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 2



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 Appr oved

– 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. S ection 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. Se ction 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 it em 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 3

 Vapor Recovery Control as certified by CARB pursuant to Certif ication

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. E nforceability

- T he 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 Sta ge I Vapor Control Systems Gasoline Service Stations (EPA

450/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 re quirements 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 c ertified 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

s tringen cy 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 provisio n on Standing Loss Vapor Recovery. Such a processor typically provides tig ht 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 limi ted exemption as it only applies to vertical tanks larger than 15,000 gallons. Therefore, the exemption is approv able. 4



1. The rule requirements and applicability are clear, and recordkeeping, reporting and other provisions sufficient ly 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 d istrict rules , such as t he Sacramento Metropolitan and Bay Area Air Quality Management Districts,

fo r this category and it is more stringent than EPA ’ s 19 75 CTG. As a result, we have determined that this rule fulfils RACT requirements.

3. W e 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

- appr oved control requirements that they would replace.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

- The following revision s are not currently the basis for rule disapproval, but are recommended for the next time the rule is amended.

1. T o 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 :

“ a ny delivery vessel into which gasoline vapor s 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

Sacr amento Metropolitan Air Quality Management District Rule 448, paragraph 302.

EPA ACTION

– Th e 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)

.

REFERENCES

1. 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. 5



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), R egulation 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 P rocedure (CP

- 201, amended February 9, 2005)

8

. The Little Bluebook, EPA Region 9, A ugust 21, 2001. 9. The Bluebook, EPA, May 25, 1988