1 Final Staff Report with Appendices for 

Revised Proposed Amendments to Rules 2020, 4621, 4622, and 4624

 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

FINAL STAFF REPORT 

Revised Proposed Amendments to Rule 2020 (Exemptions) 

Revised Proposed Amendments to Rule 4621 (Gasoline Transfer into Stationary 

Storage Containers, Delivery Vessels, and Bulk Plants) 

Revised Proposed Amendments to Rule 4622 (Gasoline Transfer into Motor 

Vehicle Fuel Tanks) 

Revised Proposed Amendments to Rule 4624 (Transfer of Organic Liquid) 

January 10, 2008 

 Prepared by: Sandra Lowe-Leseth, Air Quality Engineer 

Laura Weber, Air Quality Specialist 

Peter Biscay, Air Quality Specialist 

Manuel Salinas, Air Quality Engineer 

Leonard Scandura, Supervising Air Quality Engineer 

 Reviewed by: Jim Swaney, Permit Services Manager 

George Heinen, Supervising Air Quality Engineer 

Morgan Lambert, Supervising Air Quality Inspector 

Joven R. Nazareno, Senior Air Quality Engineer 

Matthew O’Donnell, Air Quality Engineer 

Ben Ellenberger, Air Quality Engineer 

I. SUMMARY 

A. Reasons for Rule Development and Implementation 

In the San Joaquin Valley Air Basin (SJVAB), monitored levels of ozone exceed 

National Ambient Air Quality Standards (NAAQS), which are set at levels that protect 

public health and welfare. Consequently, the U.S. Environmental Protection Agency 

(EPA) has classified the SJVAB’s air quality as serious for its nonattainment designation 

for the federal eight-hour ozone NAAQS. Under the now revoked federal one-hour 

ozone standard, the SJVAB was classified as extreme nonattainment. 

The federal Clean Air Act (CAA) requires air districts in nonattainment areas to prepare 

plans that are designed to achieve and maintain the NAAQS by the earliest practicable 

date, and no later than attainment deadlines given in the CAA. The San Joaquin Valley 

Unified Air Pollution Control District (District) adopted the Extreme Ozone Attainment 
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Demonstration Plan (EOADP) on October 8, 2004. The EOADP calls for a reduction in 

volatile organic compound (VOC) emissions by 2010 by amending Rules 4621 

(Gasoline Transfer into Stationary Storage Containers, Delivery Vessels, and Bulk 

Plants) and 4624 (Organic Liquid Loading) to further reduce VOC emissions by 

introducing more stringent limits. 

Control Measure U (New Rule for Aviation Fuel Transfer) in the District’s EOADP

originally was scheduled as a separate project to reduce VOC emissions created during 

aircraft refueling operations. Aircraft refueling operations include filling aviation fuel bulk 

storage tanks from primary fuel delivery trucks as well as transferring fuel from the bulk 

storage tanks into fuel delivery trucks, which are then used to fill an aircraft’s on-board 

fuel tanks. Control Measure U would affect bulk aviation fuel storage operations, 

including those at military, civilian, and private airports and operators of air fleet 

services. Tanks at these bulk storage facilities typically hold either aviation gasoline or 

a variety of kerosene-based jet fuels. Forty-three airports in the SJVAB sell one or both 

types of aviation fuel to airlines. After further research, District staff determined that 

Phase II vapor recovery systems are not certified by ARB for aircraft refueling 

operations, since aircraft fill pipes are not standardized as they are on motor vehicles. 

The District staff has always considered aviation gasoline included in the definition of 

gasoline. Affected sources are currently under permit and required to be equipped with 

Phase I vapor recovery systems. Because of these facts, aviation fuel is addressed as 

part of the current project to amend Rule 4621 (Gasoline Transfer into Stationary 

Storage Containers, Delivery Vessels, and Bulk Plants). 

Although the EPA has revoked the federal one-hour ozone NAAQS the VOC emission 

reduction commitment for amendments to Rules 4621 and 4624 must still be met. 

EPA’s final Phase 1 rule implementing the eight-hour ozone NAAQS (69 FR 23858 and 

70 FR 30592) identifies a number of federal CAA requirements that applied to an area 

by virtue of its one-hour ozone nonattainment classification and that continue to apply 

after revocation of the one-hour ozone NAAQS [40 CFR 51.900(f)]. Because the 

SJVAB was classified as extreme nonattainment, and because an attainment 

demonstration (as defined by 40 CFR 51.905) is one of the requirements, the EOADP

becomes one of the requirements that still apply to the SJVAB by virtue of its former 

classification under the now-revoked one-hour ozone NAAQS. The EOADP uses the 

VOC emissions reductions from the Rule 4621 and Rule 4624 amendments to project 

attainment. Thus, the District must proceed with the Rule 4621 and Rule 4624 emission 

reductions even though the one-hour ozone standard was revoked. In addition to the 

EOADP commitment, the District’s 2007 Ozone Plan included commitments for Control 

Measures S-PET-1, S-PET-2, and S-PET-3 that call for reduction in VOC emissions 

from Rules 621, 4622, and 4624. 

B. Rule Development Process 

As part of the rule development process, District staff conducted a public scoping 

meeting in September of 2006. At the scoping meeting, District staff presented the 
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objectives of the proposed rulemaking project, and solicited comments and suggestions, 

which were then used to develop the draft amendments to the rule and staff report. The 

first public workshop was held on December 19, 2006. A second public workshop was 

held on April 4, 2007. District staff invited affected source operators, consultants, 

vendors and manufacturers of control technologies, and trade associations to comment 

on the technological feasibility and compliance cost information that would be useful in 

developing changes to the rules. A third workshop as held on July 23 and July 24, 2007 

to discuss technical issues before proposed amendments would be brought to a public 

hearing before the District’s Governing Board. In addition to the public workshops, 

District staff also conducted a technical meeting in October 2007 to further discuss 

stakeholders’ concerns and provide additional opportunity for comments. 

Pursuant to state law, District staff are required to perform a socioeconomic impact 

analysis prior to the adoption, amendment, or repeal of a rule that has significant air 

quality benefits or that will strengthen emission limitations. As part of the Districts 

socioeconomic analysis process, District staff sought representatives from interested 

groups to participate as members of a Socioeconomic Focus Group on April 5, 2007. 

The Focus Group assisted District staff in determining the appropriate method for 

gathering information on regulatory compliance costs and business impacts resulting 

from compliance with the rule. The results of the socioeconomic analysis were 

compiled into a report that has been presented along with the refined version of the 

proposed rule to the public and interested parties during the workshop on July 23 and 

July 24, 2007. The date for the public hearing to consider adoption of the proposed rule 

amendments is December 20, 2007. 

II. CURRENT REGULATIONS 

The purpose of Rules 4621, 4622, and 4624 is to limit VOC emissions during storage 

and transfer of gasoline and other organic liquids. The purpose of Rule 2020 is to 

clarify which operations are exempt from permitting requirements. Current rule specifics 

are available online at: http://valleyair.org/rules/1ruleslist.htm. 

A. Rule 4621 

Rule 4621 requires aboveground and underground gasoline storage containers be 

equipped with a California Air Resource Board (ARB) certified Phase I vapor recovery 

system, a permanent submerged fill pipe, and pressure-vacuum relief valve with 

specified operational settings. Bulk plants and loading racks are required to be 

maintained free of leaks and inspected annually. 

B. Rule 4622 

Rule 4622 requires that tanks subject to Rule 4621 also be equipped with an ARBcertified Phase II Vapor Recovery system subject to periodic maintenance inspections 
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based on gasoline throughput, maintenance of an operations and maintenance manual 

(O&M manual), and prompt replacement of damaged Phase II components. 

C. Rule 4624 

Rule 4624 limits Class 1 facilities’ emissions to 0.08 pounds VOC per 1,000 gallons 

organic liquid loaded. Class 1 facilities are facilities that load 20,000 gallons per day or 

more of organic liquids. The rule also requires a 95% vapor capture for Class 2 facilities 

that load at least 4,000 gallons per day of organic liquid but less than 20,000 gallons per 

day. The rule specifies pressure settings for delivery tank loading, as well. 

