Gasoline Distribution Rule implementation support

About this project

Client
Multiple gasoline distribution clients
Location
United States

Helping gasoline distributors navigate new EPA air quality requirements

Gasoline distributors across the United States are preparing for significant changes under the U.S. Environmental Protection Agency’s Gasoline Distribution Rules (GDR). These updates—including amendments to NESHAP Subpart 6B and the addition of NSPS Subpart XXa—introduce new emission standards, monitoring requirements, and compliance deadlines that affect bulk terminals, bulk plants, and pipeline facilities.

For many operators, the challenge is not just understanding what the rules say, but how they apply to individual sites, equipment, and planned projects. Barr partners with gasoline distribution clients nationwide to help bridge that gap and support practical, defensible compliance strategies. 

Translating complex regulations into practical guidance

Our air quality specialists review regulatory text, background materials, and rulemaking documents to provide clear interpretations of the GDR. We develop plain language summaries, applicability tools, and compliance checklists that help clients determine which requirements apply to their facilities and when those requirements would take effect. Our services have included:

  • Evaluating whether planned facility changes could trigger NSPS XXa requirements
  • Developing guidance for implementing lower explosive limit (LEL) monitoring procedures
  • Preparing test plans to assess worst-case fuel properties and loading scenarios
  • Comparing compliance approaches, such as optical gas imaging (OGI) versus Method 21 for leak detection and repair (LDAR) compliance, including cost and risk considerations
  • Providing guidance related to continuous emissions monitoring system (CEMS) requirements

A collaborative, risk-informed approach

Barr works closely with client environmental and engineering teams to identify potential compliance gaps and evaluate practical solutions. When multiple compliance pathways are available, we outline the associated risks, costs, and operational implications of each option, allowing clients to make informed decisions aligned with their business goals. 

Results that support readiness and confidence

Through this work, clients are better prepared to meet upcoming compliance deadlines, manage edge cases, and reduce regulatory uncertainty across their asset portfolios. Barr’s collaborative approach—grounded in technical expertise and an understanding of what’s at stake—helps gasoline distributors move from uncertainty to readiness, supporting safe operations and long-term planning.

Key team members

Al Reich
Senior Chemical Engineer
Tony Shoberg
Vice President
Senior Chemical Engineer

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