### JefferyYang From: KEVIN J. WILLIAMS Sent: To: Tuesday, December23, 20084:37 PM JefferyYang; ALETA KENNARD Subject: FW: EPA No comment on Sacramento 445 

### &449

From: SteckeI.Andrew@epamail.epa.gov [mailto:Steckel.Andrew@epamail.epa.gov) Sent: Tuesday, December 23, 2008 2:28 PM To: KEVIN 

### J. WILLIAMS; mguzzett@arb.ca.gov Cc: alpete99@comcast.net Subject: EPA No comment on Sacramento 445 & 449



# .oEMUnited StatesEnvironmentalProtectionAgency Region IX 75 Hawthorne Street SanFrancisco,CA 94105-3901

December23, 2008 Transmittal ofEPA Rule Review Comments To: Kevin Williams, Sacramento Metropolitan AirQuality Management District kjwilliams@airquality.org Mike Guzzetta, California Air Resources Board mguzzett@arb.ca.gov From: Andrew Steckel, Rulemaking Office Chief steckel.andrew@epa.gov 

### Page 1of1

Re: SMAQMD Rule 448 - Gasoline Transfer into Stationary Storage Containers and SMAQMD Rule 449 - Transfer of Gasoline into Vehicle Fuel Tanks, DRAFT rules of December 12, 2008

We have completed a preliminary review ofthe draft rules identified above and have identified no significant concerns. Please directany questions in this regard to me at (415) 947-4115 orto Alfred Petersen at (415) 947-4118.



### 1129/2009

### STATE OF CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY 

## AIR RESOURCES BOARD P. O. Box 2815 Sacramento, California 95812 December29, 2008 Transmittal of ARB Staff Rule Review Comments To: 

### Mr. Kevin Williams, Program Coordinator Sacramento Metropolitan Air Quality Management District Telephone Number: (916) 874-4851 e-mail: kjwilliams@airquality.org From: 

### Alex Krichevsky, (916) 324-6222 e-mail: akrichev@arb.ca.gov The following draft rules, which are scheduled for a public workshop to be held by your District staffon January 13, 2009, were received by us on December 12, 2008, for our review:Rule 448 Rule 449 Gasoline Transfer into Stationary Storage Tanks TransferofGasoline into Vehicle Fuel Tanks
We have reviewed the rules and have the comments on the following page. We believe that ourcomments are importantto the effectiveness and enforceability of Rule 449. Ifyou have any questions about our comments, please contact Mr. Angus Macpherson, Managerofthe Testing and Certification Section, Evaporative Controls and Certification Branch, Monitoring and Laboratory Division at (916) 445-4686. Rule review comments are on the following page

### Rule 448 Date: December 29, 2008
Air Resources Board Staff Comments on Sacramento Metropolitan Air Quality Management District Draft Rules 448 and 449
Gasoline Transfer into Stationary Storage Tanks We have no comments on this rule, Rule 449 Transfer ofGasoline into Vehicle Fuel Tanks 1, Section 301.1: Table 4-1 in ARB Vapor Recovery Certification Procedure CP-201 requires 95% byweight control efficiency and an emission factor < 

### 0.38 Ib/1000 gal for summerfuel. Therefore, we recommend to change this section to read as follows: For summerfuel, a gasoline vapor control efficiency ofat least 95% by weight Sf

### and a mass emission factor not exceeding 0.38 pounds ofgasoline vapors per 1,000 gallons ofgasoline dispensed. 2. Section 301.2: Table 4-1 in ARB Vapor Recovery Certification Procedure CP-201 requires 95% byweight control efficiency oran emission factor < 

### 0.38 Ib/1000 gal forwinterfuel. Therefore, we recommend to change this section to read as follows: Forwinterfuel, a gasoline vapor control efficiency ofat least 95% byweight 

## aOO or a mass emission factor not exceeding 0.38 pounds ofgasoline vapors per 1,000 gallons ofgasoline dispensed.

### JefferyYang From: Sent: To: Carney. Karen [carneyk@SacCounty.NETJ Thursday, January 15, 2009 3:37 PM Jeffery Yang Subject: January 13, 2009 SMAQMDWorkshop Questions Follow Up Flag: Follow up Flag Status: Completed Jeffery, Under Rule 448, 306.1, regarding maintenance inspections, howwill the owner/operator be able to verify: • Ifthe spill containment drain valve is vapor tight? • Ifthe poppetvalve is damaged? Should we actually compress itto see? • Ifthe submerged fill pipe is missing ordamaged? 

## Thank You, Karen C. 

## Carney Environmental Specialist County ofSacramento, DepartmentofGeneral Services 10545 Armstrong Ave. #202C Mather,CA 95655 876-6187 (office)/591-0331 (cell)/8S4-9080 (fax)



### COUNTY OF SACRAMENTO EMAIL DISCLAIMER: This email and any attachments thereto may contain private, confidential, and privileged material for the sale use of the intended recipient. Any review, copying, or distribution of this email (or any attachments thereto) by other than the County of Sacramento or the intended recipient is strictly prohibited. If you are not the intended recipient, please contact the sender immediately and permanently delete the original and any copies of this email and any attachments thereto.



### 1129/2009 Page 1of 1

### JefferyYang From: KEVIN J. WILLIAMS Sent: Friday, January 30, 2009 2:11 PM To: ALETA KENNARD; Jeffery Yang Subject: FW: EPA no comment on Sacramento 448 & 449

From: Steckel.Andrew@epamail.epa.gov [mailto:Steckel.Andrew@epamail.epa.gov] Sent: Friday, January 30, 2009 1:01 PM To: KEVIN J. WILLIAMS; mguzzett@arb.ca.gov Cc: alpete99@comcast.net Subject: EPA no comment on Sacramento 448 & 449



## ft

# EPA. United StatesEnvironmentalProtection Agency .." Region IX 75 HawthorneStreet SanFrancisco,CA 94105-3901
January30, 2009 Transmittal ofEPA Rule Review Comments To: Kevin Williams, Sacramento Metropolitan Air Quality Management District kjwilliams@airquality.org Mike Guzzetta, California Air Resources Board mguzzeU@arb.ca.gov From: Andrew Steckel, Rulemaking Office Chief steckel.andrew@epa.gov 

### Page 1of 1

Re: SMAQMD Rule 448, Gasoline Transfer into Stationary Storage Containers; and Rule 449, TransferofGasoline into Vehicle Fuel Tanks, draftversions received on January 26, 2009
We have preliminarily reviewed the draft rules identified above and have identified no concerns. Please directany questions in this regard to me at (415) 947-4115 orto Alfred Petersen at (415) 947-4118.



### 113012009