## United States Environmental Protection Agency
**, Pacific**  **Southwest**

**– Region 9**  **Clean Air Act Permit Federal Indian Country Minor New Source Review Program**  https://www.epa.gov/caa

- permitting/tribal

- nsr

- permits

- region

- 9



## Technical Support Document (DRAFT) General Air Quality Permit for New or Modified Minor Source Gasoline Dispensing Facilities in Indian Country within California

**September 2016** 

## Table of Contents

Summary

................................ ................................ ................................ ................................ ................. 1

1. Applicability of the Federal Indian Country Minor NSR Program

................................ .......................... 2

2. Requirements for Developing and Issuing a General Permit

................................ ................................ 4

2.1 Purpose, Source Category, and Issuance Procedures

................................ ................................ ................. 4

2.2 Source Category Description

- Gasoline Dispensing Facilities

................................ ................................ ..... 6

2.3 Procedures for Obtaining Coverage under a General Permit

................................ ................................ ...... 7

3. Permit Content

................................ ................................ ................................ ................................ .. 7

3.1 Required Permit Content

................................ ................................ ................................ ............................. 7

3.2 Emission Limitations

................................ ................................ ................................ ................................ .... 9

4. Eligibility Criteria for CA

- GDF General Permit Coverage and Related Issues

................................ ........ 20

4.1 Screening Procedures for Threatened or Endangered Species and Historic Properties

.......................... 20

4.2 Exempt Equipment

................................ ................................ ................................ ................................ ... 20

4.3 Maximum Gasoline Throughput

................................ ................................ ................................ ............... 20
4.4 Aboveground Storage Tank s

............... ................................ ................................ ................................ ........ 21

4. 5 Major Source of HAPs

................................ ................................ ................................ ............................... 21

4. 6 Air Quality Impact Analysis

................................ ................................ ................................ ....................... 21

4. 7 Good Engineering Stack Height

................................ ................................ ................................ ................. 2 2
Appendix A: Emissions Calculations for Operating Limitation for GDFs in California

................................ . 23Draft Technical Support Document
CA

- GDF General Permit Page 1 of 25 

# Draft Technical Support Document

Clean Air Act Federal Indian Country Minor New Source Review Program General Air Quality Permit for New or Modified Minor Source Gasoline Dispensing Facilities in Indian Country within California

Version 1.0 Last Modified : September 2 9 , 2016


### Summary

This technical support document (TSD) provides the basis for the terms and condi tions of the General Air Quality Permit for New or Modified Minor Source Gasoline Dispensing Facilities in Indian Country within California (CA

GDF General Permit) under the Clean Air Act (CAA or Act) Federal Indian Country Minor New Source Review Program

. The CA

- GDF General Permit is being issued b y the U.S. Environmental Protection Agency

– Region 9 (EPA Region 9) under the Federal Indian Country Minor New Source Review ( Minor NSR) P rogram at 40 CFR
49.1 51

- 49.161. The EPA is making t his general permit available to permit certain existing or planned gasoline dispensing facilities (GDFs) in areas of Indian country within the geographic boundaries of California when such GDFs are subject to the requirements of the Minor NSR program. These a reas of Indian country include s those

areas located in an Indian reservation or in another area of Indian country (as defined in 18 U.S.C. 1151) over which an Indian tribe, or the EPA, has demonstrated that the tribe has jurisdiction

, and where there is no EPA

approved program in place

.

The CA

- GDF General Permi t that is the subject of this TSD is intended to provide a streamlined preconstruction permitting process under the Minor NSR program for certain GDFs located in Indian country within California, as well as to provide general consistency with the minor new source review ( NSR ) requirements generally applicable to GDFs in areas for which the State of California air permitting authorities have jurisdiction. T he EPA previously issued a national permit by rule for the Minor NSR Program for GDFs (GDF Permit by Ru le) to provide a similar option for streamlining the M inor NSR permitting process for GDFs in Indian country. However, the GDF Permit by Rule excluded GDFs in areas located within the geographic boundaries of the State of California. See 40 CFR 49.164 and 80 FR 25068 (May 1, 2015). 1

Owners and operators of GDFs that meet the eligibility requirements for the CA

- GDF General Permit can use this general permit as a streamline d permitting option to the meet the preconstruction requirements of the Minor
NSR P rogram . Owners and operators of such GDFs could also choose to apply to EPA Region 9 for a traditional

source

- specific permit to meet the preconstruction requirements of the Minor NSR program.

In addition to this TSD, we have made available a set of permit

- related documents in support of the CA

- GDF General Permit

. The CA

- GDF General Permit documents are largely based on similar documents that the EPA made available associated with the EPA’s GDF Permit by Rule

. These permit

- related documents consist of the following:

1 See http://www.ecfr.gov/cgi

- bin/text

idx?SID=9428c598f5856da1b03fcbd009e07c60&mc=true&node=se40.1.49_1164&rgn=div8 and https://www.gpo.gov/fdsys/pkg/FR

- 2015

- 05

- 01/pdf/2015

- 09739.pdf

.Draft Technical Support Document
CA

- GDF General Permit Page 2 of 25 • General Permit : This document c ontains the requirements with which the source must comply , if approval of a request for coverage is granted . The emission limitations and monitoring, recordkeeping and reporting requirements are in the ge neral permit.

• Request for Coverage : This document states the criteria for qualification for coverage under the general permit; gathers information on the source, the physical location, and the source contact; and requests technical information on facility equipment, throughput, and the attainment status of the area where the GDF will be located

.

• Questionnaire: This document assists owner s and operator s in determining whether the source may be eligible for coverage under the general permit.

• Instr uctions: This document g uides the applicant in filling out the Request for Coverage under the general permit.

• Potential to Emit (PTE) Calculator S preadsheet: This document a llows applicants to calculate the PTE of their GDF , based on inputs of the numbe r of refueling positions at the GDF and the ozone attainment status of the GDF ’ s physical location, assum ing compliance with the EPA ’s standards and continuous operation throughout the year. The PTE Calculator spreadsheet generates potential emissions base d on these inputs.



## 1. Applicability of the Federal Indian Country Minor NSR Program

The CAA Federal Indian Country Minor NSR P rogram at 40 CFR 49.151

– 49.161 is potentially applicable to owners and operators of sources located, or planning to locate, in Indian reservations or in other areas of Indian country over which an Indian tribe, or the EPA, has demonstrated that the tribe has jurisdiction and where there is no
EPA

- approved program in place

. 2 The Minor NSR P rogram requires owners and operators o f certain new and modified existing sources of air pollution in such areas to obtain a Minor NSR permit prior to constructing or modifying their source. 3 This preconstruction permitting program is triggered for new or modified sources based on potentia l increases in air pollutants according to the applicability criteria in 40 CFR 49.153. Generally, source owners and operators in such areas first determine whether their new or modified source is subject to the CAA major NSR permitting program (pursuant t o 40 CFR 52.21 for areas designated as attainment/unclassifiable for the National Ambient Air Quality Standards (NAAQS)) and/or 40 CFR 49.166 through 49.175 for areas designated as nonattainment for the NAAQS). For projects that are not subject to major NS R review, the owner and operator must evaluate whether the Minor NSR P rogram applies.

We developed a general permit t o streamline t his permitting process for GDFs

. 4 The CA

- GDF General Permit is only intended for those sources that trigger the Minor NSR P rogram that are not major sources

.

2 See 40 CFR 49.151(c)(1), 49.152(d)(4). See also 81 FR 35944, 35980 (June 3, 2016).

3 Also, submitting a permit application or request for coverage satisfies the requirement for true minor sources to register under the Minor NSR Program at 40 CFR 49.160(c)(1)(iii).

4 We chose to develop a general permit rather than a permit by rule for Indian country within California in order to allow for closer review of individual GDF sources in the area covered by the permit, given the unique air quality conditions in California and the associated permitting requirements.Draft Technical Support Document
CA

- GDF General Permit Page 3 of 25 In addition, we have determined it is appropriate to allow only minor sources (whether true minor or synthetic minor) to seek cove rage under this general permit. That is, existing NSR major sources of any regulated NSR pollutant that propose modifications that are subject to the requirements of the M inor NSR program are not eligible to obtain coverage under this general permit, and m ust obtain a s ource

- specific Minor NSR permit from the EPA prior to construction. 5 Further, individual sources that cannot comply with the terms and conditions in the general permit will also need to seek a source

- specific permit. Our intent is to limi t the use of this general permit to the most common and straightforward permitting actions. Modifications to major sources may require more extensive analyses than those typically associated with preconstruction review of minor sources. And, we expect the vast majority of GDFs in Indian country within California to be minor sources.

When requesting coverage under the CA

- GDF General Permit, owners and operators will be required to compare their source’s PTE to the NSR major source thresholds to determine i f the source may qualify for coverage under the CA

- GDF General Permit as a minor source. The applicability of the preconstruction review requirements of the Minor NSR P rogram is determined individually for each regulated NSR pollutant that would be emitted by the new or modified source. For this source category

– GDFs

– t he NSR major source threshold for
attainment areas is 250 tons per year ( tpy ) for any regulated NSR pollutant. 6 The NSR major source thresholds for criteria pollutants in nonattainment areas a re summarized in Table 1 below.



