Document 7VzJ9y0myYdRNzbmdkg9x15B

VRU averaging period. Some terminals reduce gasoline loading emissions using a vapor recovery unit (VRU), system that collects gasoline vapors by adsorption or refrigeration and returns them to bulk storage. These units are typically equipped with continuous emission monitoring systems (CENTS) to determine emissions. The 2024 rule revisions reduce the averaging period of VRU emission standards from 6 to 3 hours. Facilities may be subject to an implicit requirement to replace equipment. We arc concerned about equipment availability and the turnaround time to replace VRLIs if needed. Truck vapor tightness. We arc assessing the attainability of the 2027 rule's more stringent standards for vapor tightness of gasoline cargo compartments. We are concerned that in some locations, the third-party gasoline carriers may not be capable of meeting these more stringent requirements. They are subject to an even earlier compliance date of May 8, 2026. [1] The date. May 8, 2027, appears in several compliance date paragraphs of Subpart R and Subpart BBRBBI=3, though the date May 10, 2027 appears in the Federal Register preamble as May 8 is a Saturday. 121 Petition for Reconsideration caul RulemakinF, NE:S.11APfar Gasoline Distribution Facilities and the .S'tanclards of Perfarmance far Bulk Gasoline 'Terminals, II.TA, EPA-HQ-OAR-2020-0371-0160. ("Petition") See also ILIA Petition for reconsideration of I.DAR modification - Subpart XXci,II.TA, EPA-HQ-OAR-2020-0371-0161. 131 EPA, NE.S11AP caul N.SPSfar Bulk Gasoline terminals Back,,Fround Information far Final Amendments .Simunary of Public ( .ornments and Responses, p. 24, EPA-HQ-OAR-2020-0371-0150. imps: 'downloads.regulations.gov EPA-HQOAR-2020-0371-0150 contcnt.pdr ("Response to Comments.") 141 Petition, Exhibit C. [5] Gasoline Distribution Equipment Leaks Control Options Workbook, EPA-HQ-OAR-2020-0371-0010. [6] "Generally, if the PRIJs arc elevated, OGI monitoring can be used without the need to use a lift to confirm that the PRD is correctly restated. Therefore, we arc finalizing the 5-day monitoring requirement as proposed." EPA, Response to Comments, p. 42. Jay Cruz Senior Director of Government Affairs & Communications ILTA International Liquid Terminals Association 655 15' Street, Suite 230, Washington DC 20005 jeruz(iiilla.org Main: 703-875-2011 www.Ilta.org Follow us on social medial ILTA2O25 I CONFERENCE it. TRADE SHOW June 9-11, 2025 Houston, TX Sierra Club FOIA 2025-EPA-04883 ED_018388_00005750-00005 SC_EVERSPLIT0005593