D. Rule 2020 

Rule 2020 lists facilities and operations that are exempt from permitting. Among other 

things, the rule currently exempts vehicles that are used for the delivery of VOC and 

unloading racks, as well as loading racks that meet specific criteria. 

III. BACKGROUND 

A. Rule 4621 and Rule 4622 

1. Emission Control Techniques 

There are two main types of vapor recovery systems utilized to control vapor losses 

from the transfer and storage of gasoline. The Phase I systems control vapor losses 

during the transfer of gasoline from delivery vessels to storage tanks while Phase II 

systems control vapor losses from the transfer of gasoline into motor vehicle fuel tanks. 

VOC emissions at gasoline dispensing facilities can occur while the dispenser is used to 

pump gasoline into a vehicle fuel tank, while the dispenser is not in use, and during the 

filling of the aboveground or underground storage tank(s). Standing losses may also 

occur, which is vapor loss or VOC emissions, resulting from pressure change occurring 

within the storage tank due to atmospheric temperature fluctuations and the effect that 

has on gasoline temperatures. 

When the dispenser is being used, the gasoline that is introduced into the vehicle tank 

displaces the gasoline vapor that is already in the tank. Similarly, when the storage 

tank is being filled the gasoline introduced displaces the vapor in the storage tank. If 

the vapor recovery system does not adequately collect the displaced vapor, the vapor 

can be emitted into the atmosphere. 

Motor vehicles are now manufactured with Onboard Refueling Vapor Recovery (ORVR) 

systems, which are intended to capture vapor being displaced from the vehicle tanks 

during vehicle refueling. The system transfers vapor into an onboard carbon canister 
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until it can be released and burned as fuel. Some Phase II systems that were designed 

to detect gasoline vapor in the vehicle fuel tank proved incompatible with ORVR and 

incompatibility excess emissions resulted. ARB Certification Procedure for vapor 

recovery systems at gasoline dispensing facilities (CP-201) required that all Phase II 

systems be compatible with ORVR as of March 1, 2006. 

When the dispenser is not being used, gasoline vapor can be emitted through holes or 

tears in the vapor return path, through the nozzle or vapor-processing unit if these 

components do not work effectively, or through the pressure vacuum relief valve when 

tank pressure rises above three inches water column. An operator can minimize VOC 

emissions from gasoline dispensing facilities or bulk plants by using ARB certified 

Phase I and ARB certified Phase II vapor recovery systems and maintaining the 

systems and all of their components in good repair. An operator can demonstrate that 

these systems are in good repair by passing performance tests, which determine the 

system’s condition and identify any malfunctioning components of the system. 

2. Certifications 

In the currently enforced version of Rule 4622, the District requires that testers of 

gasoline vapor recovery systems attend a District orientation class. Similar 

requirements exist in many local air districts in California. Historically, the District has 

had problems with individuals or companies performing the required maintenance tests 

on the different vapor recovery systems available to gasoline dispensing facilities. 

Problems have included improper execution of tests, falsifying test results, and either 

failure to submit results to the district or submitted test results which are difficult to 

assess. Air districts have also had concerns about the installation of gasoline vapor 

recovery system and ensuring that the systems are properly installed and functioning 

correctly from inception. In both of these cases, no training has been required by 

districts and manufacturers, despite the complexity of gasoline vapor recovery systems 

and the potential for leaks or the system being installed improperly. 

With the creation of Enhanced Vapor Recovery (EVR), and the increased complexity of 

those systems, manufacturers have begun to require that installers of their systems be 

certified by the manufacturing company to perform the act of installation. Additionally, 

air districts throughout California have worked with the ARB to resolve the issues 

related to installer, tester, and repair personnel work practices. The solution that has 

been presented is the formation of a committee to work with the International Code 

Council (ICC) to develop certification exams for the different persons working with 

gasoline vapor recovery systems. The ICC, a membership association dedicated to 

building safety and fire prevention, develops the codes used to construct residential and 

commercial buildings, including homes and schools. Most U.S. cities, counties and 

states that adopt codes choose the International Codes developed by the International 

Code Council. ICC has worked with the ARB, the California Air Pollution Control Officer 

Association, and industry volunteers to formulate certifications for people performing 

installations and repairs. The certification exam for installation of underground gasoline 
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vapor recovery systems is currently available. The ICC exam is computer-based, no 

more than 60 questions and one and half hours long, open book, $75, and need to be 

renewed every two years on or before the expiration date to keep the certification 

current. 

In addition to the Districts’ involvement in the ICC certifications, the District has recently 

adopted Rule 1177 (Gasoline Dispensing Facility Tester Certification) for a gasoline 

dispensing facility tester certification and training program to ensure that the required 

performance tests are properly conducted. This program will provide testers with 

valuable training and operators with a qualified and accountable pool of testers. 

Ultimately, this program is expected to result in higher compliance rates with less direct 

oversight by District staff. This new certification program, designed by the District, was 

adopted as replacement to the previously required District orientation class. 

3. Vapor Recovery for Aboveground Storage Tanks 

The ARB has been working on a certification procedure to address vapor recovery for 

aboveground storage tanks. Until this time, facilities with aboveground storage tanks 

were required to install a Phase I and Phase II vapor recovery system that was certified 

under ARB’s certification procedure for specific facilities (CP-205). CP-205 required 

both Phase I and Phase II to achieve 90 percent efficiency but did not control standing 

losses from vapor growth that resulted from daily temperature fluctuations. In 2001, 

ARB amended CP-201 to require EVR, which requires that certified Phase I vapor 

recovery systems achieve 98 percent volumetric efficiency and Phase II vapor recovery 

systems achieve 95 percent efficiency. In doing this, it became a concern that 

operators would chose to install aboveground storage containers because of the cost to 

install an EVR system. 

During the summer of 2005, ARB staff conducted a field study on various sizes of 

aboveground storage containers in Fresno County, in cooperation with industry 

stakeholders. The purpose of the field study was to evaluate emission reductions from 

aboveground storage containers when retrofitted with various control technologies 

during periods of no fuel transfers. The study concluded that standing loss emissions 

are significant and that controls are currently available which would reduce these 

losses. 

After conducting cost effectiveness and emission reduction analyses, ARB staff 

determined the best course was to offer three different ways that manufacturers of 

vapor recovery systems could have their systems certified. Manufacturers of Phase I 

and Phase II vapor recovery systems for aboveground storage containers would be 

required to design systems with EVR so that these systems are held to the same 

stringency standards as underground storage container vapor recovery systems. The 

three different types of certifications that will be issued for aboveground storage tanks 

are: 1) standing loss controls; 2) standing loss controls and Phase I; 3) standing loss 

controls, Phase I, and Phase II. Standing loss controls for existing facilities will need to 
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achieve an efficiency of 60 percent while standing loss controls for new facilities will be 

required to function at 90 percent efficiency. 

Under the ARB adoption of CP-206 standing loss control, Phase I EVR, and Phase II 

EVR requirements would become effective January 1, 2009, and all existing tanks 

would have until January 1, 2013 to be in compliance. New tanks installed or existing 

tanks undergoing major modifications after January 1, 2009 would be required to meet 

the adopted performance standards for standing loss controls, Phase I EVR, and Phase 

II EVR. 

B. Rule 4624

Rule 4624 was last amended in December of 1992. Since the last amendments to this 

rule, many changes have taken place in other District rules. Currently, there is some 

stakeholder confusion over the applicability of Rule 4624 in light of how District Rules 

4455, 4409, 4623, and 2020 are enforced. Rule 4624 currently applies to facilities that 

are loading liquids with a true vapor pressure (TVP) of 1.5 psia or greater. However, 

this has become an issue when taken with the fact that Rule 2020 (Exemptions) 

exempts facilities that have crude oil with 0.8762 specific gravity or higher (30oAPI or 

lower). According to stakeholders there may be instances when both conditions can 

occur, that is, the liquid may have a TVP of 1.5 psia or greater and the specific gravity 

may be 30oAPI or lower. Facilities loading liquids that fall into this category have been 

required to comply with rule requirements but not to obtain permits. It is the District’s 

policy that when this happens, and the rule is open for changes, that language be 

added to modify the rules to require operators to obtain a permit-to-operate for these 

operations. By requiring facilities to be permitted, District staff can ensure that 

operators are complying with rule requirements. 

