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 Rule 4621

Gasoline Transfer Into Stationary Storage Containers, Delivery Vessels, 

and Bulk Plants 

Prepared by: James Shears

Reviewed by: Andrew Steckel

September 2014
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RULE IDENTIFICATION 

Agency: San Joaquin Valley Unified Air Pollution Control 

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 Approved – October 30, 2009 (74 FR 56120)

Subject of this TSD: Rile 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 Vessels, 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 Service Stations” (EPA450/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 Rule 4621 relative to the SIP approved rule include:

1. Section 4.0 no longer exempts 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 APCD, CARB, or EPA upon request. Besides nonexempted equipment, this 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 

husbandry; 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 transfer of gasoline into any storage 
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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 CARB 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 CARB’s bulk plant certification 

for aviation gasoline bulk loading operations, but CARB does not certify 

aviation gasoline bulk loading. This would be removed, and 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 CARB certified 

vapor recovery system.

4. Section 6.4.9, CARB 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 for 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 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. Stringency - EPA’s Control Technique Guideline (CTG) titled, -- Design 

Criteria for Stage I Vapor Control Systems Gasoline Service Stations (EPA450/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 been SIP 

approved, new submittals must comply with CAA §110(l) and §193 

regarding SIP relaxation.
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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, CARB, and 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 with an ARB certified vapor recovery 

system, and the addition of CARB 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 applicability are clear, and recordkeeping, 

reporting and other provisions sufficiently 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 Procedure TP-202.1 as 

well as other air district rules, such as the Sacramento Metropolitan and Bay 

Area Air Quality Management Districts, for this category and it is more 

stringent than EPA’s 1975 CTG. As a result, we have determined that this 

rule fulfills RACT requirements. 

3. We 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 attainment of the NAAQS are met, and (2) the requirements of the 

submitted rule are more stringent and enforceable than the existing SIPapproved control requirements that they would replace.

EPA ACTION – The submitted Rule 4621 improves the SIP and complies with all 

relevant CAA requirements. Therefore, EPA staff recommends a full approval of 

Rule 4621 pursuant to CAA §110(k)(3).
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REFERENCES –

1. SJVUAPCD Rule 4621, Gasoline Transfer into Stationary Storage 

Containers, Delivery Vessels, and Bulk Plants, as submitted 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), Regulation 

4, Rule 448.

4. PCAPCD Rule 213, Gasoline Transfer into Storage Containers.

5. Bay Area Air Quality Management District (BAAQMD), Regulation 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, August 21, 2001.

9. The Bluebook, EPA, May 25,1988.