New emission laws regarding gasoline distribution facilities and truck racks were released by the EPA last month.
"There are roughly a dozen new emission laws that EPA has been proposing and working on with the midstream industry to craft solutions for bulk gasoline terminals due to environmental concerns around emissions reduction," said Earl Crochet, API Aboveground Storage Tank (AST) inspector and owner of Crochet Midstream Consulting.
Every eight years under the Clean Air Act, EPA is required to review existing technology that could improve the National Emission Standards for Hazardous Air Pollutants and the New Source Performance Standards.
One of the potential new rules is the classification of AST transmix tanks where comingled fuels are diverted at truck racks. Transmix is when product fuels, such as gasoline and diesel, are pushed in pipelines behind each other.
"To preserve the purity of fuels, the comingled section, or transmix, is often diverted toward a tank devoted to these mixtures," Crochet said. "The purity and specifications of the two parent fuels are preserved, and the transmix tank becomes a receptacle for all transmix situations, which can include gas, diesel, jet fuel and kerosene."
New EPA rules, vital knowledge for midstream sector
Crochet said tank operators’ skills when directing fuels to a tank are much 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 often 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, Crochet said higher emission fees are paid to the states than fees paid for a diesel tank. Transmix tanks do pay some emission fees, but presently they do not have an EPA classification. He added that 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.
Crochet believes obvious solutions for transmix tanks would be better monitoring of transmix by using advanced technologies, allowing a reduction of the volume of transmix created; optimizing scheduling of various fuels in the pipelines and potentially using smaller tanks for storage, thus leading to a smaller permitting fee footprint.
"This transmix regulation and the other EPA rules will ensure safer facilities for bulk gasoline terminals and better air quality for us all," Crochet said. The rules focus on truck racks but do not encompass larger distribution facilities or refineries that may have similar infrastructures. There is a cost to bring these truck racks up to standard, which could potentially be expensive, Crochet said, especially for the smaller owners and operators in the midstream sector. He added that this technological review brings new technologies to the forefront for addressing new issues and brings environmental progress for all.
"Although some states have already met the new EPA parameters, owners and operators from other states may be burdened with upgrade costs that they may or may not be able to push on to the customer," Crochet said.
There are two other anticipated rules centered around tanks, which will include monitoring LEL levels in the headspaces of tanks and limits on butane blending.
"The complexity of these new laws will be difficult to craft on a one-size-fitsall basis," Crochet concluded. "But new technologies should shoulder the burden, and add much-needed transparency to the midstream sector."
