Contributed by Ned Coleman, Senior Project Manager, PPM Consultants
On May 8, 2024, EPA finalized revisions to multiple regulations that apply to the gasoline distribution industry, which includes bulk gasoline terminals, bulk gasoline plants, and pipeline breakout stations. These rules include 40 CFR 60 Subpart XXa (for facilities constructed, reconstructed or modified after June 10, 2022) as well as 40 CFR 63 Subparts R (for new and existing major sources) and BBBBBB (for new and existing area sources). While the most stringent of these requirements will apply to brand new terminal facilities, this rulemaking will have a major impact on existing terminals as well. While the biggest changes for existing terminals won’t take effect until May 8, 2027, there are a few things that should be on your radar now if you operate a gasoline terminal.
Existing terminals have the potential to trigger “modification” or “reconstruction,” under the new Subpart XXa rule if a terminal’s loading rack undergoes a major change, especially one that increases emissions. This would require a terminal to comply with newer Leak Detection and Repair (LDAR) requirements as well as lower emission limits for loading racks. The new LDAR rules would require a terminal to implement either an Optical Gas Imaging (OGI) or Method 21 monitoring program. While these LDAR requirements will eventually apply to most terminals in 2027 under the revised versions of Subpart R and/or BBBBBB, triggering XXa would mean a site would have to implement an LDAR program much sooner. Additionally, triggering XXa would require gasoline loading operations to meet an outlet emission limit of 5,500 parts per million by volume (ppmv) Total Organic Compounds (TOC) or 10 milligrams (mg) TOC per liter of gasoline loaded. This emission limit is about a quarter of the allowable emission limit in the older rules.
The other requirement to keep in mind applies to gasoline storage tanks. While the majority of new Subpart R and BBBBBB requirements won’t take effect until May 8, 2027, a gasoline storage tank that is emptied and degassed after July 8, 2024, has to comply with certain new requirements when it comes back into service. This means that tanks going out-of-service for API 653 inspections or service changes may need their floating roof fittings upgraded prior to refilling. Therefore, it may be in your best interest to go ahead and assess your gasoline tanks’ floating roofs so that you can plan for improvements in conjunction with any inspection or repair activities you may have planned.
We’ve seen a lot of rule updates coming out of EPA in the past couple of years, so it’s more important than ever to stay on top of all these changes and make sure you are ready for the next generation of environmental compliance requirements. Whether you have questions on these changes to gasoline distribution rules, or one of the many other regulations that EPA has recently promulgated, PPM Consultants can help you plan and prepare for the future. Please do not hesitate to reach out to me directly at ned.coleman@ppmco.com to discuss these or other air quality related regulations.