Organic Liquids Distribution (OLD) - EPA Proposed Rule

Proposed Rule Summary - (Published in the Federal Register October 21, 2019) The U.S. Environmental Protection Agency (EPA) is proposing amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Organic Liquids Distribution (Non-Gasoline) (OLD) source category. The EPA is proposing amendments to the storage tank and equipment leak requirements as a result of the residual risk and technology review (RTR). The EPA is also proposing amendments to allow terminals the option to implement a fenceline monitoring program in lieu of the enhancements to the storage tank and equipment leak requirements; correct and clarify regulatory provisions related to emissions during periods of startup, shutdown, and malfunction (SSM); add requirements for electronic reporting of performance test results and reports, performance evaluation reports, compliance reports, and Notification of Compliance Status (NOCS) reports; add operational requirements for flares; and make other minor technical improvements. We estimate that these proposed amendments would reduce emissions of hazardous air pollutants (HAP) from this source category by 386 tons per year (tpy), which represents an approximate 16-percent reduction of HAP emissions from the source category. Visit EPA's Website

Choosing to implement a fenceline monitoring program?

Here are some of the steps you will need to take:

- Develop a detailed inventory of allowable HAP emissions

- Include identification of which equipment are in OLD service

- Determine which HAP to monitor base on emissions from OLD equipment

- Run HEM--3 model to determine annual average modeled concentration of each HAP

- Set action level based on modeled concentration of selected HAP

- Submit modeling input file & results to the EPA for approval

- Deploy passive sampling tubes on the fenceline of facility every 14 days using Method 325A

- Have passive sampling tubes analyzed for the selected HAP using Method 325B

Camsco specializes in Method 325 and has helped numerous facilities with fenceline monitoring compliance. Please email for help or visit our specialized fenceline monitoring website,