UnitedStates OfficeofAirQuality EPA-45013-91-022a EnvironmentalProtection PlanningandStandards November1991 Agency Research TriangleParkNC27711 Air 

# TechnicalGuidance

# - StageII

# VaporRecovery SystemsforControlof Vehicle Refueling EmissionsatGasoline Dispensing Facilities
VolumeI:

# Chapters

# Technical Guidance

# - StageIIVaporRecoverySystems

forControlofVehicleRefueling EmissionsatGasoline

DispensingFacilities

VolumeI:Chapters

EmissionStandardsDivision

U.S.ENVIRONMENTALPROTECTIONAGENCY OfficeofAirandRadiation OfficeofAirQualityPbmlngandStandards ResearchTrianglePark,NorthCarolina27711 November1891

### This reporthas been reviewedby the Emission Standards Divisionof the Office of Air Quality Planning and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not intended to constituteendorsement or recommendation foruse.
Copies of this report are available, as supplies permit throughthe Library Services Office (MD-35),U.S. EnvironmentalProtectionAgency, Research Triangle Park NC 

### 27711, (919) 541-2777, or for a nominal fee, from National Technical Information Services, 5285 Port Royal Road, SpringfieldVA 22161, (703)487-4650.

### TABLE OF CONTENTS

CHAPTER 1.0 INTRODUCTION
1.1 Background 1.2 Clean Air Act Requirements 1.3 Organization of Report 1.4 References

CHAPTER 2.0 INDUSTRY DESCRIPTION 2.1 Industry Description 2.2 Industry Population and Size Distribution 2.3 Model Plants 2.4 Summary 2.5 References

CHAPTER 3.0 SOURCES OF EMISSIONS
3.1 General 3.2 Emission Sources 3.3 Factors Influencing Emissions 3.4 Emission Factor Calculations 3.5 Model Plant Emission Estimates 3.6 References

CHAPTER 4.0 CONTROL TECHNOWY 4-1
4.1 Types of Stage I1 Systems 4-2 4.2 System Components 4-11 4.3 California Certification Program 4-33 4.4 In-Use Effectiveness 4-46 4.5 References 4-56

iiiCHAPTER 5.0

CHAPTER 6.0

APPENDIX A
APPENDIX B APPENDIX C

APPENDIX D
APPENDIX E
APPENDIX F APPENDIX G APPENDIX H APPENDIX I APPENDIX J APPENDIX 

### K TABLE OF CONTENTS (Concluded)

STAGE 11 COSTS
5.1 Equipment, Installation and Annual Costs 5.2 Model Plant Costs 5.3 Comparison of Recent Cost Studies 5.4 Current Costs of Stage I1 Systems 5.5 References
PROGRAM IMPLEMENTATION
6.1 6.2 6.3 6.4 6.5 6.6 Planning Regulations Permitting Inspections Summary References

LUNDBERG SURVEY INCORPORATED INDIVIDUAL COUNTY SIZE DISTRIBUTION A-1 STAGE I1 FACILITY COSTS B-1 CALIFORNIAAIR RESOURCES BOARD STAGE 11 (PHASE11) CERTIFICATION TEST PROCEDURES C-1 CALIFORNIAAIR RESOURCES BOARD EXECUTIVE ORDERS D-1 ILLUSTRATIVEEXAMPLE OF IN-USE EFFICIENCY CALCULATION PROCEDURES E-1 STAGE 11 PROGRAM SUMMARIES F-1 PUBLICAWARENESS INFORMATION G-1 STAGE I1 REGULATIONS H-1 PERMITTING INFORMATION 1-1 STAGE I1 TESTWETHODS J-1 INSPECTION INFORMATION K-1LIST OF FIGURES

GasolineMarketing in theUnited States Comparison of InsAngeles Average Service Station Size toMPSI Data Comparison of EPA Nationwide, Sierra Ins Angeles, and Lundberg Retail Service Station Size Distributions

Uncontrolled Service Station Operations Controlled Service Station Operations (StageI and Stage 11) Region Boundaries

Vapor Balance System Hasstech Assist System Hirt Assist System HealyAssist System Amoco Bellowless Nozzle System Example Balance Nozzles ExampleAssist Nozzle Example Bellowless Nozzle High Hang Hose Configurations Example Liquid Removal Device Example Emergency Breakaway IndividualVapor Balance System Underground Piping Manifolded Balance System Underground Piping Relationship of Inspection Frequency to Program In-Use Efficiency Relationship of Inspection Frequency to Program In-Use Efficiency with Exemptions

Comparison of Installed Capital Costs Lines Based on Data Point Averages Comparison of Installed Capital Costs Lines Based on Linear Regression Comparison ofAnnual Costs Lines Based on Data Point Averages Comparison of Normalized Annual Costs Lines Based on Linear RegressionLIST OF TABLES

OZONE NONATTAINMENT

### AREAS CLASSIFIED MODERATE OR 

### ABOVE
MONTHLY STATE GASOLINE CONSUHPTION FOR 1990 GASOLINE THROUGHPUT PERCENTAGESOF NATIONAL TOTALFOR OZONE NONATTAINMENT 

### AREAS CLASSIFIED MODERATE OR ABOVE ESTIMATED GASOLINE CONSUMPTION BY STATE FOR MODERATE AND ABOVE OZONE NONATTAINMENTAREAS ESTIMATED 1990RETAIL SERVICE STATION POPULATION ESTIMATED PRIVATE SERVICE STATION POPULATION NATIONWIDE RETAIL SERVICE STATION DISTRIBUTION ESTIMATED BY EPA 1990 MPSI MARKET SHARE BREAKDOWN IASANGELES RETAIL SERVICE STATION DISTRIBUTION REPORTED BY SIERRA RESEARCH RETAIL SERVICE STATION DISTRIBUTION BASED ON MTNDBERG DATA FROM 16METROPOLITAN AREAS CONSUMPTION DISTRIBUTION FOR NATIONWIDE AND METROPOLITAN

### AREA SCENARIOS ESTIMATED PERCENTAGE OF RETAIL STATIONS THAT

### ARE INDEPENDENTSBY THROUGHPUT CLASSIFICATION SERVICE STATIONMODEL PLANTSAND NATIONWIDE POPULATIONS

EXAMPLE COMPOSITION OF GASOLINE VAPORS GASOLINEHAZARDOUSAIR POLLUTANT VAPOR PROFILE 1992AND BEYOND RVP LIMITS BY MONTH AND BY GEOGRAPHIC IBCATION MONTHLY AVERAGE DISPENSED LIQUID TEMPERATURE SEASONALVARIATION FOR TEMPERATURE DIFFERENCE BETWEEN DISPENSED FUEL AND VEHICLE FUEL TANK (AT)

## , 'FLIST OF TABLES (Concluded)

MONTHLY AND GEOGRAPHIC VARIATIONS IN REFUELING EMISSION FACTOR SUMMARY OF STAGEII/CONVENTIONAL REFUELING SPILLAGE DATA VOC EMISSIONS FROM REFWELING OPERATIONS FOR SERVICE STATIONMODEL PLANTS

SUMMARY OF CARB EXECUTIVE ORDERS CERTIFYING SYSTEMS TO BE AT LEAST 95 PERCENTEFFICIENT EFFICIENCY DECREASES ASSOCIATEDWITH STAGE I1 BALANCE SYSTEM DEFECTS PERCENT CONSUMPTION EXCWDEDWITH VARIOUS STAGE I1 EXEMPTION SCENARIOS

PURCHASE COSTS FOR VAPOR RECOVERY NOZZLES AND REPLACEMENT PARTS (May 1991 Dollars) TYPICALVAPOR RECOVERY HOSE COSTS (May 1991 Dollars) TYPICAL COSTS OF OTHER VAPOR RECOVERY COMPONENTS (May 1991 Dollars) PIPING COMPONENT DIFFERENCES BETWEEN INDIVIDUALAND MANIFOLDED BALAWCE SYSTEM TYPICALVAPOR PIPING COSTS FOR 65,000 GALLON PER MONTH SERVICE STATION ACTIONS TAKEN IN RESPONSE TO FINDING A 

### LEAK INAN UNDERGROUND TANK SYSTEM SUMMARY OF STAGE I1 SYSTEM CAPITAL COST ESTIMATES FROM ALL SOURCES SUMMARY OF NORMALIZED STAGE I1 SYSTEM ANNUAL COST ESTIMATES FROM ALL SOURCES SUMMARY OF COST ITEMS CHANGED INAPPENDIX B COST MODEL TO OBTAIN 1991 COSTS 1991 STAGE I1 BALANCE SYSTEM CAPITAL COST 1991 STAGE I1 BALANCE SYSTEM ANNUAL COST COST EFFECTIVENESS OF 1991 STAGE I1 BALANCE SYSTEMS PROGRAM COST EFFECTIVENESS COMPARED TO EXEMPTION LEVEL

SUMWUXY OF STAGE I1 PROGRAM EXEMPTION LEVELS AND COMPLIANCE SCHEDULES PHASE I1 INSPECTION PROCEDURES MASSACHUSETTS STAGE 11VIOLATIONS



### vii1.0 INTRODUCTION

The Clean Air Act Amendments (CAM)of 1990 require the installation of Stage I1 vapor recovery systems inmany ozone nonattainment areas and direct EPA to issue guidance

as appropriate on the effectivenessof Stage I1 systems. This document provides guidance on the effectiveness of Stage I1 systems and other Stage I1 technical information. Stage I1vapor recovery on vehicle refueling is an effective control technology to reduce gasoline vapor emissions that contain volatile organic compounds (VOC)and hazardous air pollutants. Vehicle refueling emissions consist of the gasoline vapors displaced from the automobile tank by dispensed liquid gasoline. The Stage I1 system collects these vapors at the vehicle fillpipe and returns them to the underground storage tank. Without vapor recovery, thedispensing of gasoline causes the introduction of fresh air into the storage tank. Liquid gasoline then evaporates until liquid/vapor equilibrium is attained. Stage I1 systems return saturated vapors tothe storage tank thuspreventing this evaporationand actually saving gasoline. The purpose of thisdocument is toprovide information and guidance to State and local agencies related to the planning, permitting, and implementation of Stage I1 vapor recovery programs. While the subject of enforcement is introduced in thisdocument, more detailed information and guidance for enforcement programs are provided under separate cover in the EPAtsnnEnforcement Guidance for Stage I1 Programsnt tobe issued concurrently with thisdocument.The information and guidance provided in this technical document is not intended toestablish a binding norm or a final determination of issues or policies. Decisions on issues and policies will be made during the development, submittal, and review process on each individual State ImplementationPlan.

1.1 BACKGROUND Stage 11vapor recoveryhas been a part of VOC emission control in California for some time. Since the introduction of Stage I1 in California in the early 1970s, thisprogram has become one of California's major VOC control strategies. Seventeen districts in California contain areas which are classified nonattainment for ozone and have Stage 11 programs that have been in effect for over a decade. It is estimated that in California, Stage 11vapor recovery systems reducehydrocarbon emissions by 48,000-56,000 tons annually, and save 15-18 million gallons of gasoline.ln2 The remaining districts in California have also recently adopted hazardous air pollutant regulations requiring Stage 11vapor recovery for control of benzene emissions. Other areas of the country have also established Stage 11vapor recovery programs. The District of Columbia implemented a Stage 11program in the early 1980s and Missouri adoptedvehicle refueling regulations in the St. Louis area in the late 1980s. In the late 1980s and early 19908, several other States and local agencies adopted Stage 11programs. These agencies currently include New Jersey, New York (New York city metropolitan area), Massachusetts, Philadelphia, Washington, Oregon, and Dade County, Florida. These programs range from ones that are well into the implementation and enforcementperiod to those in the initial stages. A number of additional areas are also considering Stage I1 regulations.1.2 CLEAN AIR ACT REQUIREMENTS The requirements in the CAAA of 1990 regarding Stage I1 vapor recovery are contained in Title I: Provisions for Attainment and Maintenance of National Ambient Air Quality Standards. A key element of this title is that it wclassifieswareas with similar pollution levels. The purpose of this classification system is tomatch pollution control requirements with the severity of an area's air quality problem. For ozone, there are five classes:

. marginal, moderate, serious, severe, and extreme. Marginal areas are subject to the least stringent requirements and each subsequent classification is subject tomore stringent requirements. Areas in the higher classes must meet requirements of all the areas in lower classifications plus the additional requirements of their class. Subject to the provisions of Section 202, Stage I1 vapor recovery is required formoderate areas, and thus is required for all areas classified as serious, severe, or extreme. Section 182(b) of the CAAA of 1990 contains requirements formoderate areas and section 182(b)(3) specifically addresses gasoline vapor recovery. (3)GASOLINEVAPOR RECOVERY. (A)GENERAL RULE.-Not later than 2 years after the date of the enactment of the Clean Air Act Amendments of 1990, the State shall submit a revision to the applicable implementationplan to require all owners or operators of gasoline dispensing systems to install and operate, by the date prescribed under subparagraph (B),a system for gasoline vapor recovery of emissions from the fueling of motor vehicles. The Administrator shall issue guidance as appropriate as to the effectiveness of such system. This subparagraph shall apply only to facilities which sell more than 10,000 gallons of gasoline per month (50,000 gallons per month in the case of an independent small business marketer of gasoline as defined in section 325). (B)EFFECTIVE DATE

# - The date required under subparagraph (A)shall be-ti) 6months after the ado~tion date; in the case of gasoline &spensing facilities forwhich construction commenced after the date of the enactment of the Clean Air Act Amendments of 1990; (ii) one year after the adoption date, in the case of gasoline dispensing facilitieswhich dispense at least 100,000 gallons of gasoline per month, based on averagemonthly sales for the 2-year period before the adoption date; or (iii) 2 years after the adoption date, in the case of all other gasoline dispensing facilities. Any gasoline dispensing facility described under both clause (i)and clause (ii) shall meet the requirements of clause (i). (C)REFERENCE TO TERMS

# - For purposes of this paragraph, any reference to the term

'adoption date' shall be considered a reference tothe date of adoptionby the State of requirements for the installation and operation of a system for gasoline vapor recovery of emissions from the fueling of motor vehicles. Using nonattainment designationsbased on 1987-1989 design values or a few areas based on 1988-90 design values, these requirementswould affect 56 metropolitan areas in the United States. A breakdown of these areas by classification is 32 moderate, 14 serious, 9 severe, and 1 extreme. The areas are shown in Table 1-1. In addition, Title 1, section 184, Control of Interstate Ozone Air Pollution, creates an ozone transport region comprised of the States of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, and Vermont, and the CMSA that includes the District of Columbia.TABLE 1-1. OZONE NONATTAINMENTAREAS CLASSIFIEDMODERATE OR ABOVE

Extreme Los Angeles-South Coast Air Basin, CA Severe Baltimore, MD Philadelphia-Wilm-Trent, Chicago-Gary-Lake County, IL-IN PA-NJ-DE-MD ousto on-~alveston-~razoria, TX San Diego, CA Milwaukee-Racine, WI Southeast Desert Modified New York-N New Jer-Long Is., AQMA, CA NY-NJ-CT Ventura Co, CA

Serious Atlanta, GA Portsmouth-Dover-Rochester, Baton Rouge, LA NH Beaumont-Port Arthur, TX Providence (All RI)

## ,RI Boston-Lawrence-Worcester SacramentoMetro, CA (E.MA)

## ,MA-NH San Joaquin Valley, CA El Paso, TX Sheboygan,WI Greater Connecticut Springfield (Western MA)

## ,MA Muskegon, MI Washington, DC-MD-VA Moderate Atlantic City, NJ Miami-Fort Lauderdale-W. Palm Charleston,WV Beach, FL Charlotte-Gastonia, NC Monterey Bay, CA Cincinnati-Hamilton, OH-KY Nashville, TN Cleveland-Akron-Lorain, OH Parkersburg,WV Dallas-Fort Worth, TX Phoenix, AZ Dayton-Springfield, OH Pittsburgh-Beaver Valley, PA Detroit-Ann Arbor, MI Portland, ME Grand Rapids, MI Raleigh-Durham, NC Greensboro-Winston Salem-High Reading, PA Point, NC Richmond-Petersburg, VA Huntington-Ashland, WV-KY Salt Lake City, UT Kewaunee Co, WI San Francisco-Bay Area, CA Knox & Lincoln Cos, 

### ME Santa Barbara-Santa Lewiston-Auburn, ME Maria-Lompoc, CA Louisville, KY-IN St Louis, MO-IL Manitowoc Co, WI Toledo, OH

Source: 56 Federal Reaister 56692, 40 CFR 81, Air Quality Designations; Final Rule. November 6, 1991.

1-5The requirements for this region also include provisions related to Stage 11, in section 184(b)(2). (2)Within 3 years after the date of the enactment of the Clean Air Act amendments of 1990, theAdministrator shall complete a study identifying controlmeasures capable of achieving emission reductions comparable to those achievable through vehicle refueling controls contained in section 182(b)(3), and such measures or such vehicle refueling controls shall be implemented in accordance with theprovisions of this section. Notwithstanding other deadlines in this section, the applicable implementation plan shall be revised to reflect such measures within 1 year of completion of the study.

In summary, all of the States in the transport region will be required to implement Stage 11 controls or controls determined by EPA toachieve comparable emission reductions. Another portion of theAmendmentswith potential impacts on the implementation of Stage I1 inmoderate areas is contained in Title 2: ProvisionsRelating toMobile Sources. Section 202, Control of Vehicle Refueling Emissions, deals with the control of vehicle refueling emissions using "onboard" systems. Onboard vapor control systems consist of activated carbon canisters installed on thevehicle to control refueling emissions. The carbon canister system adsorbs thevapors that are displaced from thevehicle fuel tankby the incoming liquid gasoline, and subsequently purges these vapors from the carbon to the engine when the engine is operating.



# ....The requirements of section 182(b)(3) (relatingto Stage I1 gasoline vapor recovery) for areas classified under section 181 asmoderate for ozone shall not apply after promulgation of such standards and the Administratormay, by rule, revise or waive the application of the requirements of such section 182(b)(3) for areas classified under section 181 as Serious, Severe, or Extreme for ozone, as appropriate, after such time as theAdministrator determines that onboard emissions control systems required under this paragraph are in widespread use throughout themotor vehicle fleet.This section has the effect of removing Stage I1 requirements for moderate areas once onboard controls are promulgated, and for thehigher classified areas by EPA rule, once onboard is in "widespread usem. The 1990 CAAA exempt, in section 182(b)(3), facilities with gasoline throughputs of 10,000 gallons per month or less and independent small business marketers (independents, as defined in section 325 of the Clean Air Act as amended in August 1977) with throughputs less than 50,000 gallons per month. Section 325 has now been redesignated as section 326 by PL 98-213 and reads as follows: Sec. 326. (a) The regulations under this Act applicable tovapor recovery from fueling of motor vehicles at retail outlets.of gasoline shall not apply to any outlet owned by an independent small business marketer of gasoline having monthly sales of less than 50,000 gallons. In the case of any outlet owned by an independent small business marketer, such regulations shall provide, with respect to independent small business marketers of gasoline, for a three-year phase-in period for the installation of such vapor recovery equipment at such outlets under which suchmarketers shall have- (1) 33 percent of such outlets in compliance at the end of the first year during which such regulations apply to such marketers. (2) 66 percent at the end of such second year, and (3)100 percent at the end of the third year. (b)Nothing in subsection (a)shall be construed toprohibit any State from adopting or enforcing, with respect to independent small businessmarketers of gasoline having monthly sales of less than 50,000 gallons, any vapor recovery requirements for mobile source fuels at retail outlets. Any vapor recovery requirementwhich is adopted by a State and submitted to theAdministrator as part of its implementation plan may be approved and enforced by theAdministrator as part of the applicable implementation plan for that State. (c)For purposes of this section, an independent small businessmarketer ofgasoline is a person engaged in the marketing of gasolinewho would be required to pay for procurement and installation of vapor recovery equipment under section 324 of thisAct or under regulations of the Administrator, unless such person- (1)(A) is

### a refiner, or (B) controls, is controlled by, or is under common controlwith, a refiner, (C) is otherwise directly or indirectly affiliated (asdetermined under the regulations of theAdministrator) with a refiner or with a person who controls, is controlled by, or is under a common control with a refiner (unlessthe sole affiliation referred toherein is by means of a supply contract or an agreement or contract to use as a trademark, trade name, servicemark, or other identifying symbol or name owned by such refiner or any such person), or (2) receives less than 50 percent of his annual income from refining ormarketing of gasoline. For the purpose of this section, the term "refinerwshall not include any refinerwhose total refinery capacity (includingthe refinery capacity of any person who controls, is controlled by, or is under common control with, such refiner) does not exceed 65,000 barrels per day. For purposes of this section, llcontrolw of a corporationmeans ownership of more than 50 percent of its stock. While this defines an independent marketer, it allows a State or local agency to select an exemption level less than 50,000 gallons per month. A single exemption level approach is currently takenby many regulatory agencies in their Stage I1 programs. There is anotherdirect reference to Stage 11 vapor recovery contained in the CAAA of 1977. This is section 324 regarding Cost of Emission Control for Vapor Recovery. Sec. 324. (a) The regulationsunder this Act applicable tovapor recovery with respect tomobile source fuels at retail outlets of such fuels shall provide that the cost of procurement and installation of such vapor recovery shall be borne by the owner of such outlet (asdetermined under such regulations). Except as provided insubsection (b), such regulations shall provide that no lease of a retail outlet by the owner thereofwhich is entered into or renewed after the date of enactment of the Clean Air Act Amendments of 1977may provide for a payment by the lessee of the cost of procurement and installation ofvapor recovery equipment. Such regulations shall also provide that the cost of procurement and installation ofvapor recovery equipment may be recovered by the owner of such outlet by means of price increases in the cost of any product sold by such owner, notwithstanding any provision of law. (b)The regulationsof theAdministrator referred to in subsection (a) shall permit a lease of a retail outlet toprovide for payment by the lessee of the cost of procurement and installation of vapor recovery equipment over a reasonableperiod (asdetermined in accordance with such regulations), if the owner of such outlet does not sell, trade in, or otherwise dispense any product at wholesale or retail at such outlet.
In summary, the Clean Air Act and its 1990 Amendments impose several direct requirementsregarding Stage I1 vapor recovery. The provisions in Title 1will require that Stage I1 controls be installed at all gasoline dispensing facilitieswith throughputs above specified levels in moderate, serious, severe, and extreme ozone nonattainment areas, and Title I1 contains provisions which may relieve the requirement for moderate and above areas if onboard vehicle controls are promulgated. There are also direct references that define independentmarketers and describe the party responsible for incurring the costs of vapor recovery.

1.3 ORGANIZATIONOF REPORT The chief objective of thisdocument is toprovide informationpertaining to Stage I1 vapor recovery and guidance to State and local agencies in the planning and implementation of Stage I1programs. Therefore, the reportis organized in a manner that first provides an introduction to Stage I1vapor recovery and then emphasizes implementation issues and potential problems. Chapter 2 profiles thegasoline marketing industry, with special consideration given to gasoline dispensing facilities. Nationwide populations and size distributions of these facilities are discussed aswell as size distributions representative of metropolitan areas. In addition, model facilities are provided. Chapter 3 discusses the sources of emissions at vehicle refueling facilities, including the calculation of refueling emission factors. This chapter also provides a discussion of factorswhich influence refueling emissions. Emissions

are calculated for themodel facilities described in Chapter 2. Finally, emission factorsare calculated on a State basis taking into consideration RVP and temperature differences across the nation. Chapter 4 discusses vehicle refueling control technology, both from a current and an historical basis. In addition, a description of the California Air Resources Board's (CARB)vapor recovery equipment certification program is given which includes details of the certification process and the certified equipment. Finally, the effectiveness of the equipment is discussed, along with program in-use efficiency

# . Chapter 5 addresses the costs associated with Stage I1 control. Equipment, installation, and maintenance costs are discussed. Also, studies conducted in the St. Louis area which Lnclude actual costs of Stage I1 installations are presented. The final chapter is a guidance-oriented chapter which

uses the infornationpresented in the earlier chapters. The chapter discusses regulationsand approaches toplanning, permitting, and enforcement, and is based on areas of the country that have experiencewith Stage I1 vapor recovery programs. It also addresses problems experienced by theseagencies and suggested methods for others to use in avoiding similar difficulties.

1.4 REFERENCES 1. McKinney, Laura. California Air Resources Board. Gasoline Vapor Recovery Certification. (Presented at theAir and Waste Management Association 83rd Annual Meeting. Pittsburgh, PA. June 24-29, 1990).
2. Letter from Kunaniec, K., Bay Area Air Quality Management District, to Shedd, S., U.S. Environmental Protection Agency, Chemicals and Petroleum Branch. July 31, 1991. Comments on Preliminary technical guidance document.2.0 INDUSTRY DESCRIPTION

The purpose of this chapter is todefine the industry and facilitiesaffected by a Stage I1vapor recovery program. The entire gasoline marketing industry is first discussed, with special emphasisplaced on the facilities where gasoline is dispensed into vehicle fuel tanks (service stations). Population and characteristics of the service station industry are then addressed, including a discussion of model dispensing facilities which may be used to summarize the service station size distribution and facilitate the estimation of environmental and economic impacts.

2.1 INDUSTRY DESCRIPTION The gasoline marketing industry includesmany components thatmove gasoline, from the refinery tothebulk terminal and on to service stations. Gasoline produced by refineries is distributed by a complex system comprised of wholesale and retail outlets. Figure 2-1 depicts themain elements in themarketing network. The flow of gasoline through themarketing system is shown from the point of production,(therefinery), through bulk storage facilities

(bulkterminals), and finally to retail service stations or private facilities where it is dispensed into vehicle fuel tanks. Gasoline is often carried directly to thedispensing facility from thebulk terminal;however, some gasoline passes through intermediate storage and loading facilities called bulk plants. Thewholesale operations of storing and transporting gasoline, including delivery toand storage in

# t 

# @

7 

# t ServiceStation 

## BulkPlant

1



### Consumer

Figure 2-1. 

### GasolineMarketing In The 

### United Statesa service station underground tank, are commonly called Stage 

### I operations. Vehicle refueling operations are commonly termed Stage 11. Bulk gasoline terminals serve as themajor distribution point for the gasoline after it leaves the refinery. Gasoline ismost commonly delivered to terminals by pipeline, but may also be transferred by ship or barge. Gasoline is stored in large aboveground tanks and later pumped through metered loading areas, called loading racks, into delivery tank trucks. These tank trucks, in turn, deliver product tovarious wholesale and retail accounts in themarketing network. Bulk gasoline plants are secondary distribution facilities that typically receive gasoline from bulk terminals transportedby tank trucks, store it in aboveground storage tanks, and subsequently dispense it into smaller account trucks for delivery. Only a small portion of the total gasoline is routed through bulk plants and much of this eventually is delivered toprivate accounts and small service stations. Gasoline tank trucks are normally divided into compartments with a hatchway at the top of each compartment. Loading can be accomplished by top splash loading or submerged fill through the hatch, or by bottom loading. Either top or bottom loading can be adapted for vapor collection. However, almost all gasoline is transferred using bottom loadingbecause of State vapor recovery regulations and operating and safety advantages. The vapor collection equipment on the truck is basically composed of enclosed valves and piping that enable thevapors from the compartment being filled tobe transferred to the storage tank being emptied (vaporbalance) or to a vapor control system. Although the terms @@service stationt@, or @@dispensing facilityt@, may be used to describe various types of facilities, the term is used in this document tomean anysite where gasoline is dispensed tomotor vehicle fuel tanks from stationary storagevessels. This includesboth public (retail)and private facilities. Miscellaneous retail outlets that are considered service stations include conventional service stations, convenience stores, and mass merchandisers or wlpumpers.w Other facilities that may be considered in this classification aremarinas, parking garages, and other similar facilities which sell gasoline to thepublic. Private facilities include those locations where gasoline is dispensed into government agency (Federal, military, State, and local)vehicles, fleet (auto rental, utility companies, taxis, schoolbuses, etc.) vehicles, and trucking and local servicevehicles. Other private facilities include those that refuel farm equipment.

