STORAGE TERMINALS
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International Matex Tank Terminals (IMTT) and South Coast Terminals both picked up Safety Improvement Awards, and the Platinum Safety Award went to Monroe Interstate Pipeline in the small company category and CITGO Petroleum in the large company category.
SPEAK UP Safety and regulations go hand in hand but recent developments at the US Environmental Protection Agency (EPA) suggest that terminal operators are going to have to make their own rules as well as managing safety. Two legal experts – Seth Belzley, partner at Holland & Knight, and Justin Savage, partner at the DC office of Hogan Lovells – posed the question: what is EPA up to? EPA is moving to what it calls “next
generation enforcement”, having had its headcount reduced by 300 to just 1,500 people. This loss of resources has led to a rethink on how to implement its programmes, which involves privatisation of some enforcement and inspection activities and a shift in the burden to the regulated community. Remote monitoring will increasingly be
used to check on air emissions, Belzley and Savage said. That means sites may not even know they are being inspected. Infra-red cameras can also spot flare stack emissions that are invisible to the naked eye. Terminal operators will have to be certain that their controls are working as EPA’s approach is “seeing is believing” and if monitoring shows up anything it could lead to a legal case. EPA will not tolerate facilities that are, effectively, poisoning their neighbours. Since 2014 EPA’s focus in terms of
emissions control has been on the natural gas extraction sector. The potential impact of this can be seen from a settlement reached last year with Noble Energy covering 2,382 tank systems in the Denver-Julesberg
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basin and, in particular, emissions from condensate tanks. A case was brought under Colorado state law, resulting in an agreed $73m charge, including a $4.95m civil penalty. Noble was forced to implement a massive re-engineering of its whole system, involving inter alia the sampling and modelling of each tank’s vapour control system, engineering evaluation of vapour flow rate of each tank system, evaluation of valves, hatches, mountings and gaskets on each tank, and remedial work with third-party audits. EPA is now turning its attention to storage
tanks, bringing with it new ways to monitor and measure emissions. There is some concern that EPA will use Section 303 of the Clean Air Act to shut down facilities that do not meet the required standards – this has been used only a handful of times in the 40-plus years it has been in place, so it would be a major change in policy. Terminal operators looking for guidance on the relevant standards they will be required to meet should look closely at cases brought by EPA. The Administration will be using “settlement paradigms” to set a benchmark for best practice – in other words, settlement pleas by companies defending suits will effectively establish the standards industry will have to meet.
TOUCH OF THE VAPOURS Among other presentations of interest to HCB readers, Aura Engineering’s Dean Leake looked at the changes to the US Coast Guard (USCG) rules on marine vapour control systems (VCSs). Until recently, USCG’s rules on such equipment set standards for safety, training, paperwork, inspection, testing, repairs, etc but did not mandate the use of a VCS. Those rules were replaced in 2013
by new provisions in 33 CFR 158.2000, which allow more flexibility in the siting of VCSs because of increased distance allowances between the vapour connection and the detonation arrester. They also require pressure relief valves to open fully at 1.5 psig and there is a requirement for an operational review to be carried out every five years. This must be performed by a registered Certifying Entity and includes a review of documentation, a review of the installation and test load observations. Leake advised those in scope to perform a gap analysis before the operational review is carried out and to make any necessary changes. All new systems commissioned since
August 2013 have already been certified according to the new rules but older systems had to be in compliance by 15 August 2016. »
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