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 Tr a nsfer of Gasoline

Prepared by: David Grounds

Reviewed by: Andrew Steckel

October 2 7 , 2010RULE 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) o r implement RACT as described in CAA section 182(b)(2).

The s ignificant c hanges in Rule 316 relative to the SIP approved rule include:

1. Section B, a dded definitions a nd made other editorial changes to improve clarity.
2. Section I(7)(a), a dded an exemption from Phase II vapor recovery when 100% of vehicles are equi pped with onboard refueling vapor recovery (ORVR).
3. Section I(7)(b), a dded 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
Comm on 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

- 45 0/2

- 77

- 035), “Control of Volatile Organic Emissions From Storage of Petroleum Liquids in Fixed

- Roof Tanks”( EPA

450/2

- 77

- 036),“Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks”( EPA

- 450/2

- 78

- 047), and “Sta tionary 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 rega rding 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 Cl ean 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 ba s is 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. F or example, Bay Area Air Quality Management District (BA AQMD ) , 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. F or example, BA AQMD, Regulation 8, Rule 33, Section 503.
3. Section E, we recommend biennial vapor leak testing for Bulk Plants. F or example, BA AQMD, 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. F or example, BA AQMD, 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. F or exampl e 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 B A AQMD Regulation 8, Rule 33, Sections 304, 305, 308, and 309.
9. Please consider further strengthening the emission limi tation 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. Section s 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 requireme nts. 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 Gasolin e, as adopted on April 17, 1997 South Coast Air Quality Management District, Rule 461, ‘ Gasoline Transfer and Dispensing ’ South Coast Air Quality Management District, Rul e 462, ‘Organic Liquid Loading’ Bay Area AQMD, Regulation 8, Rule 7, ‘Gasoline Dispensing Facilities’ Bay Ar ea 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 Vehicl e Fuel Tanks’ San Joaquin Valley APCD, Regulation IV, Rule 4622, ‘Gasoline Transfer Into Motor Vehicle Fuel Tanks’