The Administrative Consent Order (ACO) for Savoy Energy, LP (Savoy), Traverse City, Michigan, addresses violations regarding the New Source Performance Standards for Crude Oil and Natural Gas Production, Transmission, and Distribution, found at 40 CFR Part 60, Subpart OOOO (NSPS OOOO).
At its Adrian 25 Facility in Lenawee County, Michigan, Savoy failed to comply with provisions of NSPS OOOO that required Savoy to equip oil storage vessels with adequate covers; to design and operate a closed vent system to route all gases to a control device; to conduct inspections of the closed vent system; and to operate a combustion device with a continuously burning pilot flame.
The above provisions of NSPS OOOO apply to storage vessels with the potential to emit (PTE) 6 tons per year (TPY) VOC or greater, and cease to apply if the storage vessels? actual, uncontrolled VOC emissions drop below 4 TPY for 12 consecutive months. This ACO requires Savoy to achieve compliance with NSPS OOOO by documenting that its actual, uncontrolled VOC emissions from the storage vessels at the Adrian 25 Facility are maintained at less than 4 tons per year.
The ACO addresses the violations set forth in the NOV/FOV issued to Savoy on May 29, 2015. Savoy is entering concurrently into a CAFO which will resolve the alleged violations and require Savoy to pay a penalty of $66,000.