2.2 INDUSTRY POPULATION AND SIZE DISTRIBUTION The volume of gasoline consumed and the number of service stations in an area are important considerations in assessing refueling emissions aswell the potential emission reductions, the economic impact, and even the overall viability of a Stage I1vapor recovery program. Also, current and future trends are important in understanding the industry and possible impacts. For example, the present trend toward larger stations means that fewer stations and a greater portion of the throughputwould be subject to Stage I1 controls. Also, the emergence of single nozzle multi- product dispensers could greatly lessen the costs of Stage I1 equipment and maintenance. 2.2.1 Gasoline Consumwtioq It is estimated by the Federal Highway Administration that approximately 116 billion gallons of gasoline were consumed in theUnited States in 1990.' One can assume that essentially this entire volume was eventually loaded into vehicle fuel tanks, resulting in refueling VOC emissions. Therefore, nationwide emissions from this source could havebeen almost 700,000Mg of VOC/year, using a typical uncontrolled refueling emission factor of 1,450mg of VOC/liter of gasoline dispensed (discussedin Chapter 3). As one would expect, gasoline consumption is directly related topopulation. Therefore, States and areas with high population density tend to show the highest gasoline consumption figures. Monthly gasoline consumptionby State for 1990 is shown in Table 2-1. It is estimated that over 40percent of the gasoline in theUnited States is consumed in ozone nonattainment areas classified asmoderate and above. This is due tothe large population density and vehicle traffic centered around the metropolitan areas that traditionally have ozone attainment problems. The percentage of the nationwide throughput for each of the nonattainment areas shown in Table 1-1 represents is shown in Table 2-2. The estimated annual gasoline consumption for ozone nonattainment areas by State for 1990 is provided in Table 2-3. Ozone nonattainment area consumption was estimated using county-to-State consumption ratios calculated from EPA1s1985NEDS gasoline consumption2 and the nonattainment counties are the final area designations based on 1987-89 design values or 1988-90 design values for a few areas. These data show close to half of the national throughput could be affected by Stage I1programs and that the impacts in serious, severe, extreme, and possibly moderate areas could be considerable. Since the recommended method used to calculate refueling emissions is based on gasoline throughput, accurate consumption estimates are critical. Gasoline consumption data on a county basis are available from EPA8s National Air Data Branch. These data are calculated from State gasoline consumptiondata provided by the Bureau of the Census and apportioned to the county level using total sales data. This approach has come under scrutiny, as the relationship between gasoline consumption and total salesTABLE 2-2. GASOLINE THROUGHPUT PERCENTAGES OF NATIONAL TOTAL FOR OZONE NONATTAINMENT AREAS CLASSIFIEDMODERATE ORABOVE

Percentage Percentage of of NonattaimtAreas National NonattairrmtAreas National Throughput Throughput

LosAngeles-Swth Coast Air Basin, U

Baltimore, W) 0.99 PhiLadelphia-UiLm-Trent, PA-NJ-DE-W) Chicago-Gary-Lake Canty, IL-IN 2.52 Southeast Desert ModifiedAW, U Houston-Galveston-Brazoria, TX 1.64 San Diego, U Milwaukee-Racine, UI 0.52 Ventura Co, U Ncw York-N New Jer-Long Is, NY-NJ-CT 4.97

Seriws Atlanta, GA 1.I8 BatonRouge, LA 0.27 Portsmouth-Dover-Rochester, NH Beaunont-Port Arthur, TX 0.18 San JompinValley, U Boston-Lawrence-Uorcester (€.HA), 2.40 Providence (All RI), RI HA-NH SacrmtoMetro, CA EL Paso, TX 0.17 Sheboygan, UI Greater Connecticut 1.26 Springfield WesternHA), HA Muskegon, MI 0.05 Uashington, DC-W)-VA

Moderate Atlantic City, NJ 0.12 Hieuni-Fort Lauderdale-U. PalmBeach, Charleston, W 0.12 FL Charlotte-Gastonia, NC 0.25 Honterey Bay, CA Cincinnati-Hamilton, OH-KY 0.60 Nashville, TN Cleveland-Akron-Lorain, OH 1.10 Parkersburg, W Dallas-Fort Uorth, TX 1.63 Phoenix, AZ Dayton-Springfield, OH 0.35 Pittsburgh-BeaverValley, PA Detroit-AmArbor, HI 1.76 Portland, HE Grand Rapids, HI 0.25 Raleigh-Durham, NC Greensboro-UinstonSalcm-H Point, NC 0.30 .Reading, PA Hmtington-Ashland, W-KY 0.09 Richmond-Peterskrrg, VA Keuaunee co, UI 0.01 Salt LakeCity, UT Knox8 LincolnCos, HE 0.03 San Francisco-BayArea, U Leuiston-Alkrrn, HE 0.08 Santa Barbara-Santa Maria-Larpoc, U Louisville, KY-IN 0.34 St Louis, W-IL Hanitowoc Co, UI 0.03 Toledo, OH

Source: Nonattainwntdesig~tions fran56 56692 (See Table 1-1) Gasolineconsurptionpercentageststimtedusing 1985 WEDSfuel use report * Gasolineconsurptionnot reportedbecausetheconsurption for thisareaand the LA SwthCoast Air Basin consurption citedWe overlap, andsufficient infomtionisnot inthedatabase toallow proportion thisarea's consurption franthe LA consurption.STATE ALA0AMA ALASKA ARIZONA ARKANSAS CALIFORNIA C0L0RAOO CONNECTICUT DELAWARE DISTRICTOF COL. FLORIDA GEORGIA HAWAII IDAHO ILLINOIS INDIANA IOWA KANSAS KENTUCKY LOUISIANA MAINE MARYLAND MASSACHUSETTS MICHIGAN MINNESOTA MISSISSIPPI MISSOURI WNTANA NEBRASKA NEVADA NEW HAMPSHIRE NEWJERSEY NEWMEXICO NEW YORK NORTHCAROLINA NORTHDAKOTA OHIO OKLAHW OREGON PENNSYLVANIA RHODE ISLAND SOUTHCAROLINA SOUTH DAKOTA TENNESSEE TEXAS UTAH VERmNT VIRGINIA WASHINGTON WEST VIRGINIA WISCONSIN WYOnlNG NATIONWIDE

------=-1=1--1=1-11--I---I---I---I-I-II---=-~---=--.,---~-----=--------=---=-- SOURCES: (1) Federal HighwayAdministration, ClonthlyGasolineReports As Reportedin1991NPNFactbook (2) Preliminaryestimatebasedon 1987-89 designvalues or 1988-90design valuesfora few areashas not been well documented. EPA1sGlobal Emissions and Control Division, Air and Energy Engineering Research Laboratory, in Research Triangle Park, NC, is studying this issue in detail and plans todevelop correlations with other data such as population density, vehicle registration, number of licensed drivers, highway usage, and many other parameters, which will provide accurate estimates of gasoline consumption on the county level.3 EPA1smobile source emission factormodel, MOBILE4.1, estimates refueling emission factors that are dependent on either gasoline throughput or vehicle use, i.e. vehicle miles travelled (VMT). As discussed in more detail in Chapter 3, the emission factors are calculated in MOBILE4.1 using the same equation discussed in Section 3.4.1. However, MOBILE4.1 also uses fuel economy information to convert the emission factor frommass per gasoline throughput tomass per VMT. 2.2.2 Service Station Po~ulation While gasoline throughput, or consumption, is the parameter used to calculate emissions, an estimate of the number of facilities is necessary tohelp characterize the affected community inmore detail and toassess economic impacts, both on industry and on regulatory agencies. 2.2.2.1 Retail Stations. A precise determination of the number of retail service stations isvery difficult. The U.S. Census Bureau is the sourceusually relied upon for information of this type. The Census Bureau provides estimates of the number of retail service stations in the Census of Retail Trade, but these data have limited usefulness in defining the entire retail service station industry. These reports are produced every fiveyears and have shown a steady and dramatic decrease in the number of service stations. The reported service station population has gone from 226,459 in 1972 to 114,748 in themost recent 1987 report.4 However, thedefinition of service station used by the Census Bureau and the changing face of theindustry make it difficult, if not impossible, todraw conclusions from these estimates. The Census Bureau defines as retail service stations only those outlets that do 50 percent ormore of their dollar business in petroleum products. In 1972, this provided a reasonably representative count of the retail gasoline distribution facilities,as traditional service stations accounted for themajority of retail outlets. Today however, many facilities, such as convenience stores, have large gasoline throughputs yet their sales from gasoline may not total 50 percent of their sales due tothe wide variety of products offered. An added problem with these census data is that they consider only those stations that have payrolls. This automatically excludes theprivately owned and operated family, or "Mom and Popw,facilities. Another source of information traditionally used to estimate retail service station population in the interim period between Census Retail Trade Reports is "Franchising in the Economyw,a report formerly generated by theU.S. Department of Commerce. This survey was discontinued in January 1989, but was resumed by the International Franchising Association, a private enterprise. These reports also suffer from shortcomings as the definition of service station is identical to that used by theCensus Bureau. The estimates by Franchising in the Economy place the number of service stations in 1990 at 111,700.5 Franchising in the Economy does provide figures on convenience storepopulation. The 1988-1990 report accounts for 17,000 stores. However, "National Petroleum Newsw (NPN) refutes this number by estimating that there are asmany as 80,000 convenience stores in bu~iness.~ After determining the need for a more accurate, current estimate of retail gasoline dispensing facilities, NPN began a vigorous nationwide survey. The results of this effort

were contained in theApril 1991 issue of NPN.7 NPNembarked on this study by collecting the information on a Statebasis, and allowing each State tobe responsible for its own statistics. Official figures for retail gasoline station counts were not available for many States. The study involved searching throughmotor vehicle department, licensing department, and tax division records in more than half of the States. NPN also contacted weights and measures departments and key local trade associations. NPN estimated that approximately 67percent of thedata obtained were "hardw numbers; i.e., based on registration, licensing, and tax division compilations. The remaining third were obtained from unofficial estimates and, in a few cases, best guess type estimates. The results of thisNPN study are provided in Table 2-4. As shown, the total retail service station population in thenation is estimated tobe 210,120. The NPN article also discusses various methodologies which may be useful in thedetermination of gasoline station population on a State, regional, or localbasis. EPA has conducted several studies of thegasoline marketing industry in connection with thedevelopment and implementation of emission regulations. These studies required estimates of thenumber of service stations. For themost part, EPA has also relied on Census Bureau data as thebasis for its estimates. However, theAgency has long recognized the shortcomings of these data and has attempted to locate other sources of accurate information. EPA has utilized service station retail population estimates of approximately 211,000 in 1982,' and 190,000 in 1984.~ In 1991, EPA is studying thehazardous air pollutant (HAP) emissions from gasolinemarketing sources in accordance with Title I11 of the 1990 Clean Air Act Amendments, including those from tank truck unloading at service stations. During the search for information related tonationwide service stationpopulation, EPA received estimates of the current number of retail gasoline outletsTABLE 2-4. ESTIMATED 1990 RETAIL SERVICE STATION POPULATION

State Alabama Alaska Arizona Arkansas California Colorado Connecticut Delaware Dist. of Columbia Florida Georgia Hawaii Idaho Illinois Indiana
Iowa Kansas Kentucky Louisi'ana Maine Maryland Massachusetts Michigan Minnesota Mississippi Missouri Number of Stations State Montana Nebraska Nevada New Hampshire New Jersey New Mexico New York North Carolina North Dakota Ohio Oklahoma Oregon Pennsylvania Rhode Island. South Carolina South Dakota Tennessee Texas Utah Vermont Virginia Washington West Virginia Wisconsin Wyoming NATIONWIDE TOTAL Number of Stations

210,120

Source: National Petroleum News, ggCounting Procedure Shows How Retail Outlet Population is Greater Than Expected," April 1991.from a number of sources. Independent estimates by both the American Petroleum Institute (API)" and Lundberg Survey, 1nc.l' placed thenumber of retail outlets at approximately 175,000. The NPN estimatesdiscussed earlier were considered. However, EPA concluded thatNPN articlemay slightly overstate the retail population. Support for these conclusions lies in the fact that Lundberg Survey recently conducted a detailed survey of service stations in Arizona that placed thepopulation at 2,000, while theNPN article estimated there are twice that number in the state.'' Also, there are other questions raised by some of theNPN data,

one ofwhich is seen when comparing State service station population and gasoline throughput. For example, theNPN numbers show that North Carolina has over two times asmany retail service stations as New York, while thegasoline throughput is approximately 50percent of New York's. In lieu of any more precise or better supported number, the 175,000 figure is being used for the 1990 nationwide population of retail service stations in HAP analysis. This is a significant increase in the total number from the estimated 111,000 for 1989 in the Franchising in the Economy data. This increase is primarily due to the inclusion of "otherm gasoline dispensing facilitiesnot included in the Census Bureau definition of service station. While thenationwide estimate could be a point of contention, there are essentially no affects of the nationwide population for Stage I1purposes. Since the Stage I1 requirements contained in the 1990 CAMare related to ozone nonattainment areas only, the important service station population figures are those for these nonattainment

areas. These nationwide estimates are included here to provide Statesand local agencies with various information related toretail service stationpopulation. These agencies have the alternative touse any of this information in estimating thepopulation for their area.2.2.2.2 private Stations. All of the estimates discussed above are only for public, or retail facilities. In addition to "publicwoutlets, there are a significant number of "privatew facilities. These outlets are maintained by governmental, commercial, and industrial consumers for their own fleet operations. Government agencies with central garages are typically regional locations for the postal service, Federal government agencies, and State and county agencies. Other miscellaneous facilities include utility companies, taxi fleets, rental car fleets, school buses, and corporate fleets. Estimated national population figures for private facilities are shown in Table 2-513 The agricultural sector of private outlets, including farms, nurseries, and landscaping firms, are not included. In general, agricultural outletshave throughputs less than the cutoff levels. These private facilities are an important segment of the industry and should be considered in population estimates. The numbers shown in Table 2-5 were estimated in 1978. However, no more recent nationwide estimates have been identified since this time. 2.2.2.3 Inde~endents. One issue not addressed in any of these estimates is the number of independent service stations. As the Clean Air Act contains a different exemption level for independents, it would be beneficial to describe this segment of the industry. However, as discussed in Chapter 1, the definition of "independentw provided in the CleanAir Act is difficult to apply on a quantitative basis. Also, the complex nature of service station ownership and suppliers increases the difficulty of a tally of independents. Estimates of relative percentages of independent stations are discussed in the following section. 2.2.3 Service Station Size Distribution Not only is the number of facilities important to a Stage I1 vapor recovery program, but estimates of the- - TABLE 2-5. ESTIMATED PRIVATE SERVICE STATION POPULATION'

"Privatew Outlets Government (Federal, military, state, local) Miscellaneous (auto rental, utilities, others) Trucking and Local Service Taxis School Buses Total

a Not including about 2.5 million agricultural outlets. Source: "The Economic Impact of VaDor Recovery Reaulations on the Service Station Industrv," EPA-450/3-78-029, July 1978.relative sizes of facilitieswithin the population are needed for the cost analysesdiscussed later. The parametersmost useful to rank service stations are gasoline throughput and the number of nozzles. This apportionment is important formany reasons, but twoprincipal ones are: (1) to estimate the facilities which will be exempted, and (2) to estimate the economic impacts of a regulation. 2.2.3.1 Retail Stations. The size distribution of retail service stations according to gasoline throughput used in the 1987 EPA Stage I study is given in Table 2-6.14 This size distribution,based on throughput,was used to develop a national profile. The population is skewed toward smaller stations, with over 75 percent having throughputs less than 25,000 gallons per month. Concerns have been raised regarding the applicability of these estimates to larger metropolitan areas that are typically nonattainment for ozone. In a 1988 report, "An Analysis of Stage I1 and Onboard Refueling Emissions Controltt (SierraReport),'' prepared by Sierra Research for theMotor Vehicle ManufacturersAssociation, the characteristics of themetropolitan service station population are addressed. In this report, it is stated that "EPA has

# ... failed to recognize that the average size of gasoline stations in metropolitan nonattainment areas is larger than the national average." The Sierra Report contained a profile from Los Angeles and compared it to the EPA estimates, todemonstrate the difference in retail service station distribution for large metropolitan areas. The use of Los Angeles data to characterize all metropolitan areas in the United States is questionable;however, Sierra did provide information compiled by MPSI Americas, Inc. that suggests the Los Angeles data are only slightly higher than other areas. MPSI, Inc. of Tulsa, Oklahoma annually provides statistics that are reported in the NPN Factbook. Among the statistics are estimates of average facility gasoline consumption on aTABLE 2-6. NATIONWIDE RETAIL SERVICE STATION DISTRIBUTION ESTIMATED BY EPA
Gasoline Throughput Range Percentage of Retail (gallons/month) Service Stations

Source: "Draft RIA: Proposed Refueling Emission Regulations for Baseline Motor Vehicles

# - Volume I Analysis of Gasoline Marketing Regulatory Strategies," EPA-450/3-87-001a.category basis. The categories are service stations, pumpers, convenience food stores, and others. Overall totals are also given. The MPSI summaries for 1990 as contained in the 1991NPN Factbook16are shown in Table 2-7. In order tovalidate the application of the Los Angeles data to other areas of the country, Sierra used 1987MPSI informationas reported in the 1988 NPN Factbook. Sierra compared the average facility throughput for LosAngeles to that reported by MPSI for 1987. The retail service station size distribution from the Sierra Report for Los Angeles is shown in Table 2-8, and the relationship of the Los Angeles data to the 1987MPSI data is illustrated in Figure 2-2. The 1989 MPSI average service station size is also shown for comparison in Figure 2-2. EPA has obtained service station throughput data for severalmetropolitan areas toverify the application of the Los Angeles information presented in the Sierra Report to metropolitan areas across theU.S. The data obtained were compiled by the Lundberg Survey 

### incorporatedi'and listed gasoline stations and their associated gasolinemonthly volumes in gallons. There were approximately 11,000 individual service stations in the database which represented 16 metropolitan statistical areas across the United States. The areas included were: Syracuse, NY Houston-Galveston-Brazoria, TX Phoenix,AZ St. Louis, MI-IL San Diego, CA Portland-Vancouver, OR-WA Detroit, MI Milwaukee-Racine, WI Lansing,MI New York-Newark-Long Island, NY-NJ-CT Grand Rapids, MI Providence-Pawtucket-Fall River, MA-RI El Paso, TX Madison, WI Orlando, FL Santa Barbara-Santa Maria-Lompoc, CA The service stationswere placed into seven categories according tomonthly gasoline throughput. This was done forTABLE 2-7. 1990MPSI MARKET SHARE BREAKDOWN

Service Convenience Stations Purpers Stores Others Tota 1 NortheasternRegion X of Outlets X of Volw Avg. MonthlyVolw (Gallons) MidwesternRegion X of Outlets X of Volw Avg. MonthlyVolw (Gallons) Svlbelt Region X of Outlets X of Volw Avg. MonthlyVolw (GalLons) Yestern Region X of Outlets X of Volw Avg. MonthlyVolw (Gallons) Total UnitedStates X of Outlets X of Volw Ava. MonthlyVolw 62.4% (~al lons)

Source: MPSI Inc., Tulsa, Oklahoma, reported inlWlNPN factbook.TABLE 2-8. LOS ANGELES RETAIL SERVICE STATION DISTRIBUTION REPORTED BY SIERRA RESEARCH

Gasoline Throughput Range Percentage of Service (gallons/month) Stations

Source: Sierra Research, "An Analysis of Stage I1 and Onboard Refueling Emissions Controlw,November 30, 1988.each county as well as an overall distribution for the entire database. The overall distribution from these data is shown in Table 2-9. As seen in the table, the distribution is skewed toward the larger stations, just as Sierra reported. More detailed breakdowns of the Lundberg data are provided inAppendix A. A side-by-side comparisonof the EPA nationwide distribution, the Sierra Los Angeles distribution, and the Lundberg information distribution isprovided in Figure 2-3. These data indicate that the nationwide EPA distribution, while accurate for nationwide analyses,may not be appropriate for largemetropolitan areas. A comparison was also made between the consumption distribution of the EPA nationwide facility distribution and themetropolitan area distribution. Table 2-10 summarizes this comparison. As would be expected from the facility distribution, the throughput distribution inmetropolitan areas is skewed toward the larger throughput stations. 2.2.3.2 Private Stations. Based on information from Arthur D. Little, Inc.18 and theU.S. Census Bureau,19 it was previously estimated that approximately 90percent of private outlets have throughputs of less than 10,000 gallons per month. In other analy~es,~~#~' EPA has used this figure and distributed the remaining 10 percent in proportions representative of thepublic service station distribution. 2.2.3.3 Jndewendents. Previous EPA analyses have also estimated the relative percentages of retail facilities that would be classified as "independentmarketersw under the Clean Air Act definition discussed in Chapter 1. Table 2-11 shows the relativepercentages of retail stations that

are considered tobe independentswith the associated throughput ranges. These percentageswere originally estimated during the 1984 Study based on information contained in EPA's report "The Economic Impact of Vapor Recovery Regulations on the Service Station This report categorized publicTABLE 2-9. RETAIL SERVICE STATION DISTRIBUTION BASED ON LUNDBERG DATA FROM 16 METROPOLITAN AREAS

Gasoline Throughput Range Percentage of Service (sallons/month) Stations

Source: Lundberg Survey, Incorporated.EPANationwide SierraLosAngeles LundbergMetropolitan 

# ....-..- ............... Figure 2-3. 

### Comparison of EPA Nationwide, Sierra Los 

### Angeles, and Lundberg Retail Service station Size DistributionsTABLE 2-10. CONSUMPTION DISTRIBUTION FOR NATIONWIDE AND METROPOLITAN AREA SCENARIOS

Percent Consum~tion Facility Throughput Range Nationwide Metropolitan (gallons/month) Distribution Distribution

TABLE 2-11. ESTIMATED PERCENTAGE OF RETAIL STATIONS THAT ARE INDEPENDENTSBY THROUGHPUT CLASSIFICATION

r 

# - Throughput Range Percentage of

(gallons/month) Independents 

## - 0

# - 9,999 18%public service stationsby 

### company-controlled/company operated, company- controlled/dealer operated, dealer controlled/dealer operated, and convenience stores and provided throughputdistributions for each by direct supplier and independent marketer/wholesaler. The distributions in the Economic Impact Study were adjusted to

remove all convenience stores from independent marketers (it is not expected that convenience stores obtain greater than 50 percent of sales from gasoline) and add all dealer- controlled/dealer operated stations to independent marketer/wholesaler. Based on the Census Bureau definition of service station (greaterthan 50 percent of sales from gasoline) and studies that estimate the total number of public outlets that sell gasoline, an approximate ratio of the Census population tot total population was estimated. This ratio was approximately 2/3. The importance of this ratio is that it indicates that approximately 1/3 of the stations do not obtain over 50 percent of their sales form gasoline. Therefore, the percentages obtained for independent marketers were reduced by one-third. 2.2.4 Trends in the Service Station Industry There are several trends in the service station industry which could have an effect on a Stage 11 program. Public acceptance of Stage I1 equipment is an important aspect of any Stage I1 program. This is especially true in light of the increase in the popularity of self-service type stations. NPN reports substantial increases in the percentage of self-service outlets across the country from under 20 percent in 1975 to over 80 percent in 1989.~~ 

### A similar trend is related tounattended gasoline stations. This concept seems tobe growing faster for commercial fleets than for retail facilities. It is anticipated that the number of convenience stores selling gasolinewill continue to increase, as well as the volume of gasoline sold by these stores.As discussed in the previous section, the size of service stations continues to rise. A steady increase in the average facility gasoline throughput has been seen in the last decade. The widespread popularity of dispensers that allow the pumping of two or three gasoline products, or ggmultiproduct dispenserswhave allowed a station tohave more nozzles per station. However, the onset of dispensers that have only one nozzle that can dispensemultiple gasoline products may cause a substantial decrease in the number of nozzles per station. Costs are discussed in Chapter 5, but one trend with cost implications should be mentioned in this section. The leaking underground storage tank (USTand LUST) programs, depending upon the age and condition of the tank, require replacement of tanks and/or piping. These programs could affect Stage I1 programs in two different ways. First, if the underground tanks and piping are replaced concurrently, then the cost attributable to Stage 11 could be lessened. Second, if these events do not occur simultaneously, then it is possible that service station ownersmay be required to initiate relatively major reconstructionmore than once. This issue is discussed inmore detail in Chapter 5.

2.3 MODEL PLANTS The development of typical, ormodel plants is a technique often employed to assist in the determinationof impacts of a regulation during the planning stages. It is preferable todevelop several model plants to represent the range of sizes of facilitiespresent in the industry. The distribution of facilities is applied to themodel plants to determine the relative percentage of facilitiesdepicted by each model plant. In previous analyse~,~~~~~ EPA has developed model plants for the service station industry. The parameters selected for the model plants are shown in Table 2-12.2.4 SUBMAFtY It 

### is important todevelop an accurate characterization of the industry thatwould be affected by a Stage I1vapor recovery regulation. This chapterhas provided information related togasoline consumption, service station population, size distribution, and model plants thatmay be useful to agencies involved in these planning activities.2.5 REFERENCES

Federal Highway Administration, Monthly Gasoline Reports 1990, as reported in 1991 National Petroleum News (NPN) FactbookAnnual Issue. June 1990.
1985 NEDS Fuel Use Report. U.S. Environmental ProtectionAgency National Air Data Branch. Research Triangle Park, NC. Memorandum fromNowood, P., Pacific Environmental Services, Inc., to Shedd, S., U.S. Environmental ProtectionAgency. April 11, 1991. Reporting on a meeting with Larry Jones, EPA, AEERL, regarding gasoline consumptionproject.
1987 Census of Retail Trade. U.S. Department of Commerce. Franchising in the Economy 1988-1990. International Franchising Association, Washington, D.C. "Updated Survey Shows Fairly Static Growth In Service Station Populationn,National Petroleum News (NPN)

# . April 1990. "Counting Procedure ShowsHow Retail Outlet Population IsGreater Than Expectedmm, National Petroleum News (NPN). ~pril 1991. Evaluation of Air Pollution Regulatory Strategies for GasolineMarketing Industry. U.S. Environ- mental Protection Agency, Office of Air Quality Planning and Standards and Office of Mobile Sources. PublicationNo. EPA-450/4-84-012a. July 1984.
Draft Regulatory ImpactAnalysis: Proposed Refueling Emission Regulations for Gasoline-Fueled Motor Vehicles

# -- Volume I

# - Analysis of Gasoline Marketing Regulatory Strategies. U.S. Environ- mental ProtectionAgency. Office of Air Quality Planning and Standards and Office of Mobile Sources. PublicationNo. EPA-450/3-87-001a. July 1987. Telecon. Thompson, S., Pacific Environmental Services, Inc., with Peterson, B., American Petroleum Institute. March 27, 1991. Number of Service Stations.Telecon. Bollman, A., Research Triangle Institute, with Keene, B., Lundberg Survey, Inc. April 19, 1991. Number of Public Service Stations.
Reference 11.
The Economic Impact of Vapor Recovery Regulations on the Service Station Industry. U.S. Occupational Safety and Health Administration, Washington, D.C., and U.S. EPA, Research Triangle Park, N.C. PublicationNo. EPA-450/3-78-029. July 1978.
Reference 9. Sierra Research, An Analysis of Stage I1 and Onboard Refueling Emissions Control, prepared for Motor Vehicle Manufacturers Association, Inc. November 30, 1988.

W.S. Regional and National Market Shares.", MPSI Inc., Tulsa Oklahoma, as reported in 1990National Petroleum News (NPN) FactbookAnnual Issue. June 1990. Lundberg Survey, Inc. Census Data Gasoline Throughput forU.S. EPA, June 28, 1989.
Reference 13.
1977 Census of Retail Trade. U.S. Department of Commerce. Reference 8. Reference 9.
Reference 13.
1990National Petroleum News (NPN) FactbookAnnual Issue. June 1990.
Reference 8.
Reference 9.3.0 SOURCES OF EMISSIONS

In this chapter, the emission sources at service stations are described along with factors that affect the rate at which emissions occur. In addition, emission estimates or emission factors are presented that represent emissions in different areas of the country. Emission rates for different model facilities are presented to show how total emissionsvary by facility size and to characterize rates for facilities throughout the country.

3.1 GENERAL Invirtually all cases in the gasoline marketing chain, emissions of gasoline vapors are caused by the transfer of liquid gasoline from one container (or tank) to another. The liquid entering the fixed volume container displaces an equal volume of gasolinevapor/air mixture to the atmosphere. If thevolume of vapor displaced from the container equals thevolume of liquid loaded into the container, the ratio of vapor to liquid volume (V/L ratio) is equal to 1. However, thevolume of vapors displaced often does not equal thevolume of liquid transferred. Temperature variations between the liquid loaded and thevapors in the tank can cause an expansion or contraction of thevapors causing theV/L ratio tovary from 1. When warm liquid enters a cool tank, the temperature in the tank increases thereby increasing thevolume of vapors in the tank and increasing thevolume of vapors displaced. This causes the volume of displaced vapors tobe greater than thevolume ofliquid loaded, resulting in a V/L ratio greater than 1. This is called vapor growth. The opposite occurs when the liquid entering the fixed volume tank is cooler than the tank temperature. The cooler temperature reducesthevapor volume displaced and theV/L ratio is less than 1. This is called vapor shrinkage. Vapor growth or vapor shrinkage canbe a common occur- rence when transferring liquids from service station underground tanks containing liquid of relatively stable temperature, insulated by the surrounding earth, into a vehicle fuel tankat extreme temperaturescaused by over- road exposure to ambient conditions (fuel tanksvery warm in summer,very cold inwinter). Becausevapor growth and vapor shrinkageoccur so often, errors in emission estimates

can easily be encounteredby simply assuming thevolume of vapors displaced equals thevolume of liquid entering the tank. Testing of these emission sources requires accurate measurements of displacedvolumes to calculate themass of emissions released. Because the amount of emissions that occur is tied so closely to the amount of liquid transferred into the tank or container, emission factors are often expressed in terms of mass emitted per volume of liquid loaded (i.e., pounds of VOC per 1,000 gallons of liquid loaded ormilligrams of VOC per liter of liquid loaded). Increased emphasis is being placed on the evaluation of the emissions ofhazardous air pollutants (HAPs). The CAAA of 1990 specify 189 compounds that have been classified as HAPs. Several of these HAPs are typically found in gasoline vapors. Gasoline vapors are made up of a complex mixture of compoundsoriginating from the evaporation of liquid gasoline.' Table 3-1 showsan example mixture of compounds found in displaced gasolinevapors. Several of these compounds correspond with compounds found on the list of 189TABLE 3-1. EXAMPLE COMPOSITION OF GASOLINE VAPORS

Compound Weight Percent N-Propane Isobutane N-Butane Isopentane N-Pentane 2-2-Dimethyl Butane 2-3-Dimethyl Butane 2-Methyl Pentane 3-Methyl Pentane N-Hexane 3-3-Dimethyl Pentane 3-Methyl Hexane Methyl Cyclopentane

Benzene Toluene Othera

Other hydrocarbonswith individual weight percent less than 0.5. Source: Furey, Robert and Nagel, Bernard. Composition of Vapor Emitted From a Vehicle Gasoline Tank During Refueling. SAE Technical Paper Series #860086, February 1986.HAPS listed in Title I11 of the CAAA. Table 3-2 summarizes theHAP compounds found in normal gasoline vapors and indicates thepercent of total emissions, on a weight basis, that each HAP 

### represent^.^ These HAP emission rates were calculated using liquid gasoline composition, RaoultlsLaw, and gasoline vapor analyses. These valuesmay not compare exactly between Tables 3-1 and 3-2, since Table 3-1 is based

on one experimental sample group and thenormal fuel profile in Table 3-2 is based on a wide variety of samples. The reformulatedand oxygenated fuel requirements contained in Title I1 of the CAAA will affect the HAP content of gasoline. Also contained in Table 3.2 is an estimate of a vapor profile for a reformulated gasoline. Taken into account in thisprofile are the required reductions in benzene and total aromatic content, the addition of methyl tert butyl ether (MTBE)as an oxygenate, and the reduction of all other componentsdue to the addition of a large volume of MTBE. HAP emissions from all Stage I gasoline marketing sources (pipelines, terminals, bulk plants, storage tanks, tank trucks, service station underground tank loading) are being evaluated for regulation under theNational Emission Standards for Hazardous Air Pollutant (NESHAP)program. An interestingpoint is with regard to MTBE. MTBE is a gasoline additive traditionallyused in small amounts as an octane booster. However, with oxygenated fuel requirements contained in Title I1 of the 1990 Clean Air Amendments, the addition of MTBE in gasolinewill be widespread. Approximately 15weight percent MTBE in liquid gasoline is needed tomeet the 2.7 weight percent oxygen requirement for carbon monoxide nonattainment areas, and 11weight percent tomeet the 2.0 weight percent oxygen requirements for the largest ozone nonattainment areas. Thismeans that for gasolines containingMTBE, 15 percent ormore of gasoline vapor could be made up of components listed by EPA as hazardous pollutants.TABLE 3-2. GASOLINE HAZARDOUSAIR POLLUTANTVAPOR PROFILE

HAP Content HAP/VOC wtpercentage ratio HazardousAir Pollutant Arithmetic Estimated Average Normal Reformulated Fuel Fuel
Hexane Benzene Toluene 2,2,4 Trimethylpentane (iso-octane) Xylenes Ethylbenzene Naphthalene Cumene MTBE TOTAL HAPSa

a Columns do not add to totals. Total HAPS as well as individualHAPS were calculated for each data point in the normal fuel analysis, and thus the totals are not simply sums of the individual components. Adjustments were made to this normal fuel based on the reformulated gasoline requirements to predict a reformulated profile.

