Safely Transitioning from PFAS Firefighting Foams at Liquid Terminals: ILTA supports the safe and rapid transition to PFAS-free firefighting foams, balancing fire safety, human health, and environmental considerations.
ILTA Tracking State Restrictions on PFAS Fire-Fighting Foams
As highlighted at our recent EHSS committee meetings, a growing number of states are taking regulatory and legislative actions to restrict the use of PFAS including in fire fighting foams. The committee directed ILTA to create an online resource tracking these developments to enable terminal companies to remain up-to-date with the rapidly evolving PFAS policy environment. A current list of state actions taken to date is available here. ILTA will continue to monitor state actions and update this resource on an ongoing basis.
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ILTA/EPA Call: Report for ILTA Membership
On June 30, ILTA staff and representatives of its member companies participated in a discussion with EPA staff regarding the agency's review of certain regulatory standards affecting terminals and pipeline facilities that are involved in the distribution of gasoline. EPA staff participating in the call included Brenda Shine and Njeri Moeller, both with the Office of Air and Radiation.
EPA staff indicated the specific rules under review are Part 60 Subpart XX and Part 63 Subparts R and BBBBBB (6B). EPA was sued for missing 8-year technology reviews on these rules and they are now subject to a court-ordered consent decree that requires proposed rulemaking by December 1, 2021, and final rulemaking by December 1, 2022.
During the call, EPA staff identified the following elements that they are considering as part of the technology reviews:
Loading standard
- Lowering the 6B standard from 80 mg/l to the 10 mg/l standards presently in Subpart R, and perhaps lowering the 35 mg/l standards for new sources under XX to 10 mg/l or less
- Removing the alternative monitoring options presently in 6B.
Storage Tank standard
- Going to full Kb/WW, which means adding the control requirements for deck fittings that are presently excluded; and including the ladder sleeve and flexible enclosure options for slotted guide poles (as under MACT CC). (In response to a question on the call, EPA noted that they had not previously considered putting a WW option in Subpart R but would be willing to consider it.)
- Requiring LEL monitoring of the headspace in IFRTs.
- Requiring controlled degassing, while not directly stated, might be inferred from EPA’s remarks.
Equipment Leak standard
- Going to Method 21 or Optical Gas Imaging (OGI) rather than the present sight/sound/olfactory standard.
Cargo Truck Tightness standard
- Lowering the 3-in. pressure drop limit in 6B to the 1-in. pressure drop limit in Subpart R.
Other standards
- Removing the SSM exemptions (they are minimal at present in these rules, so this is rather insignificant)
- Requiring electronic submittal of reports to the CEDRI database.
In addition, EPA staff indicated they are particularly seeking input in the following areas:
Pressure testing of tank truck cargo compartments; what’s involved, trends in the results, etc.
- Transmix; how is it generated/stored/disposed of, and what type of facilities handle it in what types of tanks
- Pipeline breakout stations; are realistic equipment counts for the model facility in the prior rulemaking.