A Review of the Appeal to 2020 Updates to 40 CFR 63, Subpart EEEE by Alyeska Pipeline Service Company

On October 7, 2020, Alyeska appealed certain parts of the EPA’s update to the National Emissions Standards for Hazardous Air Pollutants for Organic Liquids Distribution (NESHAP-OLD). Alyeska claimed that the updated rule would require substantial changes at the terminal that will not result in any significant improvement in emissions. The Council hired experts at John Beath Environmental to conduct an independent review of Alyeska’s appeal. Their results supported Alyeska’s argument. The design of the existing vapor recovery system already controls vapors better than the alternatives required by the EPA’s rule.