Source: Preliminary Estimates from EPA Stage I NESHAP project on gasolinemarketing.3.2 EMISSION SOURCES Emission sources described in this section are divided into service station Stage I emissions (gasoline transfers into the stationunderground storage tanks) and service station Stage I1emissions (automobilerefueling emissions). 3.2.1 Service Station Stacfe

### I Emissions Gasoline vapor orvolatile organic compound (VOC) emissions occur when gasolinebeing delivered to the service station displaces vapors to the atmosphere (as described earlier). Under a typical gasoline delivery, a hose is connected from the delivery truck to a ground level fitting that is attached tothe underground gasoline storage tank (see Figure 3-1). The gasoline is allowed todrop from the delivery truck into the underground tank. This activity is often called "the service stationdropwor "dropping a load of productw. Displaced vapors are emitted to the atmosphere through the underground tankvent. Submerged loading, consisting of a tube installed towithin 6 inches of the bottom of the tank, significantly reduces emissions because turbulence caused by the splashing of thedelivery product in the underground tank isminimized. When Stage I emission controls are used, displaced vapors are collected and routed back into the delivery truck using a combination of pipes and hoses (see Figure 3-2). Stage I emissions from service stations and the resulting technology are not the subject of this report but have been included in the discussion for completeness. These emissions have been the subject of several EPA programs and further information can be obtained in other EPA publications.3*685s6*7 While tank truck unloading (StageI) and vehicle refueling (Stage 11) are separate events, defective Stage t equipment (leaking seals, missing caps, etc.) can adversely affect the efficiency of a Stage I1 system.LoadingofService Station UndergroundStorage

### Tank 

# (A) WithNoControls.



# (B) SemceStationVehicle RefuelingWithNoControls



### Figure 3-1. 

### Uncontrolled Service Station OperationsLoadingofService StationUndergroundStorage

### Tank WitbVaporBalanaSystem(Stage

### IControls). 

# (A)

CoaxialVaporfiquidHose

ServiceStation VehicleRefuelingWitbVaporBalance 

# (B) System(StageIIantrob).

Figure 3-2. Controlled Service Station operations (Stage

### I and Stage 11)3.2.2. Vehicle Refuelina Emissions 3.2.2.1 Vehicle Refuelinq. Gasoline vapor/VOC emissions occur when liquid from theunderground tank is dispensed into thevehicle fuel tank. Vapors contained in the fuel tank are displaced back through thevehicle fillneck and are emitted to the atmosphere (see Figure 3-1). With the installation of Stage I1vapor recovery equipment, displaced vapors are captured at the vehicle fillneck and routed back to the underground tank. Figure 3-2 illustrates the basic Stage I1 vapor recovery concept. Detailed descriptions of the Stage I1 vapor recovery equipment and discussions of emission reductions can be found in Chapter 4. Factors influencing emissions and estimates of emissions

are presented later in this chapter. 3.2.2.2. S~illaae.VOC emissions from thevehicle refueling operation can also occur when loading thevehicle at a rate faster than the displaced vapors can be released. When this occurs liquid is forced up the fillneck and can
cause "spitbacklIof liquid back out of the vehicle fillneck. Overfilling of thevehicle can also cause liquid spillage. Overfills can occur due to a failure in the nozzle shutoff mechanism or can occur due to operator error (repeated "topping offgg of thevehicle tank). Small amounts of liquid drips can also be spilled due towetted nozzle tips upon removal from thevehicle and vapor condensation on cool nozzle surfaces. 3.2.2.3. Breathina/Em~tvinaLosses. Emptying losses occur when gasoline is pumped out of the service station underground tank to refuel a customerlsautomobile fuel tank. Air is drawn into theunderground tank, through the underground tank vent pipe, to replace thevolume of liquid removed. Prior to any gasolinebeing removed from the tank, the liquid and vapors in the underground tank are at equilibrium and thevapor space above the liquid is essentially saturated. When liquid is pumped from the tank and air is drawn in through thevent, thevapor space abovethe liquid is no longer in equilibriumwith the liquid. A small amount of liquid evaporation takesplace in an attempt to again saturate thevapor space above the liquid. This evaporation causes an increase in volume in thevapor space and this excess volume is pushed out the underground tank Vent pipe. The portion of vapors pushed out thevent is called the emptying loss. Stage I1vapor recovery equipment helps to controls this emptying loss by returning essentially saturated vapors from thevehicle fuel tank back to the service station underground tank to replace the liquid removed. Because the return vapors are saturated and equal in volume to the liquid removed, equilibrium in the tank ismaintained, product evaporation does not take place, and emptying loss emissions do not occur. Breathing loses in fixed volume storage tanks are caused by vapor and liquid expansion and contraction due to diurnal temperature changes. As temperatures increase, vapor volume increases pushing vapor out of thevent pipe

(out-breathing). When temperaturesdecrease, vapor volume decreases and air is drawn into the tank (in-breathing). Breathing loss emissions areminimal at service stations since storage tanks are located underground, insulated by the earth, and have a very stable temperature profile. However, breathing losses from service station storage tanks

are becoming more prevalent due to the popularity of above ground storage tanks and the installation of vaulted underground storage tanks. Above ground storage tanks are more susceptible to temperature and pressure changes and thus are more likely to experienceboth vapor growth and vapor shrinkage. It is also reported that the double wall,

or Waultedt1 underground storage tanks that are being installed to comply with underground storage tank (UST) regulations are more susceptibleto thermal effect and theref ore breathing losses3.3 FACTORS INFLUENCING EMISSIONS Many studies have been done to evaluate the factors that affect refueling emissions. A recent study by EPA1s Office of Mobile Sources (OMS)empiricallyderived an equation that predicts the emissions from an automobile refueling event.'' This testing consisted of controlled vehicle refueling inside a shedwith sensors togather fuel tank temperature, liquid dispensed temperature, and displaced vapor. Emissions testing was conducted on a variety of light-duty vehicles, with varying fillneck configurations,and on light-duty trucks. The following sections describe thedifferent factors that influence this emission factor equation. 3.3.1 Reid Va~or Pressure (RVP) Certainly one of themost important factors affecting the emissions from automobile refueling is thevolatility of the gasoline. A lessvolatile gasolinewill create less emissions when transferred than a more volatile gasoline. Reid vapor pressure (RVP)is a common measure of fuel volatility and represents thevapor pressure of the fuel at 100°F. RVP is a standard industrymeasure of fuel volatility. Although RVP is a measure of fuel volatility at 100°F,the empirical emissions equation described below (3.4.1) adjusts thisvolatility to reflect actual temperature conditions. The RVP of gasoline is adjusted through blending at the refinery to account for temperature and pressure different- iations across the country. In the summer when warm temperatures enhancevolatilization, gasolines can be blended with a lowerRVP and still provide ample vaporiza- tion for combustion in thevehicle engine. Reducing RVP in the summer, therefore, reduces emissions from gasoline transferswithout reducingvehicle performance. Too high an RVP in the summer can create excess volatilization in the engine causing vapor lock. During thewinter months when cold temperatures inhibitvolatilization, gasolines can beblended with a higher RVP toensure sufficient volatiliza- tion for engine start-up and operations. This increase in RVP when temperatures decrease and decrease in RVP when temperatures increase is an attempt toprovide a uniform fuel volatility for smooth engine performance all year. Information onwinter/summer actual RVP samples are taken throughout theyear in selected areas. This information is compiled and published by theNational Institute for Petroleumand Energy Research (NIPER) organization. This data is based on fuel surveys and fuel analyses conducted throughout the country.11 Fuel RVPs can be blended to adjust for certain altitude and temperature variations in specific geographical areas. On June 11, 1990, EPA promulgated limits for RVP in the summer for all States." These limitswill reduce fuel RVP to 9.0 or below in most States in the summermonths. However, the RVP requirementsproposed in theMay 29, 1991, Federal ~eaister'~ indicate that RVPs less than 9.0 will only be required during the summer months in ozone nonattainment areas. The remaining areas in States with lower RVP limitsneed only meet 9.0. Table 3-3 summarizes the RVP restrictionsby month for each State for the entire year.14815The weighted averagespresented are weighted by themonthly fuel consumptionpresented in Table 2-1. In addition, the summerweighted average RVP is calculated using thevalues in the table (i.e. values less than 9.0 RVP) and is therefore representative of nonattainment areas for those States. Attainment area RVP would be higher since summer RVP is not regulated below 9.0. For those States where an RVP restriction less than 9.0 appears in the summer months, thismore stringent restriction applies only tononattainment areas within the State. RVP in non summer months is typicallyblended toconform to limits suggested by ASTM and is not usually regulated by EPA. 3.3.2 Liauid Tem~erature Along with fuel volatility, the temperature of the fuel being dispensed and the temperature of thevehicle fuel tank affect the rate inwhich emissions occur. Thewarmer the temperature of thedispensed liquid or thevehicle fuel tank themore volatile the liquid becomes and themore emissions

occur. Also, the temperature difference between the dispensed liquid and the liquid in the fuel tank can affect emissions. The loading of cool dispensed fuel into a warm tankwill decrease emissions (likevapor shrinkage) and the loading of warm fuel into a cold vehicle tank can increase emissions (like vapor growth). The more typical situation is where you have cool liquid being dispensed into a warm vehicle tank. The empirically derived emission factor equation accounts for these temperaturedifferences. As with RVP, these key temperature parameters will vary with time of year and with geographical location. Table 3-4 presents dispensed fuel temperaturepresented by month for several regions in the country (Figure 3-3 indicates the regional boundaries).16 As would be expected, dispensed fuel temperatures increase in the summer when RVPs decrease. Table 3-5 presents average annual fuel differentials between the dispensed fuel and the fuel in thevehicle tank. Data are presented by region for an annual average AT, plus values for summer and wintermonths.17 In addition, data

are presented for a 5-month (May-September)and 2-month (July and August) ozone season.

3.4 EMISSION FACTOR CALCULATIONS 3.4.1 Vehicle Refueling As discussed in Section 3.3, EPA Office of Mobile Sources empirically derived an equation to estimateI.: "?refueling emissions based on test data. This equation is as follows: E, = 264.21 (-5.909)

# - 0.0949 (AT)

### + 0.0884 (T,, 

## + 0.485 (RVP)]
where: E, = Emission rate, milligrams of VOC per liter of liquid loaded

RVP = Reid vapor pressure, psia

AT = Difference between the temperature of the fuel in the automobile tank and the temperature of the dispensed fuel, OF T, = Dispensed fuel temperature, OF Using this emission factor equation, .andthe RVP and temperatures found in Tables 3-3, 3-4, and 3-5, automobile refueling emission factors can be derived for specific geographic locations and for different seasons of the year. Emission factors calculatedusing this equation should allow the estimation of emissions from automobile refueling for any area of the country. This approach is certainly more accurate than using the single value provided in EPA's Compilation of Emission Factors (AP-42).18 Table 3-6 illustrates how these emission factors can vary from location to location and by time of year for each State. Using the emission factor equations indicates variations of over 40 percent between summertime emissions rates found in Colorado (1,080mg/L) and Florida (1,550 mg/liter). This indicates that an error would be introduced in emission planning activities if a single factor were used. While thismethodology has been used in prior EPA st~diesl~n~~ to estimate refueling emissions, it should be noted that revised State implementation plan (SIP) emission inventory guidance issued by EPA in 19912' recommends that refueling emissions be calculatedusing emission factorsgenerated by MOBILE 4.1, EPA's mobile source emission factor computermodel. MOBILE4.1 utilizes the same equation presented above to calculate a refueling emission factor. User supplied inputs for temperature and RVP are used to calculate an emission factorbased on gasoline throughput (-/gal). MOBILE4.1 also will convert this emission factor toone based on

### VMT by using assumptions for the on-road automobilepopulation and the fuel economy for each model year. There is uncertainty introducedby using 

### VMT as the parameter for calculating refueling emissions. First, the fact that a vehicle travels through a certain area does not indicate that thevehicle is refueled in the same area, and second, theuse of fuel economy introduces another layer of uncertainty tothe calculation. In the absence of accurate throughput data, refueling emissionsmay be estimated using VMT. However, it is suggested in MOBILE4.1 guidance that refueling emissions be calculated using throughput data instead of VMT.22 3.4.2 S~illaae Several recent studieshave been conducted comparing the occurrences of spillageduring refueling events both with and without Stage I1vapor recovery equipment. The studies are: (1)a 1989 studyby theAmerican Petroleum ~nstitute~~; (2)a 1990 study by the California Air Resources ~oard~~; and (3)a 1983 study by the Bay Area Air A fourth studywas conducted Quality Management ~istrict.~~ The Lundberg study provided some in 1987 by L~ndberg.~~ simplified frequency informationbut no quantification of spillage or emissions. The survey contained only observances of spillage along with other questions and observations taken during refueling episodes. Since no quantification of spills was contained in the study, it is not summarizedhere. The three studies were similar in that they observed refueling at both conventional and Stage I1 systems, documented spillage frequency, and estimated thequantity ofspillage that occurred. Spillage quantities were estimated by correlating spill area measured on the ground with volume quantities of liquid gasoline spilled. Table 3-7 summarizes the results of these studies. TheAPI study was conducted at 20 "well maintainedw Stage I1 systems in theWashington, DC area and 20 conventional systems in Baltimore. Considerable effortwas taken toassure that the Stage I1 and conventional stations

were comparable in throughput, number of nozzles, and location (urban inner city). Spills were quantified by measuring wetted surface area caused by the drip or spill that occurred during the refueling cycle. Inspectors/observers were trained by spilling specific liquid quantities and measuring the resulting spill area. Spill areas were calibrated at each test site to take into account differences in surface porosity, fuel character- istics, and ambient conditions. The API study found an increase in spill frequency with Stage I1 equipment and an increase in spill quantity. The CARB study was similar to theAPI study in methodology using spill size versus quantity techniques. In addition tomeasurable spills on the ground, CARB included spills along the side of thevehicle. The CARB study took place at 31 Stage I1 systems in Sacramento and 21 conventional stations north of Sacramento. Data were reported for all spills and adjusted toaccount for one large spill that CARB felt biased the results. API made no adjustments to the data collected at theWashington, DC and Baltimore stations for any large spills. To convert spill size/volume data in the CARB study toquantity data, two assumptions had tobe used: (1) gasoline density was 0.67 gm/ml (the same used in the Stage I1 recovery credit calculations), and (2)the average volume per refueling event was 10 gallons. The CARB study found a lowerS;Bg dddfrequency of spills and smaller quantities of spillswith Stage I1 equipment. It should be noted that spillage determinations

are part of the certification procedures for Stage I1 equipment in California. To pass certification,the Stage I1 equipment must have spillage quantities less than conventional equipment. The third study was conductedby the Bay Area AQMD. The results of this study was obtained from the Bay Area, but no narrativewas supplied. From the data supplied and a conversationwith Bay Area AQMD it was determined that the test program was similar to that of the CARB and API studies. The conventional nozzle study dates back to a 1974 study by Scott Environmental. This conventionalnozzle study by Scott was the basis for the AP-42 emission factor for spillage from automobile refueling (80mg/liter). The Stage I1 data were obtained from facilities in the Bay Area. The Bay Area data indicated a slight increase in spill frequency with Stage I1 equipment but a significantly lower emission rate. It is difficult todraw any specific conclusions on the relativemerit of the studies. Each appeared to incorporate similar procedures, however, slightly different results were obtained. The results of all studies are in the same order of magnitude and in the same approximate range. This further complicates the task of evaluating spillage information. It is impossible, based on this data, to conclude one way or the other

on whether Stage I1 or conventional refueling results in higher spillage. This difficulty in concluding a definitive spillage quantity must be put in perspective. The difference in this spillage data represents less than one percent of the emissions from the total refueling event. 3.4.3 Fm~tvina Losses Emissions have also been reported at service stations due to storage tank emptying and breathing losses. Breathing losses are attributable togasoline evaporation due tobarometric pressure and temperature changes. Breathing loses in fixed volume storage tanks are caused by vapor and liquid expansion and contraction due todiurnal temperature changes. As temperatures increase,vapor volume increases pushing vapor out of the vent pipe (out- breathing). When temperaturesdecrease, vapor volume decreases and air is drawn into the tank (in-breathing). Breathing loss emissions have traditionallybeen minimal at service stations since storage tanks have generally been located underground, insulated by the earth, with a very stable temperature profile. However, breathing losses from service station storage tanks are becoming more prevalent due to the popularity of aboveground storage tanks and the installation of vaulted underground storage tanks. Aboveground storage tanks are more susceptible to temperature and pressure changes and thus are more likely to experience both vapor growth and vapor shrinkage. It is also reported that the double wall, or wvaultedmunderground storage tanksbeing installed to comply with underground storage tank (UST) regulations are more susceptible to thermal effect and theref ore breathing losses.27s28 Emptying losses occur when gasoline is withdrawn from the tank allowing fresh air to enter. This enhances evaporation (i.e., vapor growth) and causes vapors tobe vented from the pipe

as the saturated gasoline vapors tend to occupy a larger volume than air. EPAtsAP-42 cites an averagebreathing emission rate of 120 milligrams per liter of throughput. This original source for this factor was a Journal of the Air Pollution Control Association November 1963 article based on
a study by theAir Pollution Control District of Los Angeles County (LAAPCD). This article was.entitled "Emissions from Underground Gasoline Storage Tanks", and lists as authors Robert Chass, Raymond Holmes, Albert Fudurich, and Ralph Burlin of the This article describes emptying losses Los Angeles Di~trict.~~

as follows. When an automobile is fueled, gasoline is pumped from the underground tank, causing air tobe inhaled through the vent pipe, the volume being approximately equal to thevolume of gasolinewithdrawn. The air then becomes saturated with gasoline vapors, tending to occupy a largervolume. This in turn, causes the vapor-air mixture to exhaust from the underground tank until a pressure equilibrium is attained.Themg/l emission factor listed in AP-42 was estimated in this study by measuring air expelled from thevent pipe after vehicle fueling and applying a theoretical gasoline vapor to air ratio of 40percent. They concluded that it was impractical, in their study, to collect representative vapor samples for analysis. While the emission factor of one pound per thousand gallon of throughput (approximately120mg/l) was presented in this study, it also discussed complexities with estimating these emissions. The study concluded: Factors affecting thebreathing losses are complex and interrelated, depending on the service station operation, pumping rate, frequency of pumping, ratio of liquid surface tovapor volume, diffusion and mixing of air and gasolinevapors, vapor pressure and temperature of the gasoline, thevolume and configuration of the tank, and the size and length of thevent pipe. Because of thesemany variables involved,much more data from a number of representative retail stations would be necessary before an accurate determination of overall, basin-wide breathing losses could be made. Since the time of this original analysis, several studies have been conducted to attempt to account for many of these variables. These range from studies that conclude there are no VOC emptying losses to those reporting emissionsmuch higher than those predicted by theAP-42 emission factor. Dr. R.A. Nichols has studied this subject extensively throughout the 1970s and 1980s. In a 1987 paper on the subject30,the conclusion is that themodel used in the LAAPCD analysis ignored the effect of thevent line. Dr. Nichols states: Air enters a nearly underground tank containing saturatedvapor. Air will spread over a large and heavier vapor layer enhancing diffusion into this layer. As the surface layer gains vapor, the lighter upper vapor, which is essentially air, isvented from the tank through thevent line. The air-vapor mixture expelled from the tank to thevent line occupy only a small fraction of thevent linevolume. The air-vapor mixture remains in thevent pipe for some time because of low diffusion rate. Subsequently,thismixture is inhaled back into the tank in the next refueling. Consequently, thevent line acts as a buffer toeffectively ensure that only air enters and leaves the vent during intermittent refueling. Dr. Nichols indicates that vapor emissions could only occur during periods of long refueling inactivity. He concludes that high fueling activity followed by long periods of inactivity will lead to the highest (andpossibly the only) vapor venting emissions. This paper did not provide any emission factor for these emissions. The California Air Resources Board (CARB) conducted a study to estimate storage tankbreathing losses in 1987.~' Emissions

were measured at a low throughput (15,000 gallons per month per tank) station and a high throughput (50,000 gallons per month per tank) station. The study found different results for the two stations. The emission factor calculated for the low throughput station was 0.92 lbsVOC per 1000 gallon throughput (110mg/l), and 0.21 pounds per 1000 gallon (25mg/l) for thehigh throughput station. Observations made during the testing indicated that mass emissions from the underground storage tanks appeared to occur during periods when dispensing of product was the lowest, that emissions were at aminimum during conditions of near continuous fuelings, and that the highest mass emissions occurred during intermittent vehicle fuelings followed by relatively long periods of dispensing inactivity. The differences in emission factors at thehigh and low throughput stations are explained in these observations. The National Institute for Petroleum and Energy Research (NIPER)conducted a study and reached conclusions partially in agreement with those of both Dr. Nichols and CARB.~~ NIPER1s study concluded that no vent losses would occur if the dispensing frequencywere high enough and thatvent losses would be markedly reduced if the height of thevent was increased. The rationale for the origin of emissions agreed with the discussion provided in the original LAAPCD study. Thiswas that emissions were due to 1) air induction through thevent, 2) dilution of the hydrocarbon vapor in the tank, 3) saturation of the diluted vapor by evaporation of the liquid fuel, resulting in increasedpressure in the tank. If this pressure was greater than that exerted by the column of vapor in thevent, emissions resulted. The emissionsmeasured for a high flow stations were 0.85 and 1.05 grams per gallons dispensed (225and 277mg/l, respectively)

# . A comparison of the CARB and NIPER studies shows that the NIPER emission factors aremuch higher than those from CARB. Recognizing this discrepancy, CARB and NIPER met on August 21, 1987 todiscuss the differences.== The conclusion reached at thismeeting was that NIPERtsresults should be adjusted because the dispensing period (8hours) during NIPERtstestswas not considered representativeof the effective dispensing period at a high volume station. Adjustmentswere made and it was determined that a more appropriate emission factor for the NIPER data is 0.6 lbs/1000 gallons (72mg/l) for a high throughput station. In summary, these studies indicate that the emissions from storage tank emptying are affected by several factors, most notably theheight of thevent pipe and thevehicle fueling activity. For the purposes of the analysis in this document, it is believed that theAP-42 factor of 120mg/l represents an emission factor thatmay be very conservative, but is not unrealistic.

3.5 MODEL PLANT EMISSION ESTIMATES Model plants, as described in Chapter 2, are used to represent the industry for cost and emission estimation purposes. The data presented earlier in this chapter and in Chapter 2 were used to calculate emissions for each model plant. Table 3-8 summarizesmodel plant emissionsusing an emission factor calculated with the overall national annual average RVP of 11.4 psi, a AT of 4.4'F and a T, of 66.0mF. Using emission factors in Table 3-8 and the gasoline throughput associated with each model plant allows the calculation of model plant emission estimates for any geographical area. The equation for estimating model plant emissions is as follows:TABLE 3.8. VOC EMISSIONS FROM REFUELING FOR SERVICE STATION MODEL PIANTSa

Average Model Service Station Average Emission Plant

Model plantsb Throughput Factor Emissions Liters/Month mg/literc 

## W/Y~ Model Plant 1 23,000 1,340 0.4 Model Plant 2 76,000 1,340 1.2 Model Plant 3 132,000 1,340 2.1 Model Plant 4 234,000 1,340 3.9 Model Plant 5 700,000 1,340 11.2

a Not including emissions associated with spillage and tank emptying/breathing. Model plants described in Chapter 2. Average emission factor based on the following:

RVP 11.4 Dispensed fuel temp. 66.0 Dispensed f uel/fuel 4.4 tank temp. diff.MP, = (E,) (MP,) (12months/year)

### /(1o9mg/~g)
where: MP, = Model plant emissions, Mg VOC/yr

Er = Emission rate, mg VOC/liter

MP, = Model plant gasoline throughput, liters/month3.6. REFERENCES 1. Furey, Robert and Bernard Nagel. Composition of Vapor Emitted from a Vehicle ~asoline Tank During Refueling. Society of Automobile Engineers (SAE) Technical Papers Series 860086, February 1986,
2. Gasoline Marketing Industry (StageI)

# - Background Information for Proposed Standards, Preliminary Draft. U.S. Environmental ProtectionAgency, Research Triangle Park, NC. November 1991.

3. Evaluation of Air PollutionRegulatory Strategies for Gasoline Marketing Industry. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards and Office of Mobile Sources. Ann Arbor, MI. Publication No. EPA-450/4-84-012a. July 1984.
4. Draft Regulatory ImpactAnalysis: Proposed Refueling Emission Regulations forGasoline-Fueled Motor Vehicles



# -- Volume I

# - Analysis of Gasoline Marketing Regulatory Strategies. U.S. Environmental ProtectionAgency. Office of Air Quality Planning and Standards and Office of Mobile Sources. Ann Arbor, MI. Publication No. EPA-450/3-87-001a. July 1987.

5. Pacific Environmental Services, Inc. Description of Analysis Conducted toEstimate Impacts of Benzene Emissions from Stage I Gasoline Marketing Sources. Prepared forU.S. Environmental ProtectionAgency. Research Triangle Park,NC 27711. August 1989.
6. Design Criteria for Stage I Vapor Control Systems Gasoline Service Stations. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27711. November 1975. 7, Norton, R.L., R.R. Sakaida, and M.M. Yamada (Pacific Environmental Services, Inc.). Hydrocarbon Control Strategies for GasolineMarketing Operations. Prepared for U.S. Environmental ProtectionAgency. State Publication No. EPA-450/3-78-017. April 1978.
8. Telecon. Bowen, E., Pacific Environmental Services, Inc. with Bradt, R., Hirt Engineers, U.S. Environmental ProtectionAgency, September 25, 1991. Comments on preliminary draft technical guidance document.

9. Letter, from Kunaniec, K., Bay Area Air Quality Management District, to Shedd, S., U.S. Environmental Protection Agency. July 31, 1991. Comments on preliminary draft technical guidance document.Rothman, David, and Robert Johnson. Technical Report

# - Refueling Emissions from Uncontrolled Vehicles. Prepared for U.S. Environmental ProtectionAgency, Office of Mobile Sources. Ann Arbor, MI. Publication No. EPA-AA-ADSB-85-6, June 1985.

Motor Gasolines, Summer 1990 and Winter 1989-1990. National Institute for Petroleum and Energy Research. Bartlesville, Oklahoma. February 1991 and June 1990. Volatility Regulations for Gasoline and Alcohol Blends Sold in Calendar Years 1991 and Beyond. Federal Reaister,Vol. 55, No. 112, 23658. June 11, 1990.
Clean fuels rules and guidelines negotiated rulemaking advisory committee. Federal,peaister, Vol. 56, No. 103, 24157. May 29, 1991. Fax communication toNorton, Robert, Pacific Environmental Services, Inc., from Johnson, Robert, U.S. Environmental ProtectionAgency, Office of Mobile Sources. April lo, 1991.
Reference 12. McAnnally, Michael and J.L. Dickerman (Radian Corporation). Summary and Analysis of Data from Gasoline Temperature Survey Conducted by American Petroleum Institute. May 1976.
Reference 10. Compilation of Air Pollutant Emission Factors, Fourth Edition (AP-42). Section 4.4 Transportation and Marketing of Petroleum Liquids. September 1985.
Reference 3.
Reference 4.
Procedures for the Preparation of Emission Inventories for Carbon Monoxide and Precursors of Ozone Volume I: General Guidance for Stationary Sources. Prepared for U.S. Environmental Protection Agency, Research Triangle Park, NC. PublicationNo. EPA-450/4-91-016. May 1991.

