On June 1, 2022, the EPA proposed to amend the 1994 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Gasoline Distribution Terminals major source category (Subpart R) and the area source category (Subpart BBBBBB). This action also includes proposed amendments to the 1988 New Source Performance Standards (NSPS) for Bulk Gasoline Terminals (Subpart XXa).

API and AFPM recently submitted comments on September 12 arguing that EPA’s proposal fails to justify compliance costs with the health benefits tied to air toxics reductions, and that it is inappropriate for EPA to use Section 112 of the Clean Air Act to address criteria air pollutants and their health effects as opposed to HAPs.

If these amendments are codified, among other changes, terminals will be required to develop comprehensive fugitive compliance programs.  As refiners and chemical plants know, LDAR programs require lots of attention and cost to maintain.  For some terminals, this may be even more difficult due to relative location to company environmental representatives, maintenance personnel and contractors.

Summary of proposed amendments:

The Federal Register publication can be found here.

Contact your TRICORD CRM if you have any questions.