The EPA recently issued a proposed rule addressing National Emission Standards for Hazardous Air Pollutants (NESHAP) for Gasoline Distribution facilities that effect gasoline bulk plants, loading racks and cargo tank vehicles. Storing, loading and unloading gasoline at these facilities release hazardous air pollutants (HAPs) regulated under the Clean Air Act according to the Biden Administration. EPA establishes emission standards and control technology to reduce HAPs from gasoline bulk plant equipment.
The proposed rule is important for energy marketers operating gasoline bulk facilities with a maximum daily design capacity of less than 20,000 gallons per day. The proposed rule would impose new compliance requirements for these facilities to reduce VOC emissions from loading racks, cargo tank vehicles, facility equipment and above ground storage tanks in gasoline service. The rule also contains new compliance requirements for bulk facilities with a daily gasoline throughput of 20,000 gallons or more but are not included in this article.
Vapor Balancing Equipment
Under current EPA regulations, gasoline bulk plants with a maximum daily design capacity of less than 20,000 gallons per day are only required to use submerged filling to capture VOC emissions. Gasoline storage tanks installed on or before November 9, 2006 must have a fill tub with a height no more than 12 inches from the bottom of the tank. Submerged fill pipes installed after November 9, 2006 must be no more than 6 inches from the bottom of the tank.
EPA’s proposed rule would require vapor balancing equipment at all gasoline bulk plants with a maximum design throughput capacity of 4,000 gallons per day or more. Gasoline bulk plants with maximum daily throughput capacity below 4,000 gallons per day would retain the requirement to use submerge fill tubes.
Cargo Tank Vehicles
Currently, EPA requires cargo tank vehicles in gasoline service to undergo EPA Method 27 tank tightness tests. The EPA Method 27 standard for cargo tank vapor tightness certification allows no more than 3 inches of water pressure drop within the tank shell measured over a five-minute period.
EPA’s proposed rule would require a graduated vapor tightness certification standard ranging between 0.5 to 1.25 inches of water pressure drop over a five-minute depending on the cargo tank compartment size. According to the EPA, model year 2004 and newer specification cargo tanks are designed to certify to the 0.5 to 1.25 inches water pressure drop standard. As a result, retrofits should not be required on these models in order to meet the proposed tank tightness standard.
AST Equipment Monitoring
Under current EPA regulations, initial leak detection for gasoline bulk plant equipment must be done using EPA Method 21 followed by monthly audio, visual and olfactory inspections. The EPA requires any detected leaks be repaired no later than 15 calendar days after discovery. Regulated equipment includes all valves, pumps, pressure relief devices, sampling connection systems, open-ended valves or lines, and flanges or other connector in the gasoline liquid transfer and vapor collection systems.
The EPA is proposing to require annual instrument monitoring of all equipment combined with a requirement to repair any leaks identified by audio, visual or olfactory methods during the course of regular business activities.
The EPA is soliciting comments on the proposed changes to NESHAP, including proposals for more stringent requirements. EMA will submit comments on the EPA proposals. EMA welcomes comments from members on the impact the proposed rule would have on gasoline bulk plants.