July 10, 2024

Join the ILTA Professional Development Committee! 

Looking to have your voice heard in the terminal industry? Join ILTA's Professional Development Committee and help lead the charge of ensuring that each member reaps maximum benefit from our annual conferences. Be at the forefront of making sure everyone has access to top-notch educational opportunities geared towards their success. 

Who should join the committee: 

ILTA’s goal is to assemble a diverse group of professionals including those with experience in: Environmental Compliance, Health and Safety, Security, Operations, Business Leadership, and/or Global Operations. 

Please reach out to Christopher Meilink at cmeilink@ilta.org to join the committee. Learn more.

Registration is Open for the Fall 2024 EGHSS Meeting! 

ILTA’s fall Environment, Government, Health and Safety, and Security (EGHSS) meeting is set for October 1-2 in Chicago, IL!  

ILTA is committed to advocating strongly for the terminal industry in Washington, and our committees play a crucial role in keeping us aligned with the industry's top priorities. As deeply engaged tank and terminal professionals, your active involvement is vital to our success, and we sincerely appreciate your contributions. We eagerly anticipate your presence as we understand the importance of having terminal industry professionals responsible for environmental, health, safety, and security compliance at all levels. Whether you're an experienced expert or a budding professional, we welcome your participation in our committees.  

The event will be held at The Drake Hotel. You can register and book your room here! 

Save the Date for our EGHSS 2025 Meetings:

March 11-12 in Louisville, KY and September 30 - October 1 in Denver, CO

Log on to ILTA Connect, the New Terminals Industry Community Platform!   

ILTA recently launched ILTA Connect, a new community platform for ILTA terminal members! ILTA Connect is meant for members to share relevant information and news about what’s going on in our industry, ask questions, and foster discussion. In this space, you will be able to join different communities based on committees and working groups. 

Log on to ILTA Connect today using your ILTA member account or create an account if you don’t have one! Email membership@ilta.org with any questions.    

ILTA 2025 Trade Show Rebooking 

Rebooking for the 2025 trade show is underway! If you have not filled out your application to exhibit, please contact Justin Olson at jolson@thewymancompany.com.

ILTA Welcomes Two New Board Members! 

ILTA is excited to announce two new members of the Board of Directors. Regina Zolnor, Vice President, MPLX Logistics and Storage Terminals and Brent Weber, President and CEO, Intercontinental Terminals Company. 

Read Regina and Brent's full bios here.

ILTA Conducts Terminal Operations Test with Zeeco 

Over June 11-14, ILTA conducted a terminal VCU operations test at Zeeco’s Broken Arrow, OK headquarters under EPA’s May 8 gasoline distribution final rule. The test plan was developed by Trinity Consultants' Harold Laurence and informed extensively by ILTA’s Air Permitting Working Group. Overall, the test plan was designed to demonstrate that vapor combustion units (VCUs) can meet EPA’s new Gasoline Distribution emission standards with more air dilution than EPA is set to require through monitoring in recent rulemaking. The equipment tests provided for regulators, VCU operators and VCU manufacturers with representative knowledge of air-assisted VCU performance. 

The test data collected for air-assisted VCUs indicate that over-dilution with the perimeter air is not a concern within the operating parameters of the loading operation and design parameters of the VCU.  This was the test objective and can be considered achieved given the results. Likewise, the test data show that air-assisted VCUs can perform at EPA’s emission standards with greater assist air, that is, at lower “dilution parameters” than 22 Btu/ft2. 

The test data cover the range of NHVdil from 2 to beyond 22.  Unlike EPA’ data on open flares used to establish the 22 value, our data for VCUs show no relationship between NHVdil and emission control effectiveness. Therefore, the results found that there is no environmental benefit to adding assist gas to VCUs. 

ILTA thanks the twelve other entities that participated in covering the cost of the test: AFPM, API, Buckeye Partners, Citgo, Colonial Group, Energy Transfer, Flint Hills Resources, Global Partners, Kinder Morgan, ONEOK, Marathon Petroleum, and TransMontaigne.

