EMA Submits Comments on EPA Bulk Plant Vapor Recovery Proposed Rule

Today, the Energy Marketers of America (EMA) submitted comments regarding EPA’s proposed revisions to the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Gasoline Distribution facilities and the Standards of Performance for Bulk Gasoline Terminals. EPA’s proposed rule would require vapor balancing equipment both for delivering to a storage tank and loading a cargo tank at all gasoline bulk plants with a maximum design throughput of 4,000 gallons per day or more. The EPA argues the proposed rule would reduce emissions from loading operations at bulk plant facilities. Unfortunately, the EPA significantly underestimated the economic impact of the proposed rule on small business energy marketers and on the availability of gasoline in rural areas.

EMA conducted a recent survey of its members by operators representing over 650 bulk plants, a significant amount, which would be forced to close or stop selling gasoline if required to install vapor balancing equipment. EMA argued that EPA’s maximum daily design throughput is an inaccurate way of defining a compliance threshold and not representative of actual throughput. Lowering the threshold from 20,000 to 4,000 maximum daily design throughput would require most bulk plants to comply with the vapor balancing requirements regardless of their actual daily throughput. Many bulk plants have gasoline storage tanks with capacities greater than 10,000 gallons suggesting throughputs greater than 4,000 gallons per day but with actual daily throughputs of less than 4,000 gallons per day.

EMA will work with EPA to provide the information necessary to address the interests and concerns of small business gasoline bulk plant operators. Click here to read EMA’s comments and click here for a diagram of the refined products distribution system.

EMA Regulatory Counsel Contact: Mark S. Morgan, EMA Regulatory Counsel