New emission laws regarding Gasoline Distribution facilities/truck racks are expected to be released by the Environmental Protection Agency (EPA) in August 2023.
Storage tanks
There are roughly a dozen new emission laws that the EPA has been proposing and they have been working with the midstream industry to craft solutions for Bulk Gasoline Terminals regarding environmental concerns around emissions reduction. Every 8 years, under the Clean Air Act, the EPA is supposed to review existing technology and improvements that could improve NESHAP and NSPS standards.
The EPA comment period closed in September of 2022 and these new rules will focus on VOCs (Volatile Organic Compounds) and the definitions of what a VOC is and could be redefined as monitoring Total Organic Compounds rather than Non-Methane Hydrocarbons (NMHC).
One of these proposals is the classification of Transmix Tanks – Above Ground Storage tanks (ASTs) where comingled fuels are diverted at truck racks. Transmix situations occur when product fuels such as gasoline and diesel are pushed in pipelines behind each other. To preserve the purity of fuels, the comingled section/transmix is often diverted towards a tank devoted to these mixtures. The purity and specifications of the 2 parent fuels are preserved and the transmix tank becomes a receptacle for all transmix situations which could include gas, diesel, jet fuel and kerosene. The operator’s skill, when directing fuels to the tank, is needed to ensure a reduction of transmix while keeping the purity and the fuel specifications within range. Transmix is normally sent offsite for reprocessing and a small percentage is added back into the regular gasoline system.
VOC tanks are defined as tanks that store gasoline or ethanol. Due to the high emission nature of these fuels and their classification, they pay higher emission fees to the States than a diesel tank. Transmix tanks do pay some emission fees, but presently, they do not have an EPA classification. Under the new Gasoline Distribution Facilities regulations, they could be labeled as a “motor fuel” and be subject to all regulations that gasoline tanks follow.
Obvious solutions for the transmix tanks would be: 1) better monitoring of turnovers 2) optimizing scheduling of fuels and their positioning in a pipeline 3) smaller tanks for a smaller permitting fee footprint.
This potential transmix regulation and the other EPA proposals will ensure safer facilities for Bulk Gasoline Terminals and better air quality for us all. The proposals are focused on truck racks but does not encompass larger distribution facilities or refineries that might have similar infrastructures. There will be a cost to bring these truck racks up to standards which could potentially be expensive, especially for the smaller owner/operators in the midstream. This technological review that is done every 8 years and it brings new technologies to the forefront for addressing new issues and brings environmental progress for all.
When enacted, these EPA regulations will be federally mandated but some states have already met the proposed EPA parameters within their particular states. For some owners/operators, they may be burdened with upgrade costs that they may/may not be able to push on to the customer.
There are two other anticipated rules centered around tanks which will include monitoring LEL Levels (Lower Explosive Limit) in the headspaces of tanks and limits on butane blending. LEL monitoring will confirm if emission levels are at low/safe standards and that internal seals/roofs are working correctly to
ensure that when tanks ‘work’ or ‘breath’, excessive VOCs are not released into the atmosphere. For butane blending, this regulation could address the amount of octane enrichment ensuring the gasoline has absorbed the butane and not released into the atmosphere.
The complexity of these proposed laws will be difficult to craft on a one-size-fits-all basis, but new technologies should shoulder the burden and add transparency to this sector.
Written by Earl Crochet and Jim Paladino of Perceptive Sensors | info@perceptivesensors.com
This topic will be presented at NISTM.