### Table 1: NSR Major Source Thresholds for Nonattainment Areas
Pollutant Nonattainment Classification NSR Major Source Threshold
Ozone Marginal 100 tpy of VOC or NO X Moderate 100 tpy of VOC or NO X Serious 50 tpy of VOC or NO X Severe 25 tpy of VOC or NO X Extreme 10 tpy of VOC or NO X PM 10 Moderate 100 tpy
Serious 70 tpy
PM 2.5 (or PM 2 .5 precursor 7 ) Moderate 100 tpy
Serious 70 tpy

CO Moderate 100 tpy
Serious 50 tpy
SO 2 , NO 2
, lead No nonattainment classification 100 tpy

If a particular GDF is not a major source for a regulated NSR pollutant, then the owner and operator will evaluate whether the new or modified source has the potential to cause an emissions increase, based on PTE, equal to or greater than the minor NS R thresholds specified in the Minor NSR rule at 40 C FR 49.153. The se minor
NSR thresholds are listed in Table 2 below. Owners and operators applying for coverage under the CA

- GDF General Permit may calculate their GDF’s PTE using the PTE calculator provided with the CA

- GDF General Permit

5 In addition, existing minor sources that become major sources as a r esult of the current modification are also not eligible for the CA

- GDF General Permit.

6 There are 28 source categories that are subject to a lower major source threshold

– 100 tons per year

– in attainment areas. See 40 CFR 52.21(b)(1)(i)(a). GDFs are not one of the listed source categories.

7 See Appendix S to 40 CFR part 51, paragraph II.A.31.Draft Technical Support Document
CA

- GDF General Permit Page 4 of 25 package. 8 Owners and operators of sources with potential emission increases above the minor NSR thresholds, and not subject to major NSR, must apply for and obtain a minor NSR permit prior to constructing or modifying their source. 

### Table 2: Minor NSR Thresholds a 

### i n 40 CFR 49.153
Pollutant Attainment Area Nonattainment Area Carbon Monoxide (CO) 10 tons per year (tpy) 5 tpy Particulate Matter (PM) 10 tpy Not Applicable

PM 10 5 tpy 1 tpy
PM 2.5 3 tpy 0.6 tpy Sulfur Dioxide (SO 2 ) 10 tpy 5 tpy

Nitrogen Oxides (NO X ) b 10 tpy 5 tpy

VOC b 5 tpy 2 tpy Lead 0.1 tpy 0.1 tpy Fluorides 1 tpy NA Sulfuric Acid Mist 2 tpy NA
H 2 S 2 tpy NA Total Reduced sulfur 2 tpy NA Reduced sulfur

compounds 2 tpy NA

a I f part of a Tribe’s area of Indian country is designated as attainment and another part as nonattainment, the applicable threshold for a proposed source or modification is determined based on the designation where the source would be located. If the source straddles the two areas, the more stringent thresholds apply.

b In extreme ozone nonattainment areas, section 182(e)(2) of the Act requires any change at a major source that results in any increase in emissions to be subject to major NSR permitting. In other words, any changes to existing major sources in extreme ozone nonattainment areas are subject to a “0” tpy threshold, but that threshold does not apply to minor sources.



## 2. Requirements for Developing and Issuing a General Permit

We develop g eneral permits under the Minor NSR P rogram consistent with the requirements in 40 CFR 49.156

– Genera l Permits . Below we discuss these general permit program requirements and how they form the basis for the CA

- GDF General Permit.



### 2.1 Purpose, Source Category, and Issuance Procedures

The purpose of a general permit under the Minor NSR program is to simplify the permit issuance process for similar facilities so that a reviewing authority’s limited resources need not be expended for case

- by

- case permit development for such facilities. It als o allows a reviewing authority to notify the public through one notice that

8 If a particular source has emission units not typically found at a GDF, whether or not not included in the GDF portion of the source, then the owner/operator mus t include the PTE of the other emissions units to determine whether the source is subject to the major or minor NSR programs.Draft Technical Support Document
CA

- GDF General Permit Page 5 of 25 the EPA intends to apply these requirements to any eligible source that seeks coverage under the permit in the future, and decreases the time required for an individual minor source to obtain a preconstruction permit because the application process is shortened

. A general permit may be issued for a category of emissions units or sources that are similar in nature, have substantially similar emissions and would be subject to the same or substantially similar requirements governing operations, emissions, monitoring, reporting and recordkeeping. “Similar in nature” refers to size, processes and operating conditions. Th e reviewing authority for the program will determine which categories of individual emissions units, groups of similar emissions units or sources are appropriate for general permits in its area. General permits are issued at the discretion of the reviewing authority.

In this case, the source category is a specific source type: GDFs. The GDF source type is a good candidate for a general permit given the common equipment at each facility, relative simplicity of the processes employed at such a facility, and the frequency with which GDFs are constructed/modified. A detailed description of the gasoline dispensing facility source category is provided below in Section 2.2.

General permits under the Minor NSR P rogram must be developed using much the same proces s that is used for traditional source

- specific Minor NSR permits issued for individual sources. General permits also generally must include the same types of requirements as s ource

- specific Minor NSR permits.

All permits issued under the Minor NSR progra m must have emission limits developed according to 40 CFR 49.154(c)

– How will the reviewing authority determine the emission limitations that will be required in my permit?

– and consider air impacts according to 40 CFR 49.154(d)

– When may the reviewing authority require an air quality impacts analysis (AQIA)? In addition, 40 CFR 49.155 identifies specific requirements that must be included in each permit under the Minor NSR P rogram. These requirements, as specified in 40 CFR 49.155(a)(1) through (7), inc lude: general requirements, emission limitations, monitoring requirements, recordkeeping requirements, reporting requirements, a severability clause, and other additional provisions. 40 CFR 49.155(b) also specifies how a permit can become invalid under the Minor NSR P rogram. 40 CFR 49.156(b) provides that general permits must be issued in accordance with these requirements.

40 CFR 49.156(d) specifies that a general permit must contain the permit elements listed in 40 CFR 49.155(a), as well as the requireme nts from 40 CFR 49.156(d), including the following:

• Identification of the specific category of emissions units or sources to which the general permit applies, including any criteria that the emissions units or sources must meet to be eligible for coverage under the general permit.

• The name and mailing address of the reviewing authority to whom the application must be submitted.

• The proce dure to obtain any standard application forms that the reviewing authority may have developed.

• Other application requirements deemed necessary by the reviewing authority.

How we considered and included these requirements is discussed in greater detail in Section 3

– Permit Content.

In addition, the public participation procedures for issuance of a general permit under the Minor NSR program are largely the same as those for source

- specific permits per 40 CFR 49.157. Final permit issuance and administrative and judicial review procedures for general permits are specified in 40 CFR 49.159, and are generally the same as those governing source

- specific permits issued under the Minor NS R program. TheDraft Technical Support Document
CA

- GDF General Permit Page 6 of 25 reviewing authority’s final permit decision for a general permit become s effective 30 days aft er the service of notice of the final permit decision , unless:

1. A later date is specified in the permit, or
2. Review of the final permit decision by the EPA’s Environmental Appeals Board is requested under 40 CFR 49.159(d) , or 3. The reviewing authority make s the permit effective immediately upon issuance if no comments requested a change in the draft permit or a denial of the permit.

Under the Minor NS R P rogram, i ssuance of a final general permit following the exhaustion of agency administrative review procedures is considered final agency action with respect to all aspects of the general permit except its applicability to an individual source. 40 CFR 49.159(d)(8). The sole issue that may be appealed after an individual source is approved to construct under a general permit is the applicability of the general permit to that particular source. The letter notifying an individual source of approval or deni al under a general permit is considered a final agency action for purposes of judicial review and is not subject to administrative
review by the EPA’s Environmental Appeals Board. See 40 CFR 49.156(b)(3), 49.156(e)(6).



### 2.2 Source Category Description

- Gasoline Dispensing Facilities

The term “g asoline dispensing facility (GDF) ” means any stationary source which dispenses gasoline into the fuel tank of a motor vehicle, motor vehicle engine, nonroad vehicle, or nonroad engine, including a nonroad vehicle or nonroad engine used solely for competition. These facilities include, but are not limited to, facilities that dispense gasoline into on

- and off

- road, street, or highway motor vehicles, lawn equipment, boats, test engines, landscaping equipment, generat ors, pumps, and other gasoline

- fueled engines and equipment. 9 A GDF can also include equipment that dispenses diesel fuel . In addition , a GDF could be an operation supporting other
activities at a facility that otherwise requires a permit. 10

Gasoli ne is delivered by tank trucks to GDFs and then transferred to highway motor vehicles and nonroad equipment and engines. GDFs include all retail outlets such as traditional gasoline service stations, convenience stores, truck stops, and hypermarkets ( e.g. , warehouse clubs and big box stores), marinas, as well as private and commercial outlets, such as centrally

- fueled fleets, government operations, and private businesses such as farms and landscaping operations. The CA

- GDF General Permit is not available to sources that store and transfer aviation gasoline at airports or other similar sources that dispense fuel through mobile (portable) fueling equipment.