1. Unloading Racks 

Rule 4624 applies to loading of organic liquid, Rule 4623 applies to organic liquid 

storage, and Rules 4455 and 4409 apply to components at specific facility types. Within 

the District, no rule applies specifically to unloading racks and components used to 

unload organic liquids from the delivery vessels into the stationary storage containers. 

Industry stakeholders have shared insight, through public commenting, on the rules by 

which they have been monitoring these components. District staff would make 

unloading racks a part of Rule 4624 to allow for clarity to which rule equipment of this 

nature would fall. Although the vapor space of railcars and tank trucks is typically under 

vacuum while unloading liquids, there is potential for fugitive leaks, both liquid and 

vapor. Rule 4624 would require that unloading equipment and components be included 

in leak detection inspections and held to the same standards as equipment and 

components used to load to railcars and tank trucks. 
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2. Closed Systems 

The configuration of facilities to which Rule 4624 may apply can vary greatly. The 

emission limit to which facilities are required to adhere must be demonstrated by 

conducting an EPA approved test method that requires facilities testing to have a vent 

point. This becomes problematic for facilities that are designed with closed vapor 

control system with no ventilation or exhaust point. 

District compliance staff has noted that it is not possible for facilities with closed VOC 

control systems to perform the test method required by rule. Facilities with this 

configuration should not only achieve the emission limits that Rule 4624 calls for but 

should actually have 100 percent vapor control, so long as the system do not leak. It is 

for this reason that District staff would modify Rule 4624 requirements to allow for 

compliance with Rule 4624 to be shown through passing leak inspections for facilities 

with closed VOC control systems. 

IV. PROPOSED CHANGES TO RULES 

The California Health and Safety Code (CH&SC) Section 40914(a)(2) states that ozone 

attainment plans should include All Feasible Control Measures (AFCMs). The ARB 

interprets “every feasible control measure to mean that, at a minimum, air districts must 

consider regulations that have been successfully implemented elsewhere. Districts 

should also consider going beyond what has already been accomplished by evaluation 

of new technologies and innovative approaches that may offer potential emission 

reductions. Further, districts should consider not only technological factors, but also 

social, environmental, economic (e.g., cost effectiveness), and energy factors which 

prevail in a district, along with the resources realistically available to a district to adopt, 

implement, and enforce the measures.” 

In the context of rule development, District staff construes AFCM to mean that each 

rulemaking project seeks to obtain as much emission reduction from the rule’s source 

category as is expeditiously practicable, technologically feasible and economically 

reasonable, as determined by the District’s Governing Board. To this end, District staff 

compare the current emission limits or control technology against what limits or control 

technology has been promulgated in other districts, as well as reviewing the federal, 

state, and local Best Available Control Technology (BACT) clearinghouses for the most 

recent control technology available for the source category. 

A. Proposed Amendments to Rule 2020 (Exemptions) 

District staff is proposing several changes to Rule 2020 to support changes in Rules 

4621, 4622, and 4624. Additionally, a revision related to the definition of natural gas 

and liquefied petroleum gas is proposed. 
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1. Section 3.0 (Definitions) 

The definition of location would be added to this section to support the proposed 

changes to Section 6.7 (Transfer Equipment). This change would affect oil field 

operations most directly. Kern River oil field operators may have transfer operations 

scattered across several square miles. Currently, Permits-to-Operate (PTOs) for these 

widely-spaced operations treat loading racks at each site as if it were a separate facility. 

The proposed language would make this distinction explicit. 

2. Sulfur Content of Natural Gas and LPG 

Rule 2020 Section 6.1.1 exempts indirect heat transfer units with a heat input rating 5 

MMBtu/hr or less if they are fired exclusively on natural gas, liquefied petroleum gas 

(LPG), or any combination thereof. LPG is a general term that includes propane, 

butane, and propane-butane blends. Current Rule 2020 also requires that LPG have no 

more than 5% by weight hydrocarbons heavier than butane and sulfur content no more 

than 0.75 grains per 100 standard cubic feet (0.75 gr S/100 scf) of gas. 

Stakeholders requested amendments to Rule 2020 because the actual sulfur content of 

LPG is typically higher than the current rule’s sulfur content limit. District staff reviewed 

other California air districts’ rules to determine the sulfur content limit of LPG and 

natural gas for permit-exempt small gas-fired units. Unlike Rule 2020, other air districts 

do not have a sulfur-content limits for LPG or for natural gas. Gas Processors 

Association (GPA) liquefied petroleum gas specifications for total sulfur content of LPG 

ranged from 123 parts per million by weight (ppmw) to 185 ppmw. Specifically, the total 

sulfur content specifications are as follows: (a) 185 ppmw for commercial propane; (b) 

140 ppmw for commercial butane; and (c) 140 ppmw for commercial propane/butane 

mixtures. A survey of LPG distributors indicates odorant (typically mercaptan) 

containing between 1 and 3 gr S/100 scf is added to LPG. 

District staff is proposing to modify Rule 2020 Section 6.1.1 to codify how the District 

has historically applied the exemption to small indirect heat transfer units. District staff 

recommends the following requirements: 

• For natural gas, the total sulfur content limit would be changed from 0.75 grains 

per 100 scf to 1.0 grain per scf of gas. This change is proposed as natural gas 

suppliers in the District can deliver gas with a sulfur content up to 1.0 gr/100 scf. 

The current limit of five (5) percent by volume hydrocarbons heavier than butane 

would remain unchanged. 

• For LPG, the total sulfur content limit would be no more than 15 grains per 100 

scf of gas and no more than two (2) percent by volume hydrocarbons heavier 

than butane. 
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• The test methods for determination of sulfur content and percent by volume 

hydrocarbons heavier than butane would be specified in the rule.

3. Section 6.6 (Mobile Storage Equipment) 

In Section 6.6 (Mobile Storage Equipment), District staff would remove draft language 

added in the previous workshop and, therefore, mobile storage equipment would remain 

exempt from permit. Mobile refuelers however, would be required to register under the 

District’s Permit-Exempt Equipment Registration rule if they were subject to Rule 4622. 

The proposed registration requirement would be included in Rule 4622. 

4. Section 6.7 (Transfer Equipment) 

The District would modify the exemptions in this section so that facilities subject to the 

proposed amendments to Rule 4624 (Transfer of Organic Liquid) need to obtain a 

permit-to-operate. In addition, language would resolve an inherent conflict between the 

current versions of Rule 2020 and Rule 4624. Rule 2020 currently exempts individual 

racks that transfer 4,000 gallons per day or less. Current Rule 4624 applies to transfer 

at least 4,000 gallons per day for the total facility, which may have more than one 

transfer rack. District staff is proposing a revision of the exemption in Rule 2020. Under 

the proposed exemption, the limit would be 4,000 gallons per day per location, not per 

individual rack. Appropriate test methods for true vapor pressure and API gravity would 

also be added to this section. 

5. Other Changes 

Throughout Rule 2020, other District rules are mentioned, however the title of the rule is 

not included. District staff has added the rule title wherever a District rule is cited in 

Rule 2020 to make it consistent with other District rules. 

B. Proposed Amendments to Rule 4621 

Language would be adjusted for consistency throughout the rule with the change of the 

term “tank” to “container.”

