UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Placer County Air Pollution Control District Rule 214

 Transfer of Gasoline Into Vehicle Fuel Tanks

Prepared by: James Shears

Reviewed by: Andrew Steckel

September 2014
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RULE IDENTIFICATION 

Agency: Placer County Air Pollution Control District (PCAPCD)

SIP Approved Rule: Rule 214 – Transfer of Gasoline into Vehicle Fuel 

Tanks

Amended – October 19, 1993

Submitted – November 30, 1994

EPA Approved – April 30, 1997 (62 FR 23365)

Subject of this TSD: Rule 214 – Transfer of Gasoline into Vehicle Fuel 

Tanks

Amended – February 21, 2013

Submitted – February 10, 2014

RULE SUMMARY - PCAPCD Rule 214, Transfer of Gasoline into Vehicle Fuel 

Tanks, is designed to limit emissions from the transfer of gasoline into vehicle fuel 

tanks, generally by requiring Stage II vapor recovery equipment as described in 

“Technical Guidance – Stage II Vapor Recovery Systems for Control of Vehicle 

Refueling Emissions at Gasoline Dispensing Facilities” (EPA 450/3-91-022).

PCAPCD regulates the Placer County portion of the Sacramento Valley Air Basin, 

a “severe” non-attainment area for the 1-hour and 8-hour ozone NAAQS (see 40 

CFR part 81). Section 182(b)(3) of the Clean Air Act (CAA) requires such areas 

to require Stage II vapor recovery and section 202(a)(6) allows EPA to waive the 

requirement after determining that Onboard Refueling Vapor Recovery (ORVR) 

systems for motor vehicles are in widespread use.

The following are the significant changes in Rule 214 to the SIP approved rule. 

Certain changes in response to EPA concerns (EPA comment letter dated 

January 4, 2012 from N. Law to A. Hobbs) are noted below.

1. Implement the standardized rule format to make it easier to read and 

understand. 

2. Section 204 adds the definition of a major defect, one that meets the 

criteria of the California Code of Regulations, Title 17, Division III, Chapter 

1, Subchapter 8, Article 1, Section 94006 and is listed on CARB’s Vapor 

Recovery Equipment Defects (VRED) list or is specified within the 

Executive Order certifying the vapor recovery system. (response to EPA 

concern)

3. Section 204 adds the definition of a minor defect, one which renders the 

gasoline dispensing equipment out of good working order but which does 

not constitute a major defect.
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4. Section 304.1 adds that no one shall operate any CARB certified vapor 

recovery system that has a major defect. (response to EPA concern)

5. Section 304.1.1 adds upon the identification of a major defect, the owner or 

operator shall tag “Out of Order” on all impaired dispensing equipment.

6. Section 304.1.2 adds that the tagged equipment shall be rendered 

inoperable and the tag not removed until the equipment has been repaired.

7. Section 304.2 adds that the owner/operator shall repair or replace any 

vapor recovery equipment having a minor defect within 7 days.

8. Section 301.1.1 adds a statement that the vapor recovery system must be 

operating with applicable CARB Executive Orders, the manufacturer’s 

specifications, and is maintained to be leak free, vapor tight, and in good 

working order.

9. Section 302 adds that operating instructions shall be posted at gasoline 

dispensing facilities conspicuously warning not to top off the gasoline tank 

when filling up. (response to EPA concern)

10. Section 201 adds that the vapor recovery system equipment must be 

CARB certified, and it cannot be replaced with non-certified equipment.

11. Section 303 adds that a person shall not supply, sell, or install any new or 

rebuilt vapor recovery system or its components unless they are CARB 

certified.

12. Section 401 adds the CARB test methods.

13. Reference to California Health and Safety Code Section 41954 was 

removed with the old regulatory format as well as Section B of the old rule

which required gasoline dispensing systems installed after June 19, 1978 

to comply with the provisions of this rule. Section C requiring gasoline 

dispensing equipment to comply with all applicable safety, fire, and other 

codes were also removed.