User's Guide toMOBILE4.1. EPA-AA-TEB-91-01. U.S. Environmental ProtectionAgency. Office of Mobile Sources. Ann Arbor, MI. July, 1991.A Survey and Analysis of Liquid Gasoline Released to the Environment During Vehicle Refueling at Service Stations. American Petroleum Institute. API PublicationNo. 4498. June 1989.
Memorandum from Fricker, Robert L., California Air Resources Board toMorgester, James T., California Air Resources Board. April 18, 1991. Investigation of Gasoline Spillage at Retail Service Stations.
Fax transmission from Kunaniec, K. Bay Area Air Quality Management District, toNorton, R., Pacific Environmental Services, Inc. September 19, 1991. Data from Bay Area Spillage Study. Stage I1 Survey Statistical Data Report. Lundberg Reports Corporation. Fredericksburg, VA. August 1987.
Reference 8.
Reference 9. Burlin, R., and A. Fudiruch. Air Pollution From Filling Underground Gasoline Storage Tanks. Los Angeles Air Pollution Control District. December 1962. Nichols, R.A. Service StationUnderground Tank Breathing Emissions. R.A. Nichols Engineering. October 13, 1987. Memorandum. Simeroth, D.C., California Air Resources Board, to Cackette, T., California Air Resources Board, September 15, 1987. Determination of Mass Emissions from Underground Storage Tanks. National Institute for Petroleum and Energy Research. Evaporative Losses from a Vented Underground Gasoline Storage Tank (withaddendum discussing August 24, 1987 meeting with CARB). Undated.
Reference 32.4.0 CONTROL TECHNOLOGY

This Chapterprovides a basic technical discussion of Stage I1 technology and equipment. Phase I1vapor recovery is also used to describe this technology. However, this document uses the terminology, nStage 11". While the fundamental concept of Stage I1 vapor recovery is simple, the practical applicationbecomes quite complex. There are many components that have small but important roles in Stage I1 systems. The initial sections of this chapter discuss the types of Stage I1 systems and the system components. Excessive equipment malfunctions and user dissatisfaction have been traditional stumbling blocks to Stage I1 program implementation. Where there were problems with earlier generations of equipment a discussion of corrections or improvementshas been included. Stage I1 originated in California and this State has continued tobe at the center of developing Stage I1 technology. Fundamental to the Stage I1 program in California (aswell as the rest of the country) is the equipment certificationprogram conducted by the CARB. This program is also discussed in the chapter. Much of the information regarding system components and CARB certification is taken from a paper presented at the 83rd annual meeting of theAir and Waste Management Association in June, 1990, entitled "Gasoline Vapor Recovery CertificationM

## ,by Laura McKinney of CARB.' Finally, the chapter discusses the effectiveness of Stage I1 systems. Results of studies of in-use effectiveness and methodologies for determiningprogram effectiveness are provided.4.1.1 4.1 TYPES OF STAGE I1 SYSTEMS Loading losses due to the refueling of motor vehicles

can be significantlyreduced by Stage I1 systems. There are currently twobasic types of Stage I1 systems in use in the United States. These are thevapor balance system and the vacuum assist system.

The balance typevapor recovery system operates on the principle of positive displacement during gasoline transfer operations. Balance systemsuse pressure created in the vehicle fuel tankby the incoming liquid gasoline and the slight negative pressure created in the storage tankby the departing liquid to transfer thevapors through the combination fuel dispensing/vapor collection nozzle, through thevapor passage, and into the service station underground storage tank. Because a slight pressure is generally created at the nozzle/fillpipe interface, effective operation requires that a tight seal be made at the interface during vehicle fuelings tominimize vapor leakage into the atmosphere. Also, it isvery important that the vapor path remain unobstructed. The basic design of a balance system is shown in Figure 4-1. As illustrated, thevapors and liquid are simply "balancednbetween thevehicle and underground storage tanks. 4.1.2 Vacuum Assist Svstem An assist system is designed to enhance vapor recovery at the nozzle/fillpipe interfaceby drawing in vapors using

a vacuum. Because of this design, assist systems can recover vapors effectively without a tight seal at the nozzle/fillpipe interface. There are four assist systems that are currently available and certified by the California Air Resources Board (CARB):theHasstech, the Healy, the Hirt, and theAmoco Bellowless Nozzle Systems. The Hirt and Hasstech Systems have a vacuum-generating device, such as acompressoror turbine that creates a vacuum such that vapors
are pulled from the vehicle tank into the storage tank. They utilize a processing unit for combustion of the excess vapor, while the Healy system creates a vacuum by spraying liquid gasoline through saturated vapor by way of a jet, or multi-jet pump, and the vapor is driven back to the underground storage tank. 

### A vacuum is created in the bellowless systemby a hydraulic pump driven by the dispensed gasoline. The excess vapors are drawn through a coaxial spout on the nozzle. The Red Jacket aspirator assist ,systemwas one of the first true aspirator assist systems to be certified, but is no longer produced. It was fully equipped with an aspirator, amodulating valve, and a check valve; but it has not been sold since the early 1980's. The Hasstech System, shown in Figure 4-2, uses a blower

as a vacuum generating device that is activatedwhenever gasoline is dispensed. As product is dispensed, thevapors
are drawn through the vapor hose until they encounter a valve that is located inside the dispenser. The purpose of thisvalve is toprevent ambient air flow into thevapor recovery line while other nozzles are in use. Vapors pass through the valve, then through the blower located between the dispensers and the storage tanks. This blower is capable of a pressure differential of 20 inches water column (inwc), which means that theblower readily pushes the vapor into the tanks. When there is an excess volume of vapor from either Stage I1 or Stage 

### I, the tank pressure rises. When thepressure reaches approximately 1 inwc, a switchwithin the processor is activated and this initiates processor operation. The processor incinerates the excess, then automatically turns off when pressure equilibrium is restored. This system is closed with a pressure/vacuum relief valve on the tankvents. There is also a pressure gauge located on the vent line that allows the owner/operator tomonitor the pressure of the system.The Hirt System is a vacuum assisted, vapor processing Stage I-Stage I1 control system, shown in Figure 4-3. The system is piped as a balance system, returning vapor from nozzles to storage tank free space through unobstructed vapor piping. 

### An assisting vacuum is held in the storage tanks by a vapor processor. The processor is piped into the top of the storage tank vents which aremanifold together and closed from the atmosphere. The processor contains a regenerative vapor turbine which prevents pressurizing by removing excess vapor to the balancing forces, and a thermal oxidizer which destroys only that vapor. If for any reason the processor should shut down, the system will function as a normal vapor balance system. The processor is automatically activated if thevacuum degenerates to neat atmospheric and remains activated until the vacuum reaches about 0.5 in wc. Another example of an assist system is the Healy System

as shown in Figure 4-4. This system operates under negative pressure derived from a gasoline driven jet pump. Originally the jet pumps were located in the dispensers, however, the newer system pumps may be in thevapor return piping at the storage tank. The unit located at the tank is called a multi-jet or mini-jet, depending on the number of jet pumps it contains. The jet pump draws a strong vacuum that creates enough suction todraw any excess liquid that may be present in the vapor passage. When the pump switch is activated, gasoline under pressure is provided to the jet pump. At this point an internal pressure sensing valve opens and a small stream of gasoline flows through the jet pump back to the underground storage tank. Vacuum produced by the mini-jet is immediately produced at a controlled maximum level (15to 70" wc). When the nozzle is in use the vapors are recovered through the jet pump and returned to the gasoline storage tank, A vacuum regulatory, which has a0.17 inch diameter orifice, is located within the nozzle and monitors this pressure. This opens into a pressure regulated chamber that adjusts the flow of vapors and air through thevapor recovery line. The regulator in the nozzle is designed to open thevapor path when pressure inside the nozzle is slightly above atmosphericpressure. It also closes thevapor path when the pressure becomes slightly negative; and this prevents excess air from entering the system. This also keeps a slight vacuum (0to .25 inwc) at the nozzle/fillpipe interfaceand a tight seal is not necessary between thevehicle tank and the nozzle fillpipe. Because of thispressure regulator, thehigh

vacuum in thevapor return line is not at the nozzle/fillpipe interface. There is no need for an incineration device with this system, because the amount of ambient air drawn into the system is kept at a minimum. Healy Systemswhich have themini-jet ormulti-jet unit are required tohave a pressure/vacuum (P/V)valve on thevent pipes. The pressure setting of thisvalve is 1" wc. Another type of vacuum system, the bellowless nozzle system shown in Figure 4-5, develops suctionby a dual chamber gasoline driven vacuum pump. Currently, the only certification for a bellowless nozzle has been issued to Amoco Oil Company. A vacuum is created by a hydraulic pump driven by the dispensed gasoline. The vapors are drawn through spout openings in a bellowless nozzle into the underground tank. Thevacuum is regulated by the flow of fuel, and the ratio of gasolinedispensed tovapors collected is approximately one-to-one. Because thevapors are drawn into the tank at this "one-to-onew ratio, excess vapors are not generated, and incineration is not necessary. In addition, thevapor does not contact the liquid driving the pump, thus not creating additional evaporation or misting into the air-vapor mixture. The bellowless system also has a P/V valve on thevent pipes. The currentsettings are 8 oz. and -1/2 oz. The system is under additional testing and may be certified by CARB with different settings but a P/V valve will be required.

4.2 SYSTEM COMPONENTS A more complete understanding of the technology of Stage I1vapor recoverymay be gained by considering the equipment on an individual component basis. In this section, the function and operation of components are discussed aswell as a presentation of traditional problems and improvements made to Stage I1 equipment. 4.2.1 Va~or Recoverv Nozzles The collection of gasoline vapors at thevehicle- fillpipe interface is the starting point for a Stage I1 vapor recovery system. The component vital tothis step is the combination fuel dispensing/vapor collection nozzle. The nozzle is responsible for dispensing gasoline into the vehicle fuel tankwhile simultaneously collecting thevapors being forced from the tank and routing them through the vapor recovery hose and the underground piping to the storage tank. Due todifferences in Stage I1vapor recovery systems and themanner inwhich thevapors are collected, the nozzles vary from vapor balance nozzles that require a tight seal at the fillpipe interface to the f bellow less^ nozzle, which differs only slightly in appearance from conventional nozzles. Figures 4-6 (balance),4-7 (assist), and 4-8 (bellowless) show various types of nozzles. Many past problems with Stage I1 vapor recovery have been associated with thevapor recovery nozzle. A survey conducted in California in the late 1970's during the early period of Stage I1 indicated that torn nozzle bellows and faceplates, loose ormissing latching lugs on balance nozzles, loose or unwound latch springs on assist nozzles, and fuel recirculation were among themost significant



### problem^.^ Also, a 1983 report tothe California legislature listed four major consumer complaints all ofVapor Check Secondary Shutoff Valve

-.\ '.

### '. 

# I

be1lows

Photos Courtesy of Dover Corporation/oPW Division cincinnati, 0 and Emco Wheaton, Inc. Research Triangle Park, NC


### Figure 4-6. 

### Example Balance Nozzles

## \ LATCHINODEVICE SPOUT Photo Courtesy of Emco Wheaton, Inc. Research Triangle Park, NC



### Figure 4-7. 

### Example As8ist

### NoztleFigure 4-8. Example Bellowless Nozzlewhich were nozzle related: (1) spillage of liquid gasoline during refueling, (2)equipment defects, (3)nozzle operation and handling difficulty, and (4)gasoline recir~ulation.~ Stage I1 equipment, especially nozzles, are farmore reliable and user friendly today than in thepast. New nozzles are shorter, narrower, and lighter than their predecessors. Originally weighing over six pounds, newer nozzle designs have reduced theweight by 2 to 3 pounds,4 rendering vapor recovery nozzles only slightly heavier than conventional ones. A major problem that occurred during the initial phase of Stage I1 was the compatibility of Stage I1 nozzles and vehicle fillpipes. There were many vehicles that had fillpipes that simply would not accept the Stage I1 nozzles. The State of California quickly recognized this problem and passed legislation that required the standardization of all vehicle fillpipes for 1977 and subsequent model years

(CaliforniaAdministrative Code, Title 17, Section 2290, Chapter 7, page 267). Due to the difficulty of producing

carswith different fillpipes and toprovide allow motorists to fuel vehicles in all areas without difficulty, automakers responded by standardizing vehicle fillpipes forvehicles sold throughout the country.' Therefore, newer model cars should not have a problem using Stage I1 equipment, although therewill probably be a very small percentage of vehicles still in use that have fillpipe configurations that will make it difficult touse Stage 11. There are several parts of the nozzle which are fundamental to the function of the nozzle and the recovery of gasoline vapors. These parts are thebellows, the primary and secondary shutoffs, the insertion interlock, the latch assembly, thehold-open latch, and thevapor check valve. Each of these units is discussed in detail in the following.4.2.1.1 pozzle Bellows. The nozzle bellows, or l1bootw,is the device that captures the displaced gasoline vapors at thevehicle fillpipe. Bellows were originally composed of rubber-like materials over a shape-retaining inner spring. Themost recent generation of bellows are made from shape-holding more durable materials (see Figures 4-6 and 4-7). For balance systems, the tight fit at thevehicle fillpipe interface is critical, so the bellowsmust be compressed to create this seal. The faceplate and insertion interlock (discussed later) are other components that assist in assuring a tight fit. The tension of the bellows and the difficulty of compression have been a source of consumer complaints during the history of Stage I1 vapor recovery. Also, the durability of bellows has been an often cited problem. The durability of bellowsmaterial has also been significantly improved since the introductionof Stage 11. This is largely responsible for an increased 1-ifeexpectancy of bellows for all systems and the improvements in the user- friendlinessof balance systems. The high spring-tension of early balance bellowswas responsible formuch of the "hard- to-usew reputation of vapor recovery nozzles. The tension the bellows exerts on balance-type faceplates is substantially less now than it was years ago, and the nozzles are consequently much.easiertouse. The early popularity of assist systems was in part due to the difference in the type of bellows necessary for proper system operation. Because thevapors are drawn into the bellows using a slight vacuum, a tight seal at the vehicle fillpipe interface is not necessary. In fact, the existence of a tight fit could cause removal problems and a chance of pulling a vacuum on thevehicle tank. This less stringentdemand on the bellows allowed the use of lighter,

more pliable bellowsmaterial for assist systems. Therefore, assist systems were attractive due to theirincreased user friendliness over the early designs of balance nozzles. Improved technology has resulted in lighter and more durable assist bellows, but the gap in user friendliness has been closed by the improvements tobalance systems bellows. Despite these improvements, the importanceof the bellows and the desire to avoid bellows maintenance continue to interest the industry. This is evident in the excitement and anticipation created by thebellowless nozzle (see Figure 4-7). While thebellows improvements have lessened many problems, the bellowless nozzle, in theory, will eliminate themaintenance associated with nozzle bellows. However, thisbellowless nozzle has not been installed on a wide scale basis at thispoint. Part of the reason that this system is not currently

more prevalent is due to the fact that the system design was developed by Amoco Oil company, and Amoco does not market their gasoline products in California. Therefore, the incentive todevelop and fully market this product in the past has not been great. However,, due tothe onset of Stage I1 regulations in other areasmarketed by Amoco, these systems have been installed at approximately 100 stations in St. Louis, D.C., and Philadelphia, with some "experimentalm sites in Maryland. There has been one bellowless nozzle system certified by CARB for limited application with certification testing for a second generation nozzle planned for the near future. It is expected that with the regulation in Dade County, the number of operating Amoco bellowless nozzle systems could double due to the numerous affiliated stations in this county. 

### An Amoco representative indicated that the initial plans are to limit the availability of these systems toAmoco stations, although there is the possibility that market rights will be sold to other distributors in areas not marketed by Amoco (suchas California).64.2.1.2 Face~late or Facecone. Balance nozzles have a tight-fitting soft donut-type faceplate,while assist nozzles are often equipped with loose-fitting facecones. The faceplatesare designed to achieve the close seal between thenozzle and vehicle fillpipeonwhich thebalance system depends. Assist facecones are loose-fitting and often contain grooves toprevent a tight seal so that a dangerous vacuum in thevehicle tankwill be avoided. The differences between balance faceplatesand assist facecones are apparent in Figures 4-6 and 4-7. There are exceptions to this generic characterization. For example, one vacuum assist systemwas originally designed and still can be used with normal balance nozzles. Difficulties have alsobeen noted regarding the durability of faceplatesand facecones. New materials have been developed which make these components stronger and much more durable than their predecessors. 4.2.1.3 

## 1. Conventional and vapor recovery nozzles have a primary overfill shutoffmechanism, sometimes called the liquid shutoff. This causes thenozzle to stop dispensing, thus preventing overfills, when a sensingmechanism in the tip of the spout (seeFigure 4-6) detects that the spout tip is submerged. A small tube inside the spout provides a path forvapors from a small hole in the tip of the spout to a chamber at thebase of the spout. As gasoline flows through thenozzle, vapor is sucked through this tube and fed through tiny holes in thebase of the spoutback into the gasoline. The suction that causes this is created by the venturi effect of gasoline flowing through the spout. As long as the flow of vapor is uninterrupted, thenozzle continues todispense gasoline. When the tip of the spout becomes covered with liquid, however, the flow of vapors stops and a vacuum is created. This vacuum pulls a thin, rubber-like diaphragm and triggers a mechanical shutoff mechanism to stop the flow of gasoline in thenozzle. Thelocation of the diaphragm and theway it triggers the shutoff differ with nozzle design. Some nozzles have a three-ball latch mechanism that

causes the nozzle to shut off when the tip of the spout is in liquid. Another type of shutoff mechanism uses the

vacuum topull thediaphragm and twometal rollers away from the shaft, which activates the shutoff. If the primary shutoff fails on a conventional nozzle the customer or attendant can easily recognize an overfill situation as gasoline rises in the fillpipe or spills on the ground. However, since vapor balance nozzles form a tight fit at the fillpipe, it is difficult todetermine if the primary shutoff ismalfunctioning. The nozzle may collect the liquid, thus preventing a spill but allowing liquid to collect in thevapor passage of thehose. Another common problem for vapor balance and assist systems is "topping off1#. Customers or attendants wish to fill thevehicle tank as full as possible so they attempt toadd more gasoline

once the primary shutoff has been activated. This provides the opportunity for liquid tobe introduced into thevapor passage of the hose. Because thebalance system depends on a tight nozzle/fillneck connection, there is a potential for building up pressure in thevehicle tank if thevapor return becomes blocked. Thiswas a problem with the early designed nozzles as pressure caused forcible ejection of liquid product when the nozzle was removed at the end of the fueling. To prevent this from occurring, a pressure sensing shutoff mechanism (secondary shutoff)was required. The pressure shutoff will be triggered if the primary shutoff fails and thevapor line becomes blocked with fuel. The secondary, or high-pressure, shutoff is required to
ensure that high pressure in thevehicle tankwill not occur when thevapor passage is blocked. The first vapor recovery nozzles were required to shut off at about 20 inches water column. Thiswas later changed and nozzles are now requiredto shut off at or below 10 inches. The current industry standard is 6 to 10 inches water for the pressure shutoff. Blockage of the vapor return path because of liquid, a kinked or flattened hose or other obstruction, can cause the nozzles to repeatedly shut off as pressure in thevehicle tank builds up. The secondary shutoff also acts as a guard against recirculation of gasoline through thevapor passage. In the event of a failureby theprimary shutoff system, thebuild up of liquid in thevapor passage will activate the secondary shut-off and turn off the nozzle so that no gasoline could be recirculated into the underground storage tank. California Weights and Measures conducts stringent testing of the secondary shutoffduring nozzle certification. These secondary shutoffs have also contributed to the hard-to-use reputation of balance nozzles. Inmost instances continued shut offs occurwhen problems, especially liquid blockage, exist in other parts of the system, such as thevapor hose or the underground piping. The certification process in California contains stringent tests conducted by California Weights and Measures which verify the delivery accuracy of nozzles and specifically test theprimary and secondary shutoffs (see Section 4.3.3.1). 4.2.1.4 Insertion InterlockMechanism. As noted previously, balance systemsmust maintain a tight fit at the nozzle/fillpipe interfacewhile assist and hybrid systems do not. To achieve this tight fit, balance nozzles employ a soft faceplate discussed above and an interlocking mechanism. The insertion interlock, or "no seal-no flow" device ensures that gasoline cannot be dispensed unless the bellows of the balance nozzle are compressed to ensure a tight fit at the nozzle/fillpipe interface. In some balance nozzles, compression of the bellows opens a valve which permits the flow of air from the spout-tip to theprimaryshutoff chamber. Attempting todispensewithout compressing the bellows therefore triggers the primary shutoff mechanism. Other balance nozzles have a mechanical interlock which prevents rollers from contacting the shaft unless thebellows is compressed. The nozzle trigger is loose and @@floppy1@ until the bellows is compressed. This is the type of interlock shown in Figure 4-6. The difficulty in compressing the bellows so that the insertion interlock will allow gasoline flow has been another contributing factor to the complaints relating to Stage I1 equipment. The earlier generation nozzles required

a pressure of up totwenty-four pounds todeactivate the interlock. This, combinedwith theweight of the nozzle and the tension of the springs in thebellows, made nozzle operation difficult for many customers. However, the improvement of each of these componentshas greatly reduced this problem. The pressure required todeactivate insertion interlocks has been decreased to as low as five pounds on

some nozzles.8
A lack of understanding of the interlockand latch mechanisms can frustratecustomers. This problem is one that can be corrected with public awareness programs and proper operating instructions at the pump. 4.2.1.5 Latch Assemblv. The purpose of the latch assembly is to allow the customer or operator to lock the nozzle into the vehicle fillpipeby hooking the latch on the lip of the fillpipe. The latch assembly may be a spring wound around the spout, a ring around the spout (see Figure 4-7) or a bar riveted or screwed onto the spout (see Figure 4-6). This device is more critical tobalance-type nozzles because of the interlock and the greater tension exerted by the bellows. Therefore, it is required on balance nozzles and is optional for conventional nozzles and some assist nozzles. This simple device created problems specified in the earlier surveys. The difficulties were mainly due to thelatch assembly coming off the spout. Design and manufacturing improvements have been made and complaints in this area are now practically nonexistent. 4.2.1.6 Hold-Oven Latch. This latch allows the nozzle trigger tobe mlockedwin operatingposition, freeing the operator tomove away from the nozzle. Some establishments elect to remove hold open latches for business reasons. They prefer tokeep customers at the nozzle so that they will not leave vehicles unattended or drive off with the nozzle still in the car. Hold open latches are not critical to the actual recovery of vapors and nozzles are allowed with and without them. The decision whether hold open latchesmay be used is often decided by local firemarshals. 4.2.2 Vapor Check Valve The vapor check valve opens and closes the vapor passage between theunderground tank and the atmosphere

(throughthe nozzle bellows). This valve closes when the nozzle is not in use toprevent vapors from escaping. This also prevents air leakage into the Stage I1 system and vapor leakage out of it during vehicle refueling at another nozzle or tank truck unloading. With the exception of a few nozzleswhich have remotely-located flow-activated vapor checkvalves, balance nozzles generally have vapor check valves located in the nozzle at thebase of thebellows which are opened by compression of thebellows. Most assist systems have vapor check valves located in thevapor passage but not in the nozzle. For example, one assist system nozzle has a ball-check valve (avery simplemechanism involving a largerball-bearing which blocks thevapor passage when the nozzle spout points upward). Another has a flow-control valve in the dispenser. Another system employs a regulating diaphragm inside the nozzle designed to open or close the vapor passage as necessary tominimize the pressure difference inside and outside the nozzle.4.2.4 Hoses and Hose Confiauration Svstems 4.2.4.1 fisses. Vapor recovery hoses may be coaxial or dual hose. Coaxial hoses contain twopassages, configured

as a hose within a hose. One of thepassages dispenses liquid gasoline. The other passage, thevapor hose, receives the gasoline vapors and carries them back through the underground piping tothe underground storage tank. Most coaxial systems employ a 1/2 or 5/8 inch product hose inside l-f to 1-# inchvapor hose. The single exception is The Healy systemwhich has thevapor hose inside theproduct hose. Dual hose systems have separate hoses for the liquid and vapor. Since 1986, all new or modified balance systems installed in Californiamust be coaxial. Other areas with recently implemented Stage I1 programs only allow coaxial hoses. Historically, hoses have been a source of problems, specifically with regard to their weight, durability, and propensity to kink. Also, hoses often touched the ground which made them susceptible to damage due tovehicles running over them. Also, since Stage I1was a technology originally developed in central and southern California, the durability of hoses in colder climates has been a concern. The original twohose systemwas heavy and proved tobe awkward (duetohose twisting, etc.) for consumers and gas pump attendants to use. To overcome thisproblem, manufacturers developed a more manageable coaxial hose. However, thesewere still hardwalled and continue tohave a weight problem. A second generation of coaxial hoses was then developed that is much lighter and even more manageable. The swivels that were necessary with the dual hose systems and thehardwall coaxial hoses are not required with these newer coaxial hoses. This further reduces the weight of the hose and makes them easier tohandle. Due to improvements in thermal plastic materials, new coaxial hoses will weight only about fivepounds, which is comparable to theweight of conventional gasoline dispensing hoses.Also, the durability of early model hoses under extreme winter temperatures has been questioned. Fifth generation coaxial hoses and bellows are designed towithstand temperatures as low as -60' F.~Stage I1 systems have been installed in New Jersey and New York and no significant increase inweather related defects has been observed.lo*'' 4.2.4.2 piah Hana and Hose Retractor Svstems. Another hardware improvement is the development of high-hang hose dispensers and hose retractor systems. A major advantage of these configurations is that they minimize hose kinks and the possibility of the hose being flattened and help to lessen theweight of the nozzle for the customer. This helps to eliminate these situations which interfere with the flow of gasoline vapors to the underground storage tank. The hose retractor configurations also are designed to allow any liquid gasoline trapped in thevapor portion of the hose todrain into the fuel tank during normal fueling. The exception to this are systems required tohave liquid removal devices. Figure 4-9 shows high hang hose and hose retractor configurations. 4.2.4.3 Liuuid Removal Svstems. As stated above, one major reason for the advent of the hose retractor systems

was to allow any gasoline trapped in the vapor passage of the hose todrain into the fuel tank. However, the structure of multiproduct dispensers does not contain the loop that allows this drainage to thevehicle fuel tank. Therefore, a method for removing liquid trapped in the vapor passage of the hose was developed. Liquid removal systems are designed to evacuate trapped liquid from thevapor passages in coaxial hoses. They operate using the venturi principle. A slightvacuum is created by the fuel flowing in the interior hose that draws the liquid out of the vapor passage and into the liquid gasoline stream. The venturi device can be located at the dispenser end of the hose or the nozzle end, depending on the type. Figure 4-10 shows an example liquid removal device and illustrates its operation.----

## -- ---- Overhead Hose Retractor



# =' Hose Assemblies

r Sloped To Permit /Natural Drainage coaxial Hose ,' Into Vapor Return /' Piping When Retractor fa In Retracted Posistic

Nozzle

# 1

Vent Here Separate Liquid Pick

Designed So That During Liquid Pick-Up Or F'ueling Hose Is Sloped Venturi Placed To Vehicle ToAllow Any Here F'uel InVapor Line To Drain Into Vehicle F'uel Tank


### Figure 4-9. 

### High 

### Hang Hose Configurations -*4.2.4.4 

### Ern-. An addition to Stage I1 systems is the emergency breakaway valve. These breakaways separate and close the product hose when a customer drives off with the nozzle in the fillpipe, thereby preventing damage tothe equipment and reducing the danger of fire. Figure 4-11 shows an example emergency breakaway. 4.2.5 u Un q The underground vapor piping is an often ignored,but important component of Stage I1 systems. In fact, CARB certification includesnot only the nozzles, hoses, and other above ground equipment, but the underground piping as well. Therefore, a CARB certified systemmust have the correct underground piping configuration as specified in the Executive Order. The vapor piping begins with the riser pipe that is located either inside the dispenser or on the pump island. Inmany instances, this is a 3/4 inch galvanized riser pipe. All vapor return and vent piping should be provided with swing joints at thebase of the riser to each dispenser, at each tank connection, and at thebase of thevent pipe riser where it fastens to a building or other structure. The underground vapor piping system can be made up of individual return lines or a manifolded system. In either instance, the minimum vapor pipe diameter is commonly 2 or 3 inches. The underground piping was originally all made of steel, but fiberglassvapor piping has now become popular. The individual return line system shown in Figure 4-12 is the simplest design and has one pipe for each underground storage tank. If there are multiple dispensers of a particular product or grade of gasoline, thevapor lines are tied together into one line going to the appropriate tank. Therefore, the vapors from thevehicle tankmust be transferred to the same tank fromwhich liquid gasoline is being drawn, The piping should slope towards the underground storage tank with sufficient drop so that anyPhotoCourtesy ofGoodyearTire& Rubber, Co. Akron, OH.

Product Vapor Product6Vapor

Product

PhotoCourtesy of Themid/HBD Industries, Inc. Be1lefontaine, OH.