The operations and equipment at a typical GDF are described in AP 42 , Chapter 5.2, Transportation and Marketing of Petroleum Liquids. 11 Emissions of volatile organic compounds (VOC) at GDFs occur due to evaporation, displacement of vapors during unloading of the fuel into onsite storage tanks, displacement of vapors during refueling of vehicles, and breathing losses from the storage tanks

. As discuss ed in greater detail in
Section 3.2 .1.1 , e missions from GDF are generally addressed by two categories of v apor r ecovery control technologies, referred to as Stage I and Stage II.

9 See 40 CFR 63.11132.

10 This general permit only covers emission units at the GDF, and other emissions units may require a separate permit. The other emission units could be covered by a source

- specific permit, a general permit, or a permit by rule.

11 AP 42, Chapter 5.2, Transpo rtation a nd Marketing o f Petroleum Liquids, June 2008, http://www.epa.gov/ttn/chief/ap42/ch05/index.html

.Draft Technical Support Document
CA

- GDF General Permit Page 7 of 25 

### 2.3 Procedures for Obtaining Coverage under a General Permit

40 CFR 49.156(e) specifies the procedures for obtain ing cover age under a general permit. We have included these requirements in the Request for Coverage document developed for the CA

- GDF General Permit. As such, by completing the Request for Coverage, owners/operators will meet or be notified of the requirements applicable to them in order to qualify for coverage under the CA

- GDF General Permit. The requirements include:

• The timef rame w hen a source can begin to request coverage under the CA

- GDF General Permit once it is finalized;

• T he requirement to submit a copy of the Request for Coverage to the t ribe in the area where the source is locating;

• T he timeframe for action by the rev iewing authority after a Request for Coverage is submitted, including a completeness determination, and notification of approval or denial;

• Clarification that the approval or denial of the Request for Coverage is a final action for purposes of judicial re view only for the issue of whether the source qualifies for coverage under the CA

- GDF General Permit;

• The requirement to prominently post a copy of the letter granting the Request for Coverage at the site where the source is locating;

• T he timeframe for com mencing construction if the Request for Coverage is approved ;

• T he requirement to comply with the all conditions and terms of the CA

- GDF G eneral P ermit if approval is granted ; and

• T he option for requesting a source

- specific permit instead of coverage under the CA

- GDF G eneral
P ermit.



## 3. Permit Content

As discussed in Section 2 above, t he terms and conditions o f the CA

- GDF General P ermit are based on the required permit content and analyses specified in the Minor NSR r ule. The required permit conte nt for Minor NSR permits is listed in 40 CFR 49.155

– What information must my permit include? Below we describe the basis for the CA

- GDF General P ermit conditions.



### 3.1 Required Permit Content

40 CFR 49.155(a)(1)

– General Requirements 40 CFR 49.155(a)(1) speci fies the following elements that each Minor NSR permit must i nclude : t he effective date of the permit and the date by which the owner/operator must commence construction in order for the permit to remain valid; the emission s units subject to the permit and their associated emission limitations; and monitoring, recordkeeping, and reporting requirements to assure compliance with the emission limitations.

The CA

- GDF General Permit includes all of th ese required elements , except for the specific emission s uni ts subject to the permit. Because of the nature of general permits, we believe it is more appropriate to identify the specific emission units covered by the General P ermit for a particular source in the Approval of Request for Coverage, as the CA

- GDF General P ermit makes enforceable the Approval of the Request for Coverage. However, all of the emission limits applicable to the equipment at a GDF are included in the CA

- GDF G eneral
Permit.Draft Technical Support Document
CA

- GDF General Permit Page 8 of 25 40 CFR 49.155(a)(2)

– Emission Limitations 40 CFR 49.155(a)(2) states that each Minor NSR permit must include the emission limitations determined by the reviewing authority under 40 CFR 49.154(c) for each affected emiss ions unit. The permit must also include annual allowable emissions limits for sources needing enforceable emission limitations to lower their potential
to emit . 40 CFR 49.154(c)

– How will the reviewing authority determine the emission limitations that will be required in my p ermit?

– describes the case

- by

- case control technology review that must be used by the reviewing authority to determine the appropriate level of control. In carrying out the case

- by

- case control technology review, the reviewing authority must consider the following factors:

1. Local air quality conditions;
2. Typical control technology or other emission reduction measures used by similar sources in surrounding

areas; 3. Anticipated economic growth in the area; and
4. Cost

- effective emission reduction alternatives.

In addition, 40 CFR 49.154(c) provides that the reviewing authority must require a numerical limit on the quantity, rate
, or concentration of emissions for each regulated NSR pollutant emitted by each affected emissions unit for which such a limit is techn ically and economically feasible. 40 CFR 49.154(c) further provides that t he emission limitation s required by the reviewing authority may consist of numerical limits on the quantity, rate or concentration of emissions; pollution prevention techniques ; desi gn standards ; equipment standards ; work practices ; operational standards ; requirements relating to the operation or maintenance of the

source; or any combination thereof. T he emission s limitations must assure that each affected emission unit will comply with all requirements of 40 CFR parts 60, 61, and 63, as well as any federal or tribal implementation plans that apply to the unit. Finally, the emission s limitations required may not re ly on a stack height that exceeds good engineering practice or any other dispersion technique, except as allowed by 40 CFR 51.118(b).

Our detailed analysis supporting the emission s limitations in the CA

- GDF General Permit is provided below in
Section 3.2.

40 CFR 49.155(a)(3)

– Monitoring Requirements 40 CFR 49.155(a)(3) provides that e ach Minor NSR permit must include monitoring that is sufficient to assure compliance with the emission s limitations that apply to the affected emission s units at the sourc e. In this case, the CA

- GDF General P ermit requires monitoring of the required vapor control recover y systems on a weekly basis to determine whether the equipment is in good working order. For sources located in extreme ozone nonattainment areas, this moni toring shall be performed daily. The CA

- GDF General Permit also requires : (1) initial and ongoing performance testing to ensure that the vapor recovery systems are designed and working properly , and (2) for GDFs in ozone nonattainment areas, regular monito ring of the vapor recovery systems through an in

- station diagnostics (ISDs) system.

40 CFR 49.155(a)(4)

– Recordkeeping Requirements 40 CFR 49.155(a)(4) provides that e ach Minor NSR p ermit must include recordkeeping requirements sufficient to assure compliance with the emission s limitations and monitoring requirements, including the elements listed in 40 CFR 49.155(a)(4)(i) and (ii). In addition to the recordkeeping elements in 40 CFR 49.155(a)(4)(i) and (ii), the
CA

- CDF General P ermit also requires records of the weekly (or daily) inspections of the vapor recovery systems, the reports from the ISD system, and the results of each performance test required by the permit. Furthermore

,Draft Technical Support Document
CA

- GDF General Permit Page 9 of 25 t he permittee must maintain records of monthly g asoline throughput and the 12

- month rolling total of gasoline throughput.

40 CFR 49.155(a)(5)

– Reporting Requirements 40 CFR 49.155(a)(5) requires that each Minor NSR p ermit include the reporting requirements listed in 40 CFR 49.155(a)(5)(i) and (ii) rel ated to annual reports and reporting of deviations. The CA

- GDF General Permit includes such requirements, as well as requiring notifications of construction/modification, notification of change in owner or operator, notification of closure, and requirement s for performance test reports.

40 CFR 49.155(a)(6)

– Severability Clause 40 CFR 49.155(a)(6) provides that e ach Minor NSR p ermit include a severability clause to ensure the continued validity of the other portions of the permit in the event of a challeng e to a portion of the permit. The CA

- GDF Permit includes the required severability clause.

40 CFR 49.155(a)(7)

– Additional Provisions 40 CFR 49.155(a)(7) requires that each Minor N SR permit contain provisions stating the requirements in paragraphs (a)(7) (i) through ( v ii) of that section. The CA

- GDF G eneral P ermit contains the required provisions

. These conditions are found in the Gen eral Provisions section of the p ermit

.



### Section 3.2 Emission Limitations

In this section, we discuss the basis for the emission s limitations in the CA

- GDF General Permit, based on the requirements in 40 CFR 49.155(a), including the control technology review required by 40 CFR 49.154(c). We did not conduct an air quality impact analysis in developing these limitations

. Inst ead , in determining whether to grant coverage under the CA

- GDF General Permit for individual sources, we will consider whether such an analysis is needed for that particular source. See the discussion below in Section 4.6

.


### Section 3.2.1 Control Technolog y Review

As discussed above, 40 CFR 49.154(c) describes the case

- by

- case control technology review that must be conducted by the reviewing authority to determine the appropriate level of control for the permitted source . In carrying out the control technology review, the reviewing authority must consider the following four factors:

1. Local air quality conditions;
2. Typical control technology or other emission reduction measures used by similar sources in surrounding

areas; 3. Anticipated economic growth in the area; and
4. Cost

- effective emission reduction alternatives.

Below , we discuss our analysis of these factors in the context of the CA

- GDF General Permit.



