In light of EPA’s final amendments to the New Source Performance Standards (NSPS) for Oil and Gas Production, Transmission and Distribution, the Texas Commission on Environmental Quality released a statement via email on March 10, 2015. Copied below is TCEQ’s statement, in its entirety:

On December 31, 2014, a notice was published in the Federal Register finalizing amendments to NSPS OOOO. Prior to these amendments, the NSPS were silent on the applicability determination for storage vessels connected in parallel. However, the December 31, 2014 amendments added language to the definition of “storage vessel” that provides: “Two or more storage vessels connected in parallel are considered equivalent to a single storage vessel with throughput equal to the total throughput of the storage vessels connected in parallel.” Therefore, applicability, emissions, and control determinations conducted prior to December 31, 2014 for storage vessels connected in parallel may need to be reevaluated.

In light of the above information, TCEQ has chosen to exercise its enforcement discretion for Group 1 and 2 vessels to expire on April 15, 2016 to allow operators of storage vessels connected in parallel additional time to reevaluate emissions and NSPS OOOO applicability. This applies to reporting, recordkeeping and control requirements. The scope of this enforcement discretion is limited to NSPS OOOO compliance and applies only to storage vessels operated in parallel that were constructed, modified or reconstructed prior to December 31, 2014.