R 336.1640
R 336.1640 Emission of volatile organic compounds from existing storage vessels in the oil and natural gas industry located in the 2015 ozone nonattainment areas.
Cite as Mich. Admin. Code R 336.1640
Rule 640. (1) As used in this rule, "storage vessel” means a tank or other vessel that contains an
accumulation of oil and gas related liquids, and that is constructed primarily of non-earthen
materials, such as wood, concrete, steel, fiberglass, or plastic that provide structural support.
(2) A person shall not cause or allow the emission of any volatile organic compound in excess of
the limitations of this rule from the use of existing storage vessels utilized in the oil and natural
gas production, natural gas processing, and natural gas transmission and storage segments of the
oil and natural gas industry that meet both of the following criteria:
(a) A storage vessel located in the 2015 ozone nonattainment area.
(b) A storage vessel used for the storage of crude oil or condensates, intermediate hydrocarbon
liquids, or produced water.
(3) Except as provided in subrule (6) of this rule, the provisions of this rule do not apply to the
following:
(a) Storage vessels with a potential to emit volatile organic compounds of less than 6 tons per
year. This potential to emit can be limited by a federally enforceable permit or order.
(b) Storage vessels with uncontrolled actual volatile organic compound emissions of less than 4
tons per 12-month rolling average. If the combined actual emission rate equals or is more than 4
tons per year on a 12-month rolling basis before consideration of controls, as determined in a
subsequent month, then this rule permanently applies to the storage vessel.
(c) Vessels that are skid-mounted or permanently attached to a mobile source, such as trucks,
railcars, barges, or ships, and are intended to be located at a site for less than 180 consecutive days.
(d) Process vessels, such as surge control vessels, bottoms receivers, or knockout vessels.
(e) Pressure vessels designed to operate in excess of 204.9 kilopascals (29.7 pounds per square
inch) and that are not expected to have emissions to the atmosphere during normal operation.
(f) A storage vessel with a capacity greater than 100,000 gallons used to recycle water that has
been passed through 2 stage separation.
(g) VOC emission control requirements do not apply to storage vessels subject and controlled in
accordance with the requirements for storage vessels in “Standards of Performance for Volatile
Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which
Construction, Reconstruction, or Modification Commenced After July 23, 1984” 40 CFR part 60,
“National Emission Standards for Organic Hazardous Air Pollutants From the Synthetic Organic
Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations, and
Wastewater” 40 CFR part 63, subpart G, “National Emission Standards for Hazardous Air
Pollutants From Petroleum Refineries” 40 CFR part 63, subpart CC, “National Emission Standards
for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities” 40 CFR part 63,
subpart HH, or “National Emission Standards for Storage Vessels (Tanks) – Control Level 2” 40
CFR part 63, subpart WW. All regulations stated within this subdivision are adopted by reference
in R 336.1902.
(4) A person subject to the requirements of this rule shall not cause or allow the emission of any
volatile organic compound from storage vessels, unless emissions are reduced by 95% by weight
or greater as determined by subrule (5) of this rule and the following provisions are met, as
applicable:
(a) If utilized, an enclosed combustion control device for the volatile organic compound
emissions from material storage must meet 1 of the following:
(i) Emissions must be less than 275 ppm by volume as propane on a wet basis corrected to 3%
oxygen.
(ii) The control must be operated at a minimum temperature of 760 degrees Celsius, provided a
valid performance test as required in subrule (5) of this rule is on file that demonstrated the
combustion zone temperature is an indicator of sufficient destruction efficiency.
(iii) The vent stream must be introduced into the flame zone of the boiler or process heater.
(b) A person using a control device to reduce emissions shall meet the following requirements:
(i) Covers must satisfy all of the following:
(A) The covers and all openings on the cover must form a continuous impermeable barrier over
the entire surface area of the liquid in the vessel.
(B) Each cover opening must be secured in a closed sealed position when material is in the unit
except during time necessary to use the opening, such as adding, removing, sampling, or inspecting
material in the unit, maintaining equipment, or venting through a closed vent system.
(C) Each storage vessel thief hatch must be maintained and operated with a mechanism to
ensure that the lid remains properly seated and sealed under normal operating conditions.
(ii) Closed vent systems must satisfy all of the following, unless routed to a process:
(A) The closed vent system must route all gases, vapors, and fumes to the control device.
(B) The closed vent system must have no detectable emissions when using, at a minimum,
olfactory, visual, and auditory inspections.
(C) Any bypass must have a properly operated and maintained flow indictor at the inlet with an
alarm that is recorded when activated. Low leg drains, high point bleeds, analyzer vents, and open-
ended valves or lines and safety devices are not considered bypasses.
(D) The closed vent system must be properly designed and operated, as described in subrule
(5) of this rule.
(iii) Control devices must satisfy all of the following, if applicable:
(A) The control device must be operated and maintained properly as described in subrule (5) of
this rule.
(B) When using a combustion control device, it must have a continuous burning pilot flame or
alternative approved by the department.
(C) When using a flare as a control device, it must be designed and operated in accordance with
the requirements of 40 CFR 60.18(b), adopted by reference in
R 336.1902.
(D) When using carbon absorption as a control device, the carbon must be regenerated or
reactivated.
(c) If a floating roof is used to reduce emissions, the storage vessel must meet all relevant
requirements of “Standards of Performance for Storage Vessels for Petroleum Liquids for Which
Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July
23, 1984,” 40 CFR 60.112b(a)(1) or (2), and all relevant monitoring, inspection, recordkeeping,
and reporting requirements in “Standards of Performance for Volatile Organic Liquid Storage
Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or
Modification Commenced After July 23, 1984.” 40 CFR part 60, subpart Kb. Both are adopted by
reference in R336.1902.
(5) Compliance with this rule must be determined as follows:
(a) Initial performance and compliance testing must be conducted in accordance with a stack
testing protocol approved by the department.
(b) All control devices must have an approvable operation and maintenance plan that contains,
at a minimum, the following:
(i) A schedule of maintenance for the control devices in use.
(ii) An inspection schedule at least once every calendar month.
(iii) Written instructions from the manufacturer.
(c) An analysis must be performed, documented, and maintained that the closed vent system is
of sufficient design and capacity to ensure all emissions from the storage vessel is routed to the
control device or process and that the control device is of sufficient design and capacity to
accommodate all emissions from the storage vessel.
(d) The person subject to this rule for a closed vent system shall conduct and maintain records
of annual visual inspections for defects that could result in air emissions.
(6) A person operating a storage vessel subject to this rule shall obtain current information and
maintain records for all applicability and requirements in sufficient detail to determine compliance.
The records must be made available to the department upon request. The records must include the
following, as applicable:
(a) Records of each volatile organic compound emission determination for each storage vessel.
(b) Records of deviations in cases where the storage vessel was not operated in compliance with
requirements.
(c) Records of the identification and location of each storage vessel subject to emission control
requirements.