### Section 3.2.1 .1

Available Control Technologies at GDFs

The primary pollutant s at GDFs are VOC emissions caused by the volatile nature of gasoline. There are two major categories of control technologies for GDFs

, which are referred to as Stage I and Stage II. Both technologies areDraft Technical Support Document
CA

- GDF General Permit Page 10 of 25 designed to reduce VOC emissions by recovering gasoline vapors ( referred to as “vapor recovery”) that are emitted as part of the processes at GDFs.

Stage I vapor recovery is intended to reduce e missions during unloading of the gasoline fuel from a tanker truck

to storage tanks at the GDF. Stage I vapor recovery minimi ze s such emissions by using submerged filling or bottom filling, in which the fill pipe opening is below the liquid surface level in the receiving tank. Liquid turbulence is controlled significantly during submerged/bottom filling, resulting in low vapor g eneration. Emissions during unloading can also be controlled with vapor balance. The vapors displaced from the receiving tank during unloading are routed back into the transport tank and returned to the loading terminal. Stage I vapor balance requires that the GDF source control emissions from the storage tanks during unloading of the gasoline fuel from the tanker truck. This typically involves having an extra tube hooked up to the receiving tank to transfer VOC

- laden vapors displaced from the tank back int o the tanker truck for processing/disposal back at the loading terminal. As discussed below, t he requirements in 40 CFR part 63, s ubpart CCCCCC

, include a comprehensive set of Stage I vapor control requirements.

Stage II vapor recovery is intended to reduce e vaporative emissions from vehicle refueling and diurnal breathing (everyday evaporative losses from storage tanks) at GDFs , and control such emissions using vapor recovery devices. 12 Recovery of vapors displaced fr om the vehicle fuel tank during refueling can be accomplished with

pump

- based controls and/ or vehicle

- based onboard refueling vapor recovery (ORVR) systems. Pump

- based Stage II vapor recovery requires that the GDF equip its dispensing pumps with nozzles th at recover the VOC

laden fumes that are displaced from the vehicle fuel tank during fueling. A coaxial tube and special nozzle are designed to attach to the vehicle ’ s fuel port and to recover vented fumes during filling. The recovered fumes are pumped back into the fuel storage tank. S torage tank diurnal breathing loss emissions are controlled by properly maintaining pressure in vent pipe s and vacuum valves

. ORVR controls are installed by the vehicle manufacturer. ORVR controls started phasing

- in in 1998 a nd ha ve been required for all new vehicles since model year 2006

. 13

Our control technology review for CA

- GDF General Permit is limited to these two types of vapor recovery, Stages I and II, as we are not aware of any other available control technologie s for GDFs. As such

, our determination of which emission limits to include in the CA

- GDF General Permit is based on whether it is appropriate to require either, or both, of these types of vapor recovery.



### Section 3.2.1 .2 Factor 1

– Local Air Quality Conditions

Local air quality conditions

– Local air quality considerations were a key consideration in setting the emission limitations in the CA

- GDF General Permit. This permit was developed separately from the EPA’s national GDF Permit by Rule , which is applicable outside of the State of California

, to ensure that the permit conditions would be appropriate for the air quality conditions within the State of California, which are in many locations in Indian country much worse than those in other areas of I ndian country across the nation

. To appropriately address the air quality conditions within California, the CA

- GDF General Permit applies controls that are generally consistent

12 AP 42, Chapter 5.2, Transportation a nd Marketing o f Petroleum Liquids, June 2008, http://www.epa.gov/ttn/chief/ap42/ch05/index.html

. 13 See Section I.B, pp. 3 of Stage II Vapor Recovery Systems Issues Paper , U.S. EPA, Office of Air Quality Planning and Standards, Emissions M onitoring and Analysis Division, Emissions Factors and Policy Applications Group (D243

- 02) , August 12, 2004. ORVR requirements are for motor vehicles and are outside the scope of what can be required for stationary

sources.Draft Technical Support Document
CA

- GDF General Permit Page 11 of 25 with those required for similar sources in surrounding areas ; i.e.
, Stage I vap or recovery in all areas and Stage II vapor recovery in ozone nonattainment areas

. Our decision to apply Stage I and II controls is discussed in more detail below in Section 3.2.1.3 , where we discuss our consideration of control technologies used by similar sources in surrounding areas. In some instances, our control technology determination adopts the same level of control as the national GD F Permit by Rule, and in others it is more stringent than the national GDF Permit by Rule.

T he CA

- GDF General P ermit may be used only by smaller GDFs , in terms of emissions

, i.e. , those with approximate emissions of less than 30 tons per year of VOC in attainment areas 14

, and marginal and mode rate ozone nonattainment areas, and those with emissions of less th an 10 tons per year in serious, severe, and extreme ozone nonattainment areas. We are implementing this restriction by including permit conditions limiting the amount of gasoline that can be dispensed annually (based on a 12

- month rolling total) , which is referred to as a throughput limit . Section 3.2.2 contains a discussion of these limits. In addition, as discussed in
Section 4 .6 , the permitting authority has the discretion to determine that an individual source should not be approved to use the CA

- GDF General Permit and must instead seek a source

- specific Minor NSR permit due to local air quality conditions.



### Section 3.2.1 .3 Fac tor 2

– Typical Control Technologies

Typical control technology or other emission reduction measures used by similar sources in surrounding areas

– For this factor , we considered two main sets of requirements: (1) the minimum technology and emission limit ations that must be met by GDFs nationally under the federal requirements of 40 CFR p arts 60, 61
, and 63 ; and (2) the technology and emission limitations required by the State of California. At a minimum, the emission limitations in the CA

- GDF General Permit must ensure compliance with parts 60, 61, and 63 (see 40 CFR 49.154(c)(4)). As explained above, our review of these requirements focused on the two types of control technologies for GDFs

– Stage I and II vapor recovery , and the specific requirements (emission limits, work practices standards, etc.) that are applied to GDFs when applying Stage I or II vapor recovery controls. Our review of emission reduction measures used by similar sources in the surrou nding areas considered the following potential equipment at GDF s: 15

• Gasoline stora ge tanks and filling operations ;

• Gasoline pumping operations ;

• Diesel storage tanks and filling operations ;

• Diesel pumping operations ; and

• S tationary emergency engines

.

Review of Potentially Applicable Federal Requirements:

The p otentially a pplicable f ederal r equirements that we considered for the CA

- GDF G eneral P ermit are :

14 For the purposes of this TSD , “attainment areas” include those areas that are designated attainment, unclassifiable, or attainment/unclassifiable.

15 The CA

- GDF General Permit covers only covers the type of equipment typically found at a GDF. Other equipment at the source may require a separate Minor NSR permit. Such other equipment potentially could be permitted under a source

specific permit, a general permit, or a permit by rule.Draft Technical Support Document
CA

- GDF General Permit Page 12 of 25 • 40 CFR part 60
, s ubpart IIII

– Standards of Performance for Stationary Compression Ignition Internal Combustion Engines ;

• 40 CFR part 60
, s ubpart JJJJ

– Standards of Performance for Stationary Spark Ignition Internal Combustion Engines ;

• 40 CFR part 60
, s ubpart Kb

– Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) Which Construction, Reconstruction, or Modification Commenced after July 23, 1984 ;

• 40 CFR part 63
, s ubpart CCCCCC

– National Emission Standards for Gasoline Dispensing Facilities ; and

• 40 CFR part 63
, s ubpart ZZZZ

– Nationa l Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

.

During the development of the national GDF Permit by Rule, the EPA conducted a review of the requirements for GDFs of other state and local agencie s , in addition to the federal requirements in parts 60 and 63 listed above

. 16 That review resulted in the EPA’s adoption of the control technology requirements for Stage I vapor recovery standards in 40 CFR part 63, subpart CCCCCC, in addition to certification or work practice standards for emergency engines. 17 In this case, w ith respect to attainment areas

, for the CA

- GDF General Permit w e are finding that this prior analysis, as it pertains to those areas already attaining the NAAQS, continu es to be appropriate
, and we are utilizing the same requirements for such areas as those applicable under the national
GDF Permit by Rule, with one exception. A s discussed below, we are not including the control requirements for emergency engines in the CA

- GDF General Permit.

We included permit conditions in the CA

- GDF General Permit that incorporate Stage I requirements from 40 CFR part 63, subpart CCCCCC : 18

• 40 CFR 63.11116(a)

– requirement to minimize vapor releases;

• 40 CFR 63.11117(b)

– requirement to use submerged filling;

• 40 CFR 63.11117(c)

– exception of certain tanks from 63.11117(b);

• 40 CFR 63.11118(b)(1)

- requirement to use Stage I dual

- point vapor balance systems;

• 40 CFR 63.11118(c)

– exception of certain tanks from 63.11118(b)(1);

• 40 CFR 6 3.11118(d)

– requirements for cargo tanks;

• 40 CFR 63.11120(a)

– initial and ongoing testing requirements;

• Table 1 to Subpart CCCCCC of 40 CFR 63

– management practices; and

• Table 2 to Subpart CCCCCC of 40 CFR 63

– management practices for cargo tanks

.

T he se requirements are also included in the national GDF Permit by Rule. In addition, we included a permit condition requiring sources to meet the exemption criteria for emergency engines discussed above.

16 See Section 5.2.2 of the Background Document: Air Quality Permit by Rule for New or Modified True Minor Source Gasoline Dispensing Facilities in Indian Country.

