Two routine losses
AP-42 Section 7.1 estimates routine losses from a fixed-roof tank in two parts. Standing loss comes from the vapor space breathing as temperature and pressure change through the day. Working loss comes from filling, as rising liquid pushes vapor out of the tank.
“Total routine losses from fixed roof tanks are equal to the sum of the standing loss and working loss:”
EPA AP-42, Section 7.1, Organic Liquid Storage Tanks (6/2026)“LT = LS + LW”
EPA AP-42, Section 7.1, Organic Liquid Storage Tanks (6/2026)
Working loss depends on turnovers
Turnovers compare a year's throughput with the tank's working volume. A tank that turns over often has less time to saturate its vapor space between fills, so AP-42 reduces the working loss with a turnover factor above a set number of turnovers. The reduction doesn't apply to vapor-balanced tanks or tanks where flashing occurs.
“for turnovers > 36, KN = (180 + N)/6N”
EPA AP-42, Section 7.1, Organic Liquid Storage Tanks (6/2026)“for tanks that are vapor balanced and tanks in which flashing occurs, KN = 1 regardless of the number of turnovers”
EPA AP-42, Section 7.1, Organic Liquid Storage Tanks (6/2026)
Crude oil gets a product factor
The working loss product factor depends on the liquid stored.
“for crude oils, KP = 0.75;”
EPA AP-42, Section 7.1, Organic Liquid Storage Tanks (6/2026)“for all other organic liquids, KP = 1”
EPA AP-42, Section 7.1, Organic Liquid Storage Tanks (6/2026)
Flashing is a separate estimate
When liquid from a pressurized separator enters a tank at lower pressure, dissolved gas comes out of solution. The standing and working loss equations don't capture this, and Section 7.1 points to other methods rather than settling on one. Some state agencies publish guidance on the methods they accept; check the state hub and the agency before choosing.
Where flashing occurs, a standing and working loss calculation alone isn't the whole estimate. OOOOb, for example, asks for a method that accounts for flashing, working, and breathing losses when a tank battery's potential is calculated.
“This scenario is typical of storage tanks receiving liquids from a separator in oil and gas production operations”
EPA AP-42, Section 7.1, Organic Liquid Storage Tanks (6/2026)“There are numerous methodologies available for estimating flashing losses and specific guidance regarding their application and use.”
EPA AP-42, Section 7.1, Organic Liquid Storage Tanks (6/2026)
Controls apply to all three losses
If vapors go to a control device, apply its efficiency to flashing as well as standing and working losses. When the result feeds potential to emit, use only the efficiency an enforceable condition supports.
“If vapors are routed to a control device, the control efficiency of the device should be applied to the flashing loss as well as to the standing and working losses.”
EPA AP-42, Section 7.1, Organic Liquid Storage Tanks (6/2026)
Check your setup against EPA's example
Section 7.1 includes worked examples. Before trusting a spreadsheet or tool, run EPA's inputs through it and compare. The AirPermitHub Fixed-Roof Tank Losses calculator is tested against the working loss example quoted here.
“N =39.9 / (11.5 – 4.5) = 5.7”
EPA AP-42, Section 7.1, Organic Liquid Storage Tanks (6/2026)“LW = (5.614)*(201.2)* (1)*(1)*(0.0143) (1) = 16.1 lb/yr”
EPA AP-42, Section 7.1, Organic Liquid Storage Tanks (6/2026)
What to record
A tank estimate someone else can check records:
- Tank dimensions, roof type, and shell and roof color and condition
- Liquid stored, with vapor pressure and molecular weight and their source
- Annual throughput and its basis: metered, projected, or permitted
- The meteorological data used, and where it came from
- For flashing: the method, the sample and its conditions, and separator pressure and temperature
- Any control device and the basis for its efficiency
- The AP-42 section and revision date used
Sources
- EPA AP-42, Section 7.1, Organic Liquid Storage Tanks (6/2026)
- 40 CFR 60.5365b: Subpart OOOOb applicability, including tank battery potential (eCFR)
This guide explains how programs fit together. Thresholds, limits, and dates appear only in the quoted text, linked to its source; read the full provision before relying on it.
AirPermitHub provides educational, engineering, research, and compliance-support information. Information provided by the platform does not constitute legal advice and should not replace review of applicable regulations, permits, agency guidance, or consultation with qualified professionals. Full disclaimer
