Newsletter

On July 21, ILTA and a team of terminal industry representatives met with Brenda Shine and Michael Cantoni of the Environmental Protection Agency (EPA) in Durham, North Carolina to discuss pending rulemaking regarding the Gasoline Distribution Industry package of air regulations that EPA proposed last year and the NSPS Subpart Kb storage tank standard that EPA is currently reviewing.  In addition to the 5-person delegation representing ILTA, over fifty additional members called into the meeting.  

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.

As mentioned in previous editions of this newsletter, capitalizing on the growth of the hydrogen economy as a key part of the energy transition may require investment by the liquid terminal industry store hydrogen or ammonia (a common hydrogen energy carrier). However, liquid terminal facilities will not only act as integral pieces of the hydrogen supply chain but may also become hydrogen customers.