ILTA Launches Air Permitting Working Group

In a May 9, 2023, meeting with industry representatives, including ILTA members, the Environmental Protection Agency (EPA) discussed an upcoming Technology Review of the New Source Performance Standards (NSPS) for storage tanks, 40 CFR Part 60 Subpart Kb, which applies to the construction, reconstruction, or modification of tanks storing volatile organic liquids. Pursuant to a consent decree in Environmental Integrity Project, et al. and Concerned Citizens of St. John et al. v. Michael Regan, the EPA is expected to release a proposed new NSPS, 40 CFR Part 60 Subpart Kc, by September 29, 2023.

In that NSPS standards are effective as of their proposal date, the pending NSPS Subpart Kc is expected to apply to storage tank projects that commence after September 29, 2023. The EPA is presently reviewing control technologies and industry practices to propose a best system of emissions reduction for storage tanks.  As a part of the consent decree, the agency is expected to finalize the rulemaking by September 30, 2024. Again, however, once finalized the new standard will apply retroactively to the proposal date.

The EPA indicated they are evaluating measures such as aluminum domes on external floating-roof tanks, cable-suspended internal floating roofs, welded deck seam construction for internal floating roofs rather than bolted, liquid-mounted rim seals rather than the mechanical-shoe type, and enhanced monitoring and inspection techniques.

ILTA has organized a working group with Rob Ferry, previously with Trinity Associates, to develop responses to the EPA on these issues. On behalf of ILTA, Rob will convene and lead several ILTA member driven meetings to develop comments and input as EPA continues its process of developing new regulations. Anyone interested in participating on this working group should contact Rob Ferry at RFerry@TrinityConsultants.com and/or Jay Cruz at jcruz@ilta.org.