Storage vessels reconnected to the original source of liquids or is used to replace any `affected' storage vessel, is considered an `affected' facility immediately upon startup/return to service, and is therefore subject to the control requirements of OOOOa.  Per 60.5360a(a)(3), refracturing of a well does not affect the modification status of storage vessels.
Initial compliance demonstration for storage vessels in 60.5410a(h) requires determination of VOC emissions within 60 days, reduce VOC emissions by 95%, meet the cover requirements of 60.5411a(b), meet the closed vent system requirements of 60.5411a(c), conduct initial performance test within 180 days of startup, submit annual report, and maintain records for 5 years.  Additional initial compliance in 60.5411a(b) & (c) requires that cover & openings must form a continuous impermeable barrier over the liquid, cover openings must be in a closed, sealed position (unless gauging, maintenance, unloading, etc.), must ensure that thief hatches remain properly seated and sealed, the closed vent system must be designed to route all vapors to the control device or a process, no visible emissions per OVA, must be operational 95% of the year or greater, and meet bypass device requirements (install meter and use an alarm or use a lock).
                                Control Device
                   Performance Specifications (60.5412a(d))
                Performance Testing Requirements (60.5413a(b))
                    Compliance Demonstration (60.5415a(e))
                     Inspection Requirements (60.5416a(c))
                     Monitoring Requirements (60.5417a(h))
Flare meeting 40 CFR 60.18(b)
   *    Operate in accordance with 40 CFR 60.18(b)
   *    Reduce the mass content of methane and VOC by weight >95.0%
   *    Operate at all times when gases, vapors, and fumes are vented from the tanks(s)

   *    Exempt from performance testing requirements provided you use a flare that meets 40 CFR 60.18(b)
   *    However, must still verify that there are no visible emissions using Method 22*
   *    Reduce VOC emissions by 95% within 60 days of startup
   *    Conduct monthly OVA*** inspection of covers & closed vent system to verify integrity (i.e. no  cracks, holes, liquid leaks, damaged gaskets, etc.)
   
   *    If cover or system has a bypass device, then install flowmeter with audible & visible alarm
                                      or
   Install car-seal or lock to secure bypass device in non-diverting position & visually inspect monthly to ensure valve in non-diverting position
   
   *    First attempt to repair leaks must be made in 5 calendar days, complete the repair w/in 30 days
   *    Operate & maintain per the manufacturer instructions
   *    Must have copies of manufacturer instructions

Combustion Device (non-manu-facturer certified)
   

   * Maintain in a leak free condition
   * Have a continuous burning pilot flame
   * Conduct 15 minute visible emissions test using Method 22* once every calendar month
   * If fail visible emissions test, repair per manufacturer instructions or maintenance plan
   * Keep records of repairs & maintenance
   * Following return to operation conduct visible emissions test

   *    Reduce the mass content of methane and VOC by weight >95.0%
                                      or
   Reduce concentration of TOC <=600 ppm
                                      or
   Operate at min temperature of 760°C for devices that can demonstrate a uniform combustion zone temp
                                      or
   If using boiler or process heater then introduce vent stream into the flame zone
   
      *    Operate at all times when gases, vapors, and fumes are vented from the tank(s)
   * Conduct performance test within 180 days after initial startup
   * Conduct subsequent periodic performance tests no longer than 60 months from the last test; periodic performance tests are not required if you establish a correlation between combustion chamber temperature & emission reduction performance level
   * Select appropriate sampling sites at the inlet and outlet of the device per Method 1 or 1A of Appendix A.
   * Use appropriate Method to determine stack gas velocity and volumetric flowrate per Method 2, 2A, 2C, or 2D of Appendix A
   * Use appropriate Method to determine percent emission reduction performance per Method 25A of Appendix A
   * Take at least 4 samples per hour

Boiler or process heater is exempt if:
   *    Vent streams are introduced with the primary fuel or used as the primary fuel
   *    Design heat input is > 44 MW
   *    Reduce VOC emissions by 95% within 60 days of startup
   *    Conduct monthly OVA*** inspection of covers & closed vent system to verify integrity (i.e. no  cracks, holes, liquid leaks, damaged gaskets, etc.)
   
