Bulk Gasoline Plants are Subject to New EPA Rule

The Environmental Protection Agency (EPA) has finalized a new national emission standard for hazardous air pollutants (NESHAP) for bulk gasoline plants (40 CFR Part 63, Subpart BBBBBB). The purpose of this rule is to reduce the emissions of hazardous air pollutants to the environment and to protect public health. In summary, the NESHAP requires the following.

• All bulk gasoline plants must check for leaks and use good housekeeping procedures to prevent evaporation of gasoline.
• All bulk gasoline plants must use submerged fill pipes for loading gasoline into storage tanks, tank trucks and railcars.
• EPA has delegated authority to the Iowa Department of Natural Resources (DNR) to implement and enforce these NESHAP requirements in Iowa.

Per the new rule, bulk gasoline plants with a throughput less than 20,000 gallons per day are subject to less stringent regulatory requirements than the larger bulk gasoline terminals. EPA requires that throughput be calculated from the maximum design capacity of the facility unless enforceable throughput limits are in place. It is therefore beneficial for bulk gasoline plants to obtain an air construction permit from the DNR to limit gasoline throughput below the 20,000 gallons per day threshold. The permits must be obtained prior to the NESHAP compliance date of January 10, 2011.

The DNR has developed new permit templates to make it easier for facilities to obtain a throughput limit of 20,000 gallons per day or less. By completing this template and limiting throughput, the facility will be classified as a “bulk gasoline plant” and will be subject to the less stringent NESHAP requirements.

The Iowa Waste Reduction Center (IWRC) at the University of Northern Iowa, in partnership with the DNR, the Petroleum Marketers and Convenience Stores of Iowa (PMCI), and the Iowa Department of Economic Development (IDED) has developed a compliance calendar/log book for bulk gasoline plants. The purpose of this assistance tool is to:

• Educate the industry on the new NESHAP requirements,
• Remind facilities when to conduct the required tasks (e.g. leak inspection), and
• Document the facilities’ compliance with the new standards.

IWRC is offering the calendar/log book free-of-charge at one of the eight assistance workshops that IWRC will hold in cooperation with PMCI, DNR and IDED. The free workshops will educate facilities on the new NESHAP; demonstrate how to complete the new DNR permit template; and show facilities how to use the calendar/log book. Workshops begin later this month and continue through April 2010.

To obtain the locations and dates of these upcoming workshops and to register, please go to www.iwrc.org. For questions on these workshops, please call IWRC at 319-273-8905 or at 800-422-3109. For questions about the NESHAP or the DNR permit templates, please contact John Curtin at john.curtin@dnr.iowa.gov or at 515-281-8012, or contact Christine Paulson at christine.paulson@dnr.iowa.gov or at 515-242-5154.