UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for EPA’s Direct Final Rulemaking

for the California State Implementation Plan

South Coast Air Quality Management District Rule 463

Organic Liquid Storage

Prepared by: Cara Peck Reviewed by: Andrew Steckel

December 28 , 20122

Rule Agency: South Coast Air Quality Management District (SCAQMD)

SIP Approved Rule: Rule 463

- Organic Liquid Storage

Amended

– May 6, 200 5

Submitted

– October 20, 2005 EPA Approved on January 04

, 2007

Subject of this TSD: Rule 463, Organic Liquid Storage

Amended

– November 4, 2011

Submitted

– February 23, 2012

RULE SUMMARY

SCAQMD Rule 463 controls emissions of volatile organic compounds (VOCs) from

above

- ground storage tanks used for storage of organic liquids. Organic liquid storage tanks are classified into three types: fixed roof tanks, fixed roof tanks with internal

flo ating covers, and external floating roof tanks.

RULE BACKGROUND

Rule 463 was originally adopted on August 15, 1977. It was later amended on June 1, 1984, December 7, 1990, March 11, 1994 an d May 6, 2005. The May 6, 2005 rule was approved by the Envir onmental Protection Agency (EPA) into the California State Implementation Plan (SIP) on January 04, 2007 . The SCAQMD amend ed Rule 463 again on November 04 , 2011, and submitted it to EPA on February 23, 2012

.

RULE CHANGES

The February 23, 2012 SIP submit ted version of Rule 463 mainly differs from the current SIP rule ( approved into the SIP on January 4, 2007 ) due to updated testing methods

, aligning the rule with Rul e 1178 used in determining vapo r pressure for heavier petroleum products.

1. Definitions:

 “Ambient temperature” is added, consistent wi th the definition of Rule 1178.

 “Certified Person” is defined rather than “Certified”, consistent with the proposed amended rule language usage.

 “Drain

- Dry Breakout Tank” is defined to support a limited exempt ion from the vapo r headspace limitation requirements for such tanks that are primarily used to receive product from pipelines and to distribute product back into pipelines a nd that are subject to the vapo r control requirements of Rule 1149

- Storage Tank an d Pipeline Cleaning Degassing.

 “Vapor

- Tight” is updated to reflect current detecting methods and limits (from 1,000 to 500 ppm).

 “Volatile Organic Compound” is updated to refer to Rule 102

- Definitions.3  “Working Day” is defined as Monday through Friday and includes holidays that fall on any of the days Monday through Friday.

2. Requirements:

 Language was added stating that vapor recovery system s shall have an efficiency of at least 95 percent by weight, or vent tank emissions to a fuel gas system.

 A requirement for the Inspection and Maintenance Plan was changed and now states that the owner or operator shall maintain, rather than submit, a current or revised Inspection and Maintenance Plan approved by the Executive Officer.

3. Rep orting and Recordkeepi ng:

 All compliance and inspection reports and documents submitted to the Executive

Officer can now be submitted electronically rather than just via hard copy, within 5 working days of completion of the self

- inspection.

 An exemption was added stating tha t the provisions of (d)(2) shall not apply to

drain

- dry breakout tanks that are subject to the provisions of Rule 1149

- Storage Tank and Pipeline Cleaning and Degassing.

4. Test Methods:

 Language was added stating that the Reid vapor pressure used in determining the true vapor pressure limit shall be determined according to ASTM D

- 323

- 82

- Vapor Pressure of Petroleum Products (Reid Method) or California Code of Regulations, Title 13, Section 2297, and converted to true vapor pressure us ing applicable nomographs in U.S. EPA AP

- 42, Fifth Edition, Volume 1, Chapter 7, or nomographs approved by the Executive Officer and U.S. EPA.

 Additional language was added stating that if demonstration of true vapor pressure of less than 5mm Hg (0.1 psi) absolute is required, either of the following test methods may be used:

o Organic liquids stored at ambient temperature with a true vapor pressure of greater than 5mm HG (0.1 psi) under actual storage conditions shall be determined as those with a flash poi nt of less than 100°F as determined by

ASTM Method D

- 93

- 10a

- Flash Point by Pensky Martens Closed Cup

Tester

.

o Organic liquids stored at above ambient temperatures with a true vapor pressure greater than 5 mm Hg (0.1 psi) shall be determined by ASTM

Method D

- 86

- 11a

- Distillation of Petroleum Products at Atmospheric

Pressure.

 Language was added stating that vapor tight conditions specified in subparagraphs (c)(3)(B) shall be determined according to U.S. EPA’s Reference Method 21 using an appropriate analyzer calibrated with methane.4

EPA EVALUATION

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 Clean Air Act (CAA) § 110(a)(2)(A) requirement for enforceability.

2. Stringency : EPA ’ s Control Technique G uideline (CTG) documents titled, “Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks” (EPA

- 450/2

- 78

- 047) and “Control of Volatile Organic Emissions from Storage of Petroleum Liquid in Fixed

- Roof Tanks” (EPA

- 450/2

- 77

- 036), 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 : CAA § 110(l) prohibits EPA from approving any SIP revision that would interfere with any app licable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA § 193 prohibits the modification of any SIP

- approved control requirement in effect before November 15, 1990, in a nonattainment area.

The rule requirements and applicability are clear, and the monitoring, recordkeeping, reporting and other provisions sufficiently ensure that affected sources and regulators can evaluate and determine compliance with Rule 463 consist ently.

The submitted rule is as stringent as CARB’s RACT guidance and other California

District rules fo r this category, including BAAQMD Rule 8

- 5 and SJV U APCD Rule 4623 and it is more stringent than EPA’s 1977 CTG. As a result, we have determined

th at this rule fulfils RACT requirements.

We propose to determine that our approval of the submittal would comply with CAA §§ 110(l) and 193 because 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

.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

There are no additional recommendations for the next rule revision.5

EPA ACTION

The submitted Rule 463 would strengthen the SIP by improving enforceability of certain rule requirements. The changes are primarily administrative in nature and are not expected to have any adverse effect on emission reductions. EPA staff recommends

appr oval of SCAQMD Rule 463 pursuant to CAA § 110(k)(3) and § 301(a).

REFERENCES

1. SCAQMD Rule 463, Organic Liquid Storage, as submitted on February 23, 2012

. 2. SCAQMD Rule 463, Organic Liquid Storage, as approved into the SIP on January 04, 2007

3. Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

4. Guidance Document for Correcting Common VOC & Other Rule Deficiencies, (a.k.a., Little Bluebook), EPA Region 9, Au gust 21, 2001.

5. “Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks,” EPA

- 450/2

- 78

- 047.

6. “Control of Volatile Organic Emissions from Storage of Petroleum Liquid in

Fixed

- Roof Tanks,” EPA

- 450/2

- 77

- 036.

7. SJV U APCD Rule 46 2 3 , Organic Liquid Storage, as approved into the SIP on May 19, 2005

8. BAAQMD Rule 8

- 5

- Storage of Organic Liquids, as approved into the SIP of November 27, 2002