UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

For

EPA’s Notice of Proposed Rulemaking

For the

California State Implementation Plan

Placer County Air Pollution Control District, Rule 215

Transfer of Gasoline into Tank Trucks, Trailers, and Railroad Tank Cars at Loading 

Facilities

Prepared by: David Grounds

Reviewed by: Andrew Steckel

October 4, 2010
RULE IDENTIFICATION

Agency: Placer County Air Pollution Control District (PCAPCD)

SIP Approved Rule: Rule 215, Transfer of Gasoline Into Tank Trucks, Trailers, and 

Railroad Tank Cars at Loading Facilities 

Amended - November 3, 1994

Submitted - January 24, 1995

EPA Approved - May 6, 1996 (61 FR 20145).

Subject of this TSD: Rule 215 - Transfer of Gasoline Into Tank Trucks, Trailers, and 

Railroad Tank Cars at Loading Facilities

Amended - June 19, 1997

Submitted - July 18, 2008

There are no other submitted versions on which EPA has not acted.

RULE SUMMARY - PCAPCD Rule 215, Transfer of Gasoline Into Tank Trucks, Trailers, and 

Railroad Tank Cars at Loading Facilities, is a rule designed to limit emissions of volatile 

organic compounds (VOCs) during gasoline transfer from operations at bulk plants and 

bulk terminals. 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 National 

Ambient Air Quality Standards (NAAQS) (see 40 CFR part 81).

The significant changes in Rule 215 relative to the SIP approved rule include:

1. Section 212: The definition of “Vapor Tight” is changed to be consistent with EPA 

Method 21.

2. Section 302.1: Removed the requirement to maintain the delivery vessel vacuum

below 6 inches water gauge.

3. Revised several definitions and made other editorial changes to improve clarity.

EPA EVALUATION CRITERIA –The following criteria were used to evaluate the submitted 

Rule 215:

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 CAA 

§110(a)(2)(A) requirement for enforceability.
2. RACT –EPA’s Control Technique Guidelines (CTG) titled, “Control of Hydrocarbons 

From Tank Truck Gasoline Loading Terminals” (EPA-450/2-77-026, 10/77), 

“ Control of Volatile Organic Emissions From Bulk Gasoline Plants” (EPA-450/2-

77-035, 12/97), “Control of Volatile Organic Compound Leaks from Gasoline Tank 

Trucks and Vapor Collection Systems” (EPA-450/2-78-051, 12/78), 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 relaxations. 

EPA EVALUATION - The submitted PCAPCD Rule 215 is more stringent than the 

approved SIP, largely because of added administrative and technical details, and does 

not relax the existing SIP-approved rule. The current SIP submittal generally contains 

sufficient testing and recordkeeping requirements to satisfy enforcement requirements.

The stringency of requirements in submitted Rule 215 is also generally consistent with 

relevant guidance and analogous rules in other areas that help define RACT.

In a letter to PCAPCD, dated June 6, 1997, CARB recommended removal of the 6-inch 

water gauge vacuum requirement from their rule. We concur that this is beyond the 

requirements found in relevant guidance and analogous regulations and should not 

significantly impact emissions.

RULE DEFICIENCIES – We have identified no deficiencies with Rule 215 sufficient for 

EPA to propose less than full approval.

RECOMMENDATIONS – The following revisions are not currently the basis for rule 

disapproval, but are recommended for the next time the rule is amended.

1. In section 502.1, we recommend biennial vapor leak testing for Bulk Plants. 

See, for example, Bay Area AQMD, Regulation 8, Rule 39, Section 502.

2. In section 502.2, we recommend annual vapor leak testing for Bulk Terminals. 

See for example, Bay Area AQMD, Regulation 8, Rule 33, Section 503.

3. In Section 500, we recommend annual vapor tightness/certification testing for 

tank trucks. Gasoline Cargo Tanks are subject to annual (CP204) testing. See for 

example, San Diego APCD Regulation IV, Rule 61.2, Section d(1).

4. In section 501, we recommend adding records be kept on-site for inspections, 

repairs, maintenance, modifications, and test results. See, for example, Bay Area 

AQMD Regulation 8, Rule 33, Section 500.
5. In Section 502, we recommend adding the title for EPA Reference Method 21: 

“Determination of Volatile Organic Compound Leaks”

6. Please consider further strengthening the emission limitation for bulk terminals 

in Section 300. For example, BAAQMD Regulation 8, Rule 33, Section 301 

requires 0.04 lb VOC/1000 gallons dispensed gasoline effective January 10, 2011.

7. Please consider further strengthening Rule 215 requirements analogous to 

additional future requirements for bulk terminals found in Bay Area AQMD 

Regulation 8, Rule 33, Sections 304, 305, 308, and 309.

8. Please consider further strengthening the emission limitation for bulk plants in 

Section 300. For example, BAAQMD Regulation 8, Rule 39, Section 308.5 requires 

a pressure gauge on the vapor collection piping effective January 10, 2011.

EPA ACTION - The submitted changes to Rule 215 are largely administrative and clarify 

the SIP rule. The rule largely fulfills the relevant CAA §110 and Part D requirements. 

EPA staff recommends approval of Rule 215 pursuant to CAA §110(k)(3) and §301(a).

REFERENCES –

1. PCAPCD Rule 215, Transfer of Gasoline Into Tank Trucks, Trailers and Railroad 

Tank Cars At Loading Facilities, as submitted on July 18, 2008.

2. PCAPCD Rule 215, Transfer of Gasoline Into Tank Trucks, Trailers and Railroad 

Tank Cars At Loading Facilities, as approved on May 6, 1996 (61 FR 20145)

3. CARB Staff Comments letter to PCAPCD, dated June 6, 1997

4. CARB’s Certification Procedure CP 204: “Certification Procedure for Vapor 

Recovery Systems of Cargo Tanks”, amended on March 17, 1999.