UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

For

EPA’s Final Rulemaking

For the

California State Implementation Plan

Santa Barbara County Air Pollution Control District, Rule 316, Storage and Transfer of Gasoline

Prepared by: David Grounds

Reviewed by: Andrew Steckel

October 27, 2010
RULE IDENTIFICATION

Agency: Santa Barbara Air Pollution Control District (SBAPCD)

SIP Approved Rule: Rule 316, Storage and Transfer of Gasoline

Adopted – April 17, 1997

Submitted – March 10, 1998

EPA Approval – November 26, 1999 (64 FR 66393)

Subject of this TSD: Rule 316, Storage and Transfer of Gasoline

Amended – January 15, 2009

Submitted – March 17, 2009

RULE SUMMARY – SBAPCD Rule 316, Storage and Transfer of Gasoline, is designed to regulate volatile 

organic compound (VOC) emissions from the storage and transfer of gasoline at bulk plants, terminals, 

and vehicle dispensing facilities. Rule 316 includes requirements for installation, operation, maintenance 

and testing of vapor recovery systems and equipment used for the storage and transfer of gasoline.

The rule also describes related recordkeeping, and test method requirements. Santa Barbara County is 

an attainment area for the 8-hour ozone national ambient air quality standard (NAAQS), so Rule 316 is 

not required to impose Phase II vapor recovery requirements described in the Clean Air Act (CAA)

section 182(b)(3) or implement RACT as described in CAA section 182(b)(2).

The significant changes in Rule 316 relative to the SIP approved rule include:

1. Section B, added definitions and made other editorial changes to improve clarity.

2. Section I(7)(a), added an exemption from Phase II vapor recovery when 100% of vehicles are 

equipped with onboard refueling vapor recovery (ORVR).

3. Section I(7)(b), added an exemption from Phase II vapor recovery for the transfer of E85 fuel 

from any storage tank into a Flexible Fuel Vehicle.

EPA EVALUATION CRITERIA - The following criteria were used to evaluate the submitted Rule 316:

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

2. RACT – While RACT is not required, we have compared Rule 316 against analogous rules in other 

areas and relevant national guidance including EPA’s Control Technique Guidelines (CTG) titled, 

“Control of Volatile Organic Emissions From Bulk Gasoline Plants”(EPA-450/2-77-035), “Control 

of Volatile Organic Emissions From Storage of Petroleum Liquids in Fixed-Roof Tanks”( EPA450/2-77-036),“Control of Volatile Organic Emissions from Petroleum Liquid Storage in External 

Floating Roof Tanks”( EPA-450/2-78-047), and “Stationary Sources, Liquid Storage, Bulk 

Terminals & Plants, GDF Storage Tanks, Vehicle Refueling. ”(EPA-453/R-92-018 (ACT)).
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. 

EPA EVALUATION – The new exemption for ORVR does not relax the existing SIP-approved rule as 

discussed in EPA memo ‘Removal of Stage II Vapor Recovery from Refueling of Corporate Fleets’ 

(November 28, 2007), and envisioned by the Clean Air Act (CAA) Section 202(a)(6). Section 202(a)(6) 

allows EPA to waive the Phase II vapor recovery requirement after determining that ORVR systems for 

motor vehicle fleets are in widespread use. 

The current SIP submittal generally contains sufficient testing and recordkeeping requirements to satisfy 

enforcement requirements. The stringency of requirements in submitted Rule 316 is also generally 

consistent with relevant national guidance and analogous rules in other areas.

RULE DEFICIENCIES – We have identified no deficiencies with Rule 316 sufficient for EPA to propose less 

than full approval.

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

recommended for the next time the rule is amended.

Technical:

1. Section B.21, please consider strengthening vapor tight emission levels. For example, Bay Area 

Air Quality Management District (BAAQMD), Regulation 8, Rule 7, Section 206 defines a vapor 

leak as less than 100% of lower explosive limit (LEL) on a combustible gas detector measured at 

1 inch from source.