ILTA Meets with EPA on Gasoline Distribution Rule Ahead of July 8 Petition Deadline 

On June 26, following the Zeeco test’s completion, ILTA again met with EPA alongside API and AFPM at EPA’s Research Park, NC headquarters. The purpose was to discuss several issues the trade associations plan to address in their respective Petitions for Reconsideration for the final Air Permitting Rules.  

On ILTA’s part, ILTA communicated its message that the terminal membership needs relief on LDAR (‘leak detection and repair’ program) for subpart XXa as soon as possible. EPA appears to understand the issues though (as usual) they did not commit to specific action. ILTA briefly explained why a regulatory interpretation letter is not enough to resolve the applicability issues, and why EPA must take action to make the rule text provide clear relief.

Read more to learn the results of the meeting and next steps.  

ILTA Partnering with Nossaman LLP to Develop Comments on CIRCIA Rule 

In response to DHS CISA’s April 4, 2024 proposed Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) rule, ILTA has partnered with Nossaman LLP to develop formal comments. On June 11, Nossaman held a meeting with ILTA’s Security Subcommittee to discuss the rule and initial member concerns. A draft set of comments was distributed to members for feedback on July 1 ahead of the July 3 deadline to submit. You can read the submitted comments on our website here.  

HBIIP Program Provides Key Funding Opportunities for Terminals to Buildout Biofuel Infrastructure 

On June 20, ILTA hosted its monthly Energy Transition webinar featuring Jeff Carpenter, the Program Manager for the Higher Blends Infrastructure Incentive Program (HBIIP) at the U.S. Department of Agriculture (USDA). The HBIIP program is designed to significantly increase the sales and use of higher blends of ethanol and biodiesel by expanding infrastructure for renewable fuels through quarterly grant competitions. Jeff provided an overview of the program, guidance on applying for upcoming competition windows, and answered questions about the opportunities for utilizing HBIIP awards at liquid terminal facilities and the possibility of future rounds of funding under HBIIP.

Jeff gave a high-level summary of the HBIIP program, outlining how it provides quarterly grant competitions of $90 million for projects to support higher blend of fuel sales, such as the purchase, installation, or retrofit of fuel-dispenser or related equipment and infrastructure. Jeff’s presentation highlighted opportunities for fuel distribution facilities under HBIIP, and while installation of storage tanks for ethanol and biodiesel are common grant uses, the program is very open-ended for terminal facilities as long as the project is tied to higher blends of biofuels. Additionally, Jeff walked through additional funding opportunities from USDA for emissions reductions at liquid terminals, including the Rural Energy for America Program (REAP) and business and industry guaranteed loans. Although the last quarterly competition under HBIIP is open from July 1 through September 30 of 2024, Jeff anticipates that the program will likely be renewed in the future as result of its success and bipartisan support. 

DOD Outlines Guidance for Addressing Releases of Fluorine-Free Foam  

Recently, the Defense Department (DOD) issued new guidance on the use and release of PFAS-free firefighting foam (F3) at military installations as part of its ongoing transition from PFAS-containing foam (AFFF) to F3. DOD’s policy provides direction for managing MILSPEC-qualified F3 agents when used or released on military sites, allowing concurrent usage of both legacy AFFF and F3 products. Additionally, the policy directs DOD to track the emergency use or release of F3 agents, directs usage of F3 for training or testing of equipment only at designated locations that have systems in place to prevent discharge of F3 agents to the environment, and upholds all response and reporting requirements for AFFF as directed in a 2022 memorandum. As of the release of this guidance, the DOD has qualified several F3 products to its Qualified Products List. 

The challenges DOD faces in this transition echo similar obstacles faced by the liquid terminal industry. These hurdles include the difficulty in altering numerous facilities, assets, and infrastructure from serving AFFF to a replacement foam; insufficient funding needs for the transition; expected high demand of F3 from other stakeholders such as government agencies and non-federal entities such as airports; and technical issues that will preclude replacements at some installations. These obstacles underscore the importance of ILTA’s efforts to establish appropriate transition timelines away from PFAS-based firefighting foams and to communicate key considerations for liquid terminal owners’ liability.