1. Section 1.0 (Purpose) and Section 2.0 (Applicability) 

Section 1.0 (Purpose) will remain unchanged from current version of Rule 4621. In 

Section 2.0 (Applicability), the rule applicability would be revised slightly for clarification 

as to the container capacity to which this rule applies. As currently written, containers 

with capacity of exactly 19,800 gallons are subject to both Rule 4621 and Rule 4623 

(Storage of Organic Liquids). In order to avoid conflict between the rules, Rule 4621 

rule applicability would be modified to specify that the rule applies to containers less 

than 19,800 gallons. The change moves containers with capacity of exactly 19, 800 

gallons squarely into Rule 4623. 
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2. Section 3.0 (Definitions) 

Section 3.0 (Definitions) would have twenty-five definitions added. One of those 

additions is aviation gasoline. District staff has always considered aviation gasoline 

included in the definition of gasoline. However, a separate definition of aviation 

gasoline would be added to Rule 4621. This definition would echo the terminology used 

by ARB. The definition of gasoline would be modified to make the difference clear. 

The definition of “major modification” would be added to this section. The proposed 

definition is taken directly from ARB document D-200 “Definitions for Vapor Recovery 

Procedures.” District staff believes that this definition most accurately reflects the 

appropriate use of this term relative to Phase I vapor control systems and gasoline 

storage containers. 

The definition of leak would be revised. Within the leak definition, the allowable vapor 

leak concentration would be a reading of no greater than 10,000 parts per million by 

volume (ppmv), with the exception that in the instance of a repair, replacement, or 

sampling of process fluid, emissions may exceed this limit. The proposed change 

would align the definition of leak with ARB’s for vapor leaks of vapor recovery systems. 

Leaks associated with delivery vessels would be treated the same way. 

Other revisions to the definition section would include the removal of gasoline bulk plant 

and loading facility definitions. These terms would be replaced with “bulk plant” and 

“loading rack”, which would more accurately describe those units that are included in 

the rule requirements. The definition of “vapor tight” would be removed with the 

definition becoming part of the definition of leak. District staff would revise the definition 

of excess organic liquid drainage in order to decrease the quantity of liquid deemed 

excessive from 30 milliliters to 10 milliliters. This change is for consistency with other 

District rules definitions of “excess organic liquid drainage”. Additionally, District staff 

has defined mobile fueler to include it among vessels considered delivery vessels. This 

would require that operators of mobile fuelers comply with Rule 4621 delivery vessel 

requirements. Additional changes would be made to ease understanding of terms 

within Section 3.0 (Definitions), “tank” would be changed to “container” for consistency. 

Definitions would be renumbered as necessary. 

3. Section 4.0 (Exemptions) 

In Section 4.0 (Exemptions) language would be adjusted due to the added definitions in 

Section 3.0 (Definitions) and an exemption would be provided for mobile fuelers used 

exclusively to fuel emergency motor vehicles while on location at an emergency. 

The existing exemption for gasoline storage tanks of 550 gallons or less used to 

exclusively fill implements of husbandry would be changed to allow those tanks being 

used primarily to fill implements of husbandry to be exempt. This better aligns the 
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language with California Health and Code Section 41950(e) and is consistent with 

current District practices. The definition of implements of husbandry would be removed 

from the exemption and added to 3.0 (Definitions) where it would be more appropriately 

placed. 

Furthermore, existing exemptions for facilities with gasoline storage containers in 

existence or installed prior to July of 1975 would have language added making the 

exemption contingent on there being no major modifications as defined in Section 3.0 

(Definitions). The change aligns with the way District staff has interpreted this 

exemption. 

4. Section 5.0 (Requirements) 

Section 5.0 (Requirements) would undergo significant reorganization to allow improved 

understanding of the rule requirements for the range of facilities subject to this rule, with 

sections renumbered as necessary. Currently in Rule 4621, provisions related to 

aboveground storage containers, underground storage containers, and bulk plants are 

mixed together. Proposed changes would group the requirements for each type of 

equipment separately. In Section 5.0, all references to “tank”, wherever possible, would 

be changed to “container” for consistency. Language would also be adjusted to make 

requirements clearer due to added definitions in Section 3.0 (Definitions). 

A requirement proposed for all facilities in Section 5.2.4 would have all underground 

piping configurations and underground storage installations inspected by the APCO 

before backfilling. This provides an opportunity to spot construction problems that could 

lead to certification test failures and require retrenching the piping. Furthermore, 

operators would need to telephone the District for a confirmation number no less than 

three days before backfill. Additionally, throughout this section, District staff would 

include the requirement that all ARB-certified vapor recovery systems are maintained in 

accordance with their ARB Executive Orders and as required by the applicable 

manufacturer specifications. 

District staff is proposing that the provisions for underground storage containers be in 

one section, in this case Section 5.3 of the proposed rule. In addition to restating 

current requirements for underground storage containers, a new requirement is 

proposed that all ARB certified Phase I vapor recovery systems achieve a minimum of 

98 percent volumetric efficiency, which is the minimum efficiency that ARB currently 

certifies Phase I vapor recovery systems. District staff would adjust the settings for 

vacuum and pressure for the pressure-vacuum relief valve requirement as well to reflect 

the newest amendments to ARB’s Certification for Vapor Recovery Systems at Gasoline 

Dispensing Facilities (CP-201). This section would also address underground storage 

of aviation gasoline. The most recent revision to CP-201 requirements specifically 

exempts aviation gasoline, so District staff is proposing that the emissions be controlled 

by a Phase I system with a control efficiency of 95 percent. This control level was 
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chosen to reflect the currently-certified aviation gasoline Phase I systems. Thus, 

current control levels for aviation gasoline storage containers would remain in place. 

As with the underground storage containers, aboveground storage container provisions 

would be grouped together. The requirements for aboveground storage containers 

would be revised to reflect recent work that ARB has accomplished to develop a 

certification procedure (CP-206) for the regulation of standing losses, Phase I vapor 

recovery, and Phase II vapor recovery for aboveground storage containers. District 

staff would change the required settings for pressure vacuum relief valves to match the 

provisions of CP-206. Other changes that are brought about by CP-206, such as 

requirements to upgrade to EVR and standing loss controls, do not warrant any 

changes to rule language. Rule 4621 already requires that aboveground storage 

containers be equipped with an ARB Certified Phase I vapor recovery system. ARB will 

only certify Phase I vapor recovery systems to be equipped with EVR and standing loss 

controls and expects, at a minimum, two certified systems to be commercially available 

by 2009. As of January 1, 2009, new facilities would be required to utilize a system that 

ARB has certified as equipped with Phase I EVR and standing loss controls. Existing 

facilities would have four additional years, until January 1, 2013, to upgrade or retrofit 

their systems. For more information about ARB’s CP-206 please see Section IV.A.3 of 

this document or visit http://www.arb.ca.gov/regact/2007/ast07/ast07.htm. Section 5.4 

would also address the changes to the control of aviation gasoline by freezing the 

control levels at current levels. 

Requirements for periodic maintenance inspections of Phase I components that have 

been included in Rule 4622 (Gasoline Transfer into Motor Vehicle Fuel Tanks) would be 

moved to Rule 4621 where they more appropriately belong. Inspections would be 

based on the previous year’s highest average monthly throughput and would affect all 

facilities with Phase I vapor recovery systems. 

Bulk plant and loading rack requirements would be revised for clarity. The requirement 

for bulk plants to have a vapor recovery system would be revised to state that the vapor 

recovery system is to control emissions from the loading operation. Since gasoline 

transfers would have ARB certified vapor control equipment available while aviation 

gasoline would not, rule language would reflect this difference. District staff would also 

move the requirement that loading racks not create back pressure for delivery vessels, 

from the sections pertaining to delivery vessels. In addition to the renumbering of 

sections and language adjustments in bulk plant requirements, District staff would 

include an additional requirement that gasoline must be in a closed, non-leaking 

container to prevent the escape of gasoline vapors into the atmosphere. 

Proposed amendments would include a change in the leak testing frequency. The 

proposed version would change leak-testing frequency to semi-annual and leak tests 

would need to be conducted in accordance with EPA Method 21 using only a portable 

hydrocarbon detection instrument. Current requirements are for annual leak testing, 

and as an alternate to using a portable hydrocarbon detection instrument, the soap 
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bubble method of detecting leaks has been allowed. As is currently required by Rule 

4621, if a leak were found during an inspection, the testing frequency would be changed 

to quarterly. 

