Have you been following EPA's revisions to AP-42 air emissions calculations for storage tanks, updated November 2019 and March 2020? We've been following the TCEQ on what to expect from the permitting team for Texas air permits.
Any new storage tanks permitted through TCEQ are now required to use the recently updated AP-42 Chapter 7 tank emission calculation methodology (published November 2019 and March 2020).
For existing storage tanks, the updated methodology must be used at the next permit renewal or permit revision where the tanks are affected by the project. In the meantime, before a permit is updated you can continue to show compliance using the previously permitted calculation methodology.
TCEQ’s guidance for emissions inventories (versus permitting) is to use the updated methodology for the next emissions inventory for reporting year 2020. However, any increases in emission totals over permit limits due only to the change in calculation methodology would not be considered a permit exceedance.
Bright Sky has a tool to calculate tank emissions using the latest methodology and we are happy to help you on any permitting, record-keeping, EMIS, or emissions inventory projects. Feel free to reach out to us for any questions you may have about your current or planned storage tanks.