NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants,
and Pipeline Facilities; and Gasoline Dispensing Facilities Final Rule, Federal
Register Notice, January 10, 2008
This final rule sets national emission
standards for hazardous air pollutants at gasoline distribution (GD) area source
facilities that emit less than 10 tons per year of a single toxic air pollutant
or less than 25 tons per year of any combination of toxic air pollutants.
Provisions limit air toxic emissions from bulk terminals, bulk plants, pipeline
facilities, and dispensing facilities (such as service stations, convenience
stores, rental and fleet gasoline tanks) pursuant to the Clean Air Act (CAA)
sections 112(c)(3) and 112 (d)(5). This rule specifically excludes these areas
from CAA § 112 (c)(6) thereby exempting them from meeting the MACT (maximum
achievable control technology) requirements. It does, however, require a
standard for generally achievable control technology (GACT).
GD-GACT Proposed Rule, Federal Register Notice, November 9, 2006
This notice advises
of proposed regulations for national emission standards for hazardous air
pollutants at gasoline distribution (GD) area source facilities and seeks
industry comments on a variety of policy and implementation issues.
Clean Air Act of 1990, Title I: Air
Pollution Prevention & Control, Sec. 112, Hazardous Air Pollutants, November 15,
1990
This act requires identification and regulation of toxic air pollutants that
pose a health threat in the urban areas. Additional information on the CAA may
be found at
http://www.epa.gov/oar/oaqps/peg_caa/pegcaa02.html
May
2008 Facilities regulated under the
GD-GACT standard must submit an initial notification to EPA by May 9, unless the
facility is already fully compliant. EPA has developed example
Initial Notification
Form for reference. Please note, facilities are not required to use
this form. EPA has developed a
brochure on
the gasoline distribution rule specifically for the bulk terminal, bulk plant,
and pipeline industries.
January 2008
Rob Ferry, of TGB Partnership, issued a report summarizing the GD-GACT final
rule on December 21, 2007. To view a copy of this document,
click
here.
ILTA Submits Comments on Proposed Rule
On February 7, 2007, ILTA submitted a
letter with an
attachment demonstrating that
monitoring for the presence of a pilot flame is suitable to ensure vapor
combustion unit (VCU) compliance with GD-GACT standards. Also, the letter
expressed support for the EPA proposed alternative providing for monitoring the
presence of a pilot flame in VCUs.
ILTA also worked closely
with American Petroleum Institute (API) in preparing more detailed commentary
covering a much broader range of issues. These comments are being submitted to
EPA in a separate letter from API.
ILTA & API Suggestions to
EPA ILTA and API have collaborated and actively engaged EPA officials to
develop the proposed rule. The following letters were submitted to EPA between
June and September of 2006.
September 19, 2006 Letter
ILTA demonstrates that
proposed rules are not universally cost effective and promotes cost effective
emission controls for smaller member terminals.
August 4, 2006 Letter API
provides additional information for, and clarification of, API’s issues and
recommendations for the proposed rule.
June 15, 2006 Letter
API provides commentary
on the current plans for the proposal of the gasoline distribution area source
standards as a follow up to the May 24 meeting.
Joint Industry Meeting with
EPA, May 24, 2006 Steve Shedd of the EPA confirmed EPA intention to de-list
GD area sources from the 112 (c)(6) list in response to a joint
ILTA/API letter demonstrating the overestimation of naphthalene
emissions.