Several additional requirements would be added for repair and labeling of leaking 

components at bulk plants. The current rule requires bulk plant operators to repair 

leaks within seven business days; District staff would modify this requirement allowing 

bulk plant operators to remove components from VOC service when it is not possible to 

repair them within the allotted time. New language would require that all leaks be 

identified by a waterproof tag, displaying the date and time of inspection, date and time 

of leak detection, and for gas leaks, the leak concentration. District staff believes this 

requirement more appropriately belongs among other bulk plant and loading rack 

requirements. 

Delivery vessel requirements would be modified to require delivery vessels be equipped 

with an ARB certified vapor recovery systems for cargo tanks in addition to the valid 

State of California decals that are currently required. ARB requires this of cargo tanks 

that are used on highways, however, they do not require it for vessels used off-highway. 

District staff would add the requirement that all delivery vessels, on-highway and offhighway, be equipped with ARB certified systems and that those systems be maintained 

in accordance with the applicable ARB Executive Order. 

Until recently all hatches on cargo tanks carrying aviation fuel were required to be 

certified by ARB as leak-free. ARB will no longer certify these hatches. However, ARB 

will still perform the necessary tests if required by a district rule. This means that, 

although ARB doesn’t certify leak-free cargo tanks for aviation gasoline, ARB will 

continue to test hatches so that operators can comply with the rule. 

Stakeholders also noted that there are other agencies with jurisdiction over aircraft 

refuelers. Since the inspectors for these agencies may want to look into the cargo tank 

at any point in the loading or unloading process, District staff is proposing an alternative 

for the regulated entity by allowing an exception for other regulating bodies. 

5. Section 6.0 (Administrative Requirements) 

In Section 6.0 (Administrative Requirements), several provisions would be added, while 

others would be removed or simplified, and sections would be renumbered as needed. 

Effective on rule adoption date, all bulk plants would maintain daily records of gasoline 

throughput. All records required to demonstrate compliance would be retained for five 

years and made available on site during normal business hours to the APCO, ARB, or, 

and submitted to these agencies upon request. 

Section 6.2 outlines the performance test requirements along with the schedule of 

notification. New to the rule are certifications for installation and maintenance 
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contractors in Section 6.3. District staff is proposing that installation and maintenance 

contractors be certified for Vapor Recovery System Installation and Repair (Certification 

VI). International Code Council (ICC) offers this certification as part of its 

Aboveground/Underground Storage Tank series of certification tests. As an alternative 

certifying each worker individually, Rule 4621 would allow the workers to perform the 

installation or maintenance if they work under the direct and personal supervision of an 

individual who has the certification and the certified individual is present at the work site. 

Also in Section 6.3 are requirements for individuals who wish to conduct vapor recovery 

systems testing or repair. The District has recently adopted a rule to certify these 

testers, Rule 1177 (Gasoline Dispensing Facility Tester Certification). 

The applicable test methods would be revised to reflect the most current versions of test 

methods. The current rule allows the soap bubble method for leak detection. This 

practice would be discontinued after March 1, 2008. In its place, the use of a portable 

hydrocarbon detection instrument in accordance with EPA Method 21 would be required 

for leak inspections. Also in this section, appropriate ARB test procedures would be 

cited. Operators would be allowed to use alternative test methods if approved by the 

APCO, ARB, and EPA. 

6. Section 7.0 (Compliance Schedule) 

The compliance schedule in Section 7.0 (Compliance Schedule) would be removed and 

replaced with a schedule specifying compliance with all sections of the rule upon rule 

adoption unless otherwise specified in the rule. 

C. Proposed Amendments to Rule 4622 

1. Section 1.0 (Purpose) and Section 2.0 (Applicability) 

Sections 1.0 (Purpose) will remain unchanged from current version of Rule 4622. 

Section 2.0 (Applicability) would be expanded to include mobile fuelers and the term 

“facility” would be changed to “operation” for clarity of rule applicability. 

2. Section 3.0 (Definitions) 

Section 3.0 (Definitions) would add 17 definitions for clarification of terms used within 

the requirements of Rule 4622. The definitions for Balance System and certified Phase 

II vapor recovery system would be removed since no references to these terms exists in 

the proposed rule language. Additionally, District staff would modify several definitions 

for clarification. The term “gasoline storage and dispensing facility” would be changed 

to “gasoline storage and dispensing operation”, this is because many locations where 

gasoline transfer occurs are not considered gasoline storage and dispensing facilities. 

The definition of existing dispensing facility would be modified with a change from the 

word “facility” to “operation” to make the District staff’s intent clearer. The definition of 

leak would be reformulated for consistency with Rule 4621 and the definition of motor 
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vehicle would be changed to align it with the motor vehicle code definition of motor 

vehicle. “Major defect” would be modified to clarify the location of the major defect list 

and note that ARB maintains this list. Additional changes would be made to ease 

understanding of terms within Section 3.0 (Definitions) and definitions would be 

renumbered as necessary. 

Stakeholders have requested that the definition of “major modification” be revised to 

remove the words “end user.” District staff reviewed the ARB document D-200 

(Definitions for Vapor Recovery Procedures). The current definition mirrors ARB’s 

definition and, therefore, no change to the definition is proposed. 

3. Section 4.0 (Exemptions) 

In Section 4.0 (Exemptions), an exemption would be moved from Section 5.0 

(Requirements) that allows for facilities not subject to Rule 4621 to be exempt from the 

requirements of this rule. This change would better highlight that allowance. 

Two exemptions would be added to the rule. The first would allow operators of facilities 

with vehicle fleets having 100 percent of their vehicles equipped with ORVR to no 

longer maintain or not install Phase II vapor recovery. ORVR systems serve a similar 

function as Phase II vapor recovery, so the new exemption does not relax current rule 

requirements and does not increase emissions. Please see Section IV.A.1 for more 

information about ORVR. This added exemption is due to an EPA memorandum dated 

December 12, 2006. Although the memorandum speaks specifically to rental car fleets, 

other types of operations with car fleets would have similar operations and emission 

control would be similar. 

The second exemption would be added for mobile fuelers that serve aircraft. Section 

4.4 would specifically exempt refueling of aircraft from mobile fuel trucks. There is no 

certified ARB Phase II system for aircraft fueling, since there is no standard fueling 

configuration for individual aircraft as there is for passenger cars and trucks. 

4. Section 5.0 (Requirements) 

As in Rule 4621, Rule 4622 would be reorganized to improve understanding of the rule 

requirements. Under the proposed amendments, mobile fuelers with a tank capacity 

greater than 120 gallons would now be required to have certified ARB Phase II vapor 

control systems. New sections would also be added requiring that Phase II vapor 

system be maintained leak-free and in accordance with the most recent ARB 

certifications and manufacturer specifications. 

A new section would be added for installation requirements with provisions for prebackfill inspections, installer certification by the International Code Council, and all other 

certifications required under the applicable ARB Executive Order and operations 

manual. Clarification that Phase II vapor recovery systems may be replaced with new 
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certified Phase II vapor recovery systems would be added to the section prohibiting 

removal of a Phase II vapor recovery system. Additionally, in Section 5.2.6, District staff 

would add language allowing facilities with vehicle fleets to remove Phase II vapor 

recovery systems if their facility qualifies for an exemption as a vehicle fleet facility 

whose 100% of vehicles are equipped with ORVR. 

Requirements for the maintenance of an operations and maintenance manual (O&M) 

would be relocated to Section 6.0 (Administrative Requirements). Periodic maintenance 

requirements would be made clearer. The schedule for the inspection interval for 

periodic maintenance inspections would be changed. The inspection interval would be 

based on the previous year’s highest monthly throughput. This is proposed due to 

confusion that has resulted from the previous wording of this section. The method and 

schedule for determining the amount of liquid in the vapor path would be changed to 

require more frequent testing, with the current schedule being sunset upon rule 

adoption. District staff recommends removing sections outlining the periodic 

maintenance inspections for Phase I components. It is proposed that the requirements 

for periodic maintenance of the Phase I system be part of Rule 4621 (Gasoline Transfer 

Into Stationary Storage Containers, Delivery Vessels, and Bulk Plants), since Rule 4621 

specifically applies to facilities that are required to have and maintain a Phase I vapor 

recovery system. 