17 See Section 4.3 of the Background Document: Air Quality Permit by Rule for New or Modified T rue Minor Source Gasoline Dispensing Facilities in Indian Country.

18 We expect that all GDFs seeking coverage under the CA

- GDF General Permit will be required to have Stage I vapor controls under the federal NESHAP regulations at 40 CFR 63.11118, which req uire GDFs that dispense more than 1,200,000 gallons per year to use Stage I vapor controls.Draft Technical Support Document
CA

- GDF General Permit Page 13 of 25 We did not include requirements for diesel storage ta nks or diesel pumping operations in the CA

- GDF General
P ermit conditions . There are currently no control requirements in 40 CFR parts 60, 61, or 63 for such equipment. This is the same approach that was taken for the national GDF Permit by Rule. Diesel is less volatile than gasoline and has significantly less VOC emissions as compared to gasoline operations. Given the se limited emissions, we are not proposing any specific standards for diesel storage tanks or diesel pumping operations in the CA

- GDF General Permit. However, emissions from diesel storage tanks and diesel pumping operations must still be reflected in a GDF’s emissions calculations, and must be included in any Request for Coverage under the CA

- GDF General Permit. 19

Specifically, we did not include requirements from these regulations:

40 CFR part 60, subparts IIII and JJJJ and 40 CFR part 63, subpart ZZZZ

– The EPA has revised the Minor NSR program to exempt certain emergency generator engines from the requirement to obtain a permit. 20 We expect most GDFs to either not have emergency engines or to have engines that fall within this exemption. W e are not including the requirements from these regulations and are limiting the CA

GDF General Permit to only those new or modified GDFs that w ould have exempt emergency engines, or in the case of severe and extreme ozone nonattainment areas, no new or modified emergency engines. See 40 CFR 49.153(c)(9) and additional discussion in Section 4.2. We note that these regulations are self

implementin g and therefore all emergency engines at GDFs will need to meet the applicable requirements of these regulations. Existing engines will need to comply with subpart ZZZZ and new engines wi ll need to either comply with subpart IIII for diesel engines or subp art JJJJ for spark ignition engines , regardless of whether these requirements are included in the CA

- GDF General Permit.

• 40 CFR part 60, subpart Kb

– While this regulation is potentially applicable to the storage tanks at GDFs, the regulation specifically exempts storage vessels located at GDFs. See 40 CFR 60.110b(b)(6). In addition, diesel storage tanks are also exempt because the maximum true vapor pressure of diesel (approximately 0.4 kilopascals) is less than 3.5 kilopascals

.

Review of California Requ irements:

Our review focused on the air quality control requirements typically applied to GDFs in areas of California within the State’s jurisdiction. Due to significant air quality problems in California, the California Air Resources Board (CARB) h as developed an extensive set of regulations for controlling VOC emissions from GDFs. These regulations include requirements for both Stage I and Stage II vapor recovery. 21 In addition to the requirements

19 The PTE Calculator includes estimates for emissions from diesel storage tanks and pumping operations.

20 In May 2014, the EPA revised the Minor NSR Program to exe mpt certain emergency generator engines from the requirement to obtain a permit. Under 40 CFR 49.153(c)(9), e mergency generator engines at a single source are “ exempt ” if the combined maximum horsepower ( hp ) rating of all emergency generator engines is bel ow 1,000 hp in attainment areas or 500 hp in ozone nonattainment areas classified as Serious or lower. If the source consists of only exempt equipment, then the owner or operator is not required to obtain a minor NSR permit.

21 As discussed above, t he EPA refers to the two categories of vapor recovery control technologies at GDFs as Stage I ( to address emissions from transfer of gasoline to storage tanks) and Stage II ( to address emissions from gasoline dispensing and diurnal breathing ). In Californi a, these types of vapor recovery are referred to as Phase I and Phase II, respectively. EPA Region 9 has taken the approach here of using the Stage I and II terminology for consistency with other EPA documents and regulations that use the terms.Draft Technical Support Document
CA

- GDF General Permit Page 14 of 25 established by the CARB, we also examined p ermits for GDFs from California air distric ts in ozone nonattainment

areas, including the South Coast Air Quality Management District , as discussed below.

Specific California permits, rules, executive orders, and guidance reviewed:

• Certification Procedu res CP

- 201 and CP

- 206;

• Types of Vapor Recovery Systems certified by CARB 22 ;

• South Coast Air Quality Management District ( South Coast AQMD) Rule 461

− Gasoline Transfer and Dispensing ; and

• Sample South Coast AQMD Evaluation for Permit s to Construct /Operate

Nearly a ll GDFs in the U.S. are required to have Stage I vapor recovery controls as the use of such controls is required by 40 CFR part 63, subpart CCCCCC . Until a 2012 EPA rulemaking, Stage II vapor recovery controls for gasoline pumps during ve hicle refueling were required under the CAA for serious, severe, and extreme ozone nonattainment areas. The 2012 rulemaking concluded that these Stage II controls were no longer required for these nonattainment areas due to the widespread use of onboard re fueling vapor recovering (ORVR) technology in the U.S. motor vehicle fleet, which also serves to limit emissions during vehicle refueling. 23 ( 77 FR 28772 , May 16, 2012)

For Minor NSR P rogram national general permits and permit s by rule, the EPA has generally taken the approach of requiring more stringent emission controls in areas with poorer air quality in order to ensure that sources in these areas are minimizin g emissions and that air quality is protected

. We received comments on th e proposed national GDF Permit by Rule recommending that the EPA require Stage II controls in states that still require Stage II controls, and that we require California’s Stage II controls in all serious, severe or extreme
nonattainment areas

. 24 In light of the 2012 rulemaking, however, the EPA did not include Stage II requirements
in ozone nonattainment areas as part of the national Permit by Rule

. Nevertheless , Stage II contr ols continue to be required for GDFs in California ozone nonattainment areas by the CARB to address the ongoing air quality problems in California

. 25

Given California’s continued use of Stage II

, in issuing the final GDF P ermit by R ule

, EPA determined that it would not make the GDF Permit by Rule available for use in Indian country within the geographical boundaries of the
State of California. Instead, we decided to develop a general permit or permit by rule specifically for GDFs in Indian country within California in order to consider the appropriateness of requir ing additional controls, such as Stage II vapor recovery , in California nonattainment areas to support a level playing field and to address the air quality problems in Ca lifornia

.

Since April 2009, California has required all applicable GDFs to comply with its Stage II enhance d vapor recovery (EVR ) system standards to control evaporative emissions from vehicle refueling and from breathing losses from

22 https://www.arb.ca.gov/vapor/eo

- evrphaseII.htm

23 After the effective date of th is 2012 action, a state s previously required by the CAA to implement a Stage II program could take appropriate action to remove the program from its State Implementation Plan (SIP)

. 24 80 FR 25068, 25077 (May 1, 2015).

25 As a result, there are about 7,500 gas stations using Stage II controls in California. http://www.arb.ca.gov/vapor/workshops/op2015/nov.%202015%20over%20pressure%20workshop%20

- %20final%20nov%205.pdfDraft Technical Support Document
CA

- GDF General Permit Page 15 of 25 underground storage tanks (USTs). The se standards require greater emission reductions than were typically seen for Stage II controls in other ozone nonattainment areas outside of California

– 95% control in California versus 60

- 90 % in other areas

. 26 Additionally, Californ ia Stage II EVR standards require GDFs with Stage II equipment to install, properly operate

, and maintain CARB

- certified Stage II EVR equipment that is compatible with vehicle manufacturers’ ORVR equipment. California also requires GDFs with throughput s of more than 600,000 gallons per year of gasoline to install In

- Station Diagnostic (ISD) Systems. An ISD System is an alarm system that provides continuous real

- time monitoring of critical emission

- related vapor recovery system parameters and components, and that alerts the station operator when a failure mode is detected so that corrective action can be taken within 2 hours . If timely corrective action is not taken, the ISD System will shut down the gasoline dispensing systems.

We have determined that thes e requirements

– i.e.
, the use of Stage II EVR system with ISD systems

– are appropriate to include in the CA

- GDF General Permit for EPA

- designated ozone nonattainment areas to protect air quality based on the unique air quality problems facin g California, and to ensur e general consistency with the emission reduction measures used by similar sources in surrounding areas

. 27 While CARB only requires ISD systems for GDFs that dispense greater than 600,000 gallons of gasoline per year, w e are requiring ISD systems in the CA

- GDF General Permit for all GDFs in EPA

- designated ozone nonattainment areas

. This is appropriate because u nder the Minor NSR P rogram, GDFs dispensing less than 600,000 gallons of gasoline per year would not be expected to trigger the requirements for a Minor NSR permit

.

