Article summary: As environmental professionals gather at the 2026 American Fuel & Petrochemical Manufacturers Environmental Conference, we expect storage tank compliance to be a prominent topic amid increasing regulatory scrutiny and evolving air-quality requirements. While new federal and state regulations and enforcement actions continue to shape compliance obligations, many of the most significant risks stem from gaps that develop as operations, personnel, and tank facilities change over time. Drawing on compliance audits conducted at refineries and petrochemical facilities across the country, Barr’s air-quality experts highlight five common storage tank compliance pitfalls and practical strategies for building a program that remains inspection-ready and resilient amid change.
Next month, we’ll join environmental professionals representing refinery and petrochemical facilities across the country at the 2026 American Fuel & Petrochemical Manufacturers (AFPM) Environmental Conference in Salt Lake City, Utah. As we prepare to discuss the regulatory issues shaping the industry, storage tank compliance remains a common topic.
At the federal level, the EPA continues to focus its attention on storage vessels through enforcement actions, compliance advisories, and new air-quality requirements resulting from the 2024 new source performance standards (NSPS) under 40 CFR Part 60. Meanwhile, states with nonattainment areas are pursuing additional emissions reductions from organic liquid storage tanks, such as those recently proposed by the state of Utah.
While evolving requirements certainly bring complexity and urgency to tank compliance programs, they’re not the core challenge. It’s keeping dozens of tanks and their individual compliance obligations aligned as facilities and regulations evolve. Between preventative maintenance activities, unexpected tank issues, capital projects, routine in- and out-of-service inspections, staffing changes, and production priorities, even well-managed tank compliance programs can, and often do, drift out of compliance.
Barr’s air-quality consultants have conducted compliance audits at refineries and petrochemical facilities across the country, and we’ve distilled our recent experience into five best practices for avoiding common missteps that undermine compliance demonstration and maintaining a compliance program that withstands both regulatory and operational changes.
1. Keep current operations and compliance demonstrations aligned
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It’s likely that operators invested significant effort in developing compliance demonstrations during an initial build-out. When a tank is first constructed, for example, regulatory requirements are usually clear, and emission calculations are built using the best available information. The implementation of new regulations, such as the Refinery Sector Rule in 2016, often prompts subsequent reassessments and updates of compliance programs.
In the interim, however, small changes accumulate. New products are stored, physical modifications occur, and control equipment is upgraded. Non-routine events, such as floating-roof landings and tank cleanings, come and go. Meanwhile, regulatory methodologies for emissions calculations change as EPA guidance and industry practices are updated. Compliance programs that do not consistently track and document these changes, or that rely on outdated information, may produce a growing disconnect between day-to-day operations and how compliance demonstrations describe them. That’s a major compliance risk.
The strongest compliance programs integrate clear management-of-change activities, conduct routine internal mini-audits, and regularly update compliance demonstrations, such as emission calculations, to verify alignment with reality.
2. Clearly document the justification for permitting determinations
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Ask a long-tenured staff member why a permitting determination was made for a tank modification or maintenance activity, and you may get a detailed explanation. Ask where the supporting documentation is stored, and the answer is sometimes less certain.
Many regulatory and permitting evaluations are performed correctly at the time of a project. The challenge comes several years later when personnel change, records are relocated, or supporting information becomes scattered across emails, engineering folders, meeting notes, and project files. A regulator reviewing a past project needs to understand not only the final permitting and regulatory decisions but also the rationale behind them. If the supporting story cannot be reconstructed, questions arise.
A resilient compliance program treats documentation as part of the decision itself, not as an afterthought. Having established templates and procedures for recording permitting determinations will help demonstrate compliance down the line.
3. Record every inspection and corrective action
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When a routine tank inspection reveals a problem, the next step is to prescribe a corrective action to resolve it. Most facilities excel at this. So much, in fact, that when the issue is resolved, maintenance staff have already moved on to the next repair. Sometimes that resolution is not clearly documented, and when a regulator inevitably asks when and how the issue was resolved, the answer can’t be verified.
These records must be included in routine compliance reports, but regulators increasingly want to see the entire lifecycle of corrective actions, not just an indication that a repair occurred. Violations are easily avoided when operators and maintenance staff clearly document when and how an inspection was resolved, and environmental staff verify that it was correctly reported.
