New EPA air emission program would pose challenges for storage terminals

May 23, 2012
A new regulatory program from the US Environmental Protection Agency will have a widespread—and potentially very costly—impact on the companies that operate liquid bulk storage terminals, loading racks, and bulk plants. A final rule on the new program is expected by the end of 2012

A new regulatory program from the US Environmental Protection Agency will have a widespread—and potentially very costly—impact on the companies that operate liquid bulk storage terminals, loading racks, and bulk plants. A final rule on the new program is expected by the end of 2012.

Specifically, the agency is developing new air emission source rules that will require compliance with the new Uniform Standards initiative. The refining and chemical industries will be among the first sectors addressed. Storage tanks and loading racks will be among the operations covered by these sector-based rules. “This is the most monumental shift of paradigm in the history of the EPA regulations,” said Rob Ferry with The TGB Partnership. He spoke May 22 during the EPA Regulatory Outlook on Air Emissions at the International Liquid Terminals Association’s 2012 International Operating Conference in Houston TX. “It is happening under the radar of most folks, in that there is no immediate applicability. Unfortunately, when sector-based rulemaking imposes the Uniform Standards on you, the rules themselves will already be final.”

Ferry added that the EPA’s stated objective is to create a single set of rules for each type of air emission source. That seems like a good idea at first glance, because there is a lot of overlap and confusion in the current rules. However, there is a dark side.

EPA enforcement officials have been very involved in the current rulemaking, far more than usual. There are indications that the new rules will make it much easier for storage terminals and loading racks to be out of compliance. Finally, rulemakings incorporating the Uniform Standards initiative are moving ahead even though specific requirements to be contained in the Uniform Standards haven’t even be written yet.

Bulk Transporter will cover the ILTA International Operating Conference in detail in the August issue.