We are including these require ment s in the CA

- GDF General Permit for ozone nonattainment areas by adopting the standards issued by the CARB for Stage II EVR systems with ISD systems

, rather than the requir ements of a particular local California air district. California air district s may have their own set of GDF requirements to implement the CARB’s standards. However, g iven that there are 35 air districts in California, we ha ve determined that adopting unif orm requirements for GDFs in all the EPA

- designated ozone nonattainment areas covered by the CA

- GDF General Permit based on the CARB’s standards is the most appropriate and straightforward approach. The standards we are adopting are the CARB’s Certificatio n Procedures in CP

- 201 for ERV systems. In order to meet the CP

- 201 standards, owner and operators must use CARB

- certified equipment. 28 These standards are mainly a combination of control efficiency requirements and work practice standards, but also di rectly limit system VOC emissions to 0.38 lb/1,000 gallons of gasoline. Current CP

- 201 standards for Stage II ERV systems include , but are not limited to :

26 Stage II Vapor R ecovery Systems Issues Paper , U.S. EPA, Office of Air Quality Planning and Standards, Emissions
M onitoring and Analysis Division, Emissions Factors and Policy Applications Group (D243

- 02) , August 12, 2004.

27 We note that the CARB applies the requirement fo r GDFs to install Stage II controls in areas that are nonattainment for the State Ambient Air Quality Standards for ozone. In addition, California has an Air Toxics Control Measure that requires Stage II controls for all new GDFs in order to reduce benzene emissions . The consideration of benzene, a hazardous air pollutant, is outside the scope of EPA’s Minor NSR Program.

28 We note that California’s air quality programs are not approved by EPA to apply under the Clean Air Act within any Indian
reservation or any other area of Indian country over which an Indian tribe, or the EPA, has demonstrated that a tribe has jurisdiction. Thus, the specific air quality requirements and associated equipment certification requirements adopted by California are not approved by EPA to apply for purposes of the State’s Clean Air Act NSR program within such areas. It is only by virtue of EPA’s adoption of these requirements as appropriate permit conditions for the federal CA GDF General Permit, as we are doing in this case in i mplementing the federal NSR program, that the requirements are made applicable in such areas of Indian country.Draft Technical Support Document
CA

- GDF General Permit Page 16 of 25 • All systems shall meet a hydrocarbon efficiency rate of 95% or greater and/or an emission rate for

g asoline not to exceed 0.38 pounds per 1,000 gallons. This includes refueling and vent emissions, and

pressure

- related fugitives.

• Spillage, including drips from spouts, shall not exceed 0.24 pounds per 1,000 gallons of gasoline.

• System must be compatible with ORVR.

• System is operated with a liquid retention nozzle “spitting” rate not to exceed 100 milliliters (ml) per 1,000 gallons of gasoline and

• e not to exceed 1.0 ml per nozzle per test.

• System is operated with low permeation hoses with a permeation rate not to exceed 10.0 grams per meter squared per day (g/m 2 /day).

• Underground Storage Tank ( UST ) pressure criteria, based on a 30

- day rolling average, shall not exceed +0.25 inches of water (in. H 2 O, daily average pressure and shall not ex ceed +1.50 in. H 2 O, daily high

pressure )

.

• Each nozzle shall meet the following criteria:

o Capable of refueling any vehicle that complies with the fillpipe specifications and can be fueled by a conventional nozzle;

o “Dripless,” meaning that no more than th ree drops shall occur following each refueling operation; and

o Shall comply with the following:

 The terminal end shall have a straight section of at least 2.5 inches (6.34 centimeters) in length;

 The outside diameter of the terminal end shall not exceed 0.8 40 inch (2.134 centimeters) for the length of the straight section; and

 The retaining spring or collar shall terminate at least 3.0 inches (7.6 centimeters) from the terminal end.

• For the nozzle/dispenser compatibility: the vapor check valve shall be close d when hung and the hold

open latch disengaged when hung.

• The unihose MPD configuration shall be such that only one hose/nozzle is allowed per dispenser side.

• The Stage II vapor riser shall be a minimum of an inch nominal ID.

• The vapor return piping shall meet the following requirements:

o No liquid or fixed blockage;

o Minimum of 3

- inch nominal ID after first manifold;

o Have a recommended slop of 1⁄4 inch per foot; and

o Have a minimum slope of 1/8 inch per foot.

• The vapor return pipe shall have a maximum allowable length of pipe established during the certification

process.

• The liquid condensate traps shall have an automatic evacuation system.

• The connectors and fittings shall have no indication of vapor leaks with liquid leak detection solution (LDS) or bagging.

The current version of CP

- 201 is dated April 23, 2015. The CA

- GDF General Permit requires that owners and operators subject to the CA

- GDF General Permit, Version 1.0, comply with the standards in this version of CP

201 dated April 23, 2015

. Owners and oper ators will meet this requirement by installing EVR and ISD system s that are certified by CARB as meeting the CP

- 201 standards. There are currently three such systems certified by
CARB executive o rders and included in the CA

- GDF General Permit : VR

- 20 2

- U
, ex ecuted on August 31, 2016 ; VR

204

- S , executed on March 28, 2016; and VR

- 20 8

- A , executed on September 23, 2009

.Draft Technical Support Document
CA

- GDF General Permit Page 17 of 25 We anticipate that revisions to these standards and executive orders will be made by the State of California in the future under s tate law. Suc h revisions would not affect owners and operators that have been issued an Approval of the Request for Coverage under the CA

- CDF General Permit in terms of changing applicable CA

- CDF General Permit requirements. 29 We anticipate that we may periodically update the CA

- GDF General Permit to reflect evolving air quality control requirements for GDFs. Such revisions would only affect owners and operators that seek general permit coverage for construction or modification of a GDF following those revisions to the CA

- GDF General Permit. That is, any new requirements resulting from revisions to the CA

- GDF General Permit would not apply retroactively. 30

In addition, while CARB has a set of Stage I vapor recovery standards

, we are not adopting thos e standards in their entirety in to the CA

- GDF General Permit. CARB’s St age I vapor recovery standards are very similar, but not identical to

, the EPA’s Stage I standards in 40 CFR part 63, subpart CCCCCC , which we are applying to all sources in the CA

- GDF General Permit

. One major difference between these standards is that CARB’s standar ds require GDFs to achieve at least a 95% control efficien cy , whereas the EPA’s Stage I standards do not require all sources to meet a specific control efficiency. We have d etermined it is appropriate for GDF’s in ozone nonattainment areas to be required to meet the CARB control efficiency standard and have , therefore, included it in the CA

- GDF General Permit for ozone nonattainment areas

.

Review of California Requirements for Aboveground Storage Tanks California also has statewide Stage I and Stage II requirements for aboveground storage tanks (ASTs) in ozone
nonattainment areas. 31 The Stage I requirements that we have included in the CA

- GDF General Permit apply equally to ASTs and USTs. However , at this time, we have chosen not to cover under the CA

- GDF General Permit those new or modified GDFs located in ozone nonattainment areas that require a minor NSR permit and that utiliz e new or modified ASTs . While Stage II cont rols for USTs have been in place since 2009 in California, similar requirements for ASTs only became effective in California in 2015 and generally are not widely used at GDFs

. 32 Currently, we expect that most owners and operators of GDFs needing Minor NSR permits will use USTs. New or modified GDFs in ozone nonattainment areas located in California that include ASTs as part of the new or modified source will need to seek a source

- specific preconstruction Minor NSR permit from the EPA if their new

or mo dified source requires a Minor NSR permit . If ASTs become more commonplace for GDFs subject to the
Minor NSR program, we may revise the CA

- GDF General Permit in the future to allow GDFs utilizing ASTs in nonattainment areas the option of seeking M inor NSR permit coverage under the CA

- GDF General Permit.



### Section 3.2.1 .4 Factor 3

– Anticipated Economic Growth

The reviewing authority is to consider anticipated economic growth as part of the control technology review

. We find that it is unlikely that emission increases from GDFs, as permitted under the CA

- GDF General Permit, will pose unique or unprecedented impacts on air quality in any particular area within the geographic scope of the General Permit regardless of the anticipated economic growth for any such area. We continue to find that the

29 An owner or operator may follow a revised version of CP

- 201, but only after obtaining EPA

- approval that it is at least as stringent as the Apr il 23, 2015 version.

30 When the EPA updates general permits for a particular source category, we intend to distinguish the permits from each other by referring to the particular “version” of the general permit. We intend to identify the particular version that an owner/operator must comply with in the Approval of the Request for Coverage.

31 California has separate sets of requirements for ASTs and USTs.

32 https://www.arb.ca.gov/vapor/ astcompdeadlines052316.pdfDraft Technical Support Document
CA

- GDF General Permit Page 18 of 25 selected control technologies are protective of air quality, consistent with the controls used in the surrounding areas, and, as discussed below, economically feasible, and theref ore appropriate for purposes of the CA

- GDF General Permit.



### Section 3.2.1.5 Factor 4

– Cost

- Effective Alternatives

As noted above, t he CA

- GDF G eneral P ermit contains emission reduction requirements that are generally consistent with what is required for GDFs across California in areas within the s tate’s jurisdiction . As such, the chosen technologies are considered widely available and economically feasible and further consideration of additional, potentially cost

- effective alternatives is not necessary at this time. We intend to periodically review technology costs in the future to determine when other potentially cost

- effective technologies become widely available.


