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 213

Gasoline Transfer Into Stationary Storage Containers

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 213 – Gasoline Transfer Into Stationary Storage 

Containers

Amended – October 19, 1993

Submitted – November 30, 1994

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

Subject of this TSD: Rile 213 – Gasoline Transfer Into Stationary Storage 

Containers

Amended – February 21, 2013

Submitted – February 10, 2014

RULE SUMMARY – PCAPCD Rule 213, Gasoline Transfer Into Stationary 

Storage Containers, is designed to limit emissions from the transfer of gasoline 

into stationary source containers, generally by requiring Stage I vapor recovery 

equipment as described in “Design Criteria for Stage I Vapor Control Systems 

Gasoline Service Stations” (EPA-450/R-75-102, November 1975), and CARB 

Vapor Recovery Certification Procedure (CP-201, amended February 9, 2005).

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 federal Clean Air Act (CAA) requires such 

areas to require Stage I vapor recovery.

The significant changes in Rule 213 relative to the SIP approved rule include:

1. Section 10.2.2 exempts the white paint provision of Standing Loss 

Recovery Control from vertical, cylindrical, aboveground storage tanks over 

15,000 gallons in capacity that use a combustion type vapor processor that 

are existing on February 21, 2013. 

2. Section 20.2 adds the definition of a CARB certified vapor recovery system, 

equipment, or any component thereof, for which CARB has evaluated its 

performance and issued a valid Executive Order. Each component of a 

system that is a separate CARB certified item cannot be replaced with a 

non-certified item.

3. Section 30.1.8 adds the requirement that, after April 1, 2013, transfer is 

made to an above ground storage container equipped for Standing Loss 
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Vapor Recovery Control as certified by CARB pursuant to Certification 

Procedure CP-206.

4. Section 30.2 prohibits the sale and installation of any new or rebuilt vapor 

recovery system on aboveground storage containers unless the system 

and component are clearly marked as being CARB certified.

5. Section 40.2 adds the test methods for compliance of this rule and they 

shall be in accordance with CARB vapor recovery test procedures. 

6. Other minor formatting and editing revisions to aid clarity.

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. 

2. Stringency - EPA’s Control Technique Guideline (CTG) titled, Design 

Criteria for Stage I Vapor Control Systems Gasoline Service Stations (EPA450/R-75-102, November 1975), CARB Vapor Recovery Certification 

Procedure (CP-201, amended February 9, 2005), 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 213 is more stringent than the 

approved SIP. The definition of a CARB certified vapor recovery system, the 

prohibition of sale or installation of a system that is not CARB certified, and the 

adoption of CARB test methods for compliance testing all improve the rule 

stringency and effectiveness. Vertical tanks larger than 15,000 gallons in capacity 

that are equipped with a combustion type vapor processor are exempt from the 

white paint provision on Standing Loss Vapor Recovery. Such a processor 

typically provides tight control of vapors by combustion when tank pressures reach 

a specified value. Consequently, the combustion vapor control efficiency is 

determined to be at least equivalent to having reflective white paint on the fuel 

tanks. Additionally, this is a limited exemption as it only applies to vertical tanks 

larger than 15,000 gallons. Therefore, the exemption is approvable. 
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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 213 

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 1975 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.

1. To account for a scenario in which one delivery vessel is directly filled with 

gasoline from another delivery vessel without any intermediate storage 

tank, we recommend adding to section 301.6 the following requirement: 

“any delivery vessel into which gasoline vapors have been transferred can 

only be filled at a loading rack or another delivery vessel that is equipped 

with a CARB-certified vapor recovery system”. See, e.g., San Joaquin 

Valley Unified Air Pollution Control District Rule 4621, paragraph 5.7.3 and 

Sacramento Metropolitan Air Quality Management District Rule 448, 

paragraph 302.

EPA ACTION – The submitted Rule 213 improves the SIP and complies with all 

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

Rule 213 pursuant to CAA §110(k)(3).

REFERENCES1. PCAPCD Rule 213, Gasoline Transfer into Stationary Storage Containers, 

as submitted to EPA on February 10, 2014.

2. PCAPCD Rule 213, Gasoline Transfer into Stationary Storage Containers, 

as approved into the SIP on April 30, 1997

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

4, Rule 448.
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4. San Joaquin Valley Air Pollution Control District (SJVAPCD), Regulation 4, 

Rule 4621, “Gasoline Transfer into Stationary Storage Containers, Delivery 

Vessels, and Bulk Plants”.

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

7.

6. Design Criteria for Stage 1 Vapor Control Systems Gasoline Service 

Stations (EPA-450/R-75-102, November 1975).

7. CARB Vapor Recovery Certification Procedure (CP-201, amended 

February 9, 2005)

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

9. The Bluebook, EPA, May 25, 1988