p.1 

OAR Box 1142 

Prepped by Ollie Stewart 

Document Number: 

19) IV-F-17 

Docket Number: 

A-87-11 

Printed 4/23/2008 10:21:21 AM Sheet 19 of 30 
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M-87-// 

, IV-F-/7 

Multinational Business Services, Inc. 

11 Dupont Circle 

Washington, D. C. 20036 

U. S. A. (202) 293-5886 Regulatory and Trade 

Fax: (202) 939-6969 Counsellors 

September 30, 1991 

Mr. Donald Kopinski 

Standards Development and Support Branch 

Emission Control Technology Division :• 

Office of Mobile Sources \ ^^ „ A 

U.S. Environmental Protection Agency TM'-

2565 Plymouth Road 

Ann Arbor, Michigan 48105 

Dear Mr. Kopinski 

Enclosed are five copies of the prepared testimony that I delivered on behalf of MBS 

at the September 26-27 hearing in Romulus, Michigan on the safety of proposed 

motor vehicle ("onboard") refueling vapor recovery controls. 

Also enclosed is one copy of the video that I showed during my testimony, and one 

copy of the draft final report of the California Air Resources Board on comparative 

spillage from Stage II and conventional service station refueling equipment that I 

referred to. We are submitting additional copies of the video and the draft final 

CARB report to the Docket. 

Additionally, I am enclosing a copy of the November 2, 1990, letter from the 

American Medical Association to Congress on this subject that was referred to by Jim 

Tozzi in his testimony. Mr Tozzi did not have a prepared statement that can be 

submitted to the public docket. 

Sincerely, 

William G. KA\y^r7 

Enclosures 

The Multinational Companies 

Multinational Business Services Hamburg (40) 220-4277 

Multinational Legal Services 11 Dupont Circle Washington, D. C- (202) 797-7124 

Multinational Investment Services 11 Dupont Circle Washington, D. C-(202) 797-6353 
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Multinational Business Services, Inc. 

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cc: Mr. Richard Wilson, EPA 

Mr. Steve Silverman, EPA 

Mr. William Boehly, NHTSA 

Mr. Paul J. Rice, NHTSA 

EPA Docket A-87-11 
P.4 

S 18268 CONGRESSIONAL RECORD — SENATE November 2, 1990 

AMXRICAM MSDZCAL ASSOCIATION. 

Chicago. IL. March 5.1990. 

Hon. JAMS L. WHITTSM, 

V.S. House of Representatives. Washington. 

Da 

DEAR MR. WHITTEW: I am writing to provide our opinion regarding onboard gasoline 

vapor recovery systems for automobiles. 

Staff members of the AMA's Science and 

Technology Oroup recently reviewed this 

matter and offer the following comments. 

The part of this issue that the AMA can 

most authoritatively comment on concerns 

the measure of health risk due to individual 

and/or community exposures to gasoline 

vapors (most notably benzene and other aromatic hydrocarbons) and the likely impact 

of such fugitive vapors during refueling on 

atmospheric levels of ozone. 

The degree of human risk of leukemia 

from gasoline-associated benzene appears to 

be overstated by the EPA. Tlie amount of 

benzene in gasoline ls roughly of the order 

of 5<n; it is the sole aromatic of those in gaso!ine that is associated with leukemia in 

humans, and then only with long-term occupational exposures. The extent of the pub-

. lie's exposure to benzene in an outdoor environment during refueling is expected to be 

inconsequential: there is. therefore, no 

reason to believe that such minor, shortterm exposures will be harmful to one's 

health. Station and tanker employees' exposures are of concern, which is all the more 

reason to control emissions prior to or at 

the pump. 

Tliere is still no general agreement on the 

long-term human health effects of low 

levels of ozone. A review article on this subject is enclosed. The EPA's efforts to reduce 

the cauaes of episodic levels of ozone in the 

nonattainment areas of the country should 

continue to be pursued: however, little Is apt 

to be gained by the onboard control systems 

for those areas that are in compliance with 

the air standard 

The "on-vehicle" system seems to be an 

unnecessarily complicated way to control 

gasoline vapors that are emitted during the 

refueling process. One need not be an engineering genius to see the numerous points 

of system failure: e.g.. line rupture .irom 

both accidental and non-accidental occurrences, not to mention the results of neglected or incompetent maintenance. Auto 

emission controls are already too hopelessly 

complicated for simple maintenance, and 

this additional device begs for trouble. 

ln summary, we feel that vapor recovery 

systems placed in cars probably will Increase 

the risk of fires if crashes occur. In accordance with good medical practice, such systems must be tested in laboratories and 

then in real life before they are mandated, 

and the safety of such systems should be a 

basic determinant of what eventually is 

mandated. The health benefits of having 

these systems ln automobiles would be inconsequential, considering that the biomedical literature is not at all clear on the effects of greater exposures to benzene and 

ozone for longer periods of time. And finally, it Is more logical to apply control systems 

to service stations than to tens of millions of 

vehicles on highways. 

We appreciate having this opportunity to 

express our opinion to you and trust lt will 

be helpful and Informative. 

Sincerely yours. 

JAMES S. TOSS. M.D.. 

Acting Executive Vice President* 
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Multinational Business Services, Inc. 

TESTIMONY OF WILLIAM G. KELLY, JR. 

Multinational Business Services, Inc. 

11 Dupont Circle, Washington, D.C. 20036 

Public Hearing Before the Environmental Protection Agency 

and the Department of Transportation on 

the Safety of Onboard Refueling Vapor Recovery Systems 

September 26 and 27, 1991 

Detroit, Michigan 

My name is William G. Kelly, Jr., and I am here representing Multinational Business 

Services, Inc. of Washington, D.C. Multinational Business Services is an independent 

consulting firm with expertise in the analysis of regulatory issues. In this capacity, 

we have been a consistent participant in the analysis of regulatory alternatives for 

controlling refueