                                       
                                       







                                       
                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            REGION IX AIR DIVISION




                          Technical Support Document 
                                      for
                              EPA's Rulemaking
                                    for the
                     California State Implementation Plan
                                       
             Yolo-Solano Air Quality Management District Rule 2.21
                      Organic Liquid Storage and Transfer




                              
                         Prepared by: Rebecca Newhouse
                             Reviewed by: Doris Lo

                               December 11, 2017





RULE IDENTIFICATION

Agency:				Yolo-Solano Air Quality Management District
SIP Approved Rule:			Rule 2.21, Organic Liquid Storage and Transfer
					Submitted  -  October 10, 2005
                        EPA Approved  -  October 31, 2006 (71 FR 63694)
                        
Superseded Submittals: 		Rule 2.21, Organic Liquid Storage and Transfer
					Revised -- March 12, 2014
					Submitted -- June 26, 2015

Subject of this TSD:			Rule 2.21, Organic Liquid Storage and Transfer
					Revised  -  September 14, 2016
					Submitted  -  January 24, 2017

BACKGROUND  - 

The Yolo-Solano Air Quality Management District (YSAQMD or District) regulates a portion of the Sacramento Metropolitan Air Basin, which is designated and classified as a "Severe" nonattainment area (NAA) for the 2008 8-hour ozone National Ambient Air Quality Standards (NAAQS) (see 40 CFR section 81.305). For ozone nonattainment areas classified as Moderate or above, the Clean Air Act (CAA) requires that the State submit State Implementation Plan (SIP) provisions to require implementation of reasonably available control technology (RACT) (see CAA 182(b)(2) and 182(f)).  The submitted rule is intended to implement RACT-level controls for organic liquid storage and transfer. The YSAQMD Rule 2.21 applies to the following four CTG source categories: 1) external floating roof storage tanks, 2) fixed-roof storage tanks, 3) bulk gasoline terminals, and 4) bulk gasoline plants.

The YSAQMD revised Rule 2.21 on March 12, 2014 to remove the requirements for gasoline dispensing facilities, which are already included in SIP-approved Rule 2.22 -- Gasoline Dispensing Facilities, and strike provisions related to tanks with specific types of primary seals.  The California Air Resources Board (CARB) submitted this version of Rule 2.21 to EPA for SIP approval on June 26, 2015. On September 14, 2016, YSAQMD revised the rule again to correct a deficiency identified by EPA concerning primary seals for floating roof tanks and to make other clarifications to the rule. CARB submitted this version of the rule to EPA for SIP approval on January 24, 2017. This rule supersedes the March 12, 2014 version and is the subject of this TSD. 


RULE SUMMARY  -  

Rule 2.21 establishes requirements to reduce volatile organic compound (VOC) emissions from organic liquids during storage and transfer at bulk terminals and bulk gasoline plants. 

Changes from the approved SIP rule include:

 Removing reference to "gasoline dispensing facilities" (GDFs) and related emission requirements for gasoline transfer at GDFs, since those requirements are included in SIP-approved YSAQMD Rule 2.22, which specifically addresses gasoline transfer at GDFs. 
 Removing "liquid mounted seals" and "resilient toroid seals" as acceptable primary seal alternatives for floating roof tanks, thereby requiring all applicable storage tanks use mechanical shoe seals.
 Clarifying requirements for deck fittings by condensing redundant provisions, reorganizing deck fitting requirements for internal and external floating roofs, and specifying additional requirements, including maximum gaps for guidepoles in floating roofs and a requirement that guidepole wells project below the liquid surface.
 Removing outdated compliance dates.
 Other minor conforming and clarifying changes.  
      
EPA EVALUATION CRITERIA  -  The following criteria were used to evaluate the submitted rule: 
1.	Enforceability - The Bluebook (Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the Little Bluebook (Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to evaluate the rule for compliance with the enforceability requirement in CAA §110(a)(2)(A).  

      2.	Stringency - SIPs must require RACT for each category of sources covered by a Control Technique Guideline (CTG) document as well as each major source in ozone nonattainment areas classified as moderate or above (see sections 182(b)(2) and 182(f)). EPA's CTGs titled, "Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed-Roof Tanks" (EPA-450/2-77-036, December 1977), "Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks" (EPA-450/2-78-047, December 1978), "Control of Volatile Organic Emissions from Bulk Gasoline Plants" (EPA-450/2-77-035, December 1977), "Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals" (EPA-450/2-77-026, October 1977), and local rules implemented in other areas were used to evaluate the rule for compliance with 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 applicable 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.

