2300 Industrial Park Drive **Jim Lawrence, President/CEO** Wilson, North
Carolina 27893 Direct Phone: (252) 243-8266

Phone: (252) 243-0150 Direct Fax: (252) 206-1882

Toll Free: (800) 234-4394 Email: <jll@emcoretail.com>

Date: September 29, 2004

To: Mr. Thomas Driscoll

From: Jim Lawrence

MESSAGE\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Dear Tom,

Listed below are our comments with respect to the EPA Stage II Vapor
Recovery Systems Issues Paper.

1)  **ORVR Definition for Widespread Use**

> Ostensibly both Stage II systems and ORVR vehicles run at 95%
> efficiency. Consequently if Stage II controls were removed from
> dispensing facilities when the vehicle population is 95% ORVR, the net
> effect on emissions would be zero. The 95% ORVR vehicle trigger would
> then be a logical starting point. However, allowing the 5% non ORVR
> vehicles to begin refueling with no vapor recovery increases their
> emission rate by a factor of 20. This flies in the face of common
> sense. Surely any environmental protection advocate worth his weight
> in VOC's would cringe at the prospect of abandoning the use of
> effective, proven methods of reducing refueling emissions. This is
> particularly true if these systems are compatible with ORVR vehicles.
>
> Therefore, setting the widespread use definition at a vehicle
> population percentage of 98 seems a prudent step to insure effective
> emission control in serious, or worse, non attainment areas.
>
> The continued use of Stage II controls in moderate non attainment
> areas is likewise worthwhile, and we feel that it should be
> encouraged.
>
> With regard to the best method to determine widespread use, the
> easiest calculable method seems best suited to the situation; why use
> complex equations and immense data gathering programs when you can
> call the vehicle registration office and get a workable answer?

**2) P/V Vents on UST's**

> The Issues Paper makes frequent reference to P/V vents, and at one
> point (page 8 paragraph 1) it is stated that California is expected to
> require P/V valves on all UST vents for Stage I control. To the best
> of our knowledge the P/V vents have been required on Phase I for a
> considerable amount of time. For example, attachment 1 is a 1985 ARB
> Executive Order G-70-97-A, listing approved P/V vents.
>
> .
>
> The broader issue that P/V vent effectiveness needs additional study
> is a valid point and could result in significant emission control for
> small sums of money. Regardless of the fate of Stage II systems, UST's
> should all incorporate P/V vents.

**3) Stage II System Compatibility with ORVR**

> **Balance Systems** have been deemed compatible with ORVR by the
> California Air Resources Board (attachment 2). They do not produce
> excess UST emissions. The systems are simple and considerably less
> expensive to install and maintain than other Stage II systems.
>
> As stated by Bud Pratt of the State of Missouri (at the September 20
> meeting), interface efficiencies with Balance Stage II and ORVR have
> been shown to be 98%+. We look forward to reviewing his data when the
> meeting results are published. This 20-year-old technology effectively
> and economically, solves the ORVR incompatibility emissions problem.
> Conversion from other Stage II systems to balance is not expensive.
> The bulk of the cost is in hanging hardware - a good portion of which
> gets changed during general maintenance over the course of a few years
> anyway.
>
> The historical objection to the Balance System is that the nozzle is
> somewhat difficult to insert into the vehicle filler neck. Newer
> nozzle designs, precipitated by the new EVR requirements, are easily
> adapted to the old systems and effectively overcome this objection.
>
> **Assist and Hybrid Systems** are customer friendly, but complex.
> Since they require add-on control devises to deal with the
> incompatibility emissions problem, they are expensive. A \$30,000
> processor cost per site was quoted in the September 20 meeting,
> although there is a range among the different suppliers.

**4) Improved Monitoring for Stage II VRS**

> Oversight inspections have certainly improved Stage II efficiency. In
> Southern California an initial surge in replacement part orders
> indicated to us that many sites were not being properly maintained.
> The process has also forced equipment suppliers to improve the quality
> and reliability of their products. Faced with maintaining properly
> functioning stations, operators quickly determine what works best.
>
> However, oversight inspections are very different animals than planned
> obsolescence programs. The proposal sketched out in paragraph 1 page
> 25 of the Issues Paper is simply not realistic. Date stamping and
> replacing components on a regular basis regardless of any known
> problem is unduly burdensome to the gas station operators.
>
> The typical GDF has multiple refueling positions incorporating
> nozzles, swivels, hoses, breakaway couplings, and whip hoses. The
> volume of fuel dispensed from the separate fueling locations varies
> considerably, and that volume relates directly to wear on the
> components. The service lives of the components vary, so changing them
> at one time would be wasteful and changing them individually would be
> expensive. Added to this would be replacements due to drive away
> incidents, and equipment failures. The result is a never ending
> nightmare for the station maintenance people. They would be forced to
> continuously check dates on each and every component of every fueling
> location to insure compliance. The cost would be tremendous. This
> approach is great for equipment sales but the net effect on emission
> reduction is not so clear.

**5) California Enhanced Vapor Recovery (EVR) Requirements**

> A number of requirements incorporated into the EVR program are
> straightforward and will result in decreased emissions. These include
> the dripless nozzle, liquid retention requirements, Balance System
> component pressure drops and leak tight connectors and fittings. The
> leak tight connectors, liquid retention requirement and dripless
> nozzles all require equipment design changes, and they **directly**
> result in improved performance.
>
> To the contrary, the pressure limit requirement of +0.25 inches w.c.
> daily average, and +1.5 inches w.c. maximum requirement **seeks** to
> minimize pressure related fugitive emissions. These emissions may not
> actually exist in a properly constructed and tested system. These are
> the same emissions that are addressed by the phase I EVR requirements.
> The net result is a requirement that, in effect, chases **potential**
> fugitive emissions.
>
> The Emco Stage I EVR test site using standard balance type nozzles
> averaged +0.167 w.c. daily with a +0.947 w.c. maximum over the first
> two weeks of operation. This illustrates that the answer to lower
> emissions may well lay in the new Stage I requirements and in the
> quality of construction and maintenance of the system. It is
> interesting to note that the P/V vent (set at 3 in w.c.) never opened
> throughout the entire time period. This data are available upon
> request.

.