A new section would be included for maintenance and repair requirements that 

incorporate new provisions along with the existing maintenance and repair 

requirements. The proposed requirements include re-inspection of the affected 

equipment (e.g., breakaway valves, hoses, and nozzles) that are separated in a drive 

off. The proposed requirements for breakaways engaged in a drive-off are similar to 

requirements already in place in SCAQMD Rule 461. 

A section would also be added to require operators of mobile fuelers to register in 

accordance with District Rule 2250 (Permit-Exempt Equipment Registration) unless the 

mobile fueler is not subject to the provisions of Section 5.1. This is a change from the 

rule requirements presented in the June workshop. District staff believes that it is not 

necessary to require permits for mobile fuelers, yet the list of mobile fuelers generated 

by the registration would be important in determining compliance. 

Language throughout Section 5.0 (Requirements) would be adjusted to reflect new 

terms that have been added to Section 3.0 (Definitions), remove redundancies, and to 

aid in understanding rule provisions. Sections would be renumbered to accommodate 

changes and compliance dates added as needed. 

5. Section 6.0 (Administrative Requirements) 

In Section 6.0 (Administrative Requirements), the recordkeeping and reporting 

requirements exempt facilities would be separated from requirements for permitted 

facilities. Exempt vehicle fleet facilities would be required to keep records of the make, 
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model, model year, and vehicle identification number of all vehicles being refueled at 

the facility. Additionally, facilities that are subject to Section 5.0 would now be required 

to maintain monthly throughput records, test results, information on testers, and 

inspection results onsite for a minimum of five years and make them available to the 

EPA, ARB, or APCO upon request. The requirement to maintain five years of records is 

due to an EPA requirement and is similar to provisions in other District rules. 

Operations and Maintenance (O&M) Manual requirements would be moved from 

Section 5.0 to Section 6.3 (Recordkeeping Requirements for the O&M Manual). The 

manual would have one additional provision, requiring operators to maintain copies of 

all vapor recovery performance tests. O&M manual requirements that were redundant 

would be removed. The requirement for a protocol for performing periodic maintenance 

inspection be maintained would be removed to eliminate a redundancy, since the rule 

already specifies the inspection, maintenance and repair, and testing requirements. 

Within the testing requirement section (Section 6.4), staff would make several changes. 

The requirements that all periodic performance tests be performed at start up and 

thereafter, as required by ARB Executive Order and installations and maintenance 

manual, would be added, as well as the need to pass all tests that are conducted. Old 

compliance dates would be removed and language would be added clarifying which 

facilities are subject to the annual Dynamic Back-Pressure Test. Facilities with 

aboveground storage tanks that have integral dispensers (non-remote) need not 

conduct this test unless otherwise required under ARB Executive Order. The vapor 

return piping on an aboveground tank that has an integral dispenser is very short and is 

installed by the manufacturer at the assembly plant. As a result, there are no low points 

in the vapor path where liquid can collect and cause a blockage. Therefore, dynamic 

backpressure testing is unnecessary. District staff would also add in the requirement to 

conduct a vapor-to-liquid ratio test in lieu of the air-to-liquid volume ratio test when 

applicable. District staff would adjust the procedure for conducting the liquid removal 

test and that procedure would be placed in Section 5.0 (Requirements) as part of the 

requirement to conduct the test. 

The requirement for attendance of a District orientation class for those persons 

intending on conducting compliance tests would be sunset and a new requirement 

would be added that testers be in compliance with District Rule 1177 (Gasoline 

Dispensing Facility Tester Certification). In addition, the amount of time required for 

notifying the District of performance testing prior to the test date would be shortened 

from 15 days to seven days, this would allow operators more flexibility and still allow 

District staff enough time to schedule attendance at the tests. 

Only one change is proposed for the Section 6.5, the test methods section. District staff 

recommends that the liquid removal test be changed from ARB TP-201.6 to ARB TP201.6C the actual method necessary. 
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6. Section 7.0 (Compliance Schedule)

The compliance schedule would have additional sections added allowing time to 

comply, if necessary, for facilities commencing operation after rule adoption, facilities 

not previously subject to the rule requirements, and those already subject to the rule 

requirements. 

Additionally, a new section would be added for those owners of vehicle fleets that 

qualify for an exemption under Section 4.0 (Exemptions). Prior to operating under the 

exemption, vehicle fleet operators would need to modify their Permit to Operate 

conditions to allow such operations pursuant to District Rule 2201. 

D. Proposed Amendments to Rule 4624 

1. Rule Title, Section 1.0 (Purpose), and Section 2.0 (Applicability) 

In the current version of Rule 4624, the District only refers to loading operations and is 

silent on unloading operations. By adding these operations to rule applicability, the 

inclusion of unloading operations in the rule requirements becomes explicit. District 

staff would revise terminology to include unloading operations within the title, the 

purpose, and applicability sections. To do this, the term “loading” would be removed, 

and the term “transfer” would be used in its place. 

District staff would revise Section 1.0 (Purpose) by removing language referencing the 

limiting of vapor pressure and storage temperature. This language is not pertinent to 

the purpose of the rule. In Section 2.0 (Applicability), language would be removed 

regarding bulk plants subject to Rule 4621, since it is reiterated in Section 4.0 

(Exemptions). 

2. Section 3.0 (Definitions) 

Nineteen definitions would be added for rule clarity. Several definitions spell out 

acronyms, while other would be needed to support new requirements. The District 

would also revise several existing definitions in order to use consistent language, 

consistent definitions between rules, and for clarification of terms used throughout the 

rule. 

 Throughout this section, the term loading would be replaced with transfer or 

transferring to include both the loading and unloading operations at Class 1 and 

Class 2 facilities. 

 Within the leak definition, the allowable vapor leak concentration, above 

background, would be reduced to a reading of greater than 1,000 parts per 

million by volume (ppmv). Exceptions of this would be made for gasoline vapor 

leaks, which would remain at 10,000 ppmv, as this standard is set by ARB. 
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 District staff would also add to the leak definition language that in the instance of 

a repair, replacement, or sampling of process fluid that ppmv readings may 

exceed the 1,000-ppmv limit. 

 For consistency with other District rules the definition of Portable Hydrocarbon 

Detection Instrument would be revised to use the same definition as is used in 

Rule 4623. 

 Among those definitions that would be added is transfer rack; this term would be 

changed to include unloading racks as well as loading racks. 

3. Section 4.0 (Exemptions) 

Three of the current exemptions would be modified to accommodate the addition of 

unloading operations to the rule applicability. Also, operations subject to Rule 4622 

(Gasoline Transfer into Motor Vehicle Fuel Tanks) would be exempt from Rule 4624 

requirements. 

Current Rule 4624 specifically exempts a certain type of equipment/process 

modification from both BACT and offset requirements. In this rule development project, 

the automatic exemption from BACT and offset requirements would be removed from 

the rule. The net result of removing the exemption would be that all equipment/process 

modifications would be required to meet any BACT or offset requirements specified in 

Rule 2201 (New and Modified Stationary Source Review Rule) unless the modification 

meets the conditions for being exempt from BACT or offset requirements pursuant to 

Rule 2201. The removal of automatic exemption from BACT and offset requirements 

addresses an EPA concern about this issue. 

