The Air Pollution Control Division, in a joint effort with industry, has published Storage Tank and Vapor Control System Guidelines. The guidelines describe technical and practical considerations for design, operation, and maintenance of vapor control systems at Colorado oil and gas facilities.
Benefits of following the guidelines and notifying the division:
- Certainty and clarity for operators on designing, operating and maintaining storage tanks while complying with regulatory requirements
- A shorter list of questions and records requested during inspections (when emissions are observed)
- Reduction in repeat questions and records requests
- Improved efficiency for the operator and the Division
Process for implementing and following the guidelines:
Step 1: Review the Storage Tank and Vapor Control System Guidelines.
Step 2: Notify the Division of your company's intention to follow the guidelines.
Step 3: Prepare your materials (as needed).
The following should be addressed by the materials developed in accordance with the guidelines.
- Implementation plan, including:
- Timeline and schedule for completing design verification analyses for existing facilities
- Timeline and schedule for implementing design changes at existing facilities (as determined through design verification analysis)
- Timeline and schedule for developing written procedures (as described below)
- Timeline and schedule for implementing operation and maintenance changes
- The number of facilities affected (no names of facilities needed).
- Short term plan for minimizing emissions during the long-term implementation process. For example, consider implementing suggested O&M practices even if recordkeeping is not yet in place.
- Design protocol (and example design analysis)
- Written procedures which address the following:
- Inspections pursuant to the guidelines and conducted to comply with Regulation Number 7
- Preventative maintenance
- Predictive analysis
- Facility changes requiring design updates (note: this could be included in the design protocol, above).
- Emission response practices
- Critical operating parameter selection and monitoring
- Training plan
- Storage Tank Emission Management plan(s)
Step 4: Submit your materials to the Division.
Directions on submitting your materials will be sent to you once you have notified the Division of your intent to follow the Storage Tank and Vapor Control Guidelines, as directed in Step 2. The operator may elect to follow all or part of the guidelines. Please be clear in your submittal which parts of the guidelines are being followed and which are not. Benefits and protections offered will vary if the operator chooses not to follow the guidelines in full.
- AQCC Storage Tank Guidelines Presentation (April 19, 2018).
- Storage Tank Workshop Presentation (May 23, 2018).
- Rocky Mountain EHS Peer Group Presentation (July 26, 2018).
- COGA's 6th Annual Small Operator Half Day Presentation (October 24, 2018).
Send us comments or questions. Please include your name and organization, if applicable.