### Section 3.2.1. 6

Summary of Control Technolo gy Review

In conducting our control technology review, we have determined that it is appropriate, based on the four factors above and for the reasons discussed above , to require GDFs covered by the CA

- GDF General Permit to apply these control technologies :

1. For all GDFs, the EPA’s existing Stage I vapor recovery requirements in 40 CFR part 63, subpart CCCCCC.
2. For GDFs in ozone nonattainment areas, Stage I controls will need to meet a specific 95% control efficiency

. 3. For GDFs in ozone nonattainment areas, t he CARB’s Stage II requirements for EVR, with ISD systems.



### 3.2. 2 Operating Limitations

In addition to Stage I and II vapor recovery controls, in developing the CA

- GDF General Permit

, we considered whether it would be appropriate to require operating limits on gasoline throughput to limit the size of sources eligible for the CA

- GDF General Permit to the most common types of GDFs needing a M i n or NSR permit. The CA

GDF General Permit is intended as a streamlined permitti ng option for typical GDFs that do not require extensive review and analysis during the permitting process. In order to determine if an upper gasoline throughput limit was necessary

, we examined the throughputs of gasoline that would correspond to emission s of VOC at NSR major source levels.

GDFs tend to be located near dense population s and where vehicle traffic is greater

. For example, t he average
GDF in Los Angeles County , California dispenses about 1. 8 million gallons per year , while the average GDF in Mendocino County , California dispenses about 700,000 gallons per year. 33

The traffic congestion and wait times at the pumps at a gasoline station serve as limiting factors on the potential emissions of VOC due to vehicle tank refueling. A throughp ut of 1.8 million gallons of gasoline per year , for example, results in approximately 1.8 tons per year of VOC emissions in ozone attainment areas using Stage I controls, and 1.4 tons in ozone nonattainment areas when using the minimum federal requirement of Stage I

33 Based on station counts and throughput data in the California Energy Commission’s California Annual Retail Outlet Report Results (CEC

- A15)

– 2014, dated May 18, 2016. Available here: http://www.energy.ca.gov/almanac/transportation_data/gasoline/piira_retail_survey.htmlDraft Technical Support Document
CA

- GDF General Permit Page 19 of 25 controls

. 34 Th ese actual throughputs are well below the applicable NSR major source threshold s for VOC, which are as low as 10 tons per year for extreme ozone nonattainment areas.

Based on this information, most GDFs would not be major source s under the NSR program in even extreme ozone nonattainment areas, a lthough a GDF could be co

- located with other equipment that would need to be included in determining whether the source is a m ajor source. As discussed above, thi s CA

- GDF General Permit is only available for use by minor NSR sources and not available for use by major NSR sources. Considering the fact that most GDFs will have emissions well below the major NSR thresholds

, we belie ve that it is appropriate to set operating limits to protect air quality by limit ing the general permit to only the most routine permitting actions

. As such, we set the throughput limits, using the GDF PTE Calculator

, to ensure (1) that GDFs covered by the CA

GDF General Permit are not major sources under the NSR program, and (2) ensure s GDFs ha ve a limited air quality impact using limits that are within typical throughputs of GDFs.

The operating limits in the CA

- GDF General Permit reflect the emission rates listed in Table 4

. To ensure the entire GDF is not a major source, these operating limits are source

- wide limits, applying to the entire GDF and not just the new or modified equipment. For GDFs l ocated in serious, severe or extr eme ozone nonattainment areas, the CA

- GDF General Permit limits throughput of gasoline to less than 1 5 ,000,000 gallons per year based
on a 12

- month rolling total (See Appendix A for the calculation of this throughput limit). This ensures that even the larg est retailers should be able to qualify for the CA GDF General Permit in serious, severe, and extreme
ozone nonattainment areas. For GDFs located in attainment and marginal or moderate ozone nonattainment areas, the General Permit limits throughput of gaso line to less than 25,000,000 gallons per year based on a 12

- month rolling total

. (See Appendix A for the calculation of this throughput limit). These limits are clearly well within the expected maximum operating rates of most GDFs, and are the same operati onal limit s as those in the EPA’s national GDF Permit by Rule.



### Table 3: Throughput Operating Limitations for Gasoline Dispensing Facilities

Throughput Limit Serious, Severe or E xtreme Ozone Nonattainment Areas Ozone Attainment
, Areas and Moderate or Marginal Ozone
Nonattainment Areas
Gasoline usage 15,000,000 gallons/year 25,000,000 gallons/year



### Table 4: Corresponding Emission Rates for the Operation Limits in the General Permit

Pollutant of

Concern Serious, Severe or
E xtreme Ozone Nonattainment Areas Moderate or Marginal Ozone
Nonattainment Areas Ozone Attainment Areas

VOC 6.98 tpy 11.63 tpy 24.75 tpy

34 This analysis represents actual emissions and not potential emissions, which are expected to be higher. Th e potential emissions vary in attainment and nonattainment areas based on expected differences in the VOC content of gasoline in the two types of areas.Draft Technical Support Document
CA

- GDF General Permit Page 20 of 25 

## 4. Eligibility Criteria for CA

- GDF General Permit Coverage and Related Issues

4.1 Screening Procedures for Threatened or Endangered Species and Historic Properties

Prior to obtaining coverage under the CA

- CDF General P ermit , owners and operators must satisfactorily complete the screening processes for their source that are specified for threatened or endangered species and historic properties. EPA will provide confirmation that that the procedures were satisfactorily met. Appendices A and B to the Request for Coverage contain detailed directions t o a s s i s t source owner s and operators i n completing these processes

.



### 4.2 Exempt Equipment

The M inor NSR P rogram exempts some small equipment from the requirement to obtain a M inor NSR permit. 35 GDFs with exempt equipment are eligible for the CA

- GDF General Permit even though the CA

- GDF General Permit does not include requirements for exempt equipment. To create a General Permit that is protective of air quality, we have limited eligibility for co verage under the CA

- GDF General Permit to only those GDF sources with exempt emergency engines for all areas other than severe and extreme ozone nonattainment areas. In severe and extreme ozone nonattainment areas, GDFs with new or modified engines

are not eligible for coverage under the California GDF General Permit

.

T h e exemption from the requirement to obtain a permit for such equipment does not allow a source owner or operator to exclude the emissions from the exempt equipment when calculating a sourc e’s overall potential to emit. As such, applicants seeking coverage under the CA

- GDF General Permit must include emissions from all equipment that will be constructed or modified in determining whether the ir source is a minor source. We expect some GDFs to include emergency generators, a type of equipment that is potentially exempt from permitting under the Minor NSR program

.

Specifically

, the NSR program exempts emergency generators designed solely for the purpose of providing electrical power during pow er outages when the total maximum manufacture’s site

- rated horsepower of all units is below 500 in nonattainment areas and 1,000 in attainment area s. We expect most GDFs to either not have emergency engines or to have exempt emergency engines. Therefore, g enerally

, to be eligible for the
CA

- GDF General P ermit, the GDF source must be seeking to construct or modify emergency engines that meet the regulatory exemption thresholds for such engines as specified in the Minor NSR P rogram , or, in the case of severe or extreme ozone nonattainment areas
, the proposed project must not include emergency engines

. See 40 CFR 49.153(c).



### 4.3 Maximum Gasoline Throughput

The gasoline dispensing throughput limits discussed in Section 3.2.2 wi ll be used to determine whether a source is eligible for the CA

- GDF General Permit. Only sources that will dispense less than the throughput limits will potentially be eligible for the general permit. See Tabl e 4. These throughput limits are reflected in the CA

- GDF General Permit and each covered GDF must be able to meet the limits on an on

- going basis.

35 This exemption does not apply to new major sources or major modifications at existing major sources.Draft Technical Support Document
CA

- GDF General Permit Page 21 of 25 4.3.1 Triggering the Minor NSR Program

Owners and operators of proposed new or modified GDFs that are potentially subject to th e requirements of the Minor NSR program in the areas of Indian country within California are encouraged to consult with their reviewing authority to determine whether their proposed project would actually trigger the requirements of the
Minor NSR P rogram. Only those new or modified GDFs with potential emissions above the minor NSR threshold must obtain preconstruction permits. As ORVR continues to become prevalent in the vehicle fleet, potential emissions from GDFs will continue to decrease. We expect that due to ORVR in the vehicle fleet, by 2027, potential emissions of GDFs without Stage II EVR systems will be equal to emissions from GDFs with Stage II EVR systems. We expect to re

- evaluate the requirements for GDFs periodically, and to revise them as neede d.



### 4.4 Aboveground Storage Tanks

As discussed above in Section 3.2.1.3
, proposed new or modified GDFs that include aboveground storage tanks (ASTs) and that are located in ozone nonattainment areas are not eligible for coverage under the CA

- GDF General Permit. We expect the overwhelming majority of GDFs to use USTs rather than ASTs

. However, new or modified GDFs that include ASTs and that are located in attainment areas are eligible for the CA

- GDF General
Permit.



### 4. 5 Major Source of H APs

The CA

- GDF General Permit is limited to GDFs that are not a major source of hazardous air pollutants (HAPs). This is to ensure that a source covered by the CA

- GDF General Permit would not potentially be subject to additional requirements not included in the CA

- GDF General Permit

, as well as to ensure that GDFs seeking coverage under the CA

- GDF General Permit can avoid the additional permitting requirements of the title V operating permit program.