Figure 4-10 Example LiquidRemoval DevicePhoto courtesy of Husky Corporation Pacific, MO



### Figure 4-11. 

### Example Emergency BreakawayFigure 4-12. Individual Vapor Balance System Underground Pipingcondensate or liquid in thevapor piping will drain to the underground storage tank. Each tank also has a vent line that is usually required tobe at least 2 inches in diameter. Therefore, therewould be multiple vent lines equal to the number of underground storage tanks. The vent lines should also slope toward the tanks so that any condensate will drain back into the tank. In a manifold system, shown in Figure 4-13, all of the vapor lines from thedispensers are linked to a common manifold. Thismanifold can be run into a manifold box with vapor connections to all of the tanks. More commonly, the manifold is connected directly to the storage tank with leaded gasoline, or the lowest grade of unleaded (inthe absence of leaded). This is to avoid contamination of the higher grade gasolines. Again, themanifold must be sloped adequately to allow any liquid present in thepipe todrain to the liquid trap or storage tank. During vehicle fueling, thevapors are returned to the appropriate tank due to the slight vacuum created in the tank by the removal of the liquid. As in the individualvapor return system, each underground tank typically has a vent pipe. The minimum height of thevent pipe off theground is usually determined by the FireMarshal. A typicalminimum height is 12 feet above the adjacent ground level and should vent upward or horizontally. Some areas allow pressure vacuum vents on service stationvent pipes. Pressure Vacuum vents are required for some assist systems. Problems can occur with theunderground piping that decrease the efficiency of thevapor recovery tovery low levels. These problems can takemany forms from incorrect piping size, to improper plumbing configurations where some tanks are not even connected to the vapor piping system. Themost common problem associated with theunderground piping is the presence of low points in the line which allow the build-up of liquid gasoline. Low points often occur due

### Figure 4-13. 

### Manifolded Balance System

### Underground Pipingto inadequatebackfilling of the piping or from running over the piping by constructionequipment prior topaving or surfacing. Liquid blockage causes pressure build up which either forces thevapors out at the nozzle/fillpipe interface or causes the secondary shutoffmechanism to stop the pumping of gasoline. Many people with a great deal of experience with Stage I1 systems believe that singlemost important element to a Stage I1 program is to ensure that the systems are initially installed correctly. Systemsplumbed incorrectly reduce the emission reductionpotential of Stage I1 vapor recovery substantially. Representatives in the San Diego Air Pollution Control District of California estimate that the underground piping at over 50 percent of the stations will be installed improperly without an installation testing program (thesetests are discussed in Chapter 6 and contained in Appendix I) and inspections to identify improper systems.l2 4.2.6 E b m With theproblems associated with leaking underground storage tanks and the resulting stringent UST and LUST regulations, the interest in placing service station gasoline storage tanks above ground is gaining attention. In California there are a small number of service stations that have Stage I1 systems on above ground storage tanks.13 For themost part, these are private card lock stations serving fleets and small vaulted, tanks. Balance systems have generally been installed for small tanks and vacuum assist systems have been installed at these stations with large bulk plant type tanks. The certification of above- ground Stage XI systems in ~aliforniais discussed in Section 4.3,s.4.3 CALIFORNIA CERTIFICATION PROGRAM It iswidely recognized and accepted that Stage I1 technology originated in California and has developed largely due tothe regulations and requirements of the CARB and local California air pollution agencies such as the Bay Area Air Pollution Management District in San Francisco (Bay Area), the South Coast Air Pollution Management District in the Los Angeles area (South Coast), and the San Diego Air Pollution Control District (SanDiego). Many States and local agencies in other parts of the country rely on California for Stage I1guidance due totheir experience and expertise. California State law requires that the StateAir Resources Board adopt procedures for determining the compli-

ance of any system designed for the control of gasoline vapor emissions during gasoline marketing operations.l4 1n response to this legislative mandate, CARB developed proce- dures and test methods which describe the requirements for certification for all gasoline marketing emission sources. Appendix C.l contains the requirements for certification. Because it is not practical to test the efficiency of thevapor recovery system in each service station, CARB developed a "genericw equipment certification approach. In this program a prototype Stage I1vapor system is evaluated and specifications developed. Systems that meet these "certifiedgg specificationsmay be installed without individual efficiency tests. CARB will accept applications for certification of vapor recovery systems from any manufacturer, but there are conditions which must be met by themanufacturer before certification testing is initiated.15 Themanufacturer is required to demonstrate the ability to pay the costs of testing prior to the commencement of CARB certification testing. This demonstrationmay take the form of posting a bond of not less than $20,000. In order toprotect the purchaser, CARB is also required to evaluate the adequacy oftheplanned methods of distribution and replacement parts program, the financial responsibility of the applicant, and other factors affecting the economic interests of the eventual system purchaser. Themanufacturermust also provide a three-year warranty for the system. The only exception tothewarranty requirement is for those components that themaintenance manual identifiesashaving expected useful lives of less than threeyears, such as vapor recovery nozzles. Thewarranty in these cases is allowed to specify the expected life of the component. Specifically, it is required that the application be in writing, signed by an authorized representative of the manufacturer, and include the following information: 

### A detailed descriptionof the configuration of the vapor recovery systemwhich includes the underground piping configurationand specifications,the gasoline dispensing nozzle to be used, engineering parameters for pumps and vapor processing units, and allowable pressure drops through the system. Evidence demonstrating thevapor recovery reliability of the system or device for 90days. Theprocedures by which this is determined are discussed below in section 4.3.1.



### A description of testsperformed todetermine compliance with the general standards and the results.



### A statement of recommendedmaintenance procedures, equipment performance checkout procedures, and equipmentnecessary to assure that thevapor recovery system, in operation, conforms to the regulations,plus a description of theprogram for training personnel for such maintenance, and the proposed replacement parts program. Six copies of the service and operating manuals that will be supplied to the purchaser.



### A statement that a vapor recovery system, installed at an operating facility,will be available for certification testing no later than one month after submission of the application for certification. The certification testing procedure is discussed in detail in Section 4.3.2.The retail price of the system and an estimate of the installation and yearly maintenance costs.

A copy of thewarranty or warranties provided with the system.
If the application is for a system previously tested, but not certified, the applicationmust include identification of the system components which have been changed, and any new test results obtained by the applicant. Any other information reasonably required by CARB. While this list showsmany requirements for certification, themajor portions of CARB requirements are the operational/durability, or "90 dayutest, and the certification or "100 carwtest. 4.3.1 O~erational/DurabilitvTest. "90 Day Testw As stated above and contained inAppendix C.l, the applicantmust demonstrate the reliability of the system. This demonstration is conducted by installing a system at an operating station and observing the durability for at least 90days.l6 The facilityutilized for certification testing must have a minimum throughput of 100,000 gallonsper month and includeat least six nozzles of each type submitted for approval. No more than two types of nozzles can be present at any one test facility. During this "operationalw test, replacement of componentsor alteration of the control system is not allowed, except replacement ormodification of a component if it has been damaged due to an accident or vandalism. No maintenance or adjustments to the system are allowed during the test unless specifically called for in the system's maintenance manual. The entire system is sealed sothat unauthorized maintenance or adjustmentmay be detected. If detected, this can be reason for immediate failure of the test. CARB observes the station frequently during the testing period and evaluates thedurability of the system or componentsafter this period.4.3.2 Certification Testina, "100 Car TestB1 Aftermeeting all other CARB requirementsand successful completion of the 90day test, the efficiency of the system is tested1?during at least 100 vehicle fuelings. The testmethod is contained in Appendix C.2. The test procedures provide for the fueling to occur during the normal operation of the service station,but all CARB efficiency testing is conducted in a self-service mode. Before the 100vehicle efficiency test can be conducted, the entire vapor recovery system must be tested for leaks. Each vehicle tank that is refueled is tested to identify those which are leak tight. Vehicles that pass the leak tight test may be included in the baseline population if other measurements indicate that no vapors were lost during the fueling operation. Vehicle fuelings are observed until matrix requirements

are satisfied and at least forty baseline vehicles have been identified. This matrix identifiesvehicles by manufacturer and year and ensures that thevehicles used during the test

are representativeof the on-the-road vehicle population in terms of vehicle miles travelled. The test procedures for determining the efficiency of systems to control gasoline vapors displaced during vehicle fueling require that theweight of vapors collected at the vehicle, corrected for vent losses, be compared to the potential mass emission calculated for that vehicle. A standard test sample of thevehicle population is tested and

an average efficiency calculated. The potential mass emissions are determined during the fueling of vehicles by measuring themass of hydrocarbons collected from vehicles fromwhich no leak occurred (baselinevehicles). Potential emissions are expressed as a function of thevapor pressures of the dispensed fuel and the temperature of the gasoline in the test vehicle tank. The relationship is used as thebaseline or reference fromwhich the efficiency of a vehicle fueling vapor control system is evaluated. During these fuelings, spillage and spitback from the system are also evaluated. Spillage is defined as "a loss of

more than one milliliter of liquid gasoline from the gasoline nozzle as a result of preparing to fuel a vehicle

or at the end of a fueling operation in returning the nozzle tothe dispenserwand spitback defined as "a loss of more than one milliliter of liquid gasoline during the dispensing of gasoline." In order topass this portion of the test, no
more than ten spitbacks or twenty instances of spillage per 100vehicle fuelings can occur during the testing. 4.3.3 FDDr0val of Other Aaencies The approval of three other State agencies is also required as a precondition to CARB certification. State law provides that the State FireMarshal determine whether any component of system creates a fire hazard.18 The Department of Food and Agriculture, Division of Measurement Standards, is given sole responsibility for themeasurement accuracy aspects, including gasoline recirculation, of any component

or system. Finally, the Division of Occupational Safety and Health is designated the agency responsible for determining whether any gasoline vapor control system or component creates a safety hazard other than a fire hazard.19 Appendix C also contains regulations, requirements, and test procedures for these other agencies. 4.3.3.1 California Measurement Standards Division. Prior toAir Resources Board certification, the system must be submitted for type approval tothe California Department of Food and Agriculture, Division of Measurement Standards and certified by this division (see Appendix C.3). The California Department of Food and Agriculture, Division of Measurement Standards, issue certificates of approval based on California Administrative Code Article 2, Procedures for TweA~~roval Certification Evaluation and Field Com~liance Testinu of Va~or Recoverv Svstems. Thiscode establishes regulationstogovern some design characteristics of Stage I1vapor recovery systems and their operation toensure liquid recirculation isprevented. There are several steps involved in order for certification. It is the responsibility of the manufacturer to request an application for theNational Type Evaluation Program (NTEP). Informationregarding the design of the system, including schematics, blueprints, instruction manuals, brochures, and all other pertinent facts are sent tothe Director of the Measurement Division for a prelimi- nary review. Once the Director reviews the preliminary application and approves, the applicant is authorized to install the system in a prescribed location for use in the type approval certification testing. The Director, in conjunctionwith the County Sealer of Weight and Measures for the designated location observe and examine the system in operation normally within 30 to 90 days. During that time, one or more inspectionswill be conducted which specifically relate the system components, their performance, and their accuracy. There are system installation specifications. There must be aminimum of six nozzles installed on hoses of both leaded and unleaded fuels, each tested aminimum of three times during an examination. Prior to the field examination, the dispensermeters for the test nozzles are tested and adjusted accordingly. Field compliance tests are conducted toexamine: (1) the proper operation of primary shut-off and secondary shut- off devices, (2)the delivery accuracy of the system, and (3) the performance accuracy of assist system evaporation and volume change. The test procedure for primary shut-off devices involves filling the test unit with fuel dispensed from the nozzle until the test unit becomes full. This should activate the primary shut-off device. Ten consecutiveoverride attempts are made which should result in automatic nozzle shut-off before the dispenser volume indicator increases more than 1/10 gallon limit. The 10 override attempts are performed aminimum of three times for each nozzle. The secondary shut-off device is tested by introducing sufficient fuel into thevapor return line toblock the return of vapors through the line. The nozzle and hose is then held in a configuration so the liquid 

### is concentrated in thevapor section of thehose. Ten attempts aremade to dispense fuel into an empty test unit. The volume shown on the dispenser indicator is recorded before and after each attempt. The nozzle must shut off automatically before the dispenser volume indicator increasesmore than 3/10 gallon for each attempt. This procedure must be performed on a minimum of 6 nozzles. Compliancewith delivery accuracy requirements is based upon data recorded for at least 150 vehicles (formerly 300 vehicles) while observing customers fuelingwith the test nozzles under normal field conditions. The 150 ormore vehicles should be representative of California vehicles. The assist system evaporation and volume change performance accuracy test is conducted because excessive

vacuum may result in artificial evaporation of customer fuel. Thiswould decrease themeasured volume and also

cause possible implosion of vehicle fuel tanks. In addition to all of these testswhich are conducted by Measurement Division personnel, type approval certification is not issued until the applicant submits a report of evaluationby an independent, pre-approved testing laboratory. It is after review of all of the test data and other information that the Division grants certification of

a vapor recovery system. 4.3.3.2 California FireMarshal. Prior toAir Resources Board certificationof thevapor recovery system, plans and specifications for the systemmust be submitted tothe State Fire Marshal's Office for review todetermine whether the system creates a hazardous condition or is contrary to adopted fire safety regulations (seeAppendix C.4). Final determinationby the State Fire Marshal may be contingent upon a review of each pilot installationof the proposed system. The California Fire Marshall has regulations, whose purpose is to establishminimum standards of fire safety for vapor recovery systems or components. Any manufacturer desiring certification and listing of a gasoline vapor recovery system or component must submit a completed application for evaluation and certification to the State Fire Marshall. This form must be accompanied by the proper fee. In addition, a test evaluation from a pre- approved testing organization, as well as technical data and black-line drawings suitable for reproduction must also be submitted. The final report should include failure analysis engineering data, writing diagrams, operating and maintenance manuals and photographs, together with a description of the testsperformed and the results. The catalog number, the laboratory test report number, and date should also be included. After review and approval of thematerial, the Fire Marshal issues a certificationof the Stage I1 system. Each vapor recovery system or componentwhich is certified by the California Fire Marshall must bear a label placed in a conspicuous locationand must be attached by the manufacturer during production or fabrication. 4.3.3.3 California OSHA. Prior to certification of the system, themanufacturer of the system must submit the system to the California Occupational Safety and Health Administration (CalOSHA) for determining compliance with appropriate safety regulations (seeAppendix C.5). The Division of Occupational Safety and Health of the Department of Industrial Relations is the only agency responsible fordetermining whether a gasoline vapor control system or component creates a safety hazard other than a fire hazard. The General Industry Safety Orders (GISO) is the guideline used in helping tomake a determination. Each section of the GISO relates to a different part of the service station, ranging from the location of the storage tanks to the safe operation of electrical equipment. All electrical equipment and wiring must be installed in accordance with the provisions of the California Electrical Safety Orders. All electrical equipment integralwith the dispensing hose or nozzlemust be suitable for use in the proper locations. They do not necessarily run tests, but assure that the GISO guidelines and requirementsand aremet. The equipment is tested by an outside labwhich submits a report to California OSHA. The final determination ismade when all of the requirements have been met. A letter is sent to CARB stating that the system in question has satisfied the requirements of California OSHA. 4.3.4 Cost of Phase I1 Certification The certification of equipment is not an inexpensive venture for equipment manufacturers. There are application fees, government charges for testing, private laboratory testing costs, as well as themanpower costs involved with the oversight of the certificationprocess. A fee not to exceed the actual cost of certification is charged by the Air Resources Board to each applicant who submits a system for certification. A conservative estimate of the fees charged by CARB is placed at around $5,000,20excluding the $20,000bond discussed earlier. The contractor fee to conduct the 100 car certificationefficiency test has been estimated at about $20,000.~' This puts the cost for only the CARB portion of certificationat approximately $25,000. California State law allows the State Fire Marshal, the Division of Measurement Standards, and the ~ivision ofIndustrial Safety to charge reasonable fees for certification of gasoline vapor systemsnot to exceed their respective estimated costs. Payment of the fee is a condition of certification. Representatives of major equipment manufacturers estimate that the total cost for obtaining CARB certificationcan range from $50,000

# - $~OO,OOO .22J3 4.3.5 Certificationof Abovearound storaae tank systems Stage I1 systems have alsobeen installed at gasoline dispensing facilities with aboveground storage tanks. CARB has certified severalbalance systems for small aboveground vaulted tanks, aswell as a Hirt assist system for similar tanks. There are also Hirt and Hasstech assist systems installed at bulk plant type card lock facilities,but no certifications have been issued at this time. CARB officials indicate that the certification of such systems on a generic basis is expected in the future.24 Sincemost of these applications in California are at private facilities,the conditions of the 100 carmatrix could never be met. Therefore, the certifications are based on a combination of emissionsmonitoring, equipment testing, and engineering analysis. Appendix D also contains examples of executive orders for the small vaulted aboveground tanks. 4.3.6 Executive Orders If the Executive Officer of CARB determines that a vapor recovery system conforms to all requirements, an order of certification, or Executive Order is issued. The Order specifies the conditionswhich must be met by any system installed under the certification. These specificationsmay include theplumbing system, an equipment list, thevapor hose configuration,and themaximum allowable pressure drop through the system. The interpretation of CARB executive orders can be both confusing and frustrating. This is in part due to the fact thatmany system updates and subsequent recertification of the equipment occur. It is also due to the large number ofcomponents and manufacturers of these components. The understanding of exactly what is "CARB certifiedtt is not an easy task, and areas with vapor recovery regulations which rely on CARB certification should take the necessary time to study and understand the Executive Orders. More discussion

on the determination of "approved systemsw is given in Chapter 6. Table 4-1 presents a list of current Stage I1 CARB certifications and executive orders. Appendix D contains a list of all Stage I1 CARB executive orders issued since the initiation of theprogram. This differs from Table 4-1 because some orders have been updated, rescinded, etc.. Also included in the appendix are summaries of the requirements for themost recent generation of equipment. And finally, the appendix contains actual executive orders. The executive orders provided include G- 70-52-AL that gives a summary of all above ground equipment for Red Jacket, Hirt, and Balance systems; G-70-70-AB that addresses the Healy aspirator assist system; G-70-7-AB that addresses the Hasstech vacuum assist system; G-70-118 that addresses theAmoco bellowless nozzle system; G-70-36-AC and G-70-17-AB that have detailed descriptions of underground piping requirements; and G-70-132 and G-70-133 that address above ground tank systems. If after certification of a system themanufacturer wishes tomodify the system, theproposed modifications must be submitted again for approval. Such modifications may include substitution of components, elimination of components and modification of the system configuration and may not require the full scale testing effort. If after certification of a system, CARB finds the system tono longer meet the specified certification specifications, they may revoke or modify the prior certification. 4.3.7 Fffectivenessof Svstems The test method for certifying Stage I1 systems states that such a system Itshallprevent emission to the atmosphere of at least 90percent or that percentage by weight of theTABLE 4-1. SUMMARY OF CARB EXECUTIVE ORDERS CERTIFYING SYSTEMS TO BE AT LEAST 95 PERCENT EFFICIENT

- Executive Order Title CARB Number

Certification of theHasstechModel VCP-2 and VCP-2A Phase I1Vapor Recovery Systems Relating toModification of Certification of the Emco Wheaton Balance Phase I1Vapor Recovery System Recertification of the Exxon Balance Phase 11Vapor Recovery System Recertification of theAtlantic Richfield Balance Phase 11Vapor Recovery System Certificationof theModified Hirt VCS-200 Vacuum Assist Phase 11Vapor Recovery System Relating toModification of Certificationof the OPW Balance Phase 11Vapor Recovery Recertification of the Texaco Balance Phase I1 Vapor Recovery System Recertification of theMobile Oil Balance Phase IVapor Recovery System Recertification of theUnion Balance Phase 11Vapor Recovery System Certification of components for Red Jacket, Hirt, and Balance Phase I1Vapor Recovery Recertificationof the Chevron Balance Phase I1 Vapor Recovery System Relating to the Certification of theHealy Phase I1Vapor Recovery System for Service Stations Certification of EZ-Flo Nozzle Company Rebuilt Vapor Recovery Nozzles and Vapor Recovery Nozzle Components Certification of EZ-Flo Nozzle Model 3006 and Model 3007Vapor Recovery Nozzles and Use of E-Z Flo Components with OPW Models llVC and llVE Vapor Recovery NozzlesTABLE 4-1 (CONTINUED). SUMMARY OF CARB EXECUTIVE ORDERS CERTIFYING SYSTEMS TO BE AT LEAST 95 PERCENT EFFICIENT

Executive Order Title

Certification of Rainbow Petroleum Products Model RA3003, RA3005, RA3006 and RA3007 Vapor Recovery Nozzles and Vapor Recovery Components Certification of ConVault Incorporated Aboveground Tank Filling/Dispensing Vapor Recovery System Certification of Amoco V-1 Vapor Recovery System Certification of the Husky Model V Phase I1 Balance Vapor Recovery Nozzles Certification of the OPW Model Ill-V Phase I1 Balance Vapor Recovery Nozzle Certification of the Bryant Fuel Systems Aboveground Tank Filling/Dispensing Vapor Recovery System Certification of the BRE Products, Inc. Enviro-Vault Aboveground Tank Filling/Dispensing Vapor Recovery System Certification of Sannipoli Corporation Petro Vault Aboveground Tank Filling/Dispensing Vapor Recovery System Certification of Hallmark Industries Tank Vault Aboveground Tank Filling/Dispensing Vapor Recovery System Certification of Trusco Tank, Inc. SupervaultAboveground Storage Tank Filling/ Dispensing Vapor Recovery System Certification of LRS, Inc. Fuelmaster Aboveground Storage Tank Filling/Dispensing Vapor Recovery System Certification of the EZ-Flo RebuiltA4000- *Series and 11V-Series Vapor Recovery Nozzles CARB Number

G-70-107

G-70-116-A

G-70-118

G-70-125

G-70-127

G-70-128

G-70-129

G-70-130

G-70-131

G-70-132

G-70-133

G-70-134

Source: May 17, 1991 letter with attachments from James Morgester, CARB, to Stephen Shedd, EPA.=gasoline vapors displaced during the filling of the stationary storage tank as required by applicable air pollution controldistrict rules and regulations.~~~ Although this provides an efficiency of 90percent, all of the air pollution districts in California contain regulations which require Stage I1 systemswhich achieve 95 percent effi~iency.~' Therefore, CARB certifies systems 

### as 95percent efficient. In other words, a CARB certified system has been tested and can be expected to achieved 95 percent or greater effectiveness in the removal of VOCs. The systems shown in Table 4-1 have all been documented to achieve 95percent efficiency or better.

4.4 IN-USE EFFECTIVENESS As stated previously, all Stage I1 systems certified in California have been shown to operatewith at least 95 percent removal efficiency. This efficiency is established during the 100-car test segment of the certification procedures. This 95percent emission reduction is the minimum required by districts in California and is required by ether States. However, after the equipment is installed and normal operation begins, associated wear and tear, malfunctions or systemproblems can result in reduction of certified efficiency. 4-4.1 In-Use Efficiencv The term in-use efficiency is used to reflect the actual average operating efficiency of the system. The in-

use efficiency takes into account system downtime, malfunctions, and defects that can occur relating to specific pieces of equipment. The in-use efficiency is calculated by determining the frequency of specific malfunctions and defects and assuming a specific efficiency decrease associated with each malfunction or defect. Factors affecting the in-use efficiency of a Stage I1 system include:misinstallation of aboveground or underground equipment; specific nozzle defects ormalfunctions; hoses tears, kinks, or liquid blockage;

vacuum vapor processor malfunctions; generally poor maintenance. Many defects ormalfunctions toequipment are as a result of the equipment being operated by thegeneral public. As a result, proper installationand maintenance of the equipment is a crucial factor in keeping the in-use effectiveness as close to 95percent as possible. Most of the discussion in this section describes the affect on efficiency of defects in aboveground equipment. Misinstallation of underground equipment can also cause significant decreases in efficiency. One person interviewed in California indicated that asmuch as 50 percent of the facilities could have problems in underground piping 

### installation^.^^ This emphasizes the importance of conducting the underground piping tests (liquid blockage, backpressure, and pressure decay) todetermine proper installation. Chapter 6 discusses these tests in more detail. Malfunctions or defective equipment left in operation can significantly reduce thevapor capture and hence the actual vapor reduction. Studieshave shown that the frequency of inspections made by enforcement personnel can affect the in-use efficiency

# . 29*30*3'*32 More frequent inspections will identify defective equipment, require replacement of the equipment, and, as a result, improve overall in-use efficiency. 4.4.2 In-Use Efficiency Calculations Several pieces of data are necessary to calculate inuse efficiency for a Stage I1program. First is a database of system malfunction and defects. This database is necessary toestablish the frequency of occurrence for specific defects. Secondly, an efficiency decrease must beassigned to eachmalfunction or defect. This efficiency decrease is an estimate .ofsystem efficiency decrease that

occurswith eachmalfunction or defect found. The overall in-use efficiency is then theproduct of the individual defect frequency and the efficiency decrease. The following equation is used to calculate in-use efficiency. El = ET [100-(F,)(ED,)][(loo-(F,) (ED,)

## I---[ F,) (ED,)

## I (100-

where: E, = In-use efficiency, %
E, = Theoretical or certification efficiency, 3 (typically 95percent) F, = Frequency of occurrence of defect x, 3
ED, = Efficiency decrease assigned to defect 

### x, 3 Table 4-2 lists common defects forvapor balance systems and the efficiency decrease associated with each defect. These efficiency reductionshave been developed and used by EPA in previous in-use efficiency The efficiency decrease assumptionswere in some cases obvious (i.e., no vapor recovery installed resulted in 100percent reduction in efficiency),while in other cases based on engineering calculations (i.e., tears in nozzle boots). Appendix E of this document contains an illustrativeexample of how touse this data togenerate an in-use efficiency estimate. The exampleprovided in Appendix E illustrates how State or local agencies can use a database of defects to estimate in-use efficiency. As new data becomes available, efficiency decrease estimates in Table 4-2 can be refined to better approximate efficiency reductions associated with each defect, and a detailed database of malfunctions can be obtained to estimate area specific in-use efficiencies. It should be noted that the example calculationsdo not include efficiency decreases due tounderground piping problems. For vacuum assist systems, malfunctions associated withTABLE 4-2. EFFICIENCY DECREASESASSOCIATED WITH STAGE I1 BALANCE SYSTEM DEFECTS

Defect

No Vapor Recovery Equipment Installed

(non-compliance)



# - Facilitieswith no equipment on any nozzle



# - Facilitieswith at least some vapor recovery Nozzle Damage Retractor Not Installed (allother V.R. equipment installed) Retractor Broken Boot and Face Seal, or Boot Only, Not Installed (V.R. nozzle installed) Torn Boot Face Seal Only Not Installed (remainder of V.R. equipment installed) Torn Seal Vapor Hose Not Installed Torn Vapor Hose No Seal-No Flow Broken Insufficient Hose Drainaqe

Source: 1987 RIA, Volume I, Appendix A. Efficiency Decrease Assigned (percent) 100

100

22

5

30 22

10 100

10vacuum blowers and vapor processors would have tobe included. 4.4.3 

### P R The in-use efficiency of a Stage I1 program is directly proportional toproper installation, operation and maintenance of the control equipment. Control agencies where Stage I1 has been installed have asserted different levels and frequenciesof compliance inspections and monitoring, and used public participation by complaint toll free numbers to assure Stage I1 compliance. This section of the document will focus on the end results of in-use effectiveness estimates of Stage I1 systems and programs. As discussed and described in the previous section, surveys of installed equipment in areaswith known levels of compliancemonitoring, and assumptionson the effect of damaged ormissing equipment, will allow the calculation of the effectiveness of a Stage I1 program in a given area. EPA has used this approach to calculate the effectiveness of Stage I1 in previous studies for supporting an analysis of Stage I1 versus onboard controls.35a36 These studies calculated in-use efficiencies of 92 percent with semiannual inspections, 86 percent with annual inspections and 62 percent with minimal or less frequent inspections. Figure 4-14 illustrates the relationship between inspection frequency and in-use effectiveness. The range of inspection frequencies shown on the graph is a simplification of actual inspection frequenciesand inmost cases actual inspection frequencieswill fall between the data points. EPA received a number of commentsduring the public comment periods on the estimates shown in Figure 4-14. Comments were received from auto manufacturers, control agencies, equipment manufacturers, and oil company trade associations that suggested both upward and downward adjustments to the Stage I1 in-use effi~iency.~' The EPA evaluated new data in an effort to update the in-use efficiency estimatesand included this asAppendix Ato the 1987 Draft RIA. As discussed previously in this chapter, EPA also examined a recent report on inspection of all Stage I1 service station installations in the Washington, D.C. area, and revisions were subsequently made tothe estimates for the frequency and types of defects affecting Stage I1 systems. Using this information,the Agency's estimate for the lower end of the Stage I1 efficiency range was adjusted from 56 to 62percent. The EPA also evaluated California Air Resources Board data, which were presented in the 1983 Report tothe ~egislature.~~ An attemptwas made to cull inspectiondata dealing with only thenewest Stage I1 systems. However, the data were insufficient todifferentiatebetween system type,

sono refinement of their 80-92 in-use efficiency rate could be obtained. The analysisused the average of this range. Additional data were obtained from randomly selected service stations in the Bay Area of California, which indicated an in-use efficiency of 90to 92percent; however, thedata were considered inadequate toupdate the in-use figure for the entire State of California. Therefore, the upper end of the in-use efficiency rangeused in the 1987 RIA was maintained at 86 percent. Since publication of 1987 RIA, additional data were obtained that included inspection results about 12,000 These inspections took place in nozzles in ~alifornia.~~ 1986 and 1987 in San Diego, San Francisco Bay Area, and in the South Coast (LosAngeles) areas of ~alifornia. Based on discussions with personnel in each of these areas, semi- annual inspectionswould best represent their inspection program (See Chapter 6). The data available allowed comparison between older and newer nozzle equipment. The results of these inspections indicated an overall in-use efficiency of 92.5 percent for all nozzles, 92 percent for older nozzles, and 94 percent for newer nozzle equipment. The data from these inspections isused inAppendix E for the illustrative example.Not taken in account in any of these in-use efficiency calculations is misinstallation of underground vapor piping. Figure 4-14 assumes 100percent proper installation, operation, and maintenance of belowground vapor piping system. In addition, Figure 4-14 presents only in-use efficiency of controls if they are installed at 100 percent of thedispensing facilities. Many areas may use size exemptions. Table 4-3 summarizes thegasoline consumption that would be exempted under different throughput level cutoffs. These gasoline consumption levels were calculated based on the size distribution information presented in Chapter 2. Figure 4-15 presents in-use efficiency for the different levels of exemptions. The curves are compared to the information in Figure 4-14, that represented essentially

no exemptions. In conclusion Figure 4-15 presents the range of in-use effectiveness of Stage I1 programs and its relationship to frequency of inspectionand exemption levels. While it is well documented that Stage I1 systems can achieve 95percent or better control efficiency, in-use efficiency is demonstrated to drop significantly without proper installation, operation, and maintenance by the owners and operators.TABLE 4-3. PERCENT CONSUMPTION EXCLUDED WITH VARIOUS STAGE I1 EXEMPTION SCENARIOS

PERCENT CONSUMPTION EXCLUDED FROM EXEMPTION SCENARIO REGULATION

EXEMPT STATIONS 2,000 GAL/MON 2.4%

EXEMPT STATIONS < 10,000 GAL/MON 2.8%

EXEMPT STATIONS < 10,000GAL/MON AND INDEPENDENTS < 50,000GAL/MON 10.0% + Exemption values based on metropolitan area throughput by model plant shown in Table 2-9, sincemost, if not all, nonattainment areas are.metropolitanareas. Table 2-10 was used to estimate exemptions for independents. The following assumptions were used:

< 2,000 gal/mon =Model Plant la

< 10,000 gal/mon =Model Plant 1

< 10,000 gal/mon non-independents, < 50,000 gal/mon independents =Model Plant 1 plus independents in Model Plants 2 and 34.5 REFERENCES McKinney, L. California Air Resources Board. Gasoline Vapor Recovery Certification. (Presented at theAir and Waste Management Association 83rd Annual Meeting. Pittsburgh, PA. June 24-29, 1990).
South Coast Air Quality Management District, "Phase I1Vapor Recovery Evaluation Program@@, 1979. California Air Resources Board. A Report to the Legislature on GasolineVapor Recovery systems for Vehicle Refueling at Service Stations. 1983.
Massachusetts Division of Air Quality Control. Stage I1 GasolineVapor Recovery Program Background Information and Technical Support Document. January 1989. Telecon. Bowen, E., Pacific Environmental Services, Inc., with Walker, G., Motor Vehicles ManufacturersAssociation, and Brooks, D., Chrysler Corporation. October 31, 1991. Fillpipe standardization.
Telecon. Norwood, P., Pacific Environmental Services, Inc., to Strock, D., Amoco Research. April 30, 1991. Amoco bellowless nozzle.
Reference 1.
Reference 1.
Reference 1.
Memorandum from Norwood, P., Pacific Environmental Services, Inc. to Shedd, S., U.S. Environmental ProtectionAgency, Chemicals and Petroleum Branch. February 22, 1991. Trip Report toNew Jersey Department of Environmental Protection.
Memorandum from Norton, R., Pacific Environmental Services, Inc. to Shedd, S., U.S. Environmental ProtectionAgency, April 29, 1991. Trip Report to New York Department of Environmental Conservation.
Memorandum from Norwood, P., Pacific Environmental Services, Inc. to Shedd, S., U.S. Environmental ProtectionAgency, April 30, 1991. Trip Report to CaliforniaAgencies to Discuss Stage 11.
Reference 12.