An exemption would be added to remove the components subject to the requirements 

of four District rules from the leak inspection requirements of Rule 4624. These rules 

are: 

• Rule 4409 (Components at Light Crude Oil Production Facilities, Natural Gas 

Production Facilities, and Natural Gas Processing Facilities); 

• Rule 4455 (Components at Petroleum Refineries, Gas Liquids Processing 

Facilities, and Chemical Plants) 

• Rule 4622 (Gasoline Transfer into Motor Vehicle Fuel Tanks) 

• Rule 4623 (Storage of Organic Liquids) 

An exemption would be added for vacuum truck operations. The District’s definition of 

transfer rack includes these vessels, although they have historically been exempt. The 

District would exempt these vessels from rule requirements with the proviso that the 

vacuum truck operators submit data as required in Section 6.0 (Administrative 

Requirements). By requiring operators to supply District staff with information about the 

number of vessels operated, capacity, throughput, transferred liquid, and VOC controls, 

the District can assess whether to include them in future rule requirements. 
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Section 4.0 (Exemptions) would be renumbered and new terms from Section 3.0 

(Definitions) would be added for rule clarity. 

4. Section 5.0 (Requirements) 

Throughout Section 5.0 (Requirements), transfer rack would replace loading 

rack/facility, and, where necessary, language would be adjusted to allow for improved 

understanding of rule requirements. Section and referenced items would be updated, 

and old compliance schedules would be removed. 

In Section 5.0, language specifying the requirements for facilities to be equipped with a 

VOC control and collection systems would be modified. The District would add in 

language that would allow operators to route VOC to a control and collection system or 

container subject to control requirements of District Rule 4623 (Storage of Organic 

Liquids). Additionally, for Class 2 facilities the District would add language identifying a 

vapor collection and control system must be utilized; in the current rule, only the term 

‘system’ is used to signify this. The District would also add language for VOC control 

systems that are closed systems, that is to say, they have no vent point. Many facilities 

within the District are configured this way and are unable to conduct the source test 

specified in the rule. Closed systems have no vent point and unless they leak, they 

should meet the emission limits specified for Class 1 and 2 facilities. As a result of this 

configuration, the rule would allow facilities with closed systems to show compliance 

with emission limits by complying with the leak provisions in Section 5.0 

(Requirements). 

In the current rule, there are no requirements to inspect for leaks. The District would 

add quarterly leak inspection requirements allowing 72 hours to repair the leak, which is 

the same repair period specified in SCAQMD Rule 462. The District would also allow 

facilities, if unable to repair leaking components in this time, to take components out of 

VOC service. Provisions would also be provided for returning repaired components to 

service and reducing leak inspections to annually, if five consecutive quarterly 

inspections are passed. 

5. Section 6.0 (Administrative Requirements) 

Section 6.1 would be expanded to require all facilities to maintain records as before 

except with the added recordkeeping requirements of keeping leak inspection and 

source test results. Because of EPA requirements, all records would be maintained for 

five years and would be made available to the APCO, ARB, and EPA upon request. 

Requirements for recordkeeping for organic liquid True Vapor Pressure (TVP) and the 

method of acquiring this data would be clarified. Operators would also have the option 

to use material data safety sheets to show compliance with the vapor pressure, rather 

than actually run the test for each material. With the inclusion of vacuum trucks to those 

vessels that Rule 4624 is applicable, through the definition of transfer rack, the District 

would add an administrative requirement that operators of vacuum trucks submit, within 
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18 months of rule adoption, information on their vacuum truck operations. The District 

would then use this information to determine if it is necessary to require further controls. 

The District would add requirements for source testing Class 1 and Class 2 organic 

liquid loading facilities in Section 6.2. The District is proposing that an initial source test 

be performed within 18 months of rule adoption and that source tests be performed 

every 60 months thereafter. An exception would be made for existing facilities that have 

performed a source test in the 60 months preceding rule adoption; these facilities need 

not perform the initial source test. The District would exempt operators of closed VOC 

emission control systems from source test requirements but require leak testing to show 

compliance with the rule limits. The source testing calls for a vent point, but closed 

systems have no vent point by which operators can source test to ensure that emission 

limits are being met.. By their nature, closed systems should be meeting emission limits 

so long as they are free from leaks. For VOC control systems regulated under Rule 

4623, it would be redundant to require source testing in Rule 4624. 

The proposed rule would revise required test methods to allow operators to use the 

most recent EPA-approved tests. Tests no longer EPA-approved would be removed. 

Test methods for determination of TVP of stored organic liquids and API gravity of crude 

oil or petroleum distillate would also be added. Two appendices would be added, one 

with a table for storage temperature versus vapor pressure, which is already present in 

the rule and a second appendix for determination of Reid Vapor Pressure (RVP) and 

equations to convert to TVP. Operators would be allowed to utilize alternative test 

methods if the APCO, ARB, and EPA approve the alternative in writing. 

6. Section 7.0 (Compliance Schedule) 

Old compliance schedules would be removed and sections would be added to allow 

facilities time to comply with new rule requirements. 

V. SUMMARY OF CHANGES TO OCTOBER 20, 2007 VERSION OF RULES 

A. Revised Proposed Rule 2020 

District staff is proposing a minor change in Section 6.7.1.2. Stakeholders noticed a 

conflict between the RVP-to-TVP reference temperature in Proposed Rule 4624. The 

exemption mentions the TVP at actual transfer temperature, but the test method 

description specifically says at the storage container’s maximum storage condition. To 

resolve this conflict, District staff proposes modification to all requirements in Rule 2020 

and Rule 4624 that mention the RVP-to-TVP reference temperature to be at the storage 

container’s maximum storage temperature. The change minimizes operator testing by 

having only one reference condition, rather than a condition for the storage container 

(defined in Rule 4623 – Storage of Organic Liquids) and a different one for the transfer 

operation (Proposed Rule 2020 and 4624). 
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B. Revised Proposed Rule 4621 

In Section 2.0, the applicability language would be revised to better delineate that the 

size of the gasoline delivery vessels are not related to the 19,800 gallons stated later in 

the applicability by grouping all of the storage container information in the first sentence 

and placing the gasoline delivery vessels in another sentence. The requirements of 

Section 5.2.1.2, which was added for aviation gasoline, would be clarified. ARB will no 

longer certify Phase I vapor control systems for aviation gasoline. However, to prevent 

backsliding, District staff proposes that operators storing aviation gasoline retain the 

current Phase I vapor control systems after ARB no longer certifies them for aviation 

gasoline. The change in language clarifies this provision. 

Three changes would be made to Section 5.3.1 through Section 5.3.4. First, the 

language describing each type of container would be revised for clarity. Second, the 

settings for the pressures-vacuum relief valves would be changed to look like the 

requirements in CP-206, although the range itself would not change. Lastly, operators 

were concerned about the language about the minimum control efficiency for Phase I 

systems. The language in the October 2007 version could imply that operators would 

have to prove the stated control efficiency a source test. Since these systems are 

certified, no source test is required. However, per Executive Order for these systems, 

operators would still be required to maintain and test parts of the system as laid out in 

the Executive Order. District staff intended that the system is certified to the stated 

control efficiency. District staff is proposing language in this section to clearly convey 

the intent of District staff. 

Section 6.3.3 requires that people wishing to perform the testing for the vapor recovery 

systems be in full compliance with the District’s 1177 (Gasoline Dispensing Facility 

Tester Certification), but no compliance date was given. As written, certification would 

be required as of the date of rule adoption. Since it does take at least some time for the 

certification process, a short compliance period would be more appropriate. District 

staff proposes three months after rule adoption date for the certification. 

C. Revised Proposed Rule 4622 

There are three minor language changes to this rule. The first one involves the 

compliance date for ICC certification in Section 5.2.3. The date was placed lower in the 

provision. District staff proposes moving the date to the top of the requirement. The 

second minor change involves the registration of mobile fuelers. Since the registration 

process can take up to a year to complete, District staff is proposing a 12 month 

compliance schedule for this provision. The last change involves the O&M manual 

provisions in Section 6.3. Since O&M are not spelled out anywhere else, District staff 

proposes putting the full title in this section. 
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D. Revised Proposed Rule 4624 

Stakeholders noticed a conflict between the RVP-to-TVP reference temperature in 

Proposed Rule 4624. The exemption mentions the TVP at actual transfer temperature, 

but the test method description specifically says at the storage container’s maximum 

storage condition. To resolve this conflict, District staff proposes modification to 

requirements in Rule 4624 that mention the RVP-to-TVP reference temperature to be at 

the storage container’s maximum storage temperature. The change minimizes operator 

testing by having only one reference condition, rather than a condition for the storage 

container (defined in Rule 4623 – Storage of Organic Liquids) and a different one for the 

transfer operation (Proposed Rule 4624). 

