The DNR reminds owners and operators of gasoline dispensing facilities that the compliance date for the Environmental Protection Agency’s "6C NESHAP" gasoline dispensing rule is January 10, 2011. The official name for this rule is the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories: Gasoline Dispensing Facilities (40 CFR Part 63, Subpart CCCCCC).
The purpose of the 6C NESHAP is to reduce the emissions of hazardous air pollutants (HAPs) to the environment and to protect public health. EPA estimates that full implementation of 6C will result in national emissions reductions of 50,000 tons annually of volatile organic compounds, which will also eliminate over 4.5 million pounds annually of HAP emissions, such as benzene.
The 6C NESHAP applies to existing or new gasoline dispensing facilities (GDF) that are area sources.* Examples of GDF include service stations, convenience stores, car rental agencies, and motor pools. The rule requirements affect each gasoline cargo tank during the delivery of product to a GDF and also affect each gasoline storage tank. The equipment used for refueling of motor vehicles (gasoline pumps) are not covered under 6C.
* An area source is a facility that is not a major source of hazardous air pollutants (HAP). A major source is a facility that has the potential to emit 10 or more tons per year of any single HAP or 25 or more tons per year of any combination of HAP.
Since EPA finalized 6C in early 2008, DNR staff from air quality, underground storage tanks (UST), and its field offices have been providing outreach to affected facilities, associations, and other affected parties. DNR activities included meetings with, presentations for, and individual compliance assistance for service stations and convenience stores, UST installers, testers and third party inspectors, Petroleum Marketers and Convenience Stores of Iowa (PMCI) and other interested stakeholders.
All existing GDF facilities must be in compliance with the 6C requirements, including any required emissions control, testing, recordkeeping and reporting, by January 10, 2011. Owners and operators of facilities that will not be in compliance by that date should follow the instructions in the Frequently Asked Question (FAQ) answers below for submitting a compliance schedule to the DNR.
If you are unfamiliar with the 6C NESHAP and think that it may affect your facility, company, customers or members, please read the information below on the 6C NESHAP, DNR Air Quality requirements, available online tools, and answers to FAQs.
The Iowa Department of Natural Resources (DNR) has 6C NESHAP tools and resources on its Area Source Toxics website (under Gasoline NESHAP).
U.S. EPA has delegated 6C authority to the DNR, which means that DNR is the primary implementation and enforcement agency in Iowa. For facilities within Polk or Linn counties, the approved local air programs are implementing and enforcing 6C. Polk and Linn counties may have different procedures for GDF permitting and registration or for 6C compliance. Please contact the local air programs directly for more information: Polk County Public Works (Air Quality Division), phone: (515) 286-3351; or, Linn County Public Health (Air Quality Division), phone (319) 892-6000.
Under 6C, EPA has established three categories of facilities based on monthly gasoline throughput. Requirements for small and medium size GDFs are similar to those already established many years ago under state and federal regulations for underground storage tanks and public safety/flammable liquids. The most significant new requirements are for large GDFs, which have to install and test vapor control equipment not previously required in Iowa.
In brief, 6C equipment and operation requirements* include:
* This summary is intended as a guide and is not a substitute for reading the 6C NESHAP. The regulation is available on EPA’s website at http://www.epa.gov/ttn/atw/gasdist/gasdispg.html and at http://www.epa.gov/ttn/atw/area/compilation.html
Owners and operators of large GDFs must submit documentation to the DNR Air Quality Bureau that they have completed vapor balance system installation and testing. The DNR has developed a form that owners and operator may use to fulfill this requirement. The new form, 6C Compliance Information, is available on the Area Source Toxics website (under Gasoline NESHAP).
Owners and operators of large GDFs must submit a completed 6C Compliance Information form or equivalent information to the DNR Air Quality Bureau once they have complied with the 6C NESHAP requirements. The DNR is requesting that facilities submit this information by March 11, 2011. Owners and operators must ensure that the 6C Compliance Information form or letter is signed by someone acting as Responsible Official for the facility/company, and should mail, fax or e-mail the information to the DNR Air Quality Bureau. Companies with multiple locations may submit one 6C Compliance Information form or letter signed by the Responsible Official and attach a table or spreadsheet summarizing the general information, 6C applicability, and compliance status for each facility. The DNR form provides additional instructions for submitting the required information.
What if I already notified DNR UST of my vapor balance installation and testing?
