Distribution and breakout terminals in the gasoline distribution industry, whether a major or minor source, are required to comply with standards found in 40 CFR Part 63. These rules are commonly known as the National Emission Standards for Hazardous Air Pollutants (NESHAP) and regulate the emissions of 189 hazardous air pollutants (HAPs).
There are two NESHAPs subparts that cover gasoline terminals within 40 CFR Part 63:
• 40 CFR Part 63, Subpart R: Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout Stations). These rules apply to "major" sources (facilities whose potential to emit are greater than major source levels); and,
• 40 CFR Part 63, Subpart BBBBBB (6B): Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities. These rules apply to "area" sources (facilities whose potential to emit are less than major source levels).
Sources in the gasoline distribution industry subject to NESHAP must perform an initial performance test as a means to demonstrate compliance. To demonstrate continuous compliance, sources are required to monitor control device operating parameters. This may include the continuous monitoring of a pilot flame for a vapor combustion unit (VCU) or VOC breakthrough for a vapor recovery unit (VRU). These operating parameters are established during the initial performance test. Each of these subparts include a myriad of requirements on operations, reporting and record keeping, implementation, and enforcement.
For 6B area sources, the EPA standards allow for the use of generally available control technologies (GACT) in place of the more stringent maximum achievable control technology (MACT) required for major sources. These two rules are often referred to simply as "GD GACT" or "GD MACT."
Navigating NESHAP compliance for gasoline terminals requires an experienced environmental professional. CFR Environmental has been providing its clients with the expertise required for NESHAP compliance for over 20 years and would like to you provide you with guidance on compliance at your location.