As proposed, Rule 4624 would apply to unloading as well as loading operations. This 

means that closed VOC emission control systems may be in use for the unloading 

operations. Because of stakeholder comments, District staff is proposing that closed 

VOC emission control systems be included to the types of acceptable emission control 

systems for both Class 1 and Class 2 transfer operations. 

Finally, record keeping requirements about the TVP would be revised to reflect the 

change in TVP requirement discussed above. 

VI. BASELINE EMISSIONS AND EMISSION REDUCTIONS 

Control Measure T in the EOADP involves emissions from gasoline dispensing facilities 

and other organic liquid transfer operations. The 2005 baseline VOC emissions 

attributed to facilities subject to Rule 4621 is 1.80 tons per day. As shown in Appendix 

B of the Final Staff Report, based on best data available to District staff, the estimated 

VOC emissions reduction from 2005 baseline emissions inventory and ARB staff report 

for CP-206 for these source categories is 1.06 tons per day. 

The baseline VOC emissions attributed to the proposed amendments to Rule 4622 and 

Rule 4624 were unavailable through the 2005 baseline emissions inventory. District 

staff analyzed information based on the best data available to develop baseline VOC 

emissions for the source categories. The baseline VOC emissions associated with the 

proposed changes to Rule 4622 is 0.31 tons per day. The estimated VOC reduction for 

Rule 4622 is 0.24 tons per day. For Rule 4624 analysis showed baseline VOC 

emissions at 0.38 tons per day and an estimated VOC reduction of 0.12 tons per day. 

The total combined VOC emissions reduction from the proposed changes to Rules 

4621, 4622, and 4624 is estimated at 1.42 tons per day as presented in Appendix B of 

the Final Staff Report. 

As previously stated in Section IA of this staff report, this rule project results from two 

control measures in the EOADP. Baseline emissions and emission reductions from 
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Control Measure T are outlined above. Control Measure U expected a total reduction of 

0.05 tons per day VOC reduction from a new rule addressing aviation gasoline. Aviation 

gasoline did not constitute a new rule and instead the District has included provisions 

regarding the regulation of aviation gasoline vapors in Rule 4621. Furthermore, due to 

technological constraints the District was not able to require a higher efficiency of vapor 

recovery systems used during the transfer of aviation gasoline. Despite the inability to 

be more stringent for aviation gasoline vapor recovery, the District will meet its 

commitment for reductions for both Control Measure T and U by reducing VOC 

emissions by approximately 1.47 tons per day through changes to Rule 4621, 4622, and 

4624. 

VII. COSTS AND COST EFFECTIVENESS ANALYSIS 

Pursuant to CH&SC 40920.6(a) a cost effectiveness analysis is required to be 

performed for rules that implement Best Available Retrofit Technology (BARCT) or all 

feasible control measures (AFCM). Since Control Measure U from the District’s 

Extreme Ozone Attainment Demonstration Plan (EOADP) for aviation gasoline does not 

impose additional requirements on current operations, no cost effectiveness analysis is 

required for the proposed changes related to aviation gasoline. A cost effectiveness 

analysis for Rule 2020 is not required because the proposed amendments do not 

implement BARCT or AFCM. The results of the cost effectiveness analysis for Rules 

4621, 4622, and 4624 are included in Appendix C of the Final Staff Report. 

VIII. SOCIOECONOMIC IMPACT ANALYSIS 

Pursuant to state law, District staff is required to perform a socioeconomic impact 

analysis prior to adoption, amendment, or repeal of a rule that has significant air quality 

benefits or that will strengthen emission limitations. 

As part of the Districts socioeconomic analysis process, District staff sought 

representatives from interested groups to participate as members of a Socioeconomic 

Focus Group on April 5, 2007. The Focus Group assisted District staff in determining 

the appropriate method for gathering information on regulatory compliance costs and 

business impacts resulting from compliance with the rule. The results of the 

socioeconomic analysis are published in a report and were presented along with the 

refined version of the draft rule to the public and interested parties during the final 

workshops for the rules in July 2007. 

IX. ENVIRONMENTAL IMPACTS 

Pursuant to the California Environmental Quality Act (CEQA), District staff has 

investigated the likely environmental impacts of the proposed changes. District staff has 
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26 Final Staff Report with Appendices for 

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found that the proposed project could not have a significant effect on the environment, 

and qualifies for exemption pursuant to CEQA guidelines Section 15061(b)(3). 

X. RULE CONSISTENCY ANALYSIS 

Pursuant to state Health and Safety Code, Section 40727.2, District staff has prepared a 

rule consistency analysis later in the rule development process. District staff found that 

facilities could comply with the proposed amendments to the three rules analyzed in this 

document as well as all other existing or proposed District rules. Furthermore, District 

staff found that none of the proposed requirements for this rule project would conflict 

with federal rules, regulations, or policies covering similar stationary sources. 

XI. REFERENCES 

1. California Air Resource Board Certification Procedure for Vapor Recovery 

Systems at Gasoline Dispensing Facilities, CP – 201; Amended May 2006. 

2. California Air Resource Board Certification Procedure for Vapor Recovery 

Systems of Bulk Plants, CP-202; Amended March 1999.

3. California Air Resource Board Certification Procedure for Vapor Recovery 

Systems of Cargo Tanks; CP-204; Amended March 1999.

4. California Air Resource Board Certification Procedure for Vapor Recovery 

Systems of Novel Facilities, CP-205; Amended March 1999. 

6. California Air Resource Board Certification Procedure for Vapor Recovery 

Systems of Aboveground Storage Tanks, CP-206; Adopted June 2007. 

7. California Air Resource Board Staff Report for the Adoption of California Air 

Resource Board Certification Procedure for Vapor Recovery Systems of 

Aboveground Storage Tanks, CP-206; May 2007. 

8. California Air Resource Board Definitions for Vapor Recovery Procedures, D200; Amended May 2006. 

9. California Air Resource Board Forecasted Emissions by Summary Category 

2006 Almanac (Base Year 2005 EI); April 5, 2006 

10. California Air Resource Board Advisory Number 360, May 2007. 

11. California Health and Safety Code, Sections 41950 – 41962. 
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12. Code of Federal Regulations; 40 CFR 60 & 40 CFR 63. 

13. San Diego Air Pollution Control District Rule 61.3.1 (Transfer of Gasoline into 

Stationary Underground Storage Tanks); Adopted March 2006. 

14. San Joaquin Valley Unified Air Pollution Control District 1-hour Extreme Ozone 

Attainment Demonstration Plan; Amended October 2005. 

15. San Joaquin Valley Unified Air Pollution Control District Rule 2020; Amended 

September 2006. 

16. San Joaquin Valley Unified Air Pollution Control District Rule 4623; Amended 

May 2005. 

17. San Joaquin Valley Unified Air Pollution Control District Rule 4409 and Staff 

Report for Rule 4409; Adopted April 2005. 

18. San Joaquin Valley Unified Air Pollution Control District Rule 4455; Adopted April 

2005. 

19. South Coast Air Quality Management District Rule 461 (Gasoline Transfer and 

Dispensing); Amended June 2005. 

20. South Coast Air Quality Management District Rule 462 (Organic Liquid Loading); 

Amended May 1999. 

21. California Air Pollution Control Officers Association Air Toxics “Hot Spots” 

Program, Appendix A; November 1997. 

22. U.S. Environmental Protection Agency Protocol for Equipment Leak Emission 

Estimates, 453/R-95-017, Tables 5-6 & 5-7; November 1995. 
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