Newsletter

ILTA’s annual Fall Environment, Health, Safety & Security Committee meeting was held in St. Louis, Missouri over September 26-27. The two-day event began with a morning tour of America’s Central Port led by Dennis Wilmsmeyer of America’s Central Port.

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.

Jay Leduc, Managing Director of Health, Safety, Environment and Sustainability for Sprague Energy, initially became involved in the terminal industry upon completing his undergraduate degree in Systems Engineering at the University of Waterloo in Ontario, Canada.

He began working as an Environmental Engineering Consultant for a large east coast consulting firm located in Halifax, Nova Scotia.

“As an Environmental Engineer I worked on many different issues for a variety of industries, from metals contamination on old junkyard lots, to large property transactions between banks, to environmental remediation of former military bases both in the US and Canada,” Leduc said.

He would eventually be asked to relocate to Portsmouth, New Hampshire, following the consulting firm’s purchase of a smaller firm located in the east coast city. It’s there Leduc was tasked with helping existing employees set up the new office and help spread the company culture to their newly acquired offices.

ILTA is engaged in a two-pronged approach on PFAS issues impacting the liquid terminal industry.

First, ILTA is working on transition legislation to provide a transparent pathway and timeline away from PFAS-based firefighting foams. ILTA is working with a coalition of other organizations, the Natural Resources Defense Council (NRDC) and the International Association of Firefighters (IAFF), to advance PFAS-transition legislation. This legislation would provide a transparent pathway to move away from PFAS-based firefighting foams. Some of the highlights of the legislation are:

• End the sale of firefighting foam containing PFAS;
• Phase out the use of firefighting foam containing PFAS;
• Prohibit the disposal of firefighting foam containing PFAS, including via incineration, landfill, underground injection and export, until a safe disposal method is identified;
• Provide a reasonable transition period accounting for the need for larger systems to replace their foam delivery systems;
• Require foam manufacturers to take back all unused foam (including from DOD);
• Require foam and PFAS manufacturers to safely store all unused foam until EPA has identified a safe method of disposal that eliminates PFAS;
• Ensure the expenses for take back and storage will be shared between foam manufacturers and PFAS manufacturers (rather than the taxpayer or private business entities);
• Require manufacturers of PFAS-containing firefighting gear to notify purchasers that it contains PFAS with written notice and labels on the gear.

As the hydrogen economy races ahead, with substantial national and local incentives in place for developing both upstream and downstream technologies, there is a growing awareness of the need to develop the storage and distribution, or “midstream”, infrastructure required by the industry. California has reacted to this need by announcing that it will be creating and implementing a California Hydrogen Market Development Strategy, using an all-of-government approach to build out the hydrogen market. Complemented by the recent creation of California’s “infrastructure strike team”, this initiative includes provisions that help develop hydrogen storage and distribution that can support the growth in production and demand.