UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Sacramento Metropolitan Air Quality Management District, Rule 448, Gasoline 

Transfer into Stationary Storage Containers

Prepared by: Nicole Law

Reviewed by: Andrew Steckel

July 2012
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RULE IDENTIFICATION -

Agency: Sacramento Metropolitan Air Quality Management District

(SMAQMD)

SIP Approved Rule: Rule 448 – Gasoline Transfer into Stationary Storage 

Containers

Amended – February 2, 1995

Submitted – August 10, 1995

EPA Approved – January 23, 1996 (61 FR 1716)

Subject of this TSD: Rule 448 – Gasoline Transfer into Stationary Storage 

Containers

Amended – February 26, 2009

Submitted – April 5, 2011

RULE SUMMARY -

Rule 448, Gasoline Transfer into Stationary Storage Containers, is designed to limit 

emissions from the transfer of gasoline into stationary storage containers. It also 

describes related certification, recordkeeping, and test methods. The rule has been 

amended to maintain consistency with state regulations for vapor recovery systems and 

to incorporate requirements from rules adopted by the San Joaquin Valley Unified Air 

Pollution Control District (SJVUAPCD) and the South Coast Air Quality Management 

District (SCAQMD). The changes from the approved SIP rule include:

1. Amended Section 101 Purpose to include transfer from delivery vessels and 

pump-out from stationary storage containers, delivery vessels, and vehicle fuel 

tanks.

2. Added Section 102 Applicability to set applicability for transfer from any delivery 

vessel into any stationary storage container with a capacity of 250 gallons or 

more and mobile fuelers with a capacity of 120 gallons or more. The section also 

sets applicability limits for “pump-out” of gasoline from any stationary storage 

container with a capacity of 250 gallons or more, mobile fueler with capacity of 

120 gallons or more, and vehicle fuel tank with a capacity of 5 gallons or more.

3. Added the following terms in the definitions section: CARB, CARB certified,

delivery vessel, dry break, executive order, gasoline dispensing facility, 

installer/contractor, mobile fueler, purge, rebuild/rebuilt, spill container, switch

loading, tester, and vapor recovery equipment defects (VRED) list.

4. Removed the following terms from the definitions section: existing vapor recovery 

system and new vapor recovery system.

5. Definitions for the following terms were revised: gasoline and vapor tight.
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6. Renamed the Vapor Recovery Required section to Equipment and Operation 

Requirements and revised Section 301 to include switch loading and transfer or 

loading into a mobile fueler with a capacity of 120 gallons or more.

7. Created three separate sections of requirements dependent on the type of 

storage tanks being used. The new sections are 301.1 underground storage 

tanks, 301.2 aboveground storage tanks, and 301.3 mobile fuelers.

8. Section 301.1 underground storage tanks requires CARB certified vapor recovery 

systems which prevent 98% by volume of gasoline vapors displaced during 

gasoline transfer.

9. Section 301.2 aboveground storage tanks requires CARB certified vapor 

recovery systems which prevent 95% by volume of gasoline vapors displaced 

during gasoline transfer.

10.Section 301.3 mobile fuelers requires CARB certified vapor recovery systems 

that prevent 95%by volume of gasoline vapors displaced during gasoline 

transfer.

11.Revised section 302 Delivery Vessels to require delivery vessels other than 

mobile fuelers to be CARB certified and meet several additional requirements.

12.Removed the former section 303 Other Equipment Requirements which listed 

requirements for storage tanks, now covered in sections 301.1 and 301.2.

13.The former section 304 has been renumbered 303 Pressure Vacuum Valve 

Requirement. It has also been revised to remove an outdated provision and 

apply the vacuum pressure settings which are consistent with CARB’s 

Certification and Test Procedures.

14.Added a section 304 Prohibition of Sale. This section prohibits the sale and 

installation of non-CARB certified equipment.

15.Added section 305 Pump-out. This section prohibits the transfer of gasoline from 

specifically sized fuel tanks unless specific forms of vapor and drip control are 

used.

