Letter - International Liquid Terminals Association
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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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ILTA Letter: Presidential Exemption - NESHAP for the Gasoline Distribution Source Category and NSPS for Bulk Gasoline Terminals

Jay Cruz 0 91 Article rating: No rating

Presidential Exemption: NESHAP for the Gasoline Distribution Source Category and NSPS for Bulk Gasoline Terminals

 

To whom it may concern at the U.S. Environmental Protection Agency,

The International Liquid Terminals Association (ILTA) is writing to express that affected sources in the Gasoline Distribution source category, 40 CFR 63 Subparts R and BBBBBB, may have urgent reason to seek Presidential Exemption from certain emission standards and monitoring provisions of these subparts.

Founded in 1974, ILTA represents 70 companies operating liquid terminals in all 50 states and in over 40 countries. Terminals provide essential logistics services, support domestic and international trade, and foster the readiness of the United States armed forces by making fuels and liquid products available throughout the world—products such as petroleum fuels, aviation fuels, petrochemical products, chemicals, asphalt, alternative fuels like ethanol, and beyond. In particular, the U.S. gasoline distribution industry comprises a vast infrastructure network that moves finished gasoline and other liquid fuels from petroleum refineries to end markets, including government, commercial and industrial facilities, and retail fueling stations.

A strong gasoline distribution industry delivers affordable energy to America and ensures liquid fuels are available wherever they are needed.

Many of the same infrastructure assets that deliver gasoline also deliver jet fuel to military and commercial air facilities, and diesel to America’s farms, food producers and manufacturing facilities. Reliable access to gasoline and other fuels is crucial for maintaining operational readiness and ensuring military bases can function independently, especially in times of crisis. Our national security relies on the services and logistical support that the bulk liquid storage industry brings to the nation’s energy supply chain.

On May 8, 2024, EPA issued a final rule entitled National Emission Standards for Hazardous Air Pollutants: Gasoline Distribution Technology Reviews and New Source Performance Standards Review for Bulk Gasoline Terminals (89 Fed. Reg. 39304) (May 8, 2024) (“Gasoline Distribution Rule”). This rulemaking includes significant changes to two National Emission Standards for Hazardous Air Pollutants (NESHAP) for the gasoline distribution industry, viz., Subpart R for major sources of Hazardous Air Pollutants (HAP) and Subpart BBBBBB for area sources. The rulemaking also comprises one New Source Performance Standard (NSPS), Subpart XXa, for gasoline loading racks and associated equipment at the bulk gasoline terminal segment of this industry. The NESHAP subparts rely on the NSPS Subpart XXa provisions for emissions monitoring requirements for loading racks.

Download a copy of the full letter below.

ILTA Letter To The Trump Administration and Members of the 119th Congress

Jay Cruz 0 177 Article rating: No rating

President Donald Trump clearly stated the importance of energy to our nation’s prosperity through several executive orders, including Executive Order 14154 (Unleashing American Energy) and Executive Order 14156 (Declaring a National Energy Emergency). Liquid terminals in the United States are exactly the type of infrastructure that will help deliver American energy (and other critical materials) to the marketplace and support the goal articulated in EO 14154 of restoring American prosperity.

The following are a few examples of how ILTA members’ operations can support the vision for energy security and economic growth.

EO 14154 – “It is the policy of the United States to protect the United States’ economic and national security and military preparedness by ensuring that an abundant supply of reliable energy is readily accessible in every State and territory of the Nation.”

ILTA Perspective: ILTA members operate over 2,000 terminals across all 50 states, providing critical infrastructure for transporting energy, agricultural goods, chemicals, and more. These materials can be raw inputs essential for U.S. manufacturing or finished goods destined for domestic consumption or export. Simply put, you cannot make an abundant supply of reliable energy available in all 50 states without a robust terminal network.

EO 14156 – “The integrity and expansion of our Nation’s energy infrastructure—from coast to coast—is an immediate and pressing priority for the protection of the United States’ national and economic security.”

ILTA Perspective: ILTA members can help support the integrity and expansion of the nation’s energy infrastructure by providing more capacity to store and distribute liquid commodities in more locations. We look forward to working with the Trump administration to ensure that regulatory requirements imposed on terminals are aligned with the integrity.

EO 14156 – “The United States’ insufficient energy production, transportation, refining, and generation constitutes an unusual and extraordinary threat to our Nation’s economy, national security, and foreign policy.”

ILTA Perspective: Liquid terminals form an integral part of the “circulatory system” of America’s economy, without which producers and consumers cannot efficiently be connected. The United States needs a resilient terminal industry to ensure there is an unencumbered flow of liquid commodities, including crude oil to refineries, finished gasoline to the market, and petrochemicals to countless American manufacturers. We believe our nation’s terminals play a pivotal role in alleviating threats to the nation’s economy, national security, and foreign policy, consistent with the President’s EO 14156.

Download a copy of the full letter below.

ILTA Clarification Letter on NJ DEP Discharges of Petroleum and Other Hazardous Substances

Jay Cruz 0 343 Article rating: No rating

Dear Commissioner LaTourette,

On behalf of its membership, the International Liquid Terminals Association (ILTA) is seeking clarification regarding the New Jersey Discharges of Petroleum and Other Hazardous Substances regulations.

Founded in 1974, ILTA represents 80 companies operating liquid terminals in all 50 states and in over 40 countries. Our members’ facilities provide critical links between all modes of transportation for liquid commodities, such as crude oil, petroleum products, chemicals, renewable fuels, fertilizer, vegetable oils and other food-grade materials that are central to the U.S. economy. Terminals provide essential logistics services that spur trade both within the United States and connect the U.S. economy with overseas markets. ILTA’s membership also includes about 400 companies that supply equipment and services to the terminal industry.

Regarding the regulation, the preamble states that there is no requirement to implement mitigation measures identified in the climate resiliency plan. N.J.A.C 7:1E-4.12b requires that major facilities identify measures to mitigate the impacts of climate change identified in the analysis required by the proposed rule, to identify those mitigation measures that are deemed to be feasible, and to develop an implementation schedule for those measures.

It looks like the Department is requiring that facilities conduct an assessment and establish an implementation schedule, while the preamble states that the proposed rule does not require the owner or operator to implement mitigation measures.

We are asking the Department to clarify the mitigation implementation requirements for the climate resiliency plan, and whether the plan needs to be certified by NJ Certified Professional Engineer. We would also like to know what format is required for the climate resiliency plan, and whether it needs to be integrated into DPCC/DCR or can be a standalone plan.

Please do not hesitate to reach out to me if you have any questions.


Respectfully,
Leakhena Swett
President
International Liquid Terminals Association

ILTA Letter to EPA on NSPS Kc Rule Development Costs to Control Tank Degassing

Jay Cruz 0 1248 Article rating: No rating

The International Liquid Terminals Association (“ILTA”) understands that EPA is involved in the development of a new 40 CFR Part 60 regulation for storage tanks to be designated Subpart Kc, and that one item under consideration is a requirement to control emissions during tank degassing events.  ILTA would like to share some of the more significant concerns with this potential requirement, namely cost and availability.

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