ILTA Monthly Newsletter

ILTA Hosts Jam-Packed Week of Committee Meetings

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Over the week of September 21, ILTA held its semi-annual fall committee meetings and its Terminal Operating Practices Symposium. These meetings were all conducted virtually on the Zoom platform, attracting nearly 100 participants.

The EHS&S meeting on September 22 featured welcoming comments from Committee Chairman Michael Santee of CITGO Petroleum and ILTA President Kathryn Clay. Peter Lidiak, Vice President of Regulatory Affairs, talked about ILTA’s advocacy effort that resulted in the Surface Transportation Board’s final rule reversing its 2014 decision allowing Class 1 railroads to directly bill warehouses and terminals for rail demurrage. Class 1 railroads must now bill shippers so long as terminal operators and their shippers agree to have shippers billed and notify the railroad(s).

Andrew Wright, Vice President of Legislative Affairs, outlined some of the more important legislation that ILTA has worked on this year, including passage of a CFATS program three-year reauthorization, ILTA’s continued efforts to solve the mischaracterization of fuels mixtures as high risk under the CFATS regulations and successful updates to Water Resources Development Act reauthorization that makes more of the fees collected for harbor maintenance available for harbor improvements and favorable changes the funding formula for inland waterway projects. He also discussed the outlook for the upcoming elections. During the full committee’s roundtable discussion, many questions around the continued impact of the pandemic on operations were discussed.

Two speakers addressed the full committee: Niall Ramsden, coordinator of the Large Aboveground Storage Tank Fire (LASTFIRE) consortium, spoke about its most recent research on the effectiveness of alternative firefighting foams as compared to PFAS-containing foams. Samuel Ciszuk with ELS Analysis in Stockholm discussed the impact of the COVID-19 pandemic on the world energy market and the importance of the energy industry addressing sustainability and climate issues in the coming years.

The Environmental Subcommittee heard from Mark Fishburn with FLIR Systems, who described how the company’s infrared video cameras can assist in identifying VOC emissions and introduced the company’s new QL quantification device to the attendees. The subcommittee covered many ongoing and trending environmental regulations and inspections that impact terminal operations, including estimating tank emissions, recent EPA enforcement activity, risk assessments and modeling of hazardous air pollutants, the latest on in-service inspection of Subpart Kb tanks, PFAS regulations, odor complaints and compliance with back pressure requirements.

The Health and Safety Subcommittee meeting was led by the new subcommittee chair, Byrne Evans with IMTT. Members of the American Waterway Operators’ Subcommittee on Tankering and Barge Operations presented their final white paper on safe barge access and egress to the subcommittee. This document lays out a protocol to keep tankerman and others (e.g., cargo inspectors, dock workers) safe as they cross from barge to dock. It stresses the need to stop work when a person observes an unsafe condition in the barge to dock interface.

Lidiak gave a presentation on the 2020 Safety Survey and Recognition Program and the industry results for the 2019 calendar year. Forty-five ILTA member companies participated in the safety survey this year, which is down from the previous two years. The average TRIR for our terminal members in 2019 was 1.82, which remains well below the private industry average and averages for related industries as reported by the Bureau of Labor Statistics.

The subcommittee also discussed COVID-19 return to work practices among the members, recent OSHA citations and the use of flame/detonation arrestors in truck bays.

The Security Subcommittee heard from CISA Assistant Director for Integrated Operations John Felker, who identified the persistent cyber threat actors and described what industry and government efforts to protect the nation’s critical infrastructure from cyber attacks.

Bill Cauley and Raymond Reese, both with TSA, gave an unclassified threat briefing to the subcommittee on cyber and physical security threats to pipelines and an overview of TSA’s pipeline security program.

Following these presentations, Steve Roberts, Chemical Security Group, ILTA advisor RADM Roy Nash (USCG Ret.), and Peter Lidiak gave an update on ILTA’s efforts to educate and engage ILTA members and the USCG in implementation of the TWIC Reader Rule. The rule goes into effect in May of 2023 and now is the time to begin planning. ILTA will offer a webinar for members on October 21, 2020, along with AFPM and ACC, addressing complying with the rule and reducing what are projected to be significant cost. Mr. Roberts also gave an update on the ongoing operation of the CFATS regulatory program and implementation of the USCG’s Cyber NVIC. Revised facility security plans will need to address cyber security beginning in October 2021. The EHS&S meeting ended on the afternoon on Wednesday, September 23, with a roundtable discussion of assorted security topics.


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