Countdown to the First Wave of NSPS Quad O Compliance Deadlines

All affected facilities (i.e. petroleum storage vessels) that fall into Group II of the September 23, 2013 NSPS Quad O standards set forth by EPA are subject to rule 60.5395(d)(1) and must control VOC emissions to 95% and 6tpy or less by April 15, 2014! Facilities that were constructed, reconstructed, or modified after April 12, 2013 fall into this group. Group II actually has an earlier date to comply than Group I because EPA conducted research that suggested there would be less affected facilities and a great enough supply of control devices and VRUs to feed the market.
Not sure what constitutes a constructed, reconstructed, or modified storage vessel facility? Let me briefly explain EPA’s definition of each. The construction date is considered the day that the facility is installed on site. However, Oklahoma’s Department of Environmental Quality is considering the day that the facility was “mass produced” to be the construction date. To be more exact, the date will correspond with the commencement of the facility at the manufacture plant if this rule makes it to law. A facility is considered to be reconstructed if the replacement of components exceed 50% of the fixed capital cost of a comparable new facility. Before the limit is breached, the owner/operator has 60 days to give notice to the state or federal environmental agency before construction may commence. Further reference may be found in 40CFR Part 60.14. A modified facility is one that undergoes a physical or operational change which results in an increase in the emission rate of any pollutant which the standard applies (i.e. VOC, HAP, H2S). It is not considered a modification when operation manipulation does not lead to an increase in regulated emissions.
Are you prepared for the more stringent environmental air regulations? Or will you be “blown away?” Don’t let the nightmare of discerning regulation and rules bog you down and let OTA assist you through the compliance process. There is even a way to avoid the new regulations all together.
Call our Lead – Environmental Services expert for more details @ 214 – 717 – 0775, or drop him an e-mail @

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