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

Tra nsfer of Gasoline into Tank Trucks, Trailers

, and Railroad Tank Cars at Loading

Faci lities

Prepared by: David Grounds Reviewed by: Andrew Steckel

October 4 , 2010RULE IDENTIFICATION

Agency: Placer County Air Pollution Control District (PC APCD)

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

Railroad Tank Cars at Loading Facilities
Amend ed

- November 3, 1994
Submitted

- January 24, 1995

EPA A pproved

- May 6, 1996 (61 FR 20145).

Subject of this TSD: Rul e 215

- Transfer of Gasoline Into Tank Trucks, Trailers, and

Railroad Tank Cars at Loading Facilities

A mended

- June 19, 1997

S ubmitted

- July 18, 2008

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

RULE SUMMARY

- PCAPCD Rule 215 , Tran sfer of Gasoline Into Tank Trucks, Trailers, and Railroad Tank Cars at Loading Facilities, is a rule designed to limit emissions of volatile organic compounds (VOC s ) during gasoline transfer from operations at bulk plants and
bulk terminals. PCAPCD regulat es 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 ap proved 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 E VALUATION 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 R egion 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 Volatil e 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 Relaxatio n

– 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

. T he current SIP submittal generally contains
sufficient testing and recordkeeping requirements to satisfy enforcement requirements

. The stringency of r equirements in s ubmitted 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 ru le . 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 revision s are not currently the basis for rule
dis approval, 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.

Se e, 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 inspectio ns, repairs, maintenance, modifications, and test results. See, for example, Bay Area AQMD Regulation 8, Rule 33, Section 500

.5. In Section 502, we recommend add ing the title for EPA Reference Method 21 : “Determination of Volatile Organic Compound Leaks”

6. P lease 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 plant s 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 P art D requirements

. EPA staff recommends a pproval 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 Railr oad 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. C ARB Staff Comments letter to PCAPCD , dated June 6, 1997

4

. CA RB’s Certification Procedure CP 204: “Certification Procedure for Vapor Recovery Systems of Cargo Tanks”, amended on March 17, 1999.