Gasoline Distribution Rule
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A respected industry publication for ILTA members, this monthly newsletter highlights legislative and regulatory activities affecting terminal facilities. It also provides news on recent business development within the terminal industry, including new construction, expansions, acquisitions and additions to ILTA's membership, as well as important information about ILTA's committee meetings, conferences and training events. ILTA also offers ILTA News Plus to members. This publication, sent on weeks that ILTA News is not published, aggregates industry and member news.

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Michael Stroud
/ Categories: ILTA News Articles

Gasoline Distribution Rule

On June 10, 2022, the Environmental Protection Agency (EPA) issued its long anticipated Proposed Rule on National Emissions Standards for Hazardous Air Pollutants: Gasoline Distribution Technology Review (EPA Federal Register Notice Linked Here). ILTA’s Working Group continues refining and shaping ILTA’s comments. The comments are now due on Monday, September 12. 

 

ILTA began preparing for this proposed rule last year and has been diligently preparing comprehensive comments to submit to EPA. The ILTA Working Group, led by ILTA Members, was formed in 2021 and began forming subgroups to focus on the various components of the proposed rule. ILTA’s outside counsel, Nossaman LLP, along with Trinity Consultants, is working with the five Working Groups to finalize the ILTA comments.  

 

As background, with this rulemaking EPA is also proposing New Source Performance Standards to reflect best system of emissions reduction for loading operations and equipment leaks. In addition, EPA is proposing revisions related to emissions during periods of startup, shutdown, and malfunction; to add requirements for electronic reporting of performance test results, performance evaluation reports, and compliance reports; to revise monitoring and operating requirements for control devices; and to make other minor technical improvements.  

 

Besides general concerns regarding proposed Subpart XXa standards, ILTA has identified portions of the proposed rule that could subject terminal facilities to overlapping, conflicting, or inconsistent requirements. Other portions of the proposed rule could impose significant costs without yielding discernable environmental benefits. Still others could create safety concerns. In some areas, the proposed amendments would require unnecessary or ineffective monitoring or testing processes. Some requirements could even have unintended negative impacts for the surrounding communities. As ILTA Members, Staff, and ILTA consultants help finalize the ILTA comments, we are confident that the interests of liquid terminal operators will be strongly represented to EPA. 

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