UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

San Joaquin Valley Unified Air Pollution Control District Rul e 4621

Gasoline Transfer Into Stationary Storage Containers , Delivery Vessels,

and Bulk Plants

Prepared by: James Shears Reviewed by: Andrew Steckel

September 2014 2



RULE IDENTIFICATION

Agency: San Joaquin Valley Unified Air Pollution Contr ol

District

SIP Approved Rule: Rule 4621

– Gasoline Transfer Into Stationary Storage

Containers , Delivery Vessels, and Bulk Plants

Amended

– December 20, 2007

Submitted

– March 7, 2008 EPA Appr oved

– October 30, 2009 (74 FR 56120)

Subject of this TSD: R ile 4621

– Gasoline Transfer Into Stationary Storage

Containers , Delivery Vessels, and Bulk Plants

Amended

– December 19, 2013

Submitted

– May 13, 2014

RULE SUMMARY

– SJVUAPCD Rule 4621 , Gasoline Transfer Into Stationary Storage Containers, Delivery Ves sels, and Bulk Plants, is designed to limit emissions from the transfer of gasoline into stationary source containers, generally by requiring Stage I vapor recovery equipment as described in “Design Criteria for Stage I Vapor Control Systems Gasoline Servi ce Stations ” (EPA

450/R

- 75

- 102, November 1975).

SJVUAPCD regulates the San Joaquin Valley , a “severe” non

- attainment area for

the 1

- hour and 8

- hour ozone NAAQS (see 40 CFR part 81). Section 182(b)(3) of the federal Clean Air Act (CAA) requires such areas to require Stage I vapor

recovery.

The significant changes in Ru le 4621 relative to the SIP approved rule include:

1. S ection 4.0 no longer exempt s the exempted equipment listed in Sections 4.1 through 4.4 from complying with the requirements of Sections 6 .1.1 and 6.1.4 for recordkeeping. Records and data necessary to demonstrate qualifications for the exemptions, as well as rule compliance records, shall be retained on the equipment premises for a minimum of 5 years and be

available to the A PC D

, C ARB, or EPA upon request. Besides non

exempted equipment, t his applies to the following exempted equipment:

Section 4.1

, the transfer of gasoline into stationary storage containers with a capacity of 550 gallons or less used primarily for fueling implements of

h usbandry; Section 4.2, the transfer of gasoline into any stationary storage container having a capacity of 2000 gallons or less which was installed prior to July 1, 1975 if such container is equipped with a permanent submerged fill pipe ; Section 4.3, the t ransfer of gasoline into any storage 3

 container in existence prior to July 1, 1975 which is equipped with a permanent submerged fill pipe; Section 4.4, mobile fuelers used exclusively for fueling emergency motor vehicles while on location at an emergency.

2. Section 5.6 is split into subsections 5.6.1.1 and 5.6.1.2. Section 5.6.1.1 applies to bulk plants not involved with aviation gasoline loading and, thus, continues to require a C ARB certified vapor recovery system for loading operations. Section 5.6.1 .2 applies to bulk plants involved with aviation gasoline loading. The current rule requires C ARB’s bulk plant certification for aviation gasoline bulk loading operations, but C ARB does not certify aviation gasoline bulk loading. This would be removed, a nd instead these operations are required to be equipped with a vapor recovery system that

meets a minimum volumetric control of 90%.

3. Section 5.7.3 is amended that any delivery vessel into which gasoline vapors have been transferred must be equipped with a C ARB certified
vapor recovery system.

4. Section 6.4.9, C ARB Test Procedure TP

- 202.1 has been added to determine the emission factor of vapor recovery systems of bulk plants. This test procedure is required to demonstrate the required control efficiency fo r bulk plant loading operations under new Section 5.6.1.2.

5. Other minor formatting and editing revisions to aid clarity.

EVALUATION CRITERIA

- 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 t he Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance wit h the CAA § 110(a)(2)(A) requirement for enforceability.

2. Stringency

- EPA ’ s Control Technique Guideline (CTG) titled,

-- Design Criteria for Stage I Vapor Control Systems Gasoline Service Stations (EPA

450/R

- 75

- 102, November 1975) , CARB Vapor Recovery Certification Procedures (CP

- 201, amended February 9, 2005), and other state and local rules for this category were used to help evaluate the RACT requirements of

CAA § 182(b)(2) and § 182(f).

3. SIP Relaxation

– Where previous versions of rules have bee n SIP approved, new submittals must comply with CAA § 110(l) and § 193 regarding SIP relaxation. 4



EPA EVALUATION

– The submitted SJVUAPCD Rule 4621 is more stringent than the approved SIP. Requiring recordkeeping on the exempted equipment listed in

Sections 4.1 through 4.4 enhances the enforceability of the rule in demonstrating qualifications for the exemptions, maintaining compliance records, and retaining all records for a minimum of 5 years on the premises and providing availability to the

APCD

, C ARB, an d EPA. For aviation gasoline bulk loading operations, the requirement to be equipped with a vapor recovery system that meets a minimum volumetric control of 90% would increase stringency. Requiring any gasoline

transfer delivery vessel to be equipped wit h an ARB certified vapor recovery system, and the addition of C ARB Test Procedure TP

- 202 .1 to demonstrate the control efficiency for bulk plant loading operations each increases the stringency

and/or effectiveness

.

1. The rule requirements and applica bility are clear, and recordkeeping, reporting and other provisions sufficient ly ensure that affected sources and regulators can evaluate and determine compliance with Rule 4621 consistently.

2. The submitted rule is as stringent as CARB Test Procedu re TP

- 202 .1 as well as other air d istrict rules , such as t he Sacramento Metropolitan and Bay Area Air Quality Management Districts, for this category and it is more stringent than EPA ’ s 19 75 CTG. As a result, we have determined that this

rule fulfills RAC T requirements.

3. W e propose to determine that our approval of the submittal would comply

with CAA § 110(l) and § 193 because (1) the proposed SIP revision would

not interfere with the on

- going process for ensuring that requirements for

RFP and attainme nt of the NAAQS are met, and (2) the requirements of the submitted rule are more stringent and enforceable than the existing SIP

approved control requirements that they would replace.

EPA ACTION

– The submitted Rule 4621 improves the SIP and complies wit h all relevant CAA requirements

. Therefore, EPA staff recommends a full approval of

Rule 4621 pursuant to CAA § 110(k)(3)

. 5



REFERENCES

–

1. SJVUAPCD Rule 4621 , Gasoline Transfer into Stationary Storage

Containers

, Delivery Vessels, and Bulk Plants

, as su bmitted to EPA on May 13 , 2014.

2. SJVUAPCD Rule 4621 , Gasoline Transfer into Stationary Storage Containers, Delivery Vessels, and Bulk Plants, as approved into the SIP on October 30, 2009.

3

. Sacramento Metropolitan Air Quality Management (SMAQMD), Regula tion 4, Rule 448.

4

. PCAPCD Rule 213, Gasoline Transfer into Storage Containers.

5

. Bay Area Air Quality Management District (BAAQMD), R egulation 8, Rule

7. 6. Design Criteria for Stage 1 Vapor Control Systems Gasoline Service Stations (EPA

- 450/R

- 75

- 102, November 1975). 7. CARB Vapor Recovery Certification Procedure (CP

- 201, amended February 9, 2005)

8 . The Little Bluebook, EPA Region 9, A ugust 21, 2001. 9. The Bluebook, EPA, May 25,1988.