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Gasoline distribution/dispensing facilities (GDFs) need to be aware of federal requirements that took effect in 2008 under the federal hazardous air emission standards. The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Gasoline Distribution Facilities, 40 CFR Part 63, Subpart CCCCCC requires all GDFs to achieve compliance with the requirements of the regulation by January 10, 2011.
Under the federal NESHAP, all GDF owners or operators are required to minimize evaporation by improving work practices. Steps include minimizing gasoline spills, cleaning up spills as expeditiously as practicable, and covering all open gasoline containers and all gasoline storage tank fill-pipes with a gasket seal when not in use.
Additionally, larger facilities, with a monthly throughput of 10,000 gallons of gasoline or more, are required to install submerged fill pipes for all gasoline storage tanks greater than or equal to 250 gallons to reduce the amount of vapors generated. Submerged pipes not meeting this specification are allowed if the GDF can demonstrate by documentation that the gasoline level never falls below the pipe discharge. The largest facilities, with a monthly throughput of 100,000 gallons of gasoline or more, are required to capture and send vapors back into the delivery tank truck (using vapor balancing controls), so that the vapors can be disposed of properly.
Indiana’s Volatile Organic Compound Rules for Petroleum Sources, 326 IAC 8-4, are very similar to 40 CFR Part 63, Subpart CCCCCC. Therefore, existing facilities that have been achieving compliance with the state rule are likely to be complying with the federal rule, too. One area where the state rule is slightly more stringent is in regards to the vapor recovery system requirements. 326 IAC 8-4-6(b) requires a GDF with a monthly gasoline throughput of 10,000 gallons per month or greater to equip all gasoline storage tanks greater than or equal to 250 gallons with the following:
IDEM’s Compliance & Technical Assistance Program (CTAP) is available to assist GDFs with environmental requirements. CTAP provides free, confidential compliance assistance, including on-site visits. Please contact Hani Sharaya with any questions, toll free at (800) 988-7901, directly at (317) 232-8174, or via e-mail at firstname.lastname@example.org.
Information regarding the federal NESHAP is available on the U.S. EPA website.