January 29 , 2009

VIA E

- MAIL TO PATRICK AU

Mr. Michael Guzzetta, Manager

Rule Evaluation Section

Emissions Assessment Branch Stationary Source Division

Air Resources Board

P.O. Box 2815 Sacramento, CA 95812

Subject: SIP Submittal for Revised Rule 10 2, Definitions, and Rule 316, Storage and Transfer of

Gasoline

Dear Mr. Guzzetta:

On January 15, 2009 , the Santa Barbara County Air Pollution Control District Board of Directors held a public hearing on adopting proposed revisions to Rule 102, Definitio ns, and Rule 316, Storage and

Transfer of Gasoline . After the public hearing, the Board adopted the revised rule s . Transmitted with this

letter are the adopted revised rules for inclusion in California State Implementation Plan.

The changes to the rules are summarized below:

 Rule 102, Definitions

The APCD modified the definitions of gasoline and organic solvents to update the referenced test

methods and improve rule clarity. On the gasoline definition, the District added including aviation gasoline

. Although, Rule 316 does not require the use of a Phase II vapor recovery system when cargo tanks refuel aircraft, the rule does require that aviation gasoline bulk plants and cargo tanks be equipped

with Phase I vapor recovery systems

.

 Rule 316

, Storage a nd Transfer of Gasoline

The District added two exemptions to allow vehicle refueling at qualifying gas stations without the use of Phase II vapor recovery systems. These exemptions appear in Rule 316, Sections I.7.a and b. Section I.7.a provide s an exem

ption to qualifying non

- retail gasoline stations that refuel only vehicles equipped with onboard refueling vapor recovery systems. Section I.7.b provide s an exemption for the refueling of

flexible fuel vehicles with ethanol (E

- 85)

. Other changes to Rule 316 include correcting typos and eliminating acronyms, adding three definitions relativ e to the new exemptions, updating source test
methods per suggestions from the ARB, and adding test method data for annual certification s of cargo

tanks per an ARB reque st

.Santa Barbara County APCD Sip Submittal Page 2

We are providing documents to complete this SIP submittal package as attachments to this letter. These

a ttachment s included :

1. SIP Completeness Checklist

2. Complete Copies of Rules 102 and 316 (as amended January 15, 2009)

3. Underline and Strikeou t Copies of Rules 102 and 316

4. Copy of the Public Notice

5. Signed Resolution and Minute Order

6. Public Comments and Responses

7. Rule Evaluation Form

8. Non

- EPA Test Method ( ARB Test Method 2

- 6 )

9. Draft Background Paper (September 2008)

We would lik e to clarify our responses to the SIP Completeness Checklist and the associated material we are submitting:

1. The SIP Completeness Checklist requests copies of all referenced rules, unless previously submitted as part of an earlier SIP submittal. Our an alysis indicates that the District has previously submitted all of the referenced rules (201, 326, 802, 803, and 806) as part of earlier SIP submittal s

. Thus, we

have not included them with this submittal.

2. Rules 102 and 316 include refer ences to non

- E PA test methods . The SIP Completeness Checklist

indi cates we may need to submit such test methods with this package . O ur analysis indicates that many of the test methods and/or procedures have likely been previously submitted to EPA

. 1 At this juncture, in lieu of submitting the t est m ethods, we ar e providing the following table, which identifies 1) where a rule references a non

- EPA test method, 2) the test method name/number , and 3) if applicable

, where the test method is available on the Internet. 2

1 Many of the test methods sh ould be common to other air district rules on gasoline storage, transfer, and vehicle refueling.

2 S taff will provide the test method(s) upon request

. I tem Rule Test Method Internet Website Where the

Test Method is Available Other Information

1 102, Gasoline

definition Test Method for the

Determination of the Reid Vapor Pressure Equivalent Using an Automated Vapor

Pressure Test Instrument http://ccr.oal.ca.gov/linkedsli ce/default.asp?SP=CCR

1000&Action=Welcome This test method is found in

the California Code of Regulations, Title 13, Division 3, Chapter 5, Article 4, section 2297

. 2 316, Section

H.1 ARB Test Method 203,

CP

- 203, Certification Procedure for Vapor Recovery Systems of

Terminals http://www.arb.ca.gov/testme

th/vol2/new2006vol2.htm