EVALUATION CRITERIA - The following criteria were used to evaluate the 

submitted rule. 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation 

Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the Little 

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, (EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 
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2. Stringency - EPA’s Control Technique Guideline (CTG) titled, -- “Technical 

Guidance – Stage II Vapor Recovery Systems for Control of Refueling 

Emissions at Gasoline Dispensing Facilities” (EPA 450/3-91-022) and other 

state and local rules for this category were used to help evaluate the RACT 

requirements of CAA §182(b)(2) and §182(f). 

3. SIP Relaxation – Where previous versions of rules have been SIP 

approved, new submittals must comply with CAA §110(l) and §193 

regarding SIP relaxation.

EPA EVALUATION – The submitted PCAPCD Rule 214 is more stringent than the 

approved SIP. The definition of a major and minor defect per California 

regulations, the requirement for the owner or operator to put an out of order tag on 

equipment to identify a major defect and prevent its operation, and the requirement 

for the vapor recovery system to be CARB certified and it cannot be replaced with 

non-certified equipment make the rule more stringent than the approved SIP.

1. The rule requirements and applicability are clear, and recordkeeping, 

reporting and other provisions sufficiently ensure that affected sources and 

regulators can evaluate and determine compliance with Rule 214

consistently. 

2. The submitted rule is as stringent as other air district rules, such as the 

Sacramento Metropolitan and Bay Area Air Quality Management Districts,

for this category and it is more stringent than EPA’s 1991 CTG. As a result, 

we have determined that this rule fulfils RACT requirements. 

3. We propose to determine that our approval of the submittal would comply 

with CAA §110(l) and §193 because (1) the proposed SIP revision would 

not interfere with the on-going process for ensuring that requirements for 

RFP and attainment of the NAAQS are met, and (2) the requirements in the 

submitted rule are more stringent than the existing SIP-approved control 

requirements that they would replace.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – The 

following revisions are not currently the basis for rule disapproval, but are 

recommended for the next time the rule is amended.
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1. We recommend that a section 305 be added requiring liquid condensate 

traps to be used, if necessary, to keep the vapor return piping clear of any 

liquid blockage from the remote dispenser to the aboveground storage tank 

or when it is not possible to achieve the necessary slope from the 

dispenser to the underground storage tank. This would help ensure proper 

system operation. See, e.g., San Joaquin Valley Unified Air Pollution 

Control District Rule 4622, paragraph 5.12.

2. We recommend that a section 306 be added to require the fuel facility 

owner or operator to not clear any ISD warning alarms and resume usage 

without first troubleshooting and repairing the problem with the vapor 

recovery system. See, e.g., San Joaquin Valley Unified Air Pollution 

Control District Rule 4622, paragraph 5.13.

EPA ACTION - The submitted Rule 214 improves the SIP and complies with all 

relevant CAA requirements. Therefore, EPA staff recommends a full approval of 

Rule 214 pursuant to CAA §110(k)(3).

REFERENCES -

1. PCAPCD Rule 214, Transfer of Gasoline into Vehicle Fuel Tanks as 

submitted to the EPA on February 20, 2014.

2. PCAPCD Rule 214, Transfer of Gasoline into Vehicle Fuel Tanks, as 

approved into the SIP on April 30, 1997.

3. Sacramento Metropolitan Air Quality Management District (SMAQMD), 

Regulation 4, Rule 449, “Transfer of Gasoline into Vehicle Fuel Tanks.”

4. San Joaquin Valley Air Pollution Control District (SJVAPCD), Regulation 4, 

Rule 4622, “Gasoline Transfer into Motor Vehicle Fuel Tanks”.

5. Bay Area Air Quality Management District (BAAQMD), Regulation 8, Rule 

7, “Gasoline Dispensing Facilities”.

6. “Technical Guidance – Stage II Vapor Recovery Systems for Control of 

Refueling Emissions at Gasoline Dispensing Facilities” (EPA 450/3-91-022)

7. The Little Bluebook, EPA Region 9, August 21, 2001.

8. The Bluebook, EPA, May 25,1988.