_ICalifornia Administrative Code, Section 41954.
State of California Air Resources Board, Certification Procedures for GasolineVapor Recovery at Service Stations, Method 2-2.
Reference 15.

State of California Air Resources Board, Test procedures for determining the efficiency of GasolineVapor Recovery systems at Service Stations, Method 2-1. California Administrative Code, Section 41955. California Administrative Code, Section 41957. California Air Resources Board Compliance Division, Gasoline Vapor Recovery Certification Program, Schedule of Test Fees. March 1991.
Reference 12.
Telecon. Norwood, P., Pacific Environmental Services, Inc. to Parrish, D.! Emco Wheaton. February 15, 1991. CARB 

### Certification program. Telecon. Norwood, P., Pacific Environmental Services, Inc. to Brown, B., OPW. April 13, 1991. CARB Certification Procedures. Telecon. Norwood, P., Pacific Environmental Services, Inc. to Zimmerman, G., CaliforniaAir Resources Board. October 17, 1991. Aboveground tank certifications.

Letter with attachments from Morgester, J., CaliforniaAir Resources Board, to Shedd, S., U.S. Environmental Protection Agency. May 17, 1991. Informationrelated to CARB Stage I1 program. Reference 15. Telecon. Norwood, P.! Pacific Environmental Services, Inc. toMcKlnney, 

### L., California Air Resources Board. May 13, 1991. Requirements of CARB Efficiency Test.
Reference 12.Evaluation of Air Pollution Regulatory Strategies for GasolineMarketing Industry. U.S. Environ- mental ProtectionAgency, Office of Air Quality Planning and Standardsand Office of Mobile Sources. EPA-450/4-84-012a. July 1984.
Draft Regulatory ImpactAnalysis: Proposed Refueling Emission Regulations for Gasoline-Fueled Motor Vehicles

# -- Volume I

# - Analysis of Gasoline Marketing Regulatory Strategies. U.S. Environ- mental ProtectionAgency. Office of Air Quality Planning and Standards and Office of Mobile Sources. EPA-450/3-87-001a. July 1987.
Reference 3. Sierra Research, An Analysis of Stage I1 and Onboard Refueling Emissions Control, prepared for Motor Vehicle Manufacturers Association, Inc. November 30, 1988.
Reference 29.
Reference 30.
Reference 29.
Reference 30. Evaluation of Air PollutionRegulatory Strategies for Gasoline Marketing Industry

# - Response to Public Comments. U.S. Environmental Protection Agency. Office ofAir Quality Planning and Standards and Office of Mobile Sources. EPA- 450/3-87-012c. July 1987.
Reference 3. Inspection Summaries of California Air Resources Board Phase I1Vapor Recovery Inspections. August 1986 throughOctober 1987. Received from McKinney, L., CARB. October 1991.5.0 STAGE I1 COSTS

The purpose of this chapter is topresent the costs associatedwith the purchase, installation, and operation of Stage I1 equipment. This cost information is useful to State and local regulatory authoritieswhen evaluating the cost impacts or burdens of a proposed Stage I1vapor recovery program, and toweigh these cost impacts against the emission reduction benefits achieved. In addition, this information is useful when reviewing cost burdens presented by commenterswhen implementing a Stage I1 program. Developing and evaluating cost estimates for Stage I1 systems has been a difficult task. 'EPAand industry have evaluated unit costs using unit cost estimate approaches as well as total cost estimate approaches from quotes from stations that have recently installed and purchased Stage I1 systems. In addition, these studies came at a timewhen each study was trying to influence a decision between Stage I1 and onboard refueling controls. These cost methods were used and issued in a number of recent Stage I1 cost studies by industry and EPA. The unit cost estimate approach was based onmodel station sizes and equipment specifications for all components in a Stage I1 system. The cost of each piece of necessary equipmentwas obtained, along with its installationand maintenance costs. These costs were then summed toproduce a "ground-upw estimate of Stage I1 costs. The total cost estimate approach, using cost quotes surveyed from stations that have installed Stage I1 equipment, is a simpler approach to obtaining Stage I1 costs, but has many drawbacks. Some stations keep detailedcost records on Stage I1 installationwhile others will have only the total cost. This makes comparison of costsvery difficult. Compounding this problem is most stations re- model or replace storage tanks or dispensers at the same time they are installing Stage I1 systems. These non-Stage I1 costs can, inmany cases, be much higher than Stage I1 installationscosts. Trying to compare a mixture of detailed and non-detailed cost quotes, and attempting to subtract out non-stage I1 costs, can not only be difficult and some times impossible toperform, but can add multiple assumptions and uncertainties intowhat were once "actualw Stage I1 costs. Without detailed costs it is also impossible to analyze the reasons associated with any outlier costs obtained from a total cost survey. This chapter discusses and presents results of both cost approaches, and compares all of the recent cost studies performed or provided to EPA toprovide the user with a range of costs touse in their own assessment. The costs presented in this chapter are divided into aboveground and below-ground components. Aboveground equipment consists of all the nozzles, hoses, swivels, check valves, and other related components needed at the dispensers to capture thevapors displaced during refueling. The costs presented are limited only to equipment that has been certifiedby the California Air Resources Board (CARB) and is currently being marketed for Stage I1 systems. The below-ground equipment consists of thepiping needed to route thevapors back to theunderground tank. The aboveground costs at a facility are driven by thenumber of nozzlespresent at the service station, while underground costs are driven by thephysical layout of the facility. Many times commenterswill present Stage I1 costs on a dollar per nozzle basis. But because underground costs are not dependent on thenumber of nozzles, and because underground costs can representmore thanhalf of the Stage I1 costs, reporting costs on a dollar per nozzle basis isnot very useful. This report presents costs for the entire vapor recovery system, broken down into aboveground and below-ground components. Because.therecan be an infinite number of service station configurations, costs are only presented for model facilities (discussed in Chapter 2), chosen to represent a cross section of the service station industry. Cost for key components (those having thebiggest cost impact and those requiring themost replacements) will be discussed. Becausemost areas implementing Stage I1 have been taking advantage of the California certification efforts by allowing only systems certified in California, component costs are presented only for certified components. In this chapter discussions of current equipment costs for above and below ground components are presented. Also presented is a discussion of capital and annual costs for model facilities, a comparison of model plant costswith several cost surveys conducted in St. Louis, and a presentation of the latest 1991 Stage I1 cost estimates.

5.1 EQUIPMENT, INSTALLATION, AND ANNUAL COSTS As discussed above, the costs are presented separately for aboveground components and underground components. Also presented in this section is a discussion of the impacts the underground storage tank (UST)program could have on Stage I1 implementation costs. 5.1.1 Abovesround Costs The aboveground costs are associated with thehardware necessary to capture thevapors displaced at thevehicle fillneck during vehicle refueling. The discussions of unit costswill be limited to certified components. Appendix D contains a list of CARB's certified systems and a list of the equipment specific to those systems. Most maintenance items and replacement components are associated with the aboveground equipment. The discussion in this section will be more detailed for the higher cost, more maintenanceintensive equipment (i.e., nozzles and hoses), and less detailed for the lower cost, less maintenance intensive equipment (i.e., swivels, checkvalves, etc.). Costs presented in this chapterdo not include costs for theAmoco bellowless nozzle system. As discussed in Chapter 4, full scaleproduction of this system has not occurred. 

### An Amoco representativestated that the actual installed costs once a wide spread production began could not be estimated at thispoint. 5.1.1.1 pozzles. The vapor recovery nozzles discussed in Chapter 4 are the key to thevapor recovery capture. Without a proper functioning and well maintained nozzle, emissions capture can be almost zero. Appendix D lists the nozzles approved for use for thebalance, hybrid, and vacuum assist systems. Information is presented for all configura- tions and generations of nozzles, however the costs in this sectionwill be presented only for the latest equipment on themarket today. Californiamaintains certification lists for older generation equipment sincemany of these systems are still being used. New Stage I1 programs, however, are excludingmost older equipment and are limiting acceptable Stage I1 systems to those of the latest design. For example,New York will allow only fourth generation or newer vapor recovery components1and St. Louiswill allow only coaxial nozzles and hoses and will not allow twin hose configurations

# . The newest of the certified balance nozzles are the A4005 from EMCO Wheaton, the lllV from OPW and theModel V from Husky. These are the only certified balance system nozzles being offered by the original equipment manufacturers. The cost for these nozzles and forvacuum assist nozzles are comparableat about Individuallythese cost seem small,but the costs canmount up quickly when there a large number of nozzles, especially if the station uses multi-product dispensers (themulti- product dispenser for this document refers to a dispenserproviding three products on each side of the dispenser, one nozzle per product, resulting in six nozzles per dispenser). The portions of the nozzlemost susceptible towear are the nozzle faceplate and bellows. These are also key items in thevapor capture system. These components cost about $15 for the fa~eplate,~ and about $30-50 for a bellows replacement kit.7#8 The life of the equipment will vary, but a service station can expect, on average, to replace bellows and faceplates about three times per year for balance systems and two times per year for vacuum assisted systems.9 Other components in the nozzle (i.e., shutoff mechanisms, no seal/no flow check valves, etc.) aremore difficult torepair. If these components fail, the nozzle usually has tobe replaced. The station operator can replace the nozzles with new equipment at the cost stated above or can reduce his costs by purchasing "rebuiltm nozzles. Rebuilt nozzles use the same core but with new components built inside. Nozzle manufacturers will rebuild nozzles and sell them back at a reduced price. The manufacturers buy back the cores of the used nozzles, repair and resell them as certified nozzles. Core credits given by themanufacturers are typically around $50. Rebuilt nozzle costs range from $145" to about $190." The State of New York only allows rebuilt nozzles repaired by the original equipmentmanufacturer. California, on the other hand, has certified rebuilt nozzles by two rebuilding companies, Rainbow and EZ-flo. These nozzles have been certified for use in balance system installations. The cost of these nozzles are about $190.'~ Table 5-1 summarizes the costs associated with purchase and maintenance of Stage I1 vapor recovery nozzles. 5.1.1.2 oses. The original Stage I1 systems incorporated a twin hose approach tovapor recovery. One hose transferred the liquid, as in conventional vehicle refueling, and an identical hose was used as a vapor return hose. These hoses were relatively inexpensive at aboutTABLE 5-1. PURCHASE COSTS FOR VAPOR RECOVERY NOZZLES AND REPLACEMENT PARTS~~~~' (May 1991 Dollars)

Item Cost Nozzle Costs New Nozzle Core Return Credit Rebuilt Nozzle

Component Costs Nozzle Boot Boot Kit Face Seal Kit Clamp Kit Boot Assembly Kit$30.'~ However, the twin hose systems were very hard to operate. Coaxial vapor return hoses eliminated the difficulties caused by twin hoses but cost considerably

more. Coaxial systems represent the latest technology in

use in California and are required on all new installations. They also are the only systems allowed in St.Louis, New York, New Jersey and Dade County, FL. A wide variety of materials and manufacturers are being offered for new Stage I1 coaxial hose systems. Manufacturers of certified coaxial vapor recovery hoses include Goodrich, Goodyear, Dayco, Gates and Thermoid. New hose materials make the latest hoses more durable and, at the same time, more lightweight and flexible. The costs for the coaxial hose range from $140 to $230.'~~'~~'~ (See Table 5-2.) Hose life has been extended greatly because of the new material, and because of the requirement for high hang hose retractors or high hang dispensers. These requirements force the hoses up off the ground and minimize or eliminate hose problems such as collapsed hoses from being run over by a vehicle, or hose tears and wearing from being constantly scuffed on the ground. With theuse of high hang hose retractors or high hang dispensers, it is conservatively assumed that vapor hose replacementwould occur only on an annual basis. High hang hose retractors and high hang dispensers also minimize vapor path blockage in thevapor hose caused by spitback or by liquid condensation. For high-hang multiproduct dispensers, venturi trap are required. These liquid removal systems consist of a small tube inserted in thevapor line extending to the low point of thehose. A venturi is placed in the liquid delivery hose and dispensed liquid passing through theventuri creates a vacuum in the tube. Thisvacuum draws the liquid from the low point in thehose into the liquid delivery hose. Liquid removal systems can be purchased separately or in conjunction with a coaxial hose assembly. These systems cost $200 if purchasedseparately17or $240-$430 if purchased with a coaxial hose a~sembly.'~Table 5-2 summarizes the costs associated with vapor recovery hose purchase and replacement. 5.1.1.3 Other Com~onents. Other components that must be purchased with the aboveground equipment could include high-retractor hose assemblies, hose breakaway fittings, vapor checkvalves, swivels (nozzle, island, dispenser, retractor), flow limiters, and hose splitters. Table 5-3 illustrates typical costs associated with these components. These pieces of equipment are not expected towear or fail at the same rate as nozzles, bellows, faceplates, or hoses, and are expected to operate relatively maintenance free. 5.1.1.4 Pis~enser Modifications. Product dispensers at existing service stationswill have tobe converted to allow the installation of vapor return piping. Conventional dispensers will typically have roomwithin the dispenser to allow thevapor piping riser to extend into the dispenser and exit out the side. Newer dispensers, such asmulti- product dispensers,may have tobe converted toallow the installation of thevapor piping through the dispenser housing and back into theunderground piping. California has included such dispenser modifications as part of a certified system since themanner inwhich the piping is plumbed through the dispenser could affect thebackpressure experienced in thevapor line at the nozzle, thereby affecting the system's ability torecover thevapors. Typical costs tomodify an existing dispenser is about $50-60. l9 5.1.1.5 Va~or Processors. The Hirt and Hasstech CARB certified vacuum assist systemsuse a thermal oxidizer as thevapor destruction device. The thermal oxidizer system necessary to transport vapors from theunderground tank to thevapor processor consist of a pilot/ignition system, vapor pump, PV vents, etc. The cost of a vapor processing system is about $4,000.20TABLE 5-2. TYPICALVAPOR RECOVERY HOSE COSTS'~~'~~'~ (May 1991 Dollars)

Itema Costs

Coaxial Hose

Liquid Removal System

Coaxial Hose with Removal System

a Costs presented for a typical 10 foot hose system.

TABLE 5-3. TYPICAL COSTS OF OTHER VAPOR RECOVERY COMPONENTS'~~'~~'~ (May 1991 Dollars)

Item Costs High hang hose assembly Hose break away fittings Vapor check valves Swivels Nozzle Island Dispenser Retractor Flow limiters Hose splittersThe vapor pump and thevapor processor will require additional adjustments and repairs. It has been estimated that annual maintenance costswould be asmuch as $400-600 21 per year. 5.1.1.6 Jnstallatioq. Installation of the aboveground equipment consists of assembling the hoses, nozzles, swivels, checkvalves, etc., and attaching the nozzle/hose assembly to thevapor piping exiting the dispenser. It has been estimated that installation would cost about $80per nozzle. If a vacuum assist unit is being installed an additional $1,300would be necessary to take care of the thermal oxidizer and vapor pump in~tallation.~' The Healy System requires the installation of the jet pump used to create the vacuum in the vapor return line. It has been estimated that the installation of the jet pump would cost $535.23 5.1.2 Underaround Pi~inq The underground portion of the vapor recovery system consists of all the underground piping and fittings necessary to allow the captured vapors tobe returned to the underground storage tank. Costs of the underground components are directly affected by the service station configuration (i.e., the number of islands, the distance between islands, the distance from the islands to the underground tank), the type of system (individual balance system, manifolded balance system, hybrid system, or vacuum assist system) and other station physical characteristics (amount of concrete over underground tanks, amount of backfill material required, orwhether the storage tanks are located above the islands). The following subsections discuss some of these costs inmore detail. 5.1.2.1 Va~or Pi~inq.Most vapor recovery piping being used in recent installations consists of fiberglass pipe. Reasons usually cited for using this type of piping is that it is leak resistant, easy towork with, and easy to install (i.e., glued not threaded). Typical vapor pipingconsists of 2 inch or 3 inch pipe laid in a trench, sloping down to the underground tank. The amount of piping required is certainly affected by specific facility distances, but also whether individual ormanifolded vapor piping is used.24 Table 5-4 summarizes the piping differences between a manifolded vapor balance system and an individual vapor balance system. Vacuum assist systems can either be manifolded or individual. Table 5-5 summarizes the piping costs for different certified systems assumed for a typical 9 nozzle, 65,000gallon per month service station. 5.1.2.2 Trenchins and Backfillinq. Themajority of the costs associated with theunderground piping tied to the costs of digging the trenches. The trenchesmust be dug from the dispensers to the underground tanks to allow the laying in of thevapor piping, assuring proper slope from the dispensers down to theunderground tanks

# . Further costs are involved with backfilling the trenches and repairing the pavement. Digging the trenches requires cutting through the concrete pad over the storage tanks and at the islands, probably shutting down the station, and using a backhoe to dig the trench back to the underground tanks. Costs associated with trenching are difficult to obtain since it is not hardware related, but consists of labor and heavy equipment charges. From a previous analysis, EPA derived trenching and backfill costs based upon an estimate obtained from a Stage I1 system installer. This cost averaged about $30 per foot of trench.25 A great deal of importance is given to the proper installation of theunderground piping. Improper slope, poor backfilling, and ground settling all can cause breaks

or low points in thevapor piping system. Breaks in the vapor piping can cause vapor leaks in the system, and low points in the piping can provide the potential for liquid accumulation resulting in liquid blockage. Some areas of California have indicated that asmany as 50 percent of the underground systems are incorrectly installed.26TABLE 5-4. PIPING COMPONENT DIFFERENCES BETWEEN INDIVIDUAL AND MANIFOLDED BALANCE 

### SYSTEM'^

Number of Components Individual Manifolded Underground Components Balance System Balance System Galvanized Pipe forVapor Risers 1" Pipe (FT) 211 Pipe (FT) 3" Pipe (FT) 3/411 CloseNipple 1" CloseNipple 211 Close Nipple 3" CloseNipple 1" Elbow 211 Elbow 3" Elbow 1"x 3/411 Reducer 2" x 1" Reducer 311 x 2" Reducer 411 x 211 Bushing Fiberglass Pipe forVapor Return Piping 211 Pipe (FT) 311 Pipe (FT) 2" Threaded adapter 3l1 Threaded adapter 2" Elbow 311 Elbow 2" Tee 311 Tee 211 Coupling 3" Coupling 3" x 211 Reducer Glued Junctions Additional Items 411 x 3" Tank Bushing 211 Float Check Valve Vent Manifold Drum BungsTABLE 5-5. TYPICALVAPOR PIPING COSTS FOR 65,000 GALLON 

### PERMONTH SERVICE STATION"

Vapor Pi~inq Costs Individual Balance System
Manifolded Balance System

Healy Assist System

Vacuum Assist Systema

a Average of both the Hirt and Hasstech certified vacuum assist systems.California, New York and several other Stage I1 areas in the country now require tests tobe conducted on the underground piping. These tests, discussed in Chapter 6, consist of the liquid blockage, pressure decay, and backpressure tests. It is estimated that the costs to perform these tests is a total of $670.'~ A common occurrence over the last several years is that station owners across the country have been installing Stage I1 underground piping whenever modifications were undertaken that required excavation. This will reduce installation costs for a great number of stations. 5.1.3 Affects of the UST Proaram Stage I1 installation costs can be affected by a simultaneous Stage II/UST program implementation by considering the cost savings of installing Stage I1 at the time underground tanks are being repaired or replaced. The potential cost savings are realized in reduced trenching and paving costs thatwould have been attributed to the Stage I1 installation in the absence of any UST activity. The key items for determining the impacts of a simultaneous Stage II/UST program on installation costs is todetermine how many tank system leaks will occur and what equipment will be excavated during repairs or replacement. Several assumptions had tobe made concerning the number and type of repairs required under an UST program. These assumptions on number or frequency of repair are drawn from a previous analysis and are presented in Table 5-6. Table 5-6 further summarizes the possible actions taken in response to finding a leak in either the underground piping or underground tank. For each remedy action, the percent of all tank systems assumed touse that remedy is listed. A description is added that summarizes the resulting savings in Stage I1 trenching associated with each remedy. For example, both Actions 1 and 4 (dig up all piping, and dig up all piping and tanks) result in theTABLE 5-6. ACTIOWS TAKEN INRESPOllSE TO FINDINGA LEAK INAN UNDERGROUNDTANK SYSTEM^

Percent of Costs ~avd Percent Dercript ionof Savings Undcrgrwnd Total of all inStage I1Piping Installation Capital

. Capital Anrnu~l Action Systems Costs Costs Costs 1. Digupallpiping 4.5% Alltrenchingcosts 65% 40% 25%

2. ~ig upmdof tanks only 11.8% Trenching costsover mdof alltanks 10% 

### n 5%

3. Digup mdof tanksend vdcr 1.3% Trenchingcostsweralltmksandvdcr 30% 20% 15% di

spmser s alldispensers

4. Dig ~p allpipingandtanks 12.5% Alltrenching costs 65% 40% 25%

5. Diguponlyonetank 1.OX Trenchingcostsover one tank 8% 5% 3%

3.1% 6. Repairone leakingtank 

# - Trenchingcostsover one tank 8% 5% 3%

Total 35.0%

Cost percentagesfor atypical 65,000 gallon/month station.

### savingsof alltrenchingcosts. Also presented inTable 5-6 is

### theresultingpercentage savings intotalStage 11

### costs thatwould occurunder each action. A 

### furtherdiscussionof cost savingsassociatedwith simultaneousStageII/UST programs can be found inAppendix K 

### of the 1987

### Regulatory Impact Analysis (RIA), 

### Volume I 

### concerninggasolinemarketing strategies.28 5.1.4 

### Pecoverv Credits Another aspect of theannual costs forStage 11 

### systems is

### recovery credits. As

### discussed inChapter 2, 

### thereturn of saturatedvaporstothe storagetank duringvehicle fuelingeliminatestheinbreathingof freshairand subsequent evaporation of liquidgasoline. Each gallonof gasolinethat is

### prevented from evaporatingrepresents a gallon of product thestationowner can sell

### thatwould not be 

### present intheabsence of Stage I1 

### controls. The earningsgenerated from thisgasolinethatwould have otherwisehave evaporated arecounted asrecovery credits. 

### Recovery creditsmay be calculated asfollows. Assuming 95 

### percent recovery of both displacement and emptying losses,

recoveredvapor = ((1,340 mg/liter)(.%)) + ((120 rg/liter)(.%)) = 1,387 mg/liter. 

### Example of recoverycredit:
1,387 mg/liter x 75,700 liters x

# axliterx 12 mo. x W.275/liter = S5Wyear. ID. 10mg 0.67kg yr 

### 5.2 MODEL PLANT COSTS 

### Costs inthissectionarepresented forthemodel plantsdescribed inChapter 2 

### of thisreport. Because of the infinitevariations inservice 

### stationlayout and design, model plantswere developed torepresent the industry and tofixthephysical parameters of each facility. Inadditiontotheitems

### specified inTable 2-5, 

### such asthroughput and number of nozzles, thephysical design of eachmodel stationwas developed. This includeddistances from the dispensers to the tank to fix trenching lengths, and designs of piping scenarios to fix piping costs. A detailed cost model was developed by EPA, in the 1987 Draft Regulatory ImpactAnalysis (RIA),that created "ground-upw costs for each model plant.a Thismodel used the piping layoutsdescribed above and detailed component costs for aboveground equipment. Costs were obtained for all certified equipment and averaged to estimate capital and installed costs for each component. Costs were also obtained for fiberglasspipe and fitting costs, installation labor, and trenching costs. For convenience, a detailed discussion of thismodel is reproduced inAppendix B of this document.

5.3 COMPARISON OF RECENT COST STUDIES EPA solicited and received public comments on the 1987 RIA associated with the proposal of onboard controls for vehicle refueling. EPA received public comments concerning Stage I1 costs frommany sources including oil companies, service station dealers, and automanufacturers. Of particular interest to EPA were comments received from the American Petroleum Institute (API) 30 and from Multinational Business Services, Inc. (MBS)~'(under contract to the Motor Vehicle ManufacturersAssociation and theAuto Importers of America). These comments were of interest because these two groups conducted their own cost analyses of Stage I1 equipment installed in St. Louis and attempted a comparison with the EPA cost analysis found in the Draft RIA on the onboard proposal, (seeAppendix B). The majority of the remaining comments provided little or no cost breakdown, making cost comparisons impossible. In addition to comments received on Stage I1 costs, Pacific Environmental Services, Inc. (PES),under EPA contract, conducted an independent analysis of Stage I1 installation costs in St. Louis, Missouri and compared the costs they obtained with theindustry studies and with the Draft 

### RIA.^^ Stage I1 costs in St. Louis were considered important at that time because Stage I1 installations were recently completed in this metropolitan area, and conflicting cost information was received during the public comment period. As stated before, the Draft RIA used a "ground-upw model of Stage I1 costs,whereas, theAPI, MBS, and PES studies were all surveys of Stage I1 costs in St. Louis. As discussed earlier in this chapter, direct comparison of cost surveys conducted by different groups is often difficult especially if cost breakdowns are not available. Cost breakdowns allow an analysis of themake-up of the costs, and ensures that like costs are being compared (i.e., only Stage I1 related costs were included in the reported costs). Cost breakdowns and raw data for all industry surveys were not available to allow direct comparison to EPA cost models. 5.3.1 Ca~ital Cost Com~arison Stage I1 system installed capital cost estimates from all data sources are shown in Table 5-7. These average Stage I1 system costs are graphically depicted by model plant category in Figure 5-1. This plot is useful in making "snapshotu comparisons among the data sources for each of themodel plant categories. In order to determine a trend or relationship among each of the subject data sets, a linear regressionmethod was used. The linear functionwas determined asmost representative, based on the use of correlation coefficient (R-squared)values as criteria for best fit. Figure 5-2 illustratesthe relationship of capital cost versus model plant category after the application of the "best fitw line. No informationwas presented in the API Report to explain why the "majorw costs

were somuch higher than the "Jobberwcosts. Because of the large differences these costs are depicted separately on these figures. Capital cost data submitted by API suggested that EPA had, on average, understated costs by about 40 percent.TABLE 5-7. SUMMARY OF STAGE I1 SYSTEM CAPITAL COST ESTIMATES FROM ALL SOURCES~~~~~~~~~~'

Model Plant Total System

No. Cost Estimate Source Capital Costs

a No data reported.Capital costs submitted by MBS suggested EPA had, on average, overstated costs by about 20 percent. Stage I1 costs published in the Draft RIA with the onboard proposal fellbetween the costs submitted by these commenters. In addition, the St. Louis data obtained by PES also fell between theAPI and MBS costs and compared favorably (within 5 percent) with the Draft RIA costs. The fitted curves of Figure 5-2 illustrate that PESacosts were close tothe Draft RIA costs for the smallermodel plants and between the Draft RIA and API costs for the largermodel plants. 5.3.2 Annual Cost Conmarison The commenters supplied annual costs associatedwith the estimated capital costs of the Stage I1 systems on a model plant basis. However, difficulties arose in summarizing and comparing these costs because each commenter used different cost assumptions for: (1)annualized cost of capital, (2).maintenancecosts, (3)recovery credits, and (4)thenumber of nozzles assigned to eachmodel plant. In

an effort tonormalize thesevariations, each~capital cost estimate presented in Section 5.3.1 was converted to annualized costs using EPA1scost methodology from the Draft RIA and using the same assumptions for equipment life

(8years aboveground equipment, 35 years below-ground equipment), interest rate (10percent), taxes and insurance

(4percent), and calculationand costs dealing with recovery credits.33 Maintenance costs'wereconsidered the same for each annual cost estimate. Table 5-8 summarizesthe annual cost estimates normalized using the assumptions above. These estimates are graphically depicted in Figures 5-3 and 5-4.