16.Added section 306 Maintenance Inspection. This section specifies what needs to 

be inspected, states equipment with major defects cannot be used until repaired, 

states that the removal of equipment should not result in vapors entering the

atmosphere, and states that defects discovered during maintenance inspections 

and repaired are not considered rule violations.

17.Added section 307 Prohibition of Use. This section prohibits the use of a system 

which contains defects listed in the VRED list. The section also requires these 

systems or components to be marked as “Out of Order.” 
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18.Added section 401 Certification under the Administrative Requirements. This 

section describes the requirements for meeting the certification requirement 

which includes who certifies equipment, maintaining valid certifications, and 

having the proof for certifications available on site.

19.Added section 402 Notification of Testing. This section requires operators to 

notify the APCO the date and time of performance or reverification testing at 

least 7 days prior to the testing. The section also allows retesting on the same 

day without re-notification if information regarding test failure and repairs 

performed are properly documented.

20.Added section 403 Test Requirements for Vapor Recovery System. This section 

describes the testing requirements including required tests, initial testing, and 

testing frequency. 

21.The Testing Procedure section 501 under Monitoring and Records has been 

revised to add in updated test methods and allow use of test methods specified 

in CARB Executive Orders. Also, a specific section 501.8 Multiple Test Methods 

has been added stating violations can be determined by any test method.

22.Added section 502 Recordkeeping section under Monitoring and Records to 

outline requirements for keeping records regarding testing, maintenance 

inspections, and retainment. 

EPA EVALUATION - The following criteria were used to evaluate the submitted rule. 

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 the CAA §110(a)(2)(A) requirement for enforceability. 

2. RACT - EPA’s Control Technique Guidelines (CTG) titled, “Design Criteria 

for Stage I Vapor Control Systems Gasoline Service Stations” (November 

1975), “Gasoline Vapor Recovery Guidelines”, EPA Region IX (April 24, 

2000), and other state and local rules for this category were used to help 

evaluate the RACT requirements of CAA §182(b)(2). 

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. We have evaluated this SIP revision to determine whether it 

would interfere with any applicable requirement concerning attainment and 

reasonable further progress (RFP) or any other applicable requirement of 

the Act (CAA 110(l)) or modify, in a nonattainment area, any SIP-approved 

control requirement in effect before November 15, 1990 (CAA 193).
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The submitted rule is enforceable and does not relax the SIP- approved version. 

Rule 448 fulfills the national requirements for gasoline vapor recovery and meets

RACT requirements. 

RULE DEFICIENCIES – We have found no rule deficiencies. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – The 

following revisions are not currently the basis for rule disapproval, but are 

recommended for the next time the rule is amended. 

 To stay consistent with CARB’s Certification Procedure for Vapor Recovery 

Systems at Gasoline Dispensing Facilities (CP 201) section 3.1, we 

recommend the district revise section 301.2 and 301.3 to increase the 

vapor recovery efficiency from 95% to 98%.

 Include the full title of EPA-approved state or local test methods. This 

helps identify what specific test methods are being referenced. Please see 

San Diego Air Pollution Control District Rule 61.4 section (f).

 We recommend requiring training of at least one employee to be familiar 

with Phase I equipment inspection and maintenance. See for example, 

Antelope Valley AQMD Regulation 4, Rule 461, Section C(4)(a)(iv).

EPA ACTION - The submitted Rule 448 strengthens the SIP. The rule largely 

fulfills the relevant CAA §110 and part D requirements. EPA staff recommends a 

full approval of Rule 448 pursuant to CAA §110(k)(3) and §301(a). 

REFERENCES -

1. SMAQMD Rule 448, Gasoline Transfer into Stationary Storage Containers, 

as submitted on April 5, 2011.

2. SMAQMD Rule 448, Gasoline Transfer into Stationary Storage Containers, 

as approved into the SIP on January 23, 1996. 

3. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

4. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

5. “Design Criteria for Stage I Vapor Control Systems Gasoline Service 

Stations” (EPA-450/R-75-102-1975/11) November 1975.

6. “Gasoline Vapor Recovery Guidelines”, EPA Region IX, April 24, 2000.