Major Updates to EPA Gasoline Distribution Rules - What You Need to Know

For those operating gasoline distribution facilities, the wait is over - the EPA has finalized updates to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for gasoline distribution and the New Source Performance Standards (NSPS) for bulk gasoline terminals. These long-awaited revisions, effective July 8, 2024, aim to reduce hazardous air pollutant emissions by over 2,200 tons per year and volatile organic compound emissions by 45,400 tons per year across the industry.

The source categories affected by this action are Gasoline Distribution regulated under 40 CFR part 63, subparts R and BBBBBB, and Bulk Gasoline Terminals regulated under 40 CFR part 60, subparts XX and XXa. The 2022 NAICS codes for the gasoline distribution industry are 324110, 493190, 486910, and 424710. If you have questions about whether these rules apply to your facility, carefully review the applicability criteria.

In the context of this article, according to the EPA, a large bulk terminal is defined as any gasoline storage and distribution facility that receives gasoline by pipeline, ship, or barge, and has a gasoline throughput of 20,000 gallons per day or greater.

Key Updates and Deadlines

• NESHAP Subpart R (major sources) introduces a graduated vapor tightness certification for gasoline cargo tanks, fitting controls for external floating roof tanks consistent with NSPS Subpart Kb, and semiannual instrument monitoring for equipment leaks.
• NESHAP Subpart BBBBBB (area sources) establishes an emission limit of 35 mg/L total organic carbon for large bulk terminals, vapor balancing for tank truck loading, graduated vapor tightness for cargo tanks, fitting controls for external floating roof tanks, and annual equipment leak monitoring.
• NSPS Subpart XXa (new/modified sources after 6/10/2022) requires 1 mg/L emission limits for new loading racks and 10 mg/L for modified racks, graduated vapor tightness for cargo tanks, and quarterly leak monitoring.

Operators should review these requirements and begin planning to implement any necessary upgrades or operational changes to ensure compliance by the deadlines noted below.

NESHAP Subpart R

For major source gasoline distribution terminals, the updates to Subpart R include:

Cargo Tank Vapor Tightness

A graduated certification scale from 0.5 to 1.25 inches water pressure drop over 5 minutes, based on cargo tank compartment capacity. Larger compartments must meet tighter vapor tightness standards.

External Floating Roof Tanks

New fitting control requirements consistent with NSPS Subpart Kb to reduce emissions from roof openings.

Equipment Leaks

Semiannual instrument monitoring using Method 21 is now required to detect and repair equipment leaks.

Operators of major source terminals should evaluate their cargo tank fleet and any external floating roof tanks to determine if upgrades are needed. Developing a leak monitoring plan that satisfies the semiannual Method 21 requirements will also be key.

NESHAP Subpart BBBBBB

Area source requirements have been strengthened, with new emission limits and vapor control requirements:

Large Bulk Gasoline Terminals

Large bulk terminals must meet a 35 mg/L total organic carbon emission limit on the loading racks.

Vapor Balancing

Bulk gasoline plants that load gasoline cargo tanks with an actual throughput of 4,000 gallons per day or more must utilize vapor balancing. Vapor balancing systems route displaced vapors from the cargo tank back into the storage tank during loading (or vice versa), lowering emissions.

Cargo Tanks

The graduated vapor tightness certification from Subpart R also applies, depending on the cargo tank compartment size.

External Floating Roofs

Same fitting control requirements as Subpart R.

Equipment Leaks

Annual instrument monitoring using Method 21 for leak detection and repair.

Bulk terminal and plant operators should model their potential emissions to determine if vapor combustion units will be needed. Installing vapor balancing equipment, evaluating the cargo tank fleet condition, and establishing a leak monitoring program will also require planning - better to be early than late!

NSPS Subpart XXa

For new, modified, or reconstructed bulk gasoline terminals after June 10, 2022, the EPA has established NSPS Subpart XXa with the following key provisions:

Loading Racks

1 mg/L TOC limit for new loading racks, 10 mg/L for modified/reconstructed. Combustion or vapor recovery will likely be required.

Cargo Tanks

Same graduated vapor tightness certification as the NESHAP.

Equipment Leaks

Quarterly instrument monitoring using Method 21.

Facilities undergoing construction, modification, or reconstruction should design their emission controls to meet the new low-emission limits and account for the frequent leak monitoring.

Preparing for Compliance

With the effective date less than a year away, operators of gasoline distribution facilities should begin taking the following actions:

• Thoroughly review the new rule text and understand all requirements based on your facility's status as a major/area source and new/existing source.
• Quantify potential emissions from loading, storage tanks, equipment leaks to determine if new controls like vapor combustion are needed.
• Evaluate cargo tank fleets and any external floating roof tanks to identify any upgrades or replacements required.
• Develop monitoring plans for equipment leak inspections at the required frequency.
• Install any necessary vapor balancing, combustion, recovery or tank fitting control equipment ahead of the deadline.
• Update facility operation and maintenance plans to account for new monitoring, testing, and recording requirements.
• Train staff on the new regulatory requirements.

The compliance date may seem far off, but the significant operational changes at some facilities will require extensive planning. Beginning assessment activities now will be critical.

Staying ahead of changes like these is key to maintaining environmental compliance. Reach out if you need any assistance with interpreting the new rules or implementing your compliance plan activities.

Further reading:

EPA Fact Sheet for Gasoline Distribution Facilities

Regulations.gov docket

UPDATED COMPLIANCE DATES

Here are the compliance dates for the new EPA standards:

NESHAP Subpart R

• The revisions are effective from July 8, 2024.
• The compliance date for existing gasoline distribution facilities is May 10, 2027, except for certain changes which must be complied with by the effective date of the final rule.
• Requirements for external floating roof storage vessels must be installed the next time the storage vessel is completely emptied and degassed or 10 years after the promulgation date of the final rule, whichever occurs first.
• New sources must comply immediately upon the effective date of the standard, July 8, 2024, or upon startup, whichever is later.

NESHAP Subpart BBBBBB

• The revisions are effective from July 8, 2024.
• The compliance date for existing gasoline distribution facilities is May 10, 2027, except for certain changes which must be complied with by the effective date of the final rule.
• Requirements for external floating roof storage vessels must be installed the next time the storage vessel is completely emptied and degassed or 10 years after the promulgation date of the final rule, whichever occurs first.
• New sources must comply immediately upon the effective date of the standard, July 8, 2024, or upon startup, whichever is later.

NSPS Subpart XXa

• The effective date of the final rule requirements will be July 8, 2024.
• Affected sources that commence construction, reconstruction, or modification after June 10, 2022, must comply with all requirements no later than the effective date of the final rule or upon startup, whichever is later.

Please note that these dates are based on the information available as of 2024 and may be subject to change. Always refer to the most recent guidelines from the EPA for the most accurate information.

Note: This isn't legal advice.