EPA EVALUATION  -  Recent rule revisions were primarily clarifying in nature.  The rule's requirements and applicability provisions remain clear and ensure affected sources and regulators can evaluate and determine compliance with Rule 2.21 consistently. Additionally, revisions to deck fitting requirements mirror guidepole requirements for BAAQMD Rule 8-5, and enhance enforceability and stringency by specifying gap requirements between guidepoles and the roof. Rule 2.21's organic liquid storage and transfer requirements are more stringent than EPA's recommendations in the applicable CTGs, and are generally consistent with other California District rules for these source categories, such as Bay Area Air Quality Management District (BAAQMD) Rule 8-5, San Joaquin Valley Air Pollution Control District (SJVAPCD) Rule 4623 and Rule 4624, Placer County Air Quality District (PCAPCD) Rule 212 and Rule 215. In some areas, including primary and secondary seal gap requirements, and VOC capture efficiency during gasoline bulk plant transfers, the provisions of Rule 2.21 are more stringent than analogous provisions in South Coast Air Quality Management District Rule 463 and Rule 462. 
We propose to determine that this rule satisfies RACT requirements.  Lastly, although the rule removes certain requirements related to gasoline dispensing facilities, these revisions to the rule would not result in a relaxation of SIP-approved requirements because equivalent requirements are included in YSAQMD SIP-approved Rule 2.22, sections 304.1, 304.2, and 304.4. 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. 
RULE DEFICIENCIES  -  We have identified no deficiencies in Rule 2.21 that would preclude full approval.
RECOMMENDATIONS  -  We recommend that the District consider the following revisions the next time the rule is amended:
 Add a definition for "zero-gap pole wiper seal." For example, see BAAQMD Rule 8-5, section 216, and SJVAPCD Rule 4623, section 3.38.
 Consider requiring tanks with true vapor pressure of 11 pounds per square inch (psi) or greater, to be either pressure tanks maintaining working pressures that prevent organic vapor or gas loss to the atmosphere or be equipped with a closed vent system routed to a control device that achieves at least a 95% reduction. See, for example, PCAQMD Rule 212, section 305 and BAAQMD Rule 8-5, section 301. 
 Consider lowering the height of allowable submerged discharge pipes, when filled from the side, from 24" to 18". For example, see PCAPCD Rule 212, section 305 and BAAQMD Rule 8-5, section 303.2.
 Consider specifying vapor control requirements for organic liquid tanks less than 40,000 gallons. For example, see BAAQMD Rule 8-5, section 301, and SJVAPCD Rule 4623, which both require tanks under 40,000 gallons be equipped with a pressure/vacuum valve or have a vapor loss control system.
 Consider adding leak inspection requirements during organic liquid transfers. See SJVAPCD Rule 4624, section 5.9.
 Consider adding a general requirement for openings through internal floating roofs, except pressure relief devices, to provide a projection below the liquid, and be equipped with a gasketed cover, seal or lid. For example, see BAAQMD Rule 8-5, section 320.2 and 320.3, and SJVAPCD Rule 4623, section 5.5.2.1.1
      
EPA ACTION  -  EPA staff recommends full approval of Rule 2.21 pursuant to CAA §110(k)(3).
REFERENCES  - 
 "Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations," (a.k.a., Bluebook) EPA OAQPS, May 25, 1988 (http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf).
 "Guidance Document for Correcting Common VOC & Other Rule Deficiencies," (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001 (http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf).
 YSAQMD Rule 2.21, Organic Liquid Storage and Transfer, as amended September 14, 2016, and submitted to EPA on January 24, 2017.
 YSAQMD Rule 2.21, Organic Liquid Storage and Transfer, as revised September 14, 2005, and approved into the SIP on October 31, 2006 (71 FR 63694).
 BAAQMD Rule 8-5, Storage of Organic Liquids, as revised October 18, 2006. 
 BAAQMD Rule 8-6, Organic Liquid Bulk Terminals and Bulk Plants, as revised February 2, 1994.
 PCAPCD Rule 212, Storage of Organic Liquids, as revised June 19, 1997, and approved into the SIP on June 11, 2009 (74 FR 27714). 
 PCAPCD Rule 215, Transfer of Gasoline Into Tank Trucks, Trailers, and Railroad Tank Cars at Loading Facilities, as revised June 19, 1997, and approved into the SIP on January 31, 2011 (76 FR 5277). 
 SJVAPCD Rule 4624, Transfer of Organic Liquid, as revised December 20, 2007, and approved into the SIP on October 15, 2009 (74 FR 52894).
 SJVAPCD Rule 4623, Storage of Organic Liquids, as revised on May 13, 2005, and approved into the SIP on September 13, 2005 (70 FR 53937).
 SCAQMD Rule 463, Organic Liquid Storage, as revised November 4, 2011, and approved into the SIP on March 28, 2013 (78 FR 18854).
 SCAQMD Rule 462, Organic Liquid Loading, as revised May 14, 1999, and approved into the SIP on July 21, 1999 (64 FR 39037).   
