Document dDMRgpx6GKqBgmYxd0yxv1Xob

Leakhena Swett President International Liquid Terminals Association 1440 N. F.dgewood St. Arlini2-ton, VA 22201 703-851-2938 lswett.(dilta.org Attachment -- Table of Availability Concern Requirement Assist gas and temperature monitoring for vapor combustion units. Availability Concern Many gasoline terminals rely on vapor combustion units (VCCs), a type of enclosed combustion system, to destroy gasoline vapors collected from cargo compartment loading racks. While the Subpart RRBBRR standard of 35 mg Total Organic Compounds (TOC) per liter of gasoline loaded (35 mg/L) is reasonable, the NESIIAP applies the same stringent monitoring provisions as it uses for more stringent standards of 10 or 1 mgil.. These stringent monitoring standards require establishing a temperature during a period of high gasoline loading ( 60.503a(c)(1)), then maintaining this high temperature even when loading other, less volatile fuels. ( 60.502a(c)(1)(ii)) EPA acknowledges that a typical facility will need to use supplemental fuel gas to achieve high VCU temperatures set during 60.503a(c) performance tests.[3] Supplemental fuel gas is not broadly available in remote locations where many gasoline distribution facilities are located. Supplemental fuel gas would typically consist of natural gas or I,PG. LPG availability and pipeline right-of-way concerns can limit where supplemental gas can be used. Also, temperature monitoring is not suitable for some VCC designs. For those VCC designs, the rule currently provides no workable monitoring option. Our Petition provides EPA with emission testing information demonstrating that VCCs meet the rule's emission standards at temperatures near 400 F. [4] Sierra Club FOIA 2025-EPA-04883 ED_018388_00005750-00003 SC_EVERSPLIT0005591