ILTA Completes Comments on EPA Gasoline Distribution Rule
ILTA and its member companies are dedicated to providing safe, sustainable, efficient, and reliable storage and logistics services for bulk liquids. In July 2021, our Board of Directors adopted our organization’s first Environmental, Social, and Governance (ESG) principles. One of these principles affirms our industry’s commitment to continually reviewing new technologies and procedures that might improve emissions monitoring and yield emissions reductions.
Putting this pledge into action, ILTA has engaged with the U.S. Environmental Protection Agency (EPA) on a technology review of gasoline distribution equipment and facilities, focused on emissions of hazardous air pollutants. EPA initiated this review and rulemaking in Spring 2021, and ILTA and its members have been in dialogue with EPA officials, providing detailed information about the proper operations of gasoline storage tanks and loading facilities. When pandemic-related travel restrictions kept EPA officials from accepting our invitation to visit a terminal site, some innovative thinking led us to host a virtual tour of a terminal and gasoline loading facilities using “Smart Helmet” technology. ILTA and its members have also given the agency information on emissions control equipment, inspection practices, and cost and efficiency data. We were also pleased to facilitate discussions between EPA officials and manufactures of a key category of emissions controls -- vapor combustion units.
ILTA appreciates the consideration that EPA officials gave to the data and information we provided as they developed their proposed rule. We are pleased to be able to support the major findings of that proposal, which was published in the Federal Register on June 10. EPA’s proposal would lower area source emission limits for loading racks at large bulk gasoline terminals -- from 80 milligrams to 35 milligrams of total organic carbon per liter of loaded gasoline. EPA’s analysis shows that this change would produce the largest share of hazardous air pollutant emissions reductions in the amendments. While this change to NESHAP Subpart 6B will impose costs to industry – estimated by EPA to be $9,700 per ton of HAP emissions reduced – we believe that the proposed standard achieves a good balance, furthering our shared goals for environmental protection.
ILTA agrees with EPA’s assessment that it would not be cost-effective to lower the 10 milligram per liter standard for loading operations for NESHAP subpart R. Similarly, ILTA agrees with EPA’s proposal to maintain current submerged loading requirements for small bulk gasoline terminals at area sources because lowering them would not be cost effective.
Still ILTA’s formal comments – to be submitted in early August -- did register several concerns with the proposed rule. In each case, we offered sensible alternatives based on industry experience that would move us toward the agency’s stated goals in a more cost-effective way. For example, we identified some portions of the proposed rule that could subject terminal facilities to overlapping, conflicting, or inconsistent requirements. We also identified other portions of the proposed rule could impose significant costs without yielding discernable environmental benefits. In still others, we noted safety concerns. We also expressed concern that parts of the proposed amendments would require unnecessary or ineffective monitoring or testing processes.
In our view, some of the issues that give rise to our concerns may arise from simple misunderstandings of how control equipment is used at terminal facilities. Other issues may result from underestimating the effectiveness of current approaches to monitor and test emissions.
Overall, this gasoline distribution technology review represents a significant regulatory milestone. It is a complex rulemaking – both technically and legally -- involving amendments to regulations implementing several provisions of the Clean Air Act. It will change equipment requirements and operating practices at over 1500 terminal facilities across the nation that are a vital part of gasoline supply chains. While we await the final rule -- expected by June of 2023 -- we welcome the opportunity to continue discussions with our regulators and other stakeholders.