4. Keep supporting documentation for emissions-control equipment centrally located
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Many facilities have robust closed-vent systems and emissions-control devices to reduce emissions from storage tanks. The equipment may be functioning exactly as intended, but the original documentation required by the background regulation becomes difficult to locate over time.
Design evaluations, operating plans, performance records, calculations, and supporting analyses are frequently stored in different places or maintained by different groups. During inspections, operators sometimes spend more time searching for records than discussing the equipment itself, even though those records are critical for demonstrating compliance. This type of documentation has become a specific area of increased regulatory scrutiny and an easy request for a regulator to make during an audit.
A compliant control system requires both functioning equipment and accessible documentation supporting how that equipment was designed and operated.
5. Define roles, establish recordkeeping, and implement procedures to survive vacations, retirements, and promotions
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Most facilities have someone who has the entire tank compliance program stored neatly in their head. This person knows why permitting decisions were made, where files are stored, how inspections are managed, and who receives which reports. That expertise is incredibly valuable. It’s also a risk if or when that person vacates their role.
When compliance depends on institutional knowledge, routine events such as vacations, promotions, retirements, or staffing changes can create compliance vulnerabilities. New personnel may struggle to locate records, understand responsibilities, or follow historical decision-making processes.
This best practice binds all the others: accurate compliance demonstrations, organized permitting records, documented corrective actions, and accessible control-device documentation all depend on having clear procedures that multiple people can understand and follow. While our first four recommendations are the building blocks of a compliance program, the fifth, having established roles and procedures, is the mortar that holds it all together.
Will your compliance program withstand future change?
The facilities that perform best during compliance audits and inspections aren’t operating perfectly. They’re keeping compliance aligned with the realities of day-to-day operations and have a system for developing and storing records and documentation. The goal isn’t perfection; it’s creating robust procedures and recordkeeping systems that consistently catch small compliance issues and bring the program back into alignment before they become bigger ones.
Amid evolving regulations, now is a great time to evaluate how well your tank compliance program is positioned to adapt to new rules, operational changes, and personnel transitions. Barr can help—contact our air-quality team.
Join us at the 2026 AFPM Environmental Conference
We’re looking forward to continuing the conversation at the 2026 AFPM Environmental Conference, October 4–6, at the Grand America Hotel in Salt Lake City, Utah.
Visit us at Barr’s exhibit or catch our presentations:
- “RSR and Alternative Modeling,” Monday, October 5, 4:00–5:00 p.m.: Beau Thurman and Phil Fish, vice presidents and senior chemical engineers, will serve as panelists in a discussion of the Refinery Sector Rule’s reshaping of MACT CC compliance, include the up-front hurdles that were introduced and the ongoing compliance risks.
- “Tanks for the Memories: Revisiting Old Lessons, New Rules, and Fresh Enforcement Theories,” Tuesday, October 6, 4:00–5:00 p.m.: Al Reich, senior chemical engineer, will join an expert panel to provide a practical look at emerging EPA regulations, enforcement priorities, and compliance challenges affecting storage tanks and related emission-control systems, with guidance on monitoring, testing, recordkeeping, inspections, and reducing enforcement risk.
About the authors
Beau Thurman, vice president and senior chemical engineer, has over 15 years of experience assisting clients with environmental permitting and regulatory compliance, particularly in support of air-quality objectives, and leading overall permitting efforts for large, greenfield, industrial developments, particularly in North Dakota. His expertise includes air permitting in numerous states, developing regulatory compliance programs and permitting strategies for clients across industries, auditing, providing training on regulatory topics, and providing on-site and remote compliance assistance.
Al Reich, senior chemical engineer, has over 14 years of experience supporting clients in the petroleum transportation and refining industry by providing air-quality compliance and permitting services, with a focus on storage vessel regulations and emissions calculations. He helps clients navigate regulatory interpretations, compliance demonstrations, program implementation, permitting, and audits. Al manages the Barr Tank Emission Calculation Spreadsheet (BTECS), a Microsoft Excel-based tool for calculating emissions from storage tanks.
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