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 44 8

, Gasoline

Transfer into Stationary Storage Containers

Prepared by: Nicole Law Reviewed by: Andrew Steckel

Ju ly 2012 2



RULE IDENTIFICATION

-

Agency: Sacramento Metropolitan Air Quality Management District ( SMAQMD )

SIP Approved Rule: Rule 44 8

– 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 vapo r recovery systems and

to incorporate requirements from rules adopted by the San Joaquin Valley U nified Air Pollution Control District (SJVUAPCD) and the South Coast Air Quality Management District (SCAQMD )

. The c hanges 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 fuel ers 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/rebu ilt, spill container

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

.

4. Removed the following terms from the def initions section: existing vapo r recovery system and new vapor recovery system.

5. Definitions for the following terms were revised: gasoline and vapor tight. 3



6. Renamed the Vapor Recovery Required section to Equipme nt 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 section s are 301.1 underground storage tanks, 301.2 above ground storage tanks, and 301.3 mobile fuelers.

8. Section 301.1 underground storage tanks req uires 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 va pors 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 v essels 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.” 4



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 t he 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

revis ed 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 Recordkeepin g 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 D ocument 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 requir ements 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 int erfere 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 Novembe r 15, 1990 (CAA 193). 5



The submitted rule is enforceable and does not relax the SIP

- approved version

. Rule 448 fulfills the national requirements for gasoline vapo r recovery and meet s 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 CAR B ’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 empl oyee to be famil iar

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 44 8 strengthens the SIP. The rule largely

fulfills the relevant CAA § 110 and part D requirements. EPA staff recommends a full approval of Rule 44 8 pursuant to CAA § 110(k)(3) and § 301(a).

REFERENCES

-

1. SMAQMD Rule 44 8

, Gasoline Transfer into Stationary Storage Containers

, as submitted on April 5, 2011

. 2. SMAQMD Rule 44 8

, 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 19 75

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