On March 8, 2024, the United States Environmental Protection Agency (EPA) promulgated Standards of Performance for New, Reconstructed and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review (40 CFR 60 subparts OOOO, OOOOa, OOOOb and OOOOc, often referred to as “Quad O”). Tanks with the Potential to Emit (PTE) greater than 20 tons/year of methane are now required to capture and reduce emissions by at least 95%. This is directly applicable to affected facilities that began construction, reconstruction, or modification after December 6, 2022.
Owners and operators have until May 2025 to achieve compliance with the revised tank standards. Closed vent systems must be designed and operated to capture and route all gases, vapors and fumes to a process or a control device. EPA’s goal is to achieve no identifiable emissions. Designs must be certified by an engineer.
Compliance Requirements Focus on Reducing Emissions
Under the final rule, production tanks with a PTE of 6 tons/yr of VOC or 20 tons/yr of methane are now required to capture emissions and route to a process or a control device. In addition to control devices, operators are also required to install hatches that provide an appropriate seal to reduce emissions.
EPA has also clarified the definition of a modification to an oil storage facility. A facility is considered to be modified if any of these conditions are met:
- Adding a storage tank
- Replacing an existing storage tank that results in an increase in capacity
- Receiving additional throughput from production well(s)
- Receiving additional fluids which cumulatively exceeds throughput used in the most recent determination of the facility’s PTE
EPA defines reconstruction to mean the replacement of at least half of the storage vessels in an existing tank facility that consists of more than one storage vessel.
If a tank facility is modified or reconstructed, it is considered an affected facility under 40 CFR 60 OOOOb and requires a combustion system if the PTE is greater than 6 tons/yr of VOC or 20 tons/yr of methane.
Next Steps: TRC Can Help
TRC’s team of engineers can review your process operations and conditions to help you determine the compliance status of your existing equipment. We will model your facility’s operations and provide recommendations to achieve compliance. We have decades of oil and gas engineering experience and the depth of staff to help operators meet the compliance deadline.
Charles Venditti
Charles currently leads the Pipeline Integrity team at TRC, bringing his experience in upstream, midstream and downstream engineering and operations. In his role, he oversees projects supporting gas and liquids pipelines throughout North America with capabilities in risk analysis and management, integrity engineering, regulatory compliance, corrosion engineering and cathodic protection, and field services. Prior to TRC, Charles led an Upstream Regulatory Compliance team where he interfaced with state and federal regulators to influence development and implementation of new regulations, as well as revisions and application of existing regulations. He also spent several years in engineering and project management roles supporting Marathon’s refining operations. He is currently the President for the Indiana Oil and Gas Association, a chairman of the Technology and Regulatory Compliance committee with the Kentucky Oil and Gas Association, and serves on two other non-profit Boards. Charles has a BS in Chemical Engineering from Virginia Tech, an MBA from Malone University, certification in project management and is a licensed Professional Engineer in multiple states.
Dan Grabowski
Dan Grabowski is a Project Director at TRC. He has been in the emissions testing industry for over 29 years, primarily managing projects in the coal-fired steam generation, refineries, steel mills, pulp and paper mills, natural gas/fuel oil fired turbines, internal combustion engines and various printing, manufacturing and food industries. As Project Director at TRC, Dan’s focus is supporting project managers with complex projects and business development of new clients, which includes introducing current clients to TRC’s comprehensive EHS services and capabilities. Dan has a Bachelor of Science degree in Environmental Biology from Eastern Illinois University and lives in Chicago with his wife. He can be reached at
DGrabowski@trccompanies.com.