5.4 CURRENT COSTS OF STAGE I1 SYSTEMS Based on the comparisonsdiscussed in Section 5.3, it

can be concluded that the ground-up model from the Draft RIA

(reproduced and presented in Appendix B) provided a reasonable estimate of actual Stage I1 installations. ThisTABLE 5-8. SUMMARY OF NORMALIZED STAGE I1 SYSTEM ANNUAL COST ESTIMATES FROM ALL SOURCES

Model Plant Normalized Annual

No. Cost Estimate Source Costs

1 Draft RIA $1,270 API-Jobber $2,045 API -Maj or NAa MBS $1,288 PES $1,244



## .........................................................

Draft RIA $1,280 API-Jobber $1,953 API-Major NAB MBS $1,195 PES $1,515



## .......................................................................

Draft RIA $2,380 API-Jobber API-Major MBS PES 4 Draft RIA $2,960 API-Jobber API-Major MBS PES $2,726 5 Draft RIA $2,430 API-Jobber API-Major MBS PES

a Cannot be calculated sinceno capital costs reported.model was, therefore,used to estimate current 1991 Stage I1 costs. The model in Appendix B was used, but replacing key component costs to reflect 1991. Table 5-9 contains a summary of the cost data changed from the Draft RIA analysis to generate 1991 costs. As stated earlier in this document, multi-product dispensers, offering each of three gasoline grades on each side of the dispenser, have increased in popularity in recent years. The Draft RIA made an attempt to estimate themix of single and multi-product dispensers to calculate a national Stage I1 cost impact. For purposes of this document two separate estimates have been made, one to represent single dispensers and one to representmulti- product dispensers. Table 5-10 summaries 1991 capital costs of Stage I1 systems for single dispenser facilities and 1991 capital costs for multi-product dispensers. Annualized costs were also calculatedusing the approach discussed in Appendix B, but using the 1991 capital costs and the 1991 RVP and gasoline price for recovery credit calculations. Table 5-11 summarizes annual costs for single and multi- product dispensers, respectively. Another important factor to considerwhen reviewing Stage I1 costs is system cost effectiveness. Cost effectiveness is the annual operating costs divided by the annual emission reduction,yielding a value of dollars spent per unit measure of emission reduction. Table 5-12 presents the 1991 cost effectiveness of Stage I1 systems, expressed

as dollars per megagram of emission reduction. Again, values are presented for both single and multi-product dispensers facilities. The program effectiveness or overall emission reduction is dependent on the exemption level selected, as indicated in Section 4.4.3. The cost effectivenessof the program is also dependent on the exemption level imposed. Smaller facilitieshave higher cost effectiveness values (see Table 5-12). Program cost effectiveness, therefore, improvesbyTABLE 5-9. SUMMARY OF COST ITEMS CHANGED IN APPENDIX B COST MODEL TO OBTAIN 1991 COSTS

Item Cost Nozzle Costs (New) Emco Wheaton OPW Husky Nozzle (Rebuilt) Emco Wheaton EZ-f10 (OPWor Emco Wheaton) Component Costs (Spout kit) Emco Wheaton Husky OPW EZ-flo (OPWor Emco wheaton) Boot Kit EZ-flo Husky Emco Wheaton Hoses (10 ft, 

### w venturi) Thermoid Goodyear Dayco Hoses (10 ft., w/o venturi) Thermoid Goodyear Dayco Breakaways (onetime) Dayco Husky Breakaway (reconnectable) Husky Petroleum EMCO WheatonTABLE 5-9. SUMMARY OF COST ITEMS CHANGED INAPPENDIX B COST MODEL TO OBTAIN 1991COSTS (CONTINUED)

Item Cost MiscellaneousEquipment 12" whiphose Goodyear 42.54 Themoid 48.76 Dayco 47.69 RetractorClamp Goodyear Thermoid EZ-flow (Dayco) (Goodyear, Thermo, and Gates) HighHang HoseRetractors Catlow

Swivels 50.50TABLE 5-10. 1991 STAGE I1 BALANCE SYSTEM CAPITAL COST

COMPONENT COST OF COMPONENT SINGLE MULTIPRODUCT MODEL PLANT 1 DISPENSER DISPENSER Number of Nozzles Dispenser Direct Cost Piping Direct Cost Total Capital Cost MODEL PLANT 2 Number of Nozzles Dispenser Direct Cost Piping Direct Cost Total Capital Cost MODEL PLANT 3 Number of Nozzles Dispenser Direct Cost Piping Direct Cost Total Capital Cost MODEL PLANT 4 Number of Nozzles 9 Dispenser Direct Cost 7,120 Piping Direct Cost 9,690 Total Capital Cost 16,810 MODEL PLANT 5 Number of Nozzles 15 30 Dispenser Direct Cost 11,860 24,060 Piping Direct Cost 12,650 12,650 Total Capital Cost 24,510 36,710TABLE 5-11. 1991 STAGE I1 BALANCE SYSTEM ANNUAL COST

COMPONENT COST OF COMPONENT SINGLE MULTIPRODUCT MODEL PLANT 1 DISPENSER DISPENSER Capital Recovery Cost Maintenance Cost Other Indirect Costs Recovery Credit Total Annualized Cost MODEL PLANT 2 Capital Recovery Cost 939 Maintenance Cost 617 Other Indirect Costs 293 Recovery Credit 518 Total Annualized 1,331 Cost

MODEL PLANT 3 Capital Recovery Cost Maintenance Cost Other Indirect Costs Recovery Credit Total Annualized Cost MODEL PLANT 4 Capital Recovery Cost Maintenance Cost Other Indirect Costs Recovery Credit Total Annualized Cost MODEL PLANT 5 Capital Recovery Cost Maintenance Cost Other Indirect Costs Recovery Credit Total Annualized CostTABLE 5-12. COST EFFECTIVENESS OF 1991 STAGE I1 BALANCE SYSTEMSa

Single Multiproduct Dispenser Dispenser MODEL PLANT 1 Annualized Costs, $ Emission Reduction, Mg Cost Effectiveness, $/Mg MODEL PLANT 2 Annualized Costs, $ Emission Reduction, Mg Cost Effectiveness, $/Mg MODEL PLANT 3 Annualized Costs, $ Emission Reduction, Mg Cost Effectiveness, $/Mg MODEL PLANT 4 ~nnualized Costs, $ Emission Reduction, Mg Cost ~ffectiveness,$/~g MODEL PLANT 5 Annualized Costs, $ 2,735 4,943 Emission Reduction, Mg 9.7 9.7 Cost Effectiveness, $/Mg 280 510

a Emission reduction from Table 3-8, and assuming annual enforcement (86percent in-use efficiency).exempting higher cost facilities. Table 5-13 summarizes program cost effectiveness when compared to certain exemption levels. This table was calculated based upon the model plant cost effectiveness values presented in Table 5-12 and themodel plant distribution values contained in Tables 2-8 and 2-10. Values are presented for facilities with either single dispensers ormultiproduct dispensers, as in Table 5-12, but also an average cost that assumes equal distribution of single and multiproduct dispensers.TABLE 5-13. PROGRAM COST EFFECTIVENESS COMPARED TO EXEMPTION LEVEL

Program Cost Effectiveness (S/Mg

### 1 Program Single Multiproduct Exemption Level Dispenser Dispenser Averagea
No Exemptions

Ex < 10,000 gal/month 820 1,210 1,020 Independents < 50,000 gal/month

a Average assumes equal distribution of single and multiproduct dispensers.5.5 REFERENCES
Memorandum from Norton, R., Pacific Environmental Services, Inc. (PES),to Shedd, S., U.S. Environmental ProtectionAgency. April 29, 1991. Trip Report

# - New York Department of Environmental Conservation. Telecon. Bowen, Elizabeth, Pacific Environmental Services, Inc. (PES) with Pratt, B., State of Missouri. May 30, 1991. Stage I1 Program Implementation.
EMCO Wheaton Price List, March 1991.
Telecon. Bowen, E., Pacific Environmental Services, Inc. (PES) with Holcom, C., Husky Corporation. April 30, 1991. Stage I1 Nozzle Costs.
Telecon Bowen, E., Pacific Environmental Services, Inc. (PES),with Taylor, B., OPW. May 29, 1991. Stage I1Nozzle Costs.
Reference 3.
Reference 3.
Reference 4.
Draft Regulatory ImpactAnalysis: Proposed Refueling Emission Regulations for Gasoline-Fueled Motor Vehicles

# -- Volume I

# - Analysis of Gasoline



### - Marketing Regulatory Strategies. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards an and Office of Mobile Sources. Publication No. EPA-450/3-87- 001a. July 1987. Appendix B, Table B-15. Telecon. Norwood, P., Pacific Environmental Services, Inc., with Friedman, G., EZ-flo. October 4, 1991. Stage I1 Equipment Costs.
Reference 3. Fax communication to Bowen, E., Pacific Environmental Services, Inc. (PES),from Carmack, M., Catlow. May 8, 1991. Price List for Stage I1 Equipment. Reference 9,Appendix B, Table B-2.Telecon. Bowen, E., Pacific Environmental Services, Inc. (PES)with Terlizzi, L., Thermoid. April 30, 1991. Stage I1 Equipment Costs. Telecon. Bowen, E., Pacific Environmental Services, Inc. (PES) with Whittington, G., Goodyear. May 6, 1991. Stage I1 Equipment Costs.

Fax Communication to Bowen, E., Pacific Environmental Services, Inc. (PES) from Gelle, B., Dayco. May 15, 1991. Stage I1 Equipment Price List.
Reference 12.
Reference 14, 15, 16.
Reference 13.
Reference 9, Appendix B, Table B-5.
Reference 20.
Reference 20.
Reference 20.
Reference 9, Appendix B, Table B-11.
Reference 24.
Memorandum from Norwood, P., Pacific Environmental Services, Inc. (PES)to Shedd, S., U.S. Environmental Protection Agency. April 30, 1991. Trip Report to California Agencies to Discuss Stage I1 Programs. Wakim, Paul, C. J. Sample, K.A. Rooney, and D. Clemons (AmericanPetroleum Institute). API Survey of Actual Stage I1 Implementation Costs In The St. Louis Metropolitan Area. American Petroleum Institute. December 2, 1988.
Reference 9, Appendix K.
Reference 9,Appendix B.
Reference 26. Responses to Points Raised by EPA Concerning the MBS Study "Costs and Cost-Effectiveness of Stage I1 and Onboard Refueling Vapor Controlsw (April 1987). Multinational Business Services, Inc. (MBS)

# . October 1987.32. Norton, R. and Scott Osbourn (Pacific Environmental Services, Inc.). Evaluation of Stage I1Vehicle Refueling Control Equipment InstallationCosts. Prepared forU.S. Environmental ProtectionAgency. November 28, 1988.

33. Reference 9.6.0 PROGRAM IMPLEMENTATION

As discussed in Chapter 1, Stage I1vapor recovery has been a part of VOC emission control in California for some time. Since the introduction of Stage I1vapor recovery California in the early 70ts,thisprogram has become one of California's major VOC control strategies. Seventeen districts in California containing areas that are classified nonattainment for ozone have Stage I1programs that have been in effect for over a decade. The remaining districts in California have also recently adopted regulations requiring Stage I1vapor recovery for benzene control. Other areas of the country have also established Stage I1vapor recovery programs. The District of Columbia implemented a Stage I1 program in the early 1980s and Missouri adopted vapor recovery regulations in the St. Louis

area later in the 80s. In the late 1980s and early 1990s several other States and local agencies have adopted Stage I1 programs. These areas include New Jersey, New York (New York City metropolitan area)Massachusetts, Pennsylvania, Washington, Oregon, and Dade County, Florida. The CAAA of 1990 require the installation of Stage I1vapor recovery systems in many ozone nonattainment areas. Based on final nonattainment designations, thiswould affect almost 60 metropolitan areas in theUnited States. The purpose of this chapter is toprovide information

on theplanning, implementation, and enforcement of Stage I1 programs in other States. Incorporated into thisdiscussion are examples of how areas with current Stage I1 programs handle certain situationsand issues. This ranges from experience in areas such as San Diego which has almost 20 years experiencewith Stage 11 to areas such asMassachusetts and Dade County, Florida with programs only recently adopted. Appendix F provides summaries of many of theprograms in the United States. For each program, Appendix F provides a description of the program with problems encountered and recommendations for new areas based

on their experience. In addition, items such as permit applications, inspection checklists, etc. are included for

some of the areas.inAppendices G-K. Specifically, this chapter addresses planning elements, regulations, and permitting and enforcement considerations. The EPA enforcement guidance document should be consulted for guidance on enforcement issues.

6.1 PLANNING The planning of a Stage I1 program involves several considerations including the characterization of the affected industry and the estimation of environmental and economic impacts. The information contained in other chapters of this document can aid in the determination of

some of these factors. An important consideration from the outset of Stage I1 program planning is towork closely with other agencies that may be affected by the program. For instance, the department or agency responsible for themeasurement and accuracy aspects of gasoline dispenserswould probably have

an interest in such a program. Other agencies that are concerned with safety aspects, such as the Occupational Safety and Health Administration (OSHA)and the Fire Marshal, will also be affected by Stage I1 and should be consulted. The significanceof working with these types of agencies is evident in the California certification process discussed in Chapter 4. Before a Stage I1 system is certified, it must meet the approval of California Division of Measurement Standards, California OSHA, and the California Fire Marshal, in addition tomeeting the requirements of the California Air Resources Board (CARB).It may be beneficial to contact these types of agencies at the beginning and solicit their involvementwith the Stage I1 program. 6.1.1 Characterizationof theAffected Industrv Chapter 2 characterizesthe industry affected by Stage I1 regulations. A service station is defined as any site where gasoline is dispensed tomotor vehicle fuel tanks from stationary storagevessels. This includes public (retail) and private facilities. Miscellaneous retail outlets that are considered service stations include conventional service stations, convenience stores,mass merchandisers, marinas, parking garages, and other similar facilities which sell gasoline to thepublic. Private facilities include those locations where gasoline is dispensed into government agency (Federal,military, State, and local) vehicles, fleet (auto rental, utility companies, taxis, schoolbuses, etc.) vehicles, and trucking and local servicevehicles. In order to estimate the impactsof a Stage 11 regulation, it is necessary to identify thenumber of facilitiespotentially affected and thevolume of gasoline dispensed at these facilities. 6.1.1.1 Number of Facilities. The number of facilities can be estimated using a variety of techniques. Sincemost areas thatwill be required to install Stage I1 have previously been classified asnonattainment for ozone, it is likely that Stage I vapor recovery regulations exist in these areas. The Stage I permit files can be used to supply an estimate of thenumber of potentially affected facilities. Other possible sources of this type of informationare recordspertaining tounderground storage tanks, Department of Weights and Measures, tax records, local fire departments or even phone directories. In the absence of actual records or data, local or State trade organizationscould be contacted. Also, information such as the survey completed by NPN discussed in Chapter 2 provides retail service station numbers on a Statebasis. These could be used and adjusted toa smaller geographic area using a factor such aspopulation or gasoline throughput. 6.1.1.2 Area Gasoline Throuah~ut. The combination of the area gasoline throughput and the emission factors discussed in Chapter 3 will provide an estimate of the uncontrolled emissions fromvehicle refueling. If gasoline taxes are imposed in the study area, records relating to gasoline sales should be available at the tax office. If the study area entails an entire State, 

### NPN annually estimates gasoline consumption on a State basis. Gasoline consumption and methods of estimating gasoline consumption

on a county level are also discussed in Chapter 2. 6.1.1.3 Size Distribution of Facilities. The distribution of facilitiesby throughput and according to the number of nozzles is important. Ideally, an agency could obtain detailed information regarding the number of service stations, the associated gasoline throughput, and the number of nozzles. However, in the absence of the

resources necessary todevelop such a database, it is possible todraw comparisons between the areas covered by the Lundberg data discussed in Chapter 2 and summarized in Appendix A and the agency's regulated area. The data can be used to estimate size distributions for counties in designated population ranges orwith a known number of service stations. For example, if a county's population is approximately 50,000, the counties of Union, Hudson, and Monmouth, New Jersey could be selected fromAppendix A as counties with comparable populations. The size distributions of these three counties could then be averaged topredict a size distribution for the study area county. Model plants could then be developed which include the number of nozzles and gasoline throughput. Alternatively, themodel plants provided in Chapter 2 may be used. The distribution of facilities could be applied to themodelplants to estimate the number of facilities representedby each model plant. 6.1.2 

### E s The population and distribution of facilities, gasoline consumption, individual facility costs, and planned enforcement levels are used topredict environmental and economic impacts. 6.1.2.1 Environmental Im~acts. The emission reductions anticipated from the regulationmay be estimated by calculating the uncontrolled emissions and multiplying these emissions by the expected overall effectiveness for the program. The uncontrolled emissions can be calculated by multiplying the gasoline throughputby the uncontrolled emission factor discussed in Chapter 3. The overall, or in- use, effectivenessmay be estimated according to the expected level of effort which the agency plans tohave available for the program. In-use effectiveness is discussed in detail in Chapter 4. In order to evaluate the impacts associated with exemption levels, the throughput for the number of facilities in model plants that fall below the anticipated exemption cutoff should not be multiplied by the selected control level or use the Stage I1 program efficiencies shown in Chapter 4 with exemption levels already assumed. 6.1.2.2 Economic Im~acts.Costs initially must be estimated on a facilitybasis. The agency may choose to gather information specific to their area regarding installation, equipment, and maintenance costs for these systems. If resources are not available for such a detailed analysis, Chapter 5 discussed costs of Stage I1with model plant costs. Model plant costsmay then be multiplied by the number of facilitiesassigned for each model plant to estimate the total area impacts. The overall cost in relation to the emission reduction, or cost effectiveness, may then be calculatedby dividing the overall cost by the overall emission reduction. Sincethe cost effectiveness for smaller facilities is higher due to the lower gasoline throughput and resulting lower emission reduction and recovery credit, cost effectiveness is often used todefine exemption levels for these smaller facilities. 6.1.3 public Awareness Public acceptance is vital to the success of any Stage I1program. The slightvariations in the operation of Stage I1 equipment can annoy uninformed customers and lead to improper use possibly reducing efficiency and the incorrect conclusion that the equipment is faulty. Therefore, an agency should consider ways to inform and educate thepublic about the Stage I1 program. Many regulations require that operating instructions be placed at thepump. This is perhaps the simplest and most straightforward method of providing the public information about the operation of Stage I1 equipment. Another method used, especially in California, is a toll free complaint number. The number is placed on the pump with the operating instructions and is specifically for Stage I1 complaints. California officials have indicated that in the earlier periods of Stage 11, these lines were used by thepublic often toexpress discontent with Stage 11. However, as the public has become more aware of the equipment, the complaint lines have evolved into a form of public compliance program, where persons call in with reports of faulty ormissing equipment. In addition to the operating instructions and telephone number, the agency can develop a public awareness program. The publication and distribution of brochures, pamphlets, fact sheets, etc. is amanner of providing information to thepublic. Such a pamphlet fromMassachusetts is provided in Appendix G-1. The use of themedia todescribe Stage I1 has been used successfully in ~alifornia. Television, radio, and newspaper spots have described the environmentaland personal health benefits associated with Stage I1 and an explanation of operatingprocedures. While these public awareness measures are important to gain acceptance of Stage 11, service station employee

awareness and educationmay have a more significant impact on reducing emissions. It is extremely helpful if these employees are knowledgeableof the operation and maintenance requirements of Stage I1 equipment. There are several ways that an agency can promote this. They can provide workshops, training courses, etc. for service station employees that discuss Stage I1 equipment, regulations, and inspectionprocedures. The agency could also promote self- inspection programs that encourage station employees to conduct periodic equipment inspectionsto ensure that the equipment is in proper condition. Appendix G-2 contains a self inspection handbook published by the California Air Resources Board that is provided to station owners. An informed and conscientious service station employee population will decrease the enforcement effort needed and the excess emissions from vehicle refueling.

6.2 REGULATIONS Development of appropriate rules is necessary in order to satisfy the intent of theprogram and determine individual facility compliance. As with any regulation, Stage I1 regulations should be clearly written and specific. The rules should contain definitions; requirements for the equipment installation, operation, and maintenance; exemptions levels; compliance schedules; and testing and recordkeeping requirements. Many Stage I1 regulations also require that operating instructionsbe posted at thepumps. Copies of many current Stage I1 regulations are contained in Appendix H. 6.2.1 paui~ment Reauirements Most current Stage I1 regulations contain a statement that prohibits gasoline refueling without a certified orapproved Stage I1 system. Common language for this requirement is IINoowner or operator shall transfer, permit the transfer, or provide equipment for the transfer of gasoline from a stationary storage tank at a service station into a motor vehicle fuel tank unless an approved Stage I1 vapor recovery systemwith 95percent or greater efficiency is installed and used during the transfer.I1 This languagebrings to light an important point, the definition of an napproved Stage I1 vapor recovery system." An "approved Stage I1 vapor recovery systemN is defined in various ways but in all current situations is directly or indirectly linked to certificationby the California Air Resources Board that the system controlsVOC emissions with 95percent efficiency. In California, an approved system is any CARB certified system. CARB certification and Executive Orders are discussed in Chapter 4. In addition, Appendix C contains the certification testing procedures and Appendix D addresses Executive Orders. Most States and local agencies automatically approve, or certify, Stage I1 systems that have been certified by CARB. EPA is not aware of any State

or local agency that has conducted testing and certified Stage I1 equipment which has not been previously CARB certified. However,most regulations outside of California do allow the possibility of non-CARB certification, although no specific test methods or procedures are identified. While the universe of certified equipment in non- California areas has not been broadened to include equipment not CARB certified,many areas are limiting the approved equipment from the complete list that is currently certified by CARB. For instance, both ~assachusetts'and Dade County, ~lorida~ allow only coaxial hoses. Dade County permits only themost recent generation of nozzles and other equipment. These are options available to a beginning program that can reduce the confusion as towhat is llapprovedll, as well as ensuring use of the prevailing technology. In fact, CARBrepresentativeshave indicated that they feel this is a sound approach for new programs.3 In all circumstances, it is important that both industry and inspectors be completely aware of those systems and equipment which are approved and acceptable for an area. Even if an agency accepts CARB certification todetermine approvable systems, it canmaintain an up-to-date listing available to all parties that clearly specifies the permissible equipment and combinationsof components. This is generally the approach being taken by the New York State 4 agency. 6.2.2 Fxem~tion Levels The CAMof 1990 require that gasoline dispensing facilitieswith more than 10,000 gallons of gasoline throughput per month (50,000 gallons per month in the case of an independent small business marketer) install Stage 11. Therefore, by legislative mandate, themaximum exemption levels which a State or local agency may adopt are clearly defined. However, there are several variations that may be incorporated. Due to the difficulty of determining the stations that fall under the definition of "independent small business marketerN,many areas choose not tohave a separate exemption level for this group. This is allowed under the Clean Air Act, as discussed in Chapter 1. In fact, presently no agency exempts independentmarketers at a different throughput level from the remainder of the service station population. Many areas choose not tohave any exemption level at all and require that all gasoline dispensing facilities install Stage I1 equipment. Pennsylvania's Stage I1 regulations contain an additional exemption requirement. Initially, all stations with monthly throughputs of 10,000gallons per month or more
are required to install Stage I1 equipment. In addition, whenever a station, regardless of throughput, is constructed

or modified it is required that Stage I1 equipment beinstalled. Massachusetts' regulations also contain similar requirements. This eliminates a large portion of the installation cost and lessens the impacts on smaller stations. It is important that the regulation include specific stipulationsand procedures toverify exemption status. As the CAAA specify exemptionsbased on gasoline sales, or throughput, it is anticipated thatmost regulatory agencies will follow this example, althoughMissouri's Stage I1 regulations contain an exemption level related to storage tank capacity (2,000gallons for agriculturalusage). Agencies with Stage I1vapor recovery programs have indicated that problems exist with theverification of facility throughput and, thus, the identification of exempt facilities. One approach is to shift theburden of proof from the agency to the facility. The Bay Area Air Quality Management District (BayArea) regulations make it apparent that theburden of proof lieswith the facility. The regulation states that "the burden of proof of eligibility for exemption from this rule is on the applicant. Persons seeking such an exemption shallmaintain adequate records and furnish them to theAir Pollution Control Officer (APCO) upon request." This allows the agency to evaluate not only the throughputdata but the adequacy of thedata provided. This situation can alsobe avoided by specifying procedures for keeping records and determining throughput. For instance, New York's regulation states, "The sum of all gasoline deliveries to a gasoline dispensing site during the previous 12 consecutive monthswill be used todetermine whether the requirements of section 230.2 of this Part apply* Once a gasoline-dispensing site becomes subject to the requirements of section 230.2 because its annual gasoline throughput exceeds an applicability level, subsequent decreases in gasoline deliveries or throughput do not excuse a source owner from having tomaintain the effectiveness of the stage I and/or stage I1 equipment."6.2.3 Com~liance Schedules The CAAA of 1990 contain specific provisions related to compliance dates. Section 182(e)(3) states that within 2 years from the enactment of the CAAA of 1990, Statesmust "submit a revision to the applicable implementation plan to require all owners or operatorsof gasoline dispensing systems to install and operate

# ...a system for gasoline vapor recovery of emissions from the fueling of motor vehicles." It also designates compliance dates as follows: (i) 6months after the adoption date, in the case of gasolinedispensing facilities for which constructioncommenced after thedate of the enactment of the Clean Air Act Amendments of 1990; (ii) one year after the adoption date, in the case of gasolinedispensing facilitieswhich dispense at least 100,000 gallons of gasoline per month, based on averagemonthly sales for the 2- year period before the adoption dater or (iii) 2 years after the adoption date, in the case of all other gasoline dispensing facilities. Any gasoline dispensing facility described under both clause (i)and clause (ii) shallmeet the requirementsof clause (i). The determinationof an appropriate and realistic compliance schedule within the CAAA requirements involves the study ofmany factors. The schedule for installationof Stage I1 equipment should allow sufficient time for facilities toplan for their needs, aswell as alleviating any contractor shortages and potential premium charges. In most instances, the compliance schedule ismulti-phase, with facilities with larger gasoline throughputs required to install the Stage I1 equipment in the initial phase and the smaller stations following. This originally would affect the larger oil companies and jobbers, and help to avoid competition between these facilitiesand smaller businesses for contractors. Thismethod also affects a larger percentage of the gasoline throughput in the shortest time frame. Under Section 325 of the CAAA, of 1977 a threeyearphase-in for independent small business marketers is provided. In determining whether a compliance schedule is reasonable, themajor issues to investigate are: (1)the number of contractors in an area; (2) the number of service stations in each cutoff classification;and (3) the equipment availability due to other areas in the region or country that are simultaneously requiring the installation of Stage I1 systems. Table 6-1 summarizes the exemption levels and compliance schedulesof various Stage I1 programs. 6.2.4 Recordkee~ina Reauirements The most common recordkeeping requirement pertains to gasoline sales or throughput. Inmany instances, throughput is determined by keeping records on the amount of gasoline delivered to the site, although the CAAA of 1990 specify exemptions based on gasoline sales. It is appropriate that records be kept for either, or both, deliveries and sales. 

### An additional check of gasoline sales could be obtained from tax records, or the facility could be required to obtain and keep this tax information on-site along with the facility generated data. It is also possible that recordkeeping requirements could be added as permit conditions. Some

areas have a recordkeeping requirement that results of installation tests be kept on site. These tests are discussed in detail in Section 6.3.3.

6.3 PERMITTING Permits are a tool that local air pollution control agencies can use in getting Stage I1 vapor recovery control systems installed properly. The permits and permit conditions should be clearlywritten to avoid confusion on thepart of the owner/operator of the facility and to enhance enforcement efforts. Several aspects of permitting

are discussed inmore detail in the following sections, including the identification of sources, permit forms andTABLE 6-1. SUMMARY OF STAGE 11 PROGRAMEXEMPTIOWLEVELSAND COMPLIANCE SCHEDULES (Ae of JVK 1991)

CoveredArea

BayAreaA90

South Coart AQW)

Sen DiegoAPQ) Sen Franciscoarea

LorAngeles area

SmDiegoarea 

## - Storwetdrwith capocitye260 The 0.y Area Dirtricther gal. adusedfor ~iaplcrrnts of hd Stage 11 rcgrircnantr husbandry" since the 1970s 

## - Herethe Dirtrictcktemimthat Stage I1ienot feasible


## - vehicle tovehicle refueling


## - Facilitiesthat excluinlyfuel motor vehicle takae5 gallam


## - Facilitiesthat excluinlyfuel aircraft 

## - Facilitieswith 64,000prywr throughputwhere St- I1un not installedbeforeJuly1, 1963


## - Fuilitfeswith7Sprcrntof Tho SouthCwt Dirtrict throughput for fuelingirplemntaof hn hd Stage I1 husbandry rrgrirmtrsincethe 1mr 

## - Retail rtatiawwlth storage tdr The SmDiegoDirtricthn lesr thm260 gallam hadSt- I Ircqulrmtr since the 19700 

# - Wonretail atatidwithatorage tdslurthan550gallam

,

# - Wonretail stations with lnrth 2,000 gallonper monththroughput for thefacility



# - Dispensingof nturalg.ror propme when notmixedwith anotherMe 

# - Intovehicles perfomingeaergmy work 

## - Storagetm&swedprinrilyfor the fueling of aircraftorbtrTABLE 6-1. SWRYOF STAGE 11 PROCRAMEXEMPTION LEVELSAND COMPLIANCESCHEDULES (COUTINUED)

State/Rcgulatory Agency Covered Area ExqtimLevela C-1 inceSch&le

WcwJeratyDEP I + P Washington, D.C.

