 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Yolo-Solano Air Quality Management District 

       

Rule 2.22 Gasoline Dispensing Facilities

	

Prepared by: James Shears

Reviewed by: Andrew Steckel

	October 2015



RULE IDENTIFICATION -

Agency	Yolo-Solano Air Quality Management District (YSAQMD)



SIP Approved Rule	Rule 2.22 -   Gasoline Dispensing Facilities

Amended –  June 12, 2002  

Submitted – August 6, 2002

EPA Approved – January 23, 2003 (68 FR 3190)



Subject of this TSD	Rule 2.22 – Gasoline Dispensing Facilities

Amended – January 14, 2014

Submitted – June 26, 2015



Completeness Finding	Determination of Completeness letter: August 13,
2015





RULE SUMMARY – 

YSAQMD Rule 2.22, Gasoline Dispensing Facilities, is a rule designed to
limit displaced gasoline vapor emissions from storage tanks, transport
vessels, and motor vehicle fuel tanks using Phase I and Phase II vapor
recovery systems certified by the California Air Resources Board (CARB).
 YSAQMD regulates all of Yolo County and the northeastern portion of
Solano County.  These areas are included in a nonattainment area
classified as severe-15 for the 2008 8-hour ozone National Ambient Air
Quality Standards (NAAQS).

The following are significant changes in Rule 2.22 to the SIP-approved
rule:

Sections 112 through 116:  adds exemptions for E85 vehicles, non-retail
dispensing facilities where 95% of the vehicles are equipped with
onboard refueling vapor recovery (ORVR), certain facilities without
Phase I enhanced vapor recovery (EVR), and aboveground storage tanks
without Phase II EVR if the vapor recovery system is CARB certified and
installed before June 1, 2001, and meets 95% VOC reduction efficiency.

Section 304.11:  requires aboveground storage tanks to be equipped with
CARB certified standing loss control.     

Section 305.1:  requires CARB certified Phase II EVR systems for
dispensing facilities unless facilities qualify for exemption.

Section 305.7:  requires gasoline dispensing facilities with Phase II
EVR systems to have an in-station diagnostics (ISD) system in accordance
with the most recent applicable CARB Executive Orders.     

Section 306.1b:  requires owner/operators of retail gasoline dispensing
facilities to conduct inspection procedures of vapor recovery systems at
least once every 12 months in accordance with the protocol specified in
section 308 and CARB Executive Orders as applicable.   

Section 306.2a:  requires owners/operators of non-retail gasoline
dispensing facilities to conduct inspections of vapor recovery systems
at least once every 3 months in accordance with the protocol specified
in section 307 and CARB Executive Orders as applicable.

Section 307.3:  adds section requiring owners/operators to check the ISD
system status including any system alarms.  In the event of an ISD fuel
system shut-down alarm, the owner/operator shall not reset the system
until repairs are made.

Section 309:  revises section to include source testing requirements as
specified in the applicable CARB Executive Orders and the District
Permits. 

Section 600:  removes specific references to CARB test procedures, and  
instead requires tests be conducted in accordance with the most recently
 approved version of CARB test methods as stated in the applicable CARB
Executive Orders. 

Other minor administrative, formatting and editing revisions to aid
clarity.

EVALUATION CRITERIA - The following criteria were used to evaluate the
submitted rule. 

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. 

Stringency – EPA’s Control Technical Guideline (CTG) documents
titled, “Design Criteria for Stage 1 Vapor Control Systems”
(EPA-450/R-75-102)   and “Technical Guidance – Stage II Vapor
Recovery Systems for Control of Refueling Emissions at Gasoline
Dispensing Facilities” (EPA-450/3-91-022), and other state and local
rules were used to help evaluate the RACT requirements of CAA
§182(b)(2) and §182(f).

SIP Relaxation - Where previous versions of rules have been SIP
approved, new submittals must comply with CAA §110(l) and §193
regarding SIP relaxations. 

EPA EVALUATION -   The submitted Rule 2.22 is more stringent than the
approved SIP rule as it brings the rule up to date and includes
provisions for CARB-certified Phase I EVR storage tank requirements,
standing loss control for aboveground storage tanks, CARB-certified
Phase II EVR systems for dispensing facilities, and ISD systems for
Phase II EVR facilities.  Rule enforceability is enhanced by specifying
improved self-compliance inspection procedures and frequencies according
to CARB Executive Orders, as well as the ISD requirements.  The source
testing section of the rule is simplified by referring to the CARB
Executive Orders instead of listing numerous test methods in the rule. 
The District’s gasoline facility permits will continue to list the
specific source test methods pursuant to the CARB Executive Orders and
maintain the corresponding testing cycles.  This will lessen the need
for the District to update source test requirements within the rule.  

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 2.22
consistently.

The submitted rule is as stringent as other air district rules, such as
the Sacramento Metropolitan Air Quality Management and San Joaquin
Valley Unified Air Pollution Control Districts, for this category and
satisfies EPA’s CTGs.  As a result, we have determined that this rule
fulfills RACT requirements.

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 in
the submitted are as stringent as the existing SIP-approved control
requirements that they would replace.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – The following
revisions are not currently the basis for rule disapproval, but are
recommended for the next time the rule is amended.

We recommend that section 502 be revised to require gasoline dispensing
facility compliance test results and maintenance records be kept on the
premises for a period of at least 5 years instead of 2 years.  Please
see, for example, San Joaquin Valley Unified Air Pollution Control
District Rule 4622, section 6.2.3.

EPA ACTION – The submitted Rule 2.22 improves the SIP and complies
with all relevant CAA requirements.  Therefore, EPA staff recommends
approval of Rule 2.22 pursuant to CAA §110(k)(3).

REFERENCES - 

1.	Yolo-Solano Air Quality Management District (YSAQMD), “Proposed
Revisions to Rule 2.22 Gasoline Dispensing Facilities” – Final Staff
Report, December 30, 2014.  

 2.       Sacramento Metropolitan Air Quality Management District, Rule
448, “Gasoline Transfer into Stationary Storage Containers”,
February 26, 2009.

3.	Sacramento Metropolitan Air Quality Management District, Rule 449,
“Transfer of Gasoline into Vehicle Fuel Tanks”, February 26, 2009.

4.        San Joaquin Valley Unified Air Pollution Control District,
Rule 4621, “Gasoline Transfer into Stationary Storage Containers,
Delivery Vessels, and Bulk Plants”, December 19, 2013.

5.	San Joaquin Valley Unified Air Pollution Control District, Rule 4622,
“Gasoline Transfer into Motor Vehicle Fuel Tanks”, December 19,
2013.

6.        “Issues Relating to VOC Regulation Cutpoints, Deficiencies,
and Deviations,” (the Bluebook), EPA OAQPS, May 25, 1988.

7.        “Guidance Document for Correcting Common VOC & Other Rule
Deficiencies” (the Little Bluebook), EPA Region 9, August 21, 2001.

8.        “Design Criteria for Stage 1 Vapor Control Systems”
(EPA-450/R-75-102)   

9.       “Technical Guidance – Stage II Vapor Recovery Systems for
Control of Refueling Emissions at Gasoline Dispensing Facilities”
(EPA-450/3-91-022).

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