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LEGISLATION & RULES

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

 

 

 UPDATES, COMMENTS & OTHER REPORTS

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.   

 

 

RELATED ILTA ARTICLES

 

ILTA provides a monthly newsletter to its membership. Members may log in to the Member Resources page to access archived newsletters. The following is a list of articles ILTA has published in its newsletter relating to GD-GACT.

 

  • Initial Notification for EPA’s Gasoline Distribution Area Source Rule is Due on May 9, May 2008 Issue (p.3)

  • Final GD-GACT Rule Requires Initial Notification From Regulated Facilities, February 2008 Issue (p.4)

  • EPA Issues Rule For Gasoline Area Source Distribution Terminals, January 2008 Issue (p.4)

  • EPA to De-List the Gasoline Distribution Source Category Under the Clean Air Act, June 2006 Issue (p.6)

  • ILTA Supports Removal of Gasoline Distribution Source Category, May 2006 Issue (p.3)

  • EPA Says Further Emission Controls Under Gasoline Distribution NESHAP Not Needed, September 2005 Issue (p.3)

 

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