St. Louie area

EntireState 

## - Alldlclpnlngfwllitiesmildle lnucordrrewlththeDC tothe mrrlplblicby virtueof AirPollutlmCmtrolAct havlngnilltrrystatushaving 3or of 1% lessdiapenalng nozzles 

# - Statlawryatoragetakahaving 8 Fin1t-llmm btefor capeclty e 2,000 gallonr dused r1 1 aarrcesunDuedm forfueling%plcnmta of 31, 1007. hwbendryn 

## - strtiawryatoragetakahaving r capcitye 2,000 gallonr lnatrlled before Septhr15, 1976 Dwhr SO, 1908for fwilities 40,000 gel/mnth dDuhr 29, 1989forfuiliticr 10,000 gal/mnth 

## - Dl11pcning deviceset arrinused exclusivelyforrrin vehicles WcwYork DEC WcwYork Cl tyarea 

# - siteqmclfltbteraintimthat July 1, 1908for Stage 11 latechnically or fuilities 500,000 uonorlcrlly infeasible gll/ye8r dJuly 1, 1- forfullltlea 250,000 gll/yearFloricb/OsdeCovltyMP TABLE 6-1. SU)URY OF STAGE I1PROeRAnEKEllPTlOll LEVfLSAM) CO)IPLIAWCESCHEDULES ~COWTIWUED)

Covered Are8 ExaptimLevels

Rrsauhuret tsDEW EntireState

Mimiare8 (Dede Covlty) 

## - <20,000 wl/mthcawtructdor April 1, 1991for difiedbefore Novcnkr 1, 1989 fullitiar 1,000,000 grl/pr; April 1, 1-1 forfuilitfaP 500,000 wl/yerr; adApril 1, 1993for fuilities> 20,000 gll/mth


## - Marimsservicingboetr



## - Airports rervicingrirplmea



# - < 10,000 wl/mthcawtructdor difiedbeforeJvw25, 1990 Idirtrlyfor m fuilitiawdDecakr 14, 1992for existing fuilitia

hnr25, 1991for fuilitia % 1,500,000 wl/pr; Deedor25, 1991for fuilitia

# . 1,000,000 981/~8t;Jvrs 25, 1992forfuilities % 500,000 @ml/pr; ndJvrs 2s. 1993forfullities+

Alllocaldistrictsincalifmi8hm rempomibilityfor St- I1(Phre 11) proerr. TheBy Am, SouthCow, udknDim districts rhacninthetableud 14otherdistrictsthataremnrttrimtfororomhavehd St- 11rtgulrtiawforonr rdoc*. therrrining districtsraq~ired St- I1kinstrlldforhzemcmtrolby 1991. Ilhilethemodel regulrtimprwifhd byCARD (see Appendix F.l) rumgmtdrthraqhput cutoff of480,000 wllarparyear (40.000 grllawprmth), theDistrictsirplawntd8 nrietyof cutoffs rrrping fraanoexmiawtothis480,000 wl/yerr Level. TheseDistrictsarediscussed inAppendixE 8s thyarethorewiththe mtexperience withStnee 11.applications, the issuance of operating permits, and testing requirements. Appendix I contains information related to permitting. 6.3.1 Identification of Sources While estimates of the number of facilitiesmay be obtained from a variety of sources as discussed in Section 6.1, the actual identification of sources tobe contacted for permitting purposes can be difficult. An analysis of themethods used for this identification process by agencies with the newest Stage I1 programs reveals several approaches. Stage I permit records can be of great assistance in this identification. New ~ersey~ and Dade County, ~lorida~ relied on these files. New Jersey sent a letter toall facilities in the Stage I permit system and informed them that they were required to obtain a Stage 11permit and install the equipment. Dade County also used information from their underground storage tank permitting program to complement the Stage I data. Pennsylvania identified sources by contacting major oil companies and obtaining information from the State Department of Licensing and In~pection.~ Massachusetts used tax records to identify sources. Each sourcewas then sent a Registration and Classification formwhich was returned to the Agency, who contacted the facilities which needed a permit. 6.3.2 Permit Forms and A~~lications The permit form and application is the best means of obtaining information regarding a facility and the type of equipment tobe installed. The forms should be designed to allow the department to easily obtain the important information without requiring a great deal of excess data. An obvious requirement for the permit application is the

name and address of the facility. However, in addition to this information it is beneficial to include the name and address of the business owner, the operator/lessee, and asite contact. The nature and purpose of.theapplication should be stated. Station characteristics such as the operating schedule, monthly and annual throughput, and number of nozzles, hoses, and dispensers should be provided. Informationpertaining to the type of Stage I1 system to be installed should also be included. Specifically, this should consist of the equipment to be installed; a preliminary site plan of all tanks, dispensers, and underground piping. Most current Stage I1 permit forms require that the 

### CARB Executive Order number be identified for the system tobe installed, regardless of the area of the country. While most of the permit forms and application requirements are similar, the proceduresvary immensely after the submission of the application. Due to resource restraints, each air pollution agency must determine the focus of their Stage I1 program. Invariably, programs are concentrated either on permitting or inspections. Therefore, the criteria for the issuance of operating permits can range from a paperwork type exercise,with emphasis on inspections, to permitting requirementsbased on stringent testing. The New Jersey DEP receives the application; checks to confirm that all information is complete and that the facility has designated a certified system for installation, and mails out a permit. The permit contains standard conditions that leak and pressure decay/liquid blockage testsmust be performed on the system after installation and that the facility must maintain verification of the tests. The existence of this documentation is checked during facility inspections. 9 Massachusetts has developed a two-phase compliance approach. The first phase involvesverification that the appropriate equipment has been installed. This initial field inspection is described as a "drive bym screening that defines a minimum level of inspection required to assurethat installation has occurred. The second phase is the more detailed verification that the equipment is operational and is being maintained." The San Diego Air Pollution Control District has perhaps themost stringent permitting and testing program observed in the country. The program is based on the experience and knowledge thatmost emissions from Stage I1 equipment are a result of improperly installed systems. The following is a description of thepermitting and testing program in San ~ie~o. l1 An applicant submits an application for a Stage I1 permit that contains a preliminary site plan of all tanks, dispensers, and underground piping. The application is reviewed in detail by a member of the engineering staff to confirm that the planned system is in accordance with CARB certification and San Diego regulations. If all the preliminary requirements aremet, the District grants Authority to Construct. ThisAuthority to Construct is issued subject to several requirements. An example is the applicant must notify the District within 10 working days after the Stage I1 installation that construction has been completed. Temporary authorization to operate begins only after receipt by the District of this notice of completion and an "as builtvv site plan. The applicantmust also have several tests performed and provide the District with the results. The District must be contacted within 10working days of completion of construction to establish a mutually agreeable test date. Normally, the tests arewitnessed by a District representative. If the District is not notified of a test, then this test may be declared invalid, inwhich case a retest is required. The required tests are: (1)a pressure decay/leak test of vapor control system; (2)a pressure drop

vs. flow test from each nozzle to its associated underground tank; (3) a liquid test of all vapor piping toensure adequate line slope and liquid drainage; (4)a tankvaporspace tie test toverify the existence of a tank interconnect vapor pipe; and (5)a maximum dispensing flow rate determination for at least one nozzle. Each of these tests is discussed in the following section. The temporary authorization to operate remains in effect, unless canceled, until the facility is inspected by the District for a Permit toOperate. If the facility passes inspection, written authorization is given for continued operation, which is followed by issuance of the Permit toOperate. The above tests are required tobe repeated if the Stage I1 piping or equipment is changed in any way. 6.3.3 Testina Reauirements While efficiency testing is not practical for each service station, there are tests that indicate improper installation of underground Stage I1vapor piping. These tests are thepressure decay/leak test, the dynamic back- pressure test, and the liquid blockage test. Testing requirements are usually included as a permit condition but could be specified in the regulation. Various testmethods

are contained in Appendix J. 6.3.3.1 pressure Decav/Leak Test. This test procedure is used toquantify thevapor tightness of any vapor recovery system installed at a gasoline dispensing facility. Leaks in a balance system can cause excessive vapor emissions. Leaks in an assist system can decrease the efficiency of thevapor collection or processing system, or
cause the pumps and the incinerator tooperate continuously while attempting tomaintain pressure or vacuum. The test is conducted by capping thevent pipe(s) and pressurizing thevapor piping systemwith nitrogen. This pressurization can be accomplished by introducing nitrogen into thevapor passage at one nozzle but is commonly done at the riser in the dispenser. An initial pressure of 10 incheswater column is obtained and the final pressure in the system is recorded after a period of 5minutes. Thefinal pressure is compared tominimum requirements linked to the ullage space in the tank. Example test procedures of this type are contained inAppendix J, Sections J.l and J.5. 6.3.3.2 Pvnamic Pressure Dro~ Test. This test is used todetermine the pressure drop (flowresistance) through balance vapor recovery systems (including nozzles, vapor hose, swivels, dispenserpiping, and underground piping) at prescribed flow rates. The test method consists of flowing gaseous nitrogen through a calibrated test panel into the vapor recovery system at different flow rates to simulate the back pressure created during vehicle refueling. The resulting backpressures aremeasured near the nozzle faceplate using a pressure gauge, and compared with CARB certification criteria. The system passes this test if, at the nitrogen flow rates of 20, 60, and 100 SCFH, the flow resistancemeasured does not exceed 0.15, 0.45, and 0.95 inches of water, respectively. This test should be run on every nozzle because nozzles, hoses, and dispenser connections can cause excessivebackpressure. However, in the event of limited resources to run this number of tests, the proper approachwould be to run this test at a minimum of the farthest dispenser from the underground tanks for each product grade. The test procedures in Appendices J.2 and 5.4 are for this test. 6.3.3.3 Liuuid Blockase Test. This test 

### is used for balance and assist systems todetermine if the piping configuration is correct and todetect low points in the piping where the accumulationof liquid condensatemay cause blockages which restrict the flow of vapors and thus decrease the system's vapor collection efficiency. The test method consists of introducing gasoline into the vapor piping at any point up to and including the riser. When adequate time has been allowed for the gasoline to flow back to the underground tank, gaseous nitrogen is introduced into thevapor piping at the three flow rates of 20, 60, and 100 SCFH. A liquid blockage is indicated either by the needlepegging on the pressure gauge and/or wild pulsing of the needle, or a reading in excess of the limits discussed above using the dynamic pressure drop test apparatus. This test is conducted using the same test methods contained in Appendices J.2 and J.4. 6.3.3.4 Va~or S~ace Tie Test. 

### An addition to the leak test/pressure decay procedure discussed above allows the determination of whether all underground tanks are plumbed into the system. After the pressure drop has been measured for the specified time period, thedry break on each underground tank fillpipe is depressed. If the tank is properly tied to thevapor system, a release of pressure will occur. The absence of pressure in the tank indicates that the tank is not connected to thevapor piping. 6.3.3.5 paximum DiSDensina Flow Rate Determination. The dispensing flow rate may be checked by simply noting the volume of gasoline pumped in a specific time interval. This

can be done during the fueling of any vehicle. This test procedure is contained inAppendix J.3. 6.3.3.6 Liauid Removal Device Test. In addition to the tests required in San Diego, there is also amass draft testmethod to check liquid removal devices in the hoses. This test can be performed to check the operation of this device. It is conducted by introducing sufficient gasoline into the vapor passage of the coaxial hose toproduce a dynamic back-pressure between 2.0and 6.0 inches water column. This is accomplishedwith approximately 150ml of gasoline. Then approximately 10gallons of gasoline are dispensed into a vehicle fuel tank. The liquid remaining in the vapor passage is then drained and the volume is measured. If the device is operating properly, most of the gasoline should be removed from thevapor passage during this fuel dispensing.6.4 INSPECTIONS The emphasis ofmost Stage I1 programs is on the inspectionprogram. The utilization of approved or certified equipment and themaintenance of this equipment is essential tothe effectiveness of a Stage I1 vapor recovery program. Therefore inspection procedures and frequency, inspector training, and themethod of handling violations

are enforcement related matters that need serious consideration. Unfortunately,most inspectionprograms concentrate on the above ground portion of Stage I1 systems, with little or no attention given to the underground piping. Testing procedures can also be incorporated into the inspection program. 6.4.1 Ins~ection Checklists and Procedures Detailed inspection procedures and checklists are helpful in the development and implementation of a consistent and equitable enforcement program. All of the standard agency pre- and post-inspection procedures such as identification of the purpose of the inspection and consultationwith the owner/operator after the inspection should be followed. In addition, procedures specific to the inspection of Stage I1 equipment can be developed. The Compliance Assistance Program of CARB publishes a Technical Manual for Inspectors of Gasoline Vapor Recovery systems.12 The inspectionprocedures shown in Table 6-2 are taken from this document, and describe step-by-step instructions for inspecting Stage I1 equipment at a gasoline dispensing facility. Also, Appendix K containsvarious inspection checklists and inspection procedures from other areas. 6.4.2 Jns~ection FreauencY The inspection frequency also varies among different agencies. The inspection frequency is a direct reflection of the resources allocated for a Stage I1 program. The frequency ranges from one inspectionper facility every 5 years to two or three annual inspectionsper facility. There is a correlation between inspection frequency and theFueling instructions:

a. See that fueling instructions are clearly displayed with the appropriate toll free number.

2. Nozzles:

a. Check each nozzle toverify that it is a current CARB certified model.
b. Verify that each nozzle is ins'talled in accordance with ARB Executive Orders.

c. Check to see that required nozzle components are in place and in good condition. Check: 1) required nozzle components (See401.3.1). 2) automatic shut-off mechanism (observethe filling of vehicles look for signs of spillage. 3) trigger (is it leaking or broken) 4) spout for damage or looseness (wigglethe spout) 5) leaded nozzle or spout to ensure that it has not been replaced an unleaded nozzle or spout (checkthe diameter). 6) nozzle for leaking gasoline or vapor (tipthe nozzle down into a container and look forvapors).

3. Faceplate:

a. Make sure that the faceplate is smooth, uniform, and capable of forming a tight seal for balance system and in good working order for assist systems.
4. Bellows:

a. Stretch the bellows to check for holes, rips, or tears.
b. Check to see that the bellows is securely attached to the nozzle.

c. Check to see that the shape of the bellows is normal and that there are no deformities.

5. Spring:

a. Check to see that the internal bellows spring is not missing, broken, distorted,welded, or homemade. Many of the newer balance systems do not require the internal spring.TABLE 6-2. PHASE I1 INSPECTION PROCEDURES (CONTINUED)

6. Latch:

a. Check toseethatthelatchingdevice is not missing, broken, distorted, welded, orhomemade.

NOTE Neither thespringnor thelatchingdevice isrequired on theHasstech system, but eithermay be present. Both the spring and latchingdevice arerequired on theHirtsysten. The Amoco bellowless nozzle incorporates a tightlywound springaround the spout asa latching device.

7. Check valve:

a. See thatthecheck valve is inplace (inspectthen0zz.e for signof tampering)

8. Hoses:

a. Only coaxialvapor recovery nozzles and hoses may be installedon balance systems afterFebruary 20, 1986. Hose configurations must be incompliance with the exhibits inthemost currentversion of executiveorder G-70-52. b. Check tosee thatproduct and vapor hoses with the overhead retractor are long enough topermit natural drainage intovapor returnpiping when the retractor 

### is intheretractedposition, but stillavoid kinking whe~ fullyextended.

c. Check toseethathoses with retractors areadjusted t> maintain a proper loop, and thatthebottom of the loc? iswithin thedistance from the island surface certified by theARB Executive Order forthatparticular dispenser configuration. d. Check tosee thathoses arenot torn, flattenedor crimped.

e. See thatthevapor recovery hoses areof therequired sizeand length. f. If liquidremoval device is required, check toseethzt it isproperly installed.Flow Limiter:

a. If required, open the dispenser (getthekey from the owner or operator) and check to see that the flow limiter indicator arrow ispointing in the same direction as the flow of gasoline and that the flow limiter isnot missing. Swivels:

a. Nozzle and dispenser swivels are optional with the lightweight coaxial hoses formany configurations. Check the appropriate executive order to seewhat swivels are required.
b. Check to see that swivels are lubricated tomaintain power movement (look for full movement).

c. Check to see that swivels are not missing, defective, or leaking.
d. Check to see that the dispenser end swivels are Fire Marshal approved. (lookfor the Fire Marshal sticker).

Vent Pipes Pressure Relief Valve



### a. Observe to see that thevalve is in place if required for a vacuum assist system.

Vacuum Pump (AmocoBellowless System Only)

a. Wait for a vehicle to fuel.
b. Verify that fuel isbeing dispensed into the vehicle by checking the flowmeter on the dispenser. Listen toward the top of the dispenser for a rapid "clickingw sound of thevapor pump. The mclickingMis caused by the movement of the pump seals as they rotate within the pump housings. Clicking sounds indicate that thepump isworking properly. Collection Unit (HasstechOnly):

a. Wait for a vehicle to fuel.TABLE 6-2. PHASE I1 INSPECTION PROCEDURES (CONTINUED)

b. Go to the collectionunit and listen for the sound of the vacuum/blower inside the collectionunit. If the collection unit does not appear tobe operating, check to see that the power switch is ON. If the switch is Cg and the collection unit is still operating, check the control panel.
14. Control Panel (Hirt system only)

a. Check to see that thepower switch is in the on position.
b. Check to see that both the power and vacuum lamps are illuminated.
If power lamp is out: 1) Check to see that the on/off switch if on. 2) Check to see that the circuit breakers in themain electrical panel box are on. If thevacuum lamp is out: 1) switch the vacuum and power lamp bulbs toverify that thevacuum lamp is not burned out.
2) check to see that all fill caps and Phase I vapor recovery connections are on and are tightly sealed.
15. Processing Unit:

a. Look for convection currents coming out of the burner stack on top of the processing unit, indicating that tie burner is operating (theburner will not be operating 3t all times). You may be able to see these currents mor2 easily by standing back and observing the top of the stack against a background (suchas power lines)or by looking for the shadowson the ground.

16. Vacuum gauge (Hirt Only): If thevacuum pump is illuminated, there is no need to chzck the vacuum gauge. If thevacuum lamp is not illuminated, a check of the vacuum gauge is needed.TABLE 6-2. PHASE I1 INSPECTION PROCEDURES (CONTINUED)

The vacuum gaugemay be found inside the base of the dispenser furthest from thevent risers.

a. If the gauge reads zero or negative during dispensing and non-dispensing, the system is operating okay.
b. If the gauge reads positive during non-dispensing or pegs topositive during dispensing, the system needs attention.

Source: CARB TechnicalManual for Gasoline Facilities; Phase I and 11, CARB Compliance Assistance Program.number of defects found, although there are other relevant factors. San Diego inspects private facilities once per year and two

or three times per year for retail service stations.'= The retail facilities in the Bay Area are inspected twice per year and the private facilities once per year.'& In the South Coast District, they strive to average two inspections per year per facility. However, their inspectionprogram is not geared to inspect each station twice annually, but rather is a priority inspection program. Stationswhich have exhibited recurrent problems in thepast are inspected three times per year, average situations twiceper year, and very conscientious stations are inspected only once per year. Also, South Coast is experimenting with a "self inspectionwprogram inwhich larger companies implement their own inspection program and report tothe District- Preliminary assessments are encouraging, but an overall evaluation of thisprogram has not been condu~ted.'~ 6.4.3 Jns~ector Training The level of training for Stage I1 inspectors alsovaries widely. It is critical that inspectors understand Stage I1 technology fully tobe able to recognize violations and potentizl problems. While segmentsof the inspectionprocedures are relatively simple, such as the identificationof torn bellows ald hoses, items such as proper checkvalve function and the identificationof properly certified equipment cannot be graspec in 

### a short training program. Inspector training ranges from agencies that provide a 2-4 hour discussionwhich includesa video of inspectionprocedures to those which have a training program that lastsup to 7weeks The Evaluation and Training Section of CARB has a series of training courses for inspectors. Generally, inspectorsattend 2-day training course that includesdetailed discussion of equipment technology, CARB certificationprocedures and Executkre Orders, inspection techniques, test procedures, and a hands-on section in the field. CARB believes that this 2-day workshop/training event could easily be 3 or more days to 1I adequately cover the necessarymaterial.l6 The South Coast District has a 7-week district training program which includes working with an experienced inspector for 2 weeks. They also have training videos on inspection techniques.17 There are currently twovideos used most often by State and local agencies. These are "Stage I1 control^^^, by Multinational Business Services (MBS)in Washington D.C. and IvForCleaner Air: Vapor Recoveryv1 by CARB. 6.4.4 Testina Durina Ins~ection As mentioned previously, Stage I1 inspections often focus entirely on the above ground portion of the system. The inspection procedures taken from the CARB technical manual that

are cited above include no mention of underground piping testing. However, the pressure vs. flow and liquid blockage tests can be conducted by inspectors in the field with minimal time and effort, and they can provide an idea of the condition of the underground piping. As discussed in Chapter 4, liquid blockages
can severely inhibit the emission reduction from Stage I1 systems

even when all nozzles, hoses, and above ground equipment are well maintained. This testing during inspections is especially critical for programs that do not require testing during the permitting process. The Bay Area District has testing units available for use by their inspectors. Tests are conducted on a random type basis during normal inspectionsand in response to complaints that seem to indicate liquid blockage type 

### problem^.'^ Without exception, every California official with knowledge and experience in Stage I1 technology interviewed by 

### EPA indicated that the testing of the underground piping for leakage and liquid blockage is possibly themost important aspect of the functioning of Stage I1 systems.l9 6.4.5 Violations There are two basic methods used for handling Stage I1 violations. These are removing (i.e., tagging out) defective equipment from service and administrative penalties forviolations. Following is a summary of themandated procedure thatmust be followed by all agencies in Calif~rnia.~' When a district inspectordetermines that a component contains a defect which substantially impairs the effectiveness of the system in reducing air contaminants,thedistrict marks the component "Out of Orderw. The use of the component is then prohibited until the component has been repaired, replaced, or adjusted, as necessary, and the district has reinspected the component or has authorized use of the component pending reinspection. Equipment defects which are considered in California to ggsubstantially impair the effectivenessof the systems in air contaminantsgg are: Absence or disconnection of any component required to be used in the Executive Order(s) that certified the system.

A vapor hosewhich is crimped or flattened such that thevapor passage is blocked, or the pressure drop through thevapor hose exceeds by a factor of two or more the requirements in the system certified in the Executive Order(s) applicable to the system.

A nozzle boot which is torn in one or more of the followingmanners: 1. Triangular-shaped or similar tear 1/2 inch or more :o a side, or hole 1/2 inch or more in length. Slit 1 inch more length. (d) Faceplate or flexible cone which is damaged in the followingmanner: 1. For balance nozzles and for nozzles for aspirator a~d educator assist type systems, damage shall be such that the capability to achieve a seal with a fill pipe interface is affected for 1/4 of the circumferenceof the faceplate (accumulated). 2, For nozzles forvacuum assist-type systems, more ttm 1/4 of the flexible conemissing. (e) Nozzle shutoffmechanisms which malfunction in any manner.Vapor return lines, including such componentsas swivels, antirecirculationvalves and underground piping, which malfunction or are blocked, or restricted such that pressure drop through the lines exceeds by a factor of two ormore requirements specified in the Executive Order(s) that certified the system. Vapor processing unit which is inoperative.

Vacuum producing device which is inoperative. Pressure/vacuum relief valves, vapor check valves, or dry beaks which are inoperative. Any equipment defect which is identified in an Executive Order certifying a system pursuant to the CertificationProcedures incorporated in Section 94001 of Title 17, California Code of regulations, as substantially impairing the effectivenessof the system in reducing air contaminants.

Where a district inspector determines that a component is not in good working order but does not contain a defect listed above, the district provides the operator with a notice specifying thedefect. The owner/operator thenmust correct the defect within 7 days or be subject to further action. Each district in California followsthis procedure, although the imposition of administrativepenalties, or fines,varies from district todistrict. San Diego assesses a fine for all defects detected, while other districts impose fines if a certain percentage of defects is found relative to the number of nozzles,

or if a set number of violations is found.*' California officials note that in some situations this tag out program has tended tobe abused by industry. An extreme example is the station owner that recognizes equipment is defective but waits until the inspector tags it out of service, then immediately replaces it with a new component. A suggestion from California officials is that any inspection program should be evaluated carefully to avoid creating the situation where the inspectors are in effect performing themaintenance program for the service stations. This can be avoided by making the penalties substantialenough to ensure that the ownerwill wantto find these defects instead of waiting for the inspector to locate them.22 Other areas impose rather severe fines for any violation noted by the inspector. In New Jersey, no definition of malfunctioning ordefective equipment is given and much is left to the discretion of the inspector in this regard. Any defect noted by an inspector is subject toa fine.a A mixture of these approaches is being implemented by Massachusetts. The State requires that the facility tag out theirown equipment if it is found tobe defective. If an inspector visits a site and equipment is tagged and not being used, then no violation occurs. However, the identificationol defective equipmentby an inspector that has not been tagged o~t and is being used results in a violation and administrative penalty.24 Massachusetts also has its own list of violations that allows an inspector topositively write violations due to the clarity of this list. In order to set somepriority between tle different types of violations which could be detected, Massachusetts separates the kinds of possible violations into "potentially emittingwand "non-emittingw

# .25 The description of theseviolations, with examples, are shown in Table 6-3.

6.5 SUMMARY In summary, there aremany issues toconsider in the implementation of a Stage I1program. The information containzd in this chapter, aswell as that provided in Appendix Elwill assist an agency in the initial stages in understanding the various aspects of planning, permitting, and enforcement that need attention. In addition, the EPA enforcement guidance document should be consulted for enforcement guidance and requirements.TABLE 6-3 MASSACHUSETTS STAGE I1VIOLATIONS

Title of Violation PRIORITY,.OR"EMITTING" VIOLATIONS 1. Dispensing motor vehicle fuel without vapor recovery equipment

2. Vapor recovery system is not operating properly

3. Vapor recovery equipment is damaged

4. Failing to prohibit use of a dispenser with an inoperative (or nonexistent) vapor recovery system 5. Failing to install signs to show how toproperly use thevapor recovery system 6. Failing to install certified equipment

7. Failing to perform or misperforming a requested compliance test Example

Station is not equipped with Stage I1vapor recovery equipment but is continuing to dispense fuel. Bellows has been "tied backw, latch system bypassed, aspirator not turned on, processor not turned on. Could also include a non-spec configuration (hosestoo long or not assembled correctly) Tears or holes in the boot, kinks in thehose, hose is flattened. Equipment is damaged but dispenser is still operational and could be used.

Signs are supposed tobe conspicuous (outside)and readable, they must say DO NOT TOP OFF Installed equipment is not on the list of CARB certified equipment or equipment has been installed which, although each piece may be certified, the components are assembled in an uncertified configuration.
Not an immediate concern since a compliance test would initially be required only as a condition of a UAO. However, if such a request is made and the facility does not conduct the test properly, or ignores the requirement, a violationwould be triggered.TABLE 6-3 MASSACHUSETTS STAGE I1 VIOLATIONS (CONTINUED)

Title of Violation Example 8. Failing to install and So as to differentiate this operate vapor recovery violation from the first equipment after the violation type listed above, appropriate deadline the finding of thisviolation should be limited to facilitieswho have made no effort to complywith the requirements of the regulation (havenot filed ICC or RCC forms) or facilitieswho are not listed but still have the fuel throughput thatwould trigger applicability to the regulation.

OTHER OR "NON-EMITTING" VIOLATIONS 1. Failing to submit Installation and Certification forms 2. Failing to train station operators 3. Failing to place an I1Out of OrderN sign on a disabled dispenser
4. Failing tomaintain continuous records N= Source: Massachusetts Department of Air Quality Control, Compliance and EnforcementManual.6.6 REFERENCES Stage I1 Background Informationand Technical Support Document. MassachusettsDepartment of Environmental Quality Engineering. January 1989. Telecon. Norwood, P., Pacific Environmental Services, InC. (PES)with Wong, R., Dade County Air Pollution Control. Hay 14, 1991. Dade County Stage I1 Program. Memorandum fromNorwood, P., Pacific Environmental Services, Inc. to Shedd, S., U.S. Environmental ProtectionAgency. April 30, 1991. Trip Report to California Agencies toDiscuss Stage 11.
Memorandum fromNorton, R. Pacific Environmental Services, Inc. to Shedd,S., Environmental Protection Agency. April 29, 1991. Trip Report toNew York Department of Environmental Conservation.
Memorandum from Norwood, P., Pacific Environmental Services, Inc., to Shedd, S., Environmental Protection Agency. February 22, 1991. Trip Report toNew Jersey Department of Environmental Protection.
Telecon. Bowen, E., Pacific Environmental Services, Inc. (PES)with Wong, P., Dade County Air Pollution Control. April 15, 1991. Dade County Stage I1 Program. Telecon. Bowen, E., Pacific Environmental Services, Inc. (PES) with Estrusky, B., Pennsylvania DER. April 11, 1991. Philadelphia Stage I1 Program. Telecon. Bowen, E., Pacific Environmental Services, Inc. (PES)with Carlson, L., Massachusetts DAQC. April 1, 1991. Massachusetts Stage I1 Program. 9. Reference 5.
10. Stage I1Complianceand Enforcement Manual. Massachusetts Department of Environmental Quality Engineering. January 1989.
11. Reference 3. 12. Gasoline Facilities Phase I & 11. California Air Resources Board, Compliance Assistance Program. Revised March 1991.
13. Reference 3.
14. Reference 3.Reference 3.
Uemorandum fromNorwood, P., Pacific Environmental Services, Inc. to Shedd, S., U.S. Environmental ProtectionAgency. April 22, 1991. Trip Report to Uonterey, CA, for CARB Stage I1 InspectionWorkshop.
Reference 3.
Reference 3. Reference 3. California Code of Regulations, Title 17, Section 94006.
Reference 3.
Reference 3.
Reference 5.
Reference 10.
Reference 10.~ I

- TECHNICALREPORTDATA 1.RECOnTNO. IAkJemdlaacnwatherevcrcc&fw CompIe,,IId, 1. EPA-450/3-91-OZ~a 3.IWC!P~€NT.S ACCESSIO~ 1.TftLEAN0SUlfITLf

Technical Guidance

# - Stage 11Vapor Recovery systems snCPOnTOAT€ for Control of Vehicle Refueling Emissions at Gasoline November 1991

I .Dispensing Facilities,Vol. I

# - Chapters 6.rtn.O~wl*G ~ ~ ~ A NCOO. Z A ~ ~ ~ 7.AUTHORIS)
8 PEAFORMINGOCIGANIZ~TION REPOR?kO

### f S.PEIICORMtNGORGANIZATIONNAMEAh0AOORESS :

US Environmental ProtectionAgency Office of Air Quality Planning and Standards Emission Standards Division (KD-13) Research Triangle Park, NC 27721 It.SPONSORINGAGENCYNAME&NOAOORESS 

# IUS Environmental ProtectionAgency

Office ofAir and Radiation Washington, DC 20460 

### I 15.SUPPLEMENTARYNOTES

c. is.AUSTRACT The Clean Air Act Amendments (CrULA) of 1990 require the installation of Stage .par recovery Systems inm+ ozone nonattainment areas and direct EPA to issue his dosment as appropriate on the effectivenessof Stage 11 systems. provides guidance on the effectivenessof Stage I1 systems and other Stage IT tech- nical infomation on emissions, controls, costs, and program implementation. Stage 11vapor recovery on vehicle refueling is an effective control technology to reduce vapor emissions that concainvolatile organic compounds (VOC) and hazardous 

### air pollutants. Vehicle refueling emissions consist of thegasoline vapors displaced au~onobil~ tank by dispensed liquid gasoline. The Stage I1 system collects frm the thev&(cle fillpipeand returns them to the undergmund storage tank. these