FR 2021-00678

The document issued by the U.S. Environmental Protection Agency (EPA) presents finalized amendments to the Standards of Performance for Volatile Organic Liquid Storage Vessels, particularly applicable to those constructed or modified after July 23, 1984. These amendments permit operators of storage tanks with external or internal floating roofs to choose compliance with updated national emission standards, which may yield environmental benefits and cost savings.

General Summary

The EPA's new rule provides an alternative compliance path for certain liquid storage vessels, which primarily aims at reducing emissions of volatile organic compounds (VOCs). Notably, the rule allows for an inspection method that avoids having to empty and degas storage tanks—a procedure traditionally required under previous standards. This alternative pathway is expected to curtail emissions released during tank degassing processes and reduce operational costs associated with these inspections.

Significant Issues or Concerns

The document is inherently complex, filled with legal jargon and technical specifics that can be challenging to interpret without specialized expertise. The use of acronyms and regulatory references can obscure the meaning for those not familiar with the EPA’s processes or the Code of Federal Regulations. Some public comments pointed out ambiguities in the rule, specifically regarding the notification procedures for transitioning between compliance standards.

Another area of concern is the lack of detailed explanation regarding the cost-benefit analysis. While the document suggests significant net savings due to reduced inspection needs, it does not lay out a comprehensive justification for these savings in layman's terms. This absence might leave stakeholders questioning the reliability and calculation methods of projected cost efficiencies.

Impact on the Public

For the general public, the rule could positively translate into environmental benefits due to decreased VOC emissions, which contribute to air pollution and health risks. In essence, these reduced emissions could lead to cleaner air, benefiting public health, particularly in communities near such storage facilities.

Impact on Specific Stakeholders

Operators and Industry: Storage vessel operators stand to gain financially from reduced compliance costs—an attractive prospect for the industry. The procedural flexibility may help align operations more closely with technological improvements without losing regulatory stringency.

Regulatory Authorities: For government and regulatory bodies, monitoring compliance may involve overseeing a dual-standard system, which could necessitate updated processes and training to ensure consistent application of the rules.

Environmental Advocacy Groups: While the overall reduction in emissions is beneficial, environmental advocates might be concerned whether these changes genuinely maintain the environmental rigor without compromising the frequency or quality of inspections.

In conclusion, while the rule is framed as beneficial in terms of efficiency and emissions reduction, careful attention must be paid to ensure clarity, both in the rule's implementation and the communication of its impacts to stakeholders and the public at large. Enhanced transparency and education regarding these amendments will be vital to their successful integration and acceptance across different sectors.

In analyzing the financial aspects of the document titled "Standards of Performance for Volatile Organic Liquid Storage Vessels," there are significant cost implications that are outlined. This document primarily addresses the amendments related to volatile organic liquid storage vessels and considers the potential cost savings these amendments might bring.

The document estimates that the amendments will result in a nationwide net cost savings of between $768,000 and $1,091,000 per year, calculated using 2019 dollars. This projected saving is substantial, suggesting that the amendments could have a considerable positive economic impact for operators of storage vessels. The reductions in costs are expected because the amendments aim to streamline compliance processes and reduce operational burdens.

Furthermore, the total estimated cost savings are specified as $930,000 per year, including a savings of $466,000 in annualized capital or operation and maintenance costs. These figures suggest that operators might not need to invest as heavily in new equipment or perform as extensive maintenance activities, which traditionally contribute to higher operational costs. This reduction in expenditure can be particularly beneficial for businesses looking for ways to improve their financial efficiency.

Nevertheless, the document raises some issues due to the complexity of the financial implications involved. For instance, the document does not provide a detailed breakdown of how these figures were derived, which makes it somewhat challenging for stakeholders to understand the exact nature of the cost savings without specialized knowledge. Providing a precise explanation of the cost-benefit analysis, particularly regarding the methodology for calculating these savings, would enhance transparency and understanding.

Moreover, the potential savings discussed are tightly linked to the technical provisions and compliance requirements, which have been pointed out as a source of potential ambiguity. Some commenters have suggested that these areas need further clarification, highlighting the intrinsic connection between regulatory compliance and economic impact. Simplifying the language and explaining the financial assumptions more clearly could help in making these projected savings more comprehensible to a broad audience.

Overall, while the document projects significant economic benefits, the lack of detailed financial transparency and explanations may pose comprehension challenges for those not well-versed in regulatory and economic analysis. Enhanced clarity in presenting these financial impacts would assist stakeholders in better understanding and potentially trusting the projected outcomes.