To ensure that DNR’s NESHAP records are complete and available for any EPA information requests, the DNR asks that all owners or operators of large GDF submit the required 6C Compliance Information to the DNR Air Quality Bureau. The DNR Air Quality Bureau will accept a copy of a previously submitted UST form in place of a 6C Compliance Information form, provided that: 1) the UST form was submitted after the installation and testing of vapor balancing equipment, and 2) the UST form has been signed by someone acting as Responsible Official for the facility/company.
Those with questions may also contact Christine Paulson at Christine.Paulson@dnr.iowa.gov or by phone at (515) 242-5154, or contact Diane Brockshus at Diane.Brockshus@dnr.iowa.gov or by phone: (515) 281-4801.
Why is a poppet valve or equivalent device required on coaxial systems?
The 6C NESHAP requires, under Table 1 in the regulation, that "a) All vapor connections and lines on the storage tank shall be equipped with closures that seal upon disconnect; and b) The vapor line from the gasoline storage tank to the gasoline cargo tank shall be vapor-tight, as defined in §63.11132."
EPA recently made a determination that a cap alone placed on the end of a coaxial system would not meet these 6C requirements. Although a cap will prevent vapors from escaping, there is a brief period of time that elapses between when the coaxial system is disconnected from the gasoline cargo tank and when the cap can be replaced. During this period, vapors escape from the end of the system into the atmosphere because the pressure in the tank is usually above atmospheric pressure. Therefore, a poppet valve (or equivalent device which seals upon disconnect) is required for coaxial systems under the 6C NESHAP.
What if the owner or operator of a large GDF cannot comply with the 6C equipment or testing requirements by January 10, 2011?
An owner or operator of a large GDF that will not be in compliance with the 6C NESHAP by January 10, 2011, should notify the DNR as soon as possible and must also submit a compliance schedule. At minimum, the compliance schedule will need to identify the work that will be done at the facility, the date this work is expected to commence, and the date they expect to be fully in compliance with the rule. The schedule will need to be submitted by the facility, and be signed by someone acting as Responsible Official for the facility/company.
The DNR has created a form that facilities may use to notify the DNR of non-compliance and to submit their compliance schedule. The form is available on the Area Source Toxics website (under Gasoline NESHAP). Facilities with questions about 6C compliance should contact Diane Brockshus at Diane.Brockshus@dnr.iowa.gov or by phone at (515) 281-4801.
Owners and operators with compliance questions regarding facilities in Polk or Linn Counties should contact their local air program offices: Polk County Public Works (Air Quality Division), by phone at (515) 286-3351, or Linn County Public Health (Air Quality Division), by phone at (319) 892-6000.
What method must a GDF owner or operator use to calculate monthly gasoline throughput to determine whether the GDF exceeds the 100,000 gallon/month threshold?
EPA proposed amendments to 6C in December 2009 that clarified the method for calculating monthly gasoline throughput. Although EPA has not yet finalized these amendments, the DNR has been recommending that GDF owners and operators use EPA’s proposed method to calculate monthly throughput, as follows:
Monthly throughput is calculated by adding the volume of gasoline loaded into or dispensed from all gasoline storage tanks located at a GDF facility during the current day plus the total volume of gasoline loaded into or dispensed from all gasoline storage tanks at the GDF for the previous 364 days and then dividing that sum by 12.
Contact the DNR for additional guidance on how to use the monthly throughput calculation.
What types of gasoline blends are included under 6C?
At this time, all gasoline blends, including ethanol blends up to 85% ethanol, are included in the 6C definition of gasoline. Diesel, propane and other fuels are not covered under 6C, and do not need to be included in the monthly throughput calculation.
Are gasoline bulk plants or bulk terminals covered under 6C?
Gasoline bulk distribution is covered under a different NESHAP (40 CFR 63, Subpart BBBBBB (6B)). The compliance date for 6B is also January 10, 2011. More information is available on the Area Source Toxics website. Those with questions may also contact Christine Paulson at Christine.Paulson@dnr.iowa.gov or by phone at (515) 242-5154, or contact Diane Brockshus at Diane.Brockshus@dnr.iowa.gov or by phone at (515) 281-4801.
Owners and operators of GDF may have additional obligations under DNR UST regulations. 6C NESHAP reports submitted to the DNR Air Quality Bureau will be provided to DNR UST. However, GDF owners and operators should contact the DNR UST section with any questions regarding these requirements. Please contact Tom Collins at Tom.Collins@dnr.iowa.gov or by phone at (515) 281-8879 or Paul Nelson at Paul.Nelson@dnr.iowa.gov or by phone at (515) 281-8779.