AVAQMD Rule 461 - Gasoline Transfer And Dispensing C

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Final Staff Report, 2/12/09 

### APPENDIX "C"

PUBLIC COMMENTS AND RESPONSES

1. CARB Comment Letter, 08/08/08C-2 AVAQMD Rule 461 - Gasoline Transfer And Dispensing Final Staff Report, 2/12/09 This page intentionally left blank.AVAQMD Rule 461 - Gasoline Transfer And Dispensing C

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Final Staff Report, 2/12/09 

## STATE OF CALIFORNIA

ENVIRONMENTAL PROTECTION AGENCY 

# AIR RESOURCES BOARD

P. O. Box 2815

Sacramento, California 95812

August 8, 2008

Transmittal
of
ARB Staff Rule Review Comments

To: Mr. Charles L. Fryxell, Air Pollution Control Officer Antelope Valley Air Quality Management District Telephone Number: (661) 723-8070 e-mail: cfryxell@mdaqmd.ca.gov

From: Patrick Au, (916) 322-3303 e-mail: pau@arb.ca.gov

The following rule, which is scheduled for a public hearing to be held by your District Board on August 19, 2008, was received by us on July 10, 2008, for our review:

461 Gasoline Transfer and Dispensing (for amendment)

We have reviewed the rule and have the comment s on the following pages. We believe that

our comments can be used to enhance the cl arity and effectiveness of Rule 461.

On July 22, 2008, Ms. Cindy Castronovo of our Laboratory and Monitoring Division discussed our comments with Ms. Tracy Walters of your staff.

If you have any questions about our comments, please contact Ms. Castronovo at (916) 322-8957.

Rule review comments are on the following pagesC-4 AVAQMD Rule 461 - Gasoline Transfer And Dispensing Final Staff Report, 2/12/09 Date: August 8, 2008

Air Resources Board Staff Comments on Antelope Valley Air Quality Management District Proposed Rule 461



## General Comments

1. Air Resources Board (ARB) staff fully suppor ts and appreciates the District’s efforts in including a Phase II exemption for facilities that fuel primarily vehicles equipped with onboard refueling vapor recovery (ORVR) as discussed in the ARB’s February 20, 2008
letter to California Air Pollution Control Officers.

2. ARB staff requests that the District sta ff also consider a Phase II exemption for dispensing systems for E85 fuel. The justificati on for this request is also provided in the February 20, 2008 letter.



## Comments on Proposed Amended Rule 461

3. Sections (B)(3): We recommend deleti ng the phrase, “An Aspirator-assist systems may also incorporate Gasoline Vapor inciner ators and/or Bellows-less Nozzles,” as the terms “vapor incinerators” and “bello ws-less nozzles” are now obsolete.

4. Section (B)(7): “CARB Certified” Vapor Recovery Systems. Language is correct, but the EVR Phase I systems are certified to a minimum 98% efficiency.

5. Section (B)(22): The definition of ORVR in Section (B)(21) is sufficient, but the language in (B)(22) is confusing. An alte rnative may be to define “vehicle fleet.”

6. Sections (B)(31): We recommend delet ing the phrase, “Vacuum-assist systems may also incorporate Gasoline Vapor incinerators and/or Bellows-less Nozzles,” as the terms “vapor incinerators” and “bellows-l ess nozzles” are now obsolete.

7. Section (C)(1)(g): We recommend deleting the phrase “The Spill Box shall be equipped with an integral Vapor-tight drain valve to return spilled Gasoline to the underground stationary storage tank.” Some EVR Phase I systems do not require drain valves, other means of removing gasoline in the spill box is allowable, such as a hand

pump.AVAQMD Rule 461 - Gasoline Transfer And Dispensing C

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Final Staff Report, 2/12/09 8. Section (C)(3)(c)(iii): We recommend delet ing the phrase “Is operated and maintained with an integral Vapor-tight drain valve to retu rn spilled Gasoline to the storage tank, if the tank is equipped with a spill container” fo r the reasons stated in Comment 7.

9. Requirements (C)(3)(f): These P/V valve settings have been modified for EVR systems. See May 2006 CP-201 for revised criteria (http://www.arb.ca.gov/testme th/vol2/cp201_may2006.pdf).C-6 AVAQMD Rule 461 - Gasoline Transfer And Dispensing Final Staff Report, 2/12/09 This page intentionally left blank.AVAQMD Rule 461 - Gasoline Transfer And Dispensing C

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Final Staff Report, 2/12/09 District response to CARB comments:

1. No response necessary.

2. The District considers E85 to have equivalent ozone forming potential to gasoline and is accordingly not exempting E85 from Phase II vapor recovery requirements. The District may revisit this decision in response to State greenhouse gas initiatives.

3. The phrase “An aspirator-assist systems may also incorporate Gasoline Vapor incinerators and/or Bellows-less Nozzles” was removed from section (B)(3).

4. Section (B)(7) was modified to reflect code section which applies.

5. Section (B)(22) was removed.

6. The phrase “Vacuum-assist systems may also incorporate Gasoline Vapor incinerators and/or Bellows-less Nozzles” was removed from section (B)(31).

7. The phrase “The Spill Box shall be equipped with an integral Vapor-tight drain valve to return spilled Gasoline to the underground stationary storage tank” was removed from section (C)(1)(g).

8. The phrase “Is operated and maintained with an integral Vapor-tight drain valve to return spilled Gasoline to the storage tank, if the tank is equipped with a spill container” was removed from section (C)(3)(c)(iii).

9. Section (C)(3)(f) was modified to add the criteria for P/V valve settings for EVR systems.