Newsletter

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

Dear Administrator Regan:

The International Liquid Terminals Association (“ILTA”) hereby petitions the U.S. Environmental Protection Agency (“EPA” or “Agency”), pursuant to Section 307(d)(7)(B) of the Clean Air Act (“CAA” or “Act”),1 to reconsider, initiate rulemaking and amend portions of its 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)

The International Liquid Terminals Association (ILTA), submit these comments responding to the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) Reporting Requirements Notice of Proposed Rulemaking (NPRM) published by the Cybersecurity and Infrastructure Security Agency (CISA) in the Federal Register on April 04, 2024. ILTA represents 82 commercial operators of over 600 aboveground liquid storage terminals that handle a wide range of liquid commodities, including crude oil, refined petroleum products, chemicals, fertilizers, animal fats, and vegetable oils. For this reason, CIRCIA’s reporting requirements are of special interest to ILTA.

Download the comments below.

On June 26, ILTA again met with EPA alongside API and AFPM at EPA’s Research Park, NC headquarters. The purpose was to discuss several issues the trade associations plan to address in their respective Petitions for Reconsideration for the final Air Permitting Rules.

On ILTA’s part, ILTA communicated its message that the terminal membership needs relief on LDAR (‘leak detection and repair’ program) for subpart XXa as soon as possible.  EPA appears to understand the issues though (as usual) they did not commit to specific action.  ILTA briefly explained why a regulatory interpretation letter is not enough to resolve the applicability issues, and why EPA must take action to make the rule text provide clear relief. 

ILTA is excited to announce two new members of the Board of Directors.  Regina Zolnor, Vice President, MPLX Logistics and Storage Terminals and Brent Weber, President and CEO, Intercontinental Terminals Company.

Regina Zolnor joined MPLX Logistics & Storage Terminals in 2018, first as a Manager of Corporate Personal Safety & Process Safety, working her way up to Vice President over the last six years. Ms. Zolnor oversees around one hundred light product and asphalt terminals across the United States, housing around one thousand tanks and storing over 35 million barrels of shell capacity.

Prior to joining Marathon, Regina worked for both British Petroleum from 2005-2013, and then Andeavor/Tesoro from 2013-2018. She holds a B.S. in Environmental Engineering and an Masters of Business Administration from Yale University.

Brent Weber, President and Chief Executive Officer (CEO) joined ITC in 2016. He began at ITC as the Senior Vice President of Operations where he focused on Safety performance, Operational Excellence, and Efficient Terminal Operations. In early 2018, he transitioned to the role of Senior Vice President of Sales and Marketing, where he and his team were focused on continued growth of the Deer Park and Pasadena terminals as well as supporting ITC-Rubis in Antwerp. On April 1, 2021, Brent became President and CEO of ITC. Mr. Weber is also the Chairman of the Board for ITC-Rubis.

Brent began his career with Nalco Chemical Company in 1999 as a District Representative in Louisiana.  In 2001, he moved to Occidental Chemical Company in Geismar, Louisiana. He started as Process Engineer and progressed through multiple positions in both Organic and Inorganic manufacturing management. Mr. Weber moved to Houston, Texas in 2012 to become the Plant Manager of the Occidental Chemical Battleground Chlor-Alkali site. From 2014 to 2016 he was the Plant Manager of the Occidental Chemical La Porte VCM site. Brent is a graduate of Louisiana State University, where he received a B.S. in Chemical Engineering in 1998.