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Air Regulations for Area Source Gasoline Distribution/Dispensing Facilities

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 establishes national emission limitations and management practices for hazardous air pollutants (HAP) emitted from the loading of gasoline storage tanks at GDFs located at area sources. This subpart also establishes requirements to demonstrate compliance with the emission limitations and management practices.

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 [PDF], 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) [PDF] 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:

  • A submerged fill pipe that extends to not more than:
    • Twelve (12) inches from the bottom of the storage tank, if the fill pipe was installed on or before November 9, 2006; or,
    • Six (6) inches from the bottom of the storage tank, if the fill pipe was installed after November 9, 2006.
  • Either a pressure relief valve set to release at not less than seven-tenths (0.7) pounds per square inch or an orifice of five-tenths (0.5) inch in diameter.
  • A vapor balance system connected between the tank and the transport operating according to manufacturer’s specifications.

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 CTAP with any questions, toll free at (800) 988-7901, directly at (317) 232-8174, or via e-mail at ctap@idem.in.gov.

Information regarding the federal NESHAP is available on the U.S. EPA website.

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