Tips to Save Time and Costs on Air Permitting of Bulk Tanks

Amid boom times for the aviation and refining industries, there is increasing demand for the infrastructure needed for present and growing fuel storage. Daily operations can require large quantities of fuel on hand. Bulk fuel tanks with capacity of more than 1 million gallons are vital to those expansion efforts.

In addition to the tanks, the components of bulk fuel storage facilities can include receiving and dispensing equipment, tank truck and tank car loading and unloading infrastructure, and related piping and equipment. Put into operation, these components can have air emissions that may be subject to air permitting requirements.

Complex environmental regulations can vary significantly regionally. As owners and operators look to construct or modify their bulk tank facilities, there are several aspects to the permitting process with the potential to deliver efficiencies and long-term cost savings. It’s a matter of knowing where to look.

Calculating emissions: The default basis for these calculations is the U.S. Environmental Protection Agency’s AP-42. That bank of emission factors reflects data that generally was collected two or three decades ago. However, technological advances in recent years have helped lower and control emissions and increase the efficiency of operation. It is prudent to check with the manufacturer for the latest equipment-specific emission factors, which could be lower than the AP-42 factors by a degree of magnitude. This strategy delivers more accurate calculations and reduces costs, both upfront and factored into estimating annual emission fees for the facility.

Communicating with permitting staff: Maintaining constructive dialogue with local regulators before, during and after the permitting process is key to obtaining a permit that fits well with the facility conditions and operations. Building strong relationships with regulators facilitates the mutual understanding needed to resolve potential conflicts favorably.

Drafting proactive applications: When applying for air permits, clarify the facility’s point of view on what it expects, based on the applicant’s understanding of the regulations. Be sure to explore these aspects:

• The application should include draft permit conditions, documenting the facility point of view and making that case to the regulatory agency. This embodies the principle of “if you don’t ask for something, you won’t get it.”
• Including a compliance calendar that spells out expected compliance obligations is another way to clearly define the deliverables that the facility expects from the permit. For a permit covering activities that may extend decades into the future, detailing a compliance calendar up front prevents obligations from being neglected. Additionally, if any legal challenge should arise in the future, an established plan written into the approved permit provides a strong defense.
• Regulatory agencies might set monthly or quarterly throughput limits, based on local policy. It can be useful to instead request an annual limit on how much fuel can be brought in or taken out of the storage tanks, because annual targets offer greater operational flexibility. For an analogy, imagine leasing a car. In one scenario you are allowed to drive up to 1,000 miles monthly. In another scenario, you have an annual limit of 12,000. Both scenarios add up to the same limit, but the latter is more flexible for addressing seasonal demand shifts. Since the limits are based on annual reviews of emission calculations, why not request an annual throughput limit in support of greater flexibility?
• The regulatory agency can issue a permit to operate directly, instead of a permit to construct (aka Authority to Construct), so it is the applicant’s responsibility to request a draft for review or a permit to construct so corrections can be made without having to open a formal revision process.

Leveraging Title V permit revisions: If the facility being upgraded or expanded has a permit under Title V of the Clean Air Act, a facility permit revision application must be submitted. As part of this revision, there is an opportunity to address any other minor changes needed in the permit — such as personnel changes, equipment identification or dates — without incurring additional cost. Think of it like the multipoint inspection that’s usually included when you get your car’s oil changed.

Interviewing compliance inspectors: It’s always a good idea to review inspection reports for similar operations, because you might identify trends in what issues inspectors are focusing on. This knowledge can help set up the permit application and compliance calendar to facilitate access and review for the inspectors, who might not necessarily have a technical background. Each enforcement department is different, so talking to them helps facility personnel prepare for likely outcomes and prioritize those preparations.

Bulk fuel storage facility projects typically are built to last 50 years or more, so it’s essential to plan carefully to minimize burdens and deliver maximum benefits. Minor adjustments to the permitting approach can yield major short- and long-term efficiencies and savings.

Learn more about our air permitting capabilities, as well as our insights on the EPA’s Risk and Technology Review (RTR) standards for petroleum refineries, on our website.