Newsletter

ILTA held a call on EPA’s proposed technology review of tank emissions on June 22 with Trinity Consultants’ Rob Ferry. Discussed was the Environmental Protection Agency’s (EPA) field visit to a terminal facility on June 7 and the conversations that followed with EPA personnel. Observations were made regarding slotted guidelines, aluminum domes, Kb clarifications, tank degassing controls, and service life.

Mr. Ferry also overviewed the working group’s proposed edits to ILTA’s draft comments on EPA’s technology review of tank air emissions regulations. After receiving more edits and advice from fellow ILTA members, ILTA will be submitting preliminary comments to EPA in July.

The 2023 iteration of ILTA’s Terminal Operating Practices Symposium (TOPS) will be held on December 5 in Houston, Texas at the Marriott Marquis, Houston. ILTA’s room block will open in the near future.

TOPS is an educational series designed to provide terminal operator with a forum to exchange lessons learned from facility incidents and near hits and discuss effective operating practices with their peers. Presentations are provided by terminal operator employees, who will share their experiences in addressing natural disasters, environmental releases, malfunctions, worker injuries and illnesses, near misses/hits and other abnormal operating events at their facilities.

If you would like to present at this year’s TOPS, please reach out to Jay Cruz: jcruz@ilta.org

Some members may be familiar with Rob Ferry as a long-time trusted consultant for ILTA, a role he’s filled for many years. Though Ferry is now retired from his position as Managing Consultant for Trinity Consultants, he continues his involvement with ILTA.

Ferry’s career in the industry began back during the period of the Ford presidency.

“While he was serving as president, I was starting my career as a structural engineer with a tank building company, where I designed the first aluminum domes ever installed on petroleum storage tanks,” Ferry said. “The dome building unit was spun off as a separate company, and I was appointed the General Manager at the tender age of 28.”

Though Ferry loved running that company, he devoted almost every waking hour to it. To resolve this dilemma, he resigned without any plan for what to do next.

European industries are pressing the European Chemicals Agency (ECHA) on the cost, effectiveness, and availability of replacements for PFAS-containing firefighting foam. In comments to ECHA’s Committee for Socio-Economic Analysis’ (SEAC) draft opinion of the proposed restriction of PFAS in firefighting foams, EU industry groups expressed the difficulty of transitioning to foams that achieve the same performance as their PFAS-based predecessors, under the timeline and phaseout scheme laid out by ECHA’s proposed restriction.

EPA is pushing back the deadlines for two major rulemaking processes concerning the designation of PFAS as a hazardous substance under CERCLA. EPA is extending both its internal deadline to finalize the rule to designate PFOA and PFOS as hazardous substances under CERCLA to February 2024 and the comment period for stakeholders to provide input and data on regulating seven additional PFAS under CERCLA to August 11, 2023. The extension of these proposed rulemakings reflects the complexity of crafting these policies and the need for further analysis of the impacts, burden, and novelty of designating PFAS as hazardous substances.