California Environmental Protection Agency — Hazardous Materials Safety Interpretation

Page 1.S. Departmen f Transportatior 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration AUG 3 0 2004 Mr. William V. Loscutoff, Chief Ref. No.: 04-0174 Monitoring and Laboratory Division Air Resources Board California Environmental Protection Agency P.O. Box 2815 Sacramento, California 95812 Dear Mr. Loscutoff: Thank you for your letter of July 21, 2004, requesting our comments regarding potential changes the California Air Resources Board (CARB) may propose in some equipment on gasoline cargo tanks. The CARB is currently evaluating emissions of gasoline vapor from the operation of cargo tank trucks. The CARB is studying emissions from three main sources: vapor and product delivery hoses; pressure-vacuum relief (p/v) valves; and degassing operations. The results of this study will be used in the development of regulations aimed at reducing the emissions from these potentially significant sources. Your ideas regarding potential equipment modifications involve the hoses and p/v valves. For example, you considered the use of caps installed on the ends of the hoses between delivery operations. Relative to p/v valves, because venting may occur during hot, sunny conditions, with the valve operating according to current "cracking pressure" standards, you have considered the potential of increasing that standard. At this time, you are seeking comments on this issue. The U.S. Department of Transportation (DOT), Research and Special Programs Administration's Office of Hazardous Materials Safety is the agency responsible for issuing and interpreting the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), which ommerce. The HMR prescribe packaging requirements, such as specifications for th stablish requirements for transporting hazardous materials in intrastate, interstate, and foreig manufacture and testing of cargo tank motor vehicles used to transport hazardous materials (e.g., gasoline). Because DOT has the authority to issue safety requirements for cargo tank motor vehicles used to ansport gasoline, any regulations established by a State in regard to modifications or changes argo tank motor vehicles must be substantively the same as the DOT's regulations. If the stuc demonstrates need for change in current regulations, you may petition for rulemaking in accordance with 49 CFR 106.95 and 106.100. 178.320 040174 180.405#

Page 2Thank you again for your interest in transportation safety and keeping us informed as the study progresses. We look forward to your future input when more conclusive results become available. Sincerely, totte z. mitchell for Edward T. Mazzullo Director, Office of Hazardous Materials Standards#

Page 3Air Resources Board Alan C. Lloyd, Ph.D. Agency Secretary Terry Tamminen 1001 | Street • P.O. Box 2815 Chairman Arnold Schwarzenegger Governor Sacramento, California 95812 • www.arb.ca.gov July 21, 2004 Charum Mr. Edward T. Mazzullo, Director Office of Hazardous Materials Standards 5178.320 United States Department of Transportation DHM-10 $180.405 400 7" Street, S.W. Washington, DC 20590-0001 argo Tanks Dear Mr. Mazzullo: 04-0174 The purpose of this letter is to notify you early in the process that the California Air Resources Board (ARB) may propose changes in some equipment on gasoline cargo tanks. Because your office may have concerns regarding these changes, we are seeking your comments at this time. The ARB is currently evaluating emissions of gasoline vapor from the operation of cargo tank trucks. Specifically, we are studying the emissions from three main sources: vapor and product delivery hoses; pressure-vacuum relief (p/v) valves; and degassing operations. The results of this study will be used in the development of regulations aimed at reducing the emissions from these potentially significant sources. Although the emissions study is still progressing, our.initial thoughts regarding potential equipment modifications involve the hoses and p/y valves For: example, we have considered the use of caps installed on the ends of the hoses between delivery operațions. Regarding p/v valves, we have concerns that significant venting may occur, especially during hot, sunny conditions (which coincides with ozone season) with the valve operating according to current "cracking pressure" standards. Thus, we have considered the possibility of increasing that standard to some degree. We will keep you informed as the study progresses and more conclusive results become available. If you have questions regarding the details of this emissions study or related regulation development; please feel free to contact Ranjit Bhullar, Manager of.the In-Use Vapor Recovery Section:at (916) 322-0223 or. via e-mail at rbhullar@arb.ca.gov. Sincerely, William V. Loscutofarre:. , Chief Monitoring and Laboratory Division The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs, see our: Website: http://www.arb.ca.gov. California Environmental Protection Agency Printed on Recycled Paper#