Gasoline Distribution Area Source Rule (GACT)

Gasoline Distribution Area Source Rule (GACT)

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LEGISLATION & RULES

NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities, Proposed Rule, Federal Register January 24, 2011 This notice finalizes amendments to the January 2008 rule in response to issues raised in petitions from Alliance of Automobile Manufacturers and from American Petroleum Institute. The rule addresses alternative monitoring for control devises, proposed tanks and sumps, monitoring requirements and the definition of gasoline. The effective date is January 24, 2011.

NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities Final Rule, Federal Register Notice, January 10, 2008 This final rule sets national emission standards for hazardous air pollutants at gasoline distribution (GD) area source facilities that emit less than 10 tons per year of a single toxic air pollutant or less than 25 tons per year of any combination of toxic air pollutants. Provisions limit air toxic emissions from bulk terminals, bulk plants, pipeline facilities, and dispensing facilities (such as service stations, convenience stores, rental and fleet gasoline tanks) pursuant to the Clean Air Act (CAA) sections 112(c)(3) and 112 (d)(5). This rule specifically excludes these areas from CAA § 112 (c)(6) thereby exempting them from meeting the MACT (maximum achievable control technology) requirements. It does, however, require a standard for generally achievable control technology (GACT).

Clean Air Act of 1990, Title I: Air Pollution Prevention & Control, Sec. 112, Hazardous Air Pollutants, November 15, 1990 This act requires identification and regulation of toxic air pollutants that pose a health threat in the urban areas. Additional information on the CAA may be found at http://www.epa.gov/oar/oaqps/peg_caa/pegcaa02.html

UPDATES, COMMENTS & OTHER REPORTS

July 2011 ILTA has recently completed Terminal Operations Series (TOS) Document #23: Semi-Annual Compliance Report Template (Corresponding to the Implementation of 40 CFR 63 Subpart BBBBBB – National Emission Standards for Hazardous Air Pollutants at Gasoline Distribution Bulk Terminals, Bulk Plants and Pipeline Facilities (GDGACT)). This template includes compliance worksheets for tanks, loading racks, and equipment leak inspections, as well as summary report templates for validating continuous monitoring system performance, reporting excess emissions, and addressing malfunctions. TOS No. 23 is available to all terminal members through the Member’s Only section

December 2010 On December 15, the Maryland Department of Environmental Protection (MDDEP) distributed a guidance document for use at gasoline terminals required to comply with GDGACT. This document provides an alternative template for the NOCS submission. MDDEP considers the NOCS due on January 10, 2011 and is requesting companies to submit specific forms indicating compliance status.

November 2010 ILTA has recently completed Terminal Operations Series (TOS) Document #21: Notification of Compliance Status (NOCS) Template (Corresponding to the Implementation of 40 CFR 63 Subpart BBBBBB – National Emission Standards for Hazardous Air Pollutants at Gasoline Distribution Bulk Terminals, Bulk Plants and Pipeline Facilities (GDGACT)).　 This template includes elements that should be included in a facility’s NOCS submission, compliance worksheets, samples of compliance methodologies for vapor units, and a prototype cover letter.　 TOS No. 21 is available to all terminal members through the Member’s Only section.　

September 2010 The American Petroleum Institute sent a letter to EPA providing further comments on the proposed revisions to the GD-GACT rule. The letter reiterated API’s concerns about expanding the applicability of the amendments to process tanks, opposed a proposed redefinition of gasoline that would include denatured ethanol and transmix, and proposed clarifying language regarding requirements for continuous monitoring systems.

February 2010 On February 16, ILTA and the American Petroleum Institute submitted joint comments to EPA on its proposed amendments to the GD-GACT rule. The letter expressed concern about expanding the applicability of the amendments to process tanks, and opposed a proposed redefinition of gasoline that would include denatured ethanol and transmix. ILTA also sent a separate comment letter to EPA requesting more time for terminals to comply with a new provision that would require “administrative approval” of facility compliance with the expanded requirements for continuous monitoring systems.

January 2009 Rob Ferry, of TGB Partnership, issued a report summarizing the GD-GACT amendments issued on December 15, 2009. To view a copy of this document, click here.

July 2009 EPA has indicated that it will issue a proposed rulemaking during October/November 2009 to amend portions of the GD-GACT regulation. Amendments are expected to address a large number of clarifying changes. There will be a 60-day comment period once the proposed rule is published in the Federal Register.

May 2008 Facilities regulated under the GD-GACT standard must submit an initial notification to EPA by May 9, unless the facility is already fully compliant. EPA has developed a brochure on the gasoline distribution rule specifically for the bulk terminal, bulk plant, and pipeline industries.

January 2008 Rob Ferry, of TGB Partnership, issued a report summarizing the GD-GACT final rule on December 21, 2007. To view a copy of this document, click here.

ILTA Submits Comments on Proposed Rule On February 7, 2007, ILTA submitted a letter with an attachment demonstrating that monitoring for the presence of a pilot flame is suitable to ensure vapor combustion unit (VCU) compliance with GD-GACT standards. Also, the letter expressed support for the EPA proposed alternative providing for monitoring the presence of a pilot flame in VCUs.

ILTA also worked closely with American Petroleum Institute (API) in preparing more detailed commentary covering a much broader range of issues. These comments are being submitted to EPA in a separate letter from API.

ILTA & API Suggestions to EPA ILTA and API have collaborated and actively engaged EPA officials to develop the proposed rule. The following letters were submitted to EPA between June and September of 2006.

September 19, 2006 Letter ILTA demonstrates that proposed rules are not universally cost effective and promotes cost effective emission controls for smaller member terminals.

August 4, 2006 Letter API provides additional information for, and clarification of, API’s issues and recommendations for the proposed rule.

June 15, 2006 Letter API provides commentary on the current plans for the proposal of the gasoline distribution area source standards as a follow up to the May 24 meeting.

Joint Industry Meeting with EPA, May 24, 2006 Steve Shedd of the EPA confirmed EPA intention to de-list GD area sources from the 112 (c)(6) list in response to a joint ILTA/API letter demonstrating the overestimation of naphthalene emissions.