Petition for Reconsideration Request for Administrative Stay NSPS Subpart Kc – Standards of Performance for Volatile Organic Liquid Storage Vessels

Dear Administrator Regan:

The International Liquid Terminals Association (“ILTA”) hereby petitions the U.S. Environmental Protection Agency (“EPA” or “Agency”), pursuant to Section 307(d)(7)(B) of the Clean Air Act (“CAA” or “Act”),1 to reconsider and amend provisions of New Source Performance Standard (“NSPS”) Subpart Kc identified below, and to stay certain of the subpart’s unique provisions (40 CFR § 60.110c(e), § 60.112c(c)(2)(vi), the final sentence of § 60.112c(d)(1), and paragraph (d)(1)(i)) until the requested amendments to Subpart Kc have been adopted.

EPA adopted Subpart Kc as part of the final rule entitled New Source Performance Standards Review for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels), 89 Fed. Reg. at 83,296 (October 15, 2024). Herein this rulemaking is referred to as the “Final Rule,” and the rule proposal, New Source Performance Standards Review for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels), 88 Fed. Reg. at 68,535 (October 4, 2023), is referred to as the “Proposed Rule.”

Attached below is a copy of the full comments.