   *    If cover or system has a bypass device, then install flowmeter with audible & visible alarm
                                      or
   Install car-seal or lock to secure bypass device in non-diverting position & visually inspect monthly to ensure valve in non-diverting position
   
      * First attempt to repair leaks must be made in 5 calendar days, complete the repair w/in 30 days
   * Conduct monthly visual inspection to confirm pilot lit, no visible emissions per Method 22*
   * Conduct OVA*** inspections to ensure overall system integrity (no leaks in vapor collection system, combustor operating properly)
   * Operate & maintain per the manufacturer instructions
   * Must have copies of manufacturer instructions
   * Conduct initial performance test, and subsequent periodic tests no later than every 60 months

Boiler or Process Heaters are exempt if:
   *    Vent streams are introduced with the primary fuel or used as the primary fuel
   *    Design heat input is > 44 MW
Manu-facturer Certified Combustion Device
   * Exempt from initial compliance requirements in 60.5412a, but still have to meet certain performance testing requirements in 60.5413a
   * Operate at all times when gases, vapors, and fumes are vented from the tank(s)
   * Exempt from performance testing & design analysis requirements
   * Inlet gas cannot exceed manufacturer recommended rates
   * Pilot flame must be present at all times of operation
   * Conduct 15 minute visible emissions test using Method 22* once every calendar month
   * If fail visible emissions test, repair per manufacturer instructions or maintenance plan
   * Keep records of repairs & maintenance
   * Following return to operation conduct visible emissions test
   * Maintain in a leak free condition

   *    Reduce VOC emissions by 95% within 60 days of startup
   
   *    Conduct monthly OVA*** inspection of covers & closed vent system to verify integrity (i.e. no  cracks, holes, liquid leaks, damaged gaskets, etc.)
   
   *    If cover or system has a bypass device, then install flowmeter with audible & visible alarm
                                      or
   Install car-seal or lock to secure bypass device in non-diverting position & visually inspect monthly to ensure valve in non-diverting position
   
      * First attempt to repair leaks must be made in 5 calendar days, complete the repair w/in 30 days
   *    Per 60.5417a(h), combustors that are manufacturer certified to 60.5413a standards are exempt from monitoring requirements provided they meet:
   o      the performance requirements of 60.5413a(d)(11) (no visible emissions, destroy THC, CO emissions <10 ppmvd, and have excess air >150%); 
   o      the reporting requirements in 60.5413a(d)(12) to submit results of test, schematics, max heating value, max inlet gas rate, test conditions, etc; and
   o      the continuous compliance requirements such as keeping inlet gas below max manuf certified, pilot present at all times, no visible emissions, be maintained leak free, etc.
Vapor Recovery Unit (This is not the same as a Vapor Recovery Device**)
Per 5365a(e)(3) do not need to do VOC PTE determination when using a VRU that captures vapors from the tank and routes them back to the process, provided you meet the cover requirements of 5411a(b), the closed vent requirements of 5411a(c) (which includes bypass device requirements to install flow meter and alarms or use locks), & maintain records to verify all of the above.

A VRU upstream of the tank that captures gas off a separator is not considered a control device and would not be subject to these requirements. 
Per 5365a(e)(3) do not need to do VOC PTE determination when using a VRU that captures vapors from the tank and routes them back to the process, provided you meet the cover requirements of 5411a(b), the closed vent requirements of 5411a(c) (which includes bypass device requirements to install flow meter and alarms or use locks), & maintain records to verify all of the above.


Per 5365a(e)(3) do not need to do VOC PTE determination when using a VRU that captures vapors from the tank and routes them back to the process, provided you meet the cover requirements of 5411a(b), the closed vent requirements of 5411a(c) (which includes bypass device requirements to install flow meter and alarms or use locks), & maintain records to verify all of the above.


   *    Conduct monthly OVA*** inspection of covers & closed vent system to verify integrity (i.e. no  cracks, holes, liquid leaks, damaged gaskets, etc.)
   
   *    If cover or system has a bypass device, then install flowmeter with audible & visible alarm
                                      or
   Install car-seal or lock to secure bypass device in non-diverting position & visually inspect monthly to ensure valve in non-diverting position
   
   * First attempt to repair leaks must be made in 5 calendar days, complete the repair w/in 30 days
Per 5365a(e)(3) do not need to do VOC PTE determination when using a VRU that captures vapors from the tank and routes them back to the process, provided you meet the cover requirements of 5411a(b), the closed vent requirements of 5411a(c) (which includes bypass device requirements to install flow meter and alarms or use locks), & maintain records to verify all of the above.



* Method 22 is used to determine visible fugitive leaks and smoke from flares, the observer does not have to be certified but must be trained and knowledgeable regarding the effects of background contrast, ambient lighting, observer position relative to lighting, wind, and the presence of uncombined water (condensing water vapor) on the visibility of emissions (http://www3.epa.gov/ttn/emc/promgate/m-22.pdf).
** OOOOa gives examples of vapor recovery devices as carbon adsorption system or condenser or other non-destructive control device; if L48 intends to use one of these devices then additional performance testing, monitoring, inspection & compliance demonstration requirements would apply.
***  OVA = olfactory, visual, auditory