A source is a major source of HAP if its potential to emit is equal to or greater than 10 tpy for a single HAP and/ or 25 tpy for any combinations of HAPs. As part of the EPA’s national GDF Permit by Rule

, 36 the EPA calculated the potential HAP emissions from GDFs and determined that a GDF would not be a major source of HAP until VOC emissions are approximately 200 tpy. Because we estimate that GDFs covered by the CA

- GDF General Permit will have VOC emissions of 30 tpy or less , we can reasonably conclude that GDFs covered by the
CA

- GDF G eneral P ermit will not be major sources of HAPs.

Should a source include other HAP emitting equipment not covered by the CA

- GDF General Permit, then those emissions would also ha ve to be included in determining whether a GDF would be a major source of HAPs. Such sources would not be eligible for the CA

- GDF General Permit if source

- wide potential emissions of HAPs exceed the major source thresholds.



### 4. 6 Air Quality Impact Analysi s

The Minor NSR regulations provide that i f the reviewing authority has reason to be concerned that the construction of a proposed minor source or modification would cause or contribute to a NAAQS or PSD

36 See Section 5.2.1 on page 12 of the Background Document: Air Quality Permit by Rule for New or Modified True Minor Source Gasoline Dispensing Facilities in Indian Country.Draft Technical Support Document
CA

- GDF General Permit Page 22 of 25 increment violation, it may require the owner and operator of the proposed source or modification to conduct and submit an air quality impact analysis ( AQIA ) 40 CFR 49.154(d). We have determined that the control technology and other requirements of this pe rmit generally should be protective of air quality, and we did not conduct an AQIA as part of the development of the CA

- GDF General Permit. Instead, in determining whether to grant coverage under the CA

- GDF General Permit for individual sources , we will co nsider, according to the criteria in 40 CFR 49.154(d), whether an AQIA is needed for that particular source prior to granting an Approval of the Request for Coverage. However, g iven the limited emissions expected from GDFs , particularly with CA

GDF General Permit’s proposed controls , we do not expect that we would determine that there is such a concern, or that an AQIA would be needed , in most cases

.



### 4. 7 Good Engineering Stack Height

The emission limitations required in the CA

- GDF General Permit must not be affected in a manner by so much of a stack’s height as exceeds good engineering practice (GEP) or by any other dispersion technique. We do not expect that any stack at a GDF would exceed GEP. In addition, none of the emission limitations were based on stack h eight or dispersion modeling. In the event the reviewing authority requires a n AQIA, and a stack height exceeds GEP, then the reviewing authority would have to follow the procedures for notifying the public and providing for a public hearing.Draft Technical Support Document
CA

- GDF General Permit Page 23 of 25 

## Appendix A: Emissions Calculation for Operating Limitation for GDFs in California

1. Calculation for Serious, Severe, and Extreme Ozone Nonattainment Areas

– 15,000,000 gallons/year

Key for Calculations:

Abbreviation Description VOC E mission F actor (lb s /1,000 gallons)
STF Storage Tank Filling Losses 0.30
STB Storage Tank Breathing Losses 0.25
DIS

- NA Dispensing Losses

– Nonattainment Area 0.38

TP Gasoline Throughput (gallons/year) 15,000,000
CF Conversion Factor (1 ton/2,000 lbs) 1 / 2,000
EF Emission Factor

- Note: Calculations are done for the year 20 16 . The EF for dispensing losses is dependent upon year and location. Assume worst case scenario storage tank breathing losses of 0.25 lb/1,000 gallons.

A. GDF Operations: VOC Emissions STF = TP STF x EF STF x CF

= 15,000,000 (gallons/year) x 0.30/1,000 (lb s /gallon) x 1/2,000 (ton/lb)

= 2.25 tpy VOC

VOC Emissions STB = TP STB x EF STB x CF

= 15,000,000 (gallons/year) x 0.25/1,000 (lb s /gallon) x 1/2,000 (ton/lb)

= 1

. 875 tpy VOC

VOC Emissions DIS

- NA = TP DIS

- A x EF DIS

- NA x CF

= 15,000,000 (gallons/year) x 0.38 /1,000 (lb s /gallon) x 1/2,000 (ton/lb)

= 2.850 tpy VOC

Total VOC Emissions from GDF Operations = 6.98 tpy

B. Emergency Engine (Serious Areas Only, maximum of 500 horsepower (hp), combined):
Worst

- case emission factor for VOC assumes a gasoline emergency engine.

VOC Emissions = capacity (hp) x conversion factor (kW/hp) emission factor x conversion factor (lbs/g) x 500 (hrs/year) x 1 ton/2,000 lb

= 5 00 hp x 0.7457 kW/hp x 9.124 g VOC /kW

- hr x 1 lb/453.5928 g x 500 hrs/year x 1 ton/2,000 lbs

= 1.875 tpy

C. Total PTE: 6.98 tpy in severe and extreme areas, and 8.86 tpy in serious areasDraft Technical Support Document
CA

- GDF General Permit Page 24 of 25 

### 2. Calculation for Moderate and Marginal Ozone Nonattainment Areas

– 25,000,000 gallons/yr

Key for Calculations:

Abbreviation Description VOC E mission F actor (lb s /1,000 gallons)
STF Storage Tank Filling Losses 0.30
STB Storage Tank Breathing Losses 0.25

DIS

- NA Dispensing Losses

– Nonattainment Area 0.38

TP Gasoline Throughput (gallons/year) 25,000,000

CF Conversion Factor (1 ton/2,000 lbs) 1 / 2,000

EF Emission Factor

- Note: Calculations are done for the year 20 16 . The EF for dispensing losses is dependent upon year and location. Assume worst case scenario storage tank breathing losses of 0.25 lb/1,000 gallons.

A. VOC Emissions from GDF Operations:
VOC Emissions STF = TP STF x EF STF x CF

= 25,000,000 (gallons/ year) x 0.30/1,000 (lb s /gallon) x 1/2,000 (ton/lb)

= 3.75 tpy VOC

VOC Emissions STB = TP STB x EF STB x CF

= 25,000,000 (gallons/year) x 0.25/1,000 (lb s /gallon) x 1/2,000 (ton/lb)

= 3.125 tpy VOC

VOC Emissions DIS

- NA = TP DIS

- A x EF DIS

- NA x CF

= 25,000,000 (gallons/year) x 0.38 /1,000 (lb s /gallon) x 1/2,000 (ton/lb)

= 4.750 tpy VOC

Total VOC Emissions from GDF Operations = 11.63 tpy

B. Emergency Engine (500 horsepower (hp), combined):
Worst

- case emission factor for VOC assumes a gasoline emergency engine.

VOC Emissions = capacity (hp) x conversion factor (kW/hp) emission factor x conversion factor (lbs/g) x 500 (hrs/year) x 1 ton/2,000 lb

= 5 00 hp x 0.7457 kW/hp x 9.124 g VOC/kW

- hr x 1 lb/453.5928 g x 500 hrs/ year x 1 ton/2,000 lbs = 1.875 tpy

C. Total PTE: 13.51 tpyDraft Technical Support Document
CA

- GDF General Permit Page 25 of 25 

### 3. Calculation for Ozone Attainment Areas

– 25,000,000 gallons/yr

Key for Calculations:

Abbreviation Description VOC E mission F actor (lb s /1,000 gallons)
STF Storage Tank Filling Losses 0.30
STB Storage Tank Breathing Losses 0.25
DIS

- NA Dispensing Losses

– A ttainment Area 1. 4 3

TP Gasoline Throughput (gallons/year) 25,000,000
CF Conversion Factor (1 ton/2,000 lbs) 1 / 2,000
EF Emission Factor

- Note: Calculations are done for the year 201 6 . The EF for dispensing losses is dependent upon year and location. Assume worst case scenario storage tank breathing losses of 0.25 lb/1,000 gallons.

A. VOC Emissions from GDF Operations:
VOC Emissions STF = TP STF x EF STF x CF

= 25,000,000 (gallons/year) x 0.30/1,000 (lb/gallon) x 1/2,000 (ton/lb)

= 3.6 tpy VOC

VOC Emissions STB = TP STB x EF STB x CF

= 25,000,000 (gallons/year) x 0.25/1,000 (lb/gallon) x 1/2,000 (ton/lb)

= 3.0 tpy VOC

VOC Emissions DIS

- NA = TP DIS

- A x EF DIS

- NA x CF

= 25,000,000 (gallons/year) x 1. 4 3/1,000 (lb/gallon) x 1/2,000 (ton/lb)

= 17.16 tpy VOC

Total VOC Emissions from GDF Operations = 24.75 tpy

B. Emergency Engine ( 1,0 00 horsepower (hp), combined):
Worst

- case emission factor for VOC assumes a gasoline emergency engine.

VOC Emissions = capacity (hp) x conversion factor (kW/hp) emission factor x conversion factor (lbs/g) x 500 (hrs/year) x 1 ton/2,000 lb = 1,000 hp x 0.7457 kW/hp x 9.124 g VOC/kW

- hr x 1 lb/453.5928 g x 500 hr s/year x 1 ton/2,000 lbs

= 3.75 tpy

C. Total PTE: 28.5 tpy