2. Section D, we recommend annual vapor leak testing for Bulk Terminals. For example, BAAQMD, 

Regulation 8, Rule 33, Section 503.

3. Section E, we recommend biennial vapor leak testing for Bulk Plants. For example, BAAQMD, 

Regulation 8, Rule 39, Section 502.

4. Section I.2, please limit exemption of gasoline dedicated to implements of husbandry to 550 

gallons per year. For example, BAAQMD, Regulation 8, Rule7, Section 111.3.

5. Section I.3, please consider requiring compressed air or nitrogen to fill tank for testing.

6. Section I.5, please limit throughput exemption to less than 4000 gallons per day, or 1.46 million 

gallons per year. For example The Blue Book, Section 2-18.

7. Please consider further strengthening the emission limitation for bulk terminals in Section D. For 

example, BAAQMD Regulation 8, Rule 33, Section 301 requires 0.04 lb VOC/1000 gallons 

dispensed gasoline effective January 10, 2011.

8. Please consider further strengthening Rule 316 requirements analogous to additional future 

requirements for bulk terminals found in BAAQMD Regulation 8, Rule 33, Sections 304, 305, 

308, and 309.

9. Please consider further strengthening the emission limitation for bulk plants in Section E. For 

example, BAAQMD Regulation 8, Rule 39, Section 308.5 requires a pressure gauge on the vapor 

collection piping effective January 10, 2011.
10. Rule 316 requires CARB-certified vapor recovery systems controlling at least 95% by weight of 

vapors. Analogous rules in other areas include additional limits on vapor emissions (e.g., 

Sacramento Rule 449, Section 301 limits vapor emissions to 0.38 pounds per 1000 gallons 

gasoline dispensed and San Joaquin Rule 4622, Sections 3.17 and 5.1.2 restrict VOC leaks). 

Please consider similar restrictions. 

Editorial:

1. Section F.2, per CARB comments of October 15, 2008, The test method required by ARB for the 

annual certification of cargo tanks is ARB Test Procedure TP-204.1

2. Section H.1, per CARB comments on March 11, 2009, the correct test method is TP-203.1.

3. Section H.1, ARB Test Method should read: CP-203

4. Section H.1 and H.2, should read: EPA Reference Methods 2A or 2B and 25A or 25B

5. Section H.2, ARB Test Method should read: CP-202

6. Section H.2, per CARB comments on March 11, 2009, the correct test method is TP-202.1

7. Section H.3, ARB Test Procedure is TP-204.1

8. Section H.4, ARB Test Procedure is TP-204.1

9. Section H.5, should refer to ARB Test Procedure TP-204.3 (Determination of Leak(s).

10. Sections I.4a, I.5 and J, many of these provisions seem obsolete. Please consider whether they 

can be removed.

EPA ACTION – The submitted changes to Rule 316 help clarify the SIP rule. The rule largely fulfills the 

relevant CAA §110 and Part D requirements. EPA staff recommends approval of Rule 316 pursuant to 

CAA §110(k)(3) and §301(a).

REFERENCES -

SBCAPCD Rule 316, Storage and Transfer of Gasoline, as amended on January 15, 2009

SBCAPCD Rule 316, Storage and Transfer of Gasoline, as adopted on April 17, 1997

South Coast Air Quality Management District, Rule 461, ‘Gasoline Transfer and Dispensing’

South Coast Air Quality Management District, Rule 462, ‘Organic Liquid Loading’

Bay Area AQMD, Regulation 8, Rule 7, ‘Gasoline Dispensing Facilities’

Bay Area AQMD, Regulation 8, Rule 33, ‘Gasoline Bulk Terminals and Gasoline Cargo Tanks’

Bay Area AQMD, Regulation 8, Rule 39, ‘Gasoline Bulk Plants and Gasoline Cargo Tanks’

Sacramento Metropolitan AQMD, Regulation 4, Rule 449, ‘Transfer of Gasoline Into Vehicle Fuel Tanks’

San Joaquin Valley APCD, Regulation IV, Rule 4622, ‘Gasoline Transfer Into Motor Vehicle Fuel Tanks’