ILTA Helping Push In-Service Tank Inspection Rules over the Finish Line
ILTA has been hard at work continuing the push to get an Environmental Protection Agency proposal on in-service tank inspections across the finish line. The proposal, on which ILTA submitted comments on November 30, would allow operators of tanks regulated under the New Source Performance Standards of Subpart Kb to use the in-service inspection requirements of Subpart WW to conduct periodic inspections of internal floating roof rim seals.
This rule would eliminate the need for tank operators to empty their Kb tanks and remove them from service to conduct these inspections. By allowing a more efficient, in-service inspection methods to about 3,500 storage vessels, the industry saves money and fewer air pollutants are emitted.
The liquid terminal industry has wanted this change for years. ILTA was able to highlight the unusual oversupply situation brought about by the COVID-19 pandemic (that has left tanks unusually full and nearly impossible to empty for inspection) to successfully make the case for the change to EPA.
EPA announced the proposal on October 7 at a rollout event in Pittsburgh, organized by ILTA. The environmental agency estimated that the proposal could save $768,000 to $1.1 million in regulatory costs annually and reduce emissions of volatile organic compounds by as much as 83 tons per year.
EPA, recognizing ILTA’s role in advocating for the change, included a quote by ILTA President Kathryn Clay in its nationally issued press release: “The EPA rule announced today is a common-sense solution that will lower emissions, ensure safety and provide operators with increased regulatory flexibility. By allowing greater use of a well-established, safe and effective inspection method, this new policy is a meaningful contribution to our shared goal of environmentally responsible facility management,” Clay said. “ILTA and its members appreciate EPA’s efforts to address an issue that became especially challenging in recent months due to the pandemic-related imbalances in petroleum and fuels markets that constrained the storage sector.”
While the proposed rule goes through the regulatory process, EPA’s Office of Enforcement and Compliance Assurance provided a template to its regional offices to allow for Subpart WW in-service inspections of Kb tanks. It also asked for comments on the proposal. ILTA, together with the American Petroleum Institute and the American Fuels & Petrochemical Manufactures, did so on November 30. The organizations said they “strongly support the proposed amendments and we greatly appreciate EPA’s efforts to address an issue that became especially challenging in recent months due to imbalances in petroleum and fuels markets constraining the storage sector. We urge the Agency to finalize this proposal as quickly as possible and to provide interim regulatory relief until promulgation.” EPA is likely to finalize the proposal in 2021’s first quarter, marking a win for the liquid terminal industry and ILTA’s advocacy efforts.
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