Jeffery Yang 

From: KEVIN J. WILLIAMS 

Sent: 

To: 

Tuesday, December 23, 20084:37 PM 

Jeffery Yang; 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 

.oEM United States Environmental Protection Agency 

Region IX 

75 Hawthorne Street 

San Francisco, CA 94105-3901 

December 23, 2008 

Transmittal of EPA Rule Review Comments 

To: Kevin Williams, Sacramento Metropolitan Air Quality 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 1 of 1 

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 of the draft rules identified above and have identified no significant concerns. Please 

direct any questions in this regard to me at (415) 947-4115 or to Alfred Petersen at (415) 947-4118. 

1129/2009 
STATE OF CALIFORNIA 

ENVIRONMENTAL PROTECTION AGENCY 

AIR RESOURCES BOARD 

P. O. Box 2815 

Sacramento, California 95812 

December 29, 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 staff on January 13, 2009, were received by us on December 12, 2008, for our 

review: 

Rule 448 

Rule 449 

Gasoline Transfer into Stationary Storage Tanks 

Transfer of Gasoline into Vehicle Fuel Tanks 

We have reviewed the rules and have the comments on the following page. We believe 

that our comments are important to the effectiveness and enforceability of Rule 449. 

If you have any questions about our comments, please contact Mr. Angus Macpherson, 

Manager of the 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 of Gasoline into Vehicle Fuel Tanks 

1, Section 301.1: Table 4-1 in ARB Vapor Recovery Certification Procedure CP-201 

requires 95% by weight control efficiency and an emission factor < 0.38 Ib/1000 gal 

for summer fuel. Therefore, we recommend to change this section to read as 

follows: 

For summer fuel, a gasoline vapor control efficiency of at least 

95% by weight Sf and a mass emission factor not exceeding 0.38 

pounds of gasoline vapors per 1,000 gallons of gasoline 

dispensed. 

2. Section 301.2: Table 4-1 in ARB Vapor Recovery Certification Procedure CP-201 

requires 95% by weight control efficiency or an emission factor < 0.38 Ib/1000 gal 

for winter fuel. Therefore, we recommend to change this section to read as 

follows: 

For winter fuel, a gasoline vapor control efficiency of at least 95% 

by weight aOO or a mass emission factor not exceeding 0.38 

pounds of gasoline vapors per 1,000 gallons of gasoline 

dispensed. 
Jeffery Yang 

From: 

Sent: 

To: 

Carney. Karen [carneyk@SacCounty.NETJ 

Thursday, January 15, 2009 3:37 PM 

Jeffery Yang 

Subject: January 13, 2009 SMAQMD Workshop Questions 

Follow Up Flag: Follow up 

Flag Status: Completed 

Jeffery, 

Under Rule 448, 306.1, regarding maintenance inspections, how will the owner/operator be able to verify: 

• If the spill containment drain valve is vapor tight? 

• If the poppet valve is damaged? Should we actually compress it to see? 

• If the submerged fill pipe is missing or damaged? 

Thank You, 

Karen C. Carney 

Environmental Specialist 

County of Sacramento, Department of General 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 1 of 1 
Jeffery Yang 

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 States Environmental Protection Agency 

.." Region IX 

75 Hawthorne Street 

San Francisco, CA 94105-3901 

January 30, 2009 

Transmittal of EPA 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 1 of 1 

Re: SMAQMD Rule 448, Gasoline Transfer into Stationary Storage Containers; and Rule 449, Transfer of Gasoline into 

Vehicle Fuel Tanks, draft versions received on January 26, 2009 

We have preliminarily reviewed the draft rules identified above and have identified no concerns. Please direct any questions in 

this regard to me at (415) 947-4115 or to Alfred Petersen at (415) 947-4118. 

113012009