A GASOLINE rule is coming for terminals! A gasoline rule is coming for terminals! And that's not Chicken Little panic, according to Rob Ferry, who said the anticipated EPA rule will likely have the greatest impact on terminals ever.
“It will hopefully be for urban areas only, although few facilities qualify as rural,” he said at the Independent Liquid Terminals Association International Operating Conference in Houston, Texas.
The Environmental Protection Agency (EPA) is expected to propose the rule October 31, 2006, with a final rule anticipated by December 20, 2007, Ferry said. “The opportunity for advocacy is now,” he added.
The EPA rule, if it becomes official, would require more stringent control of loading racks and storage tanks, and possibly require leak testing for tank trucks, vapor balancing for tank truck deliveries, and equipment leak inspections.
The rule would apply to the gasoline distribution industry, including gasoline terminals and breakout stations, and potentially to bulk plants, and service stations.
Additionally, EPA's definition of “urban” is based on population in a wide area. For example, Brewster County, Texas, would fall into the category even though its population numbers 9,225 and is an area six times the size of Rhode Island, he said.
Ferry does not expect the rule to include a Maximum Achievable Control Technology (MACT) floor, a baseline emissions rate. If a MACT floor is included in the rule, it would require the level of control achieved by the 6% of best-controlled facilities. “California's requirements would be the standard nationwide, regardless of cost or benefit,” he said. “It also would be applicable to all facilities, not just those defined as urban.”
Ferry argued that the benefits that would be obtained by such a rule are overstated by the EPA. He said that much of EPA's estimated benefit came from installing internal floating roofs. However, “virtually” all floating roof tanks storing gasoline at terminals already have internal floating roofs.
EPA overstated hazardous air pollutant (HAP) content in gasoline vapors. “For the emissions reductions that are real, the HAP portion would be less than estimated,” he added.
The agency is evaluating controls on a cost/ton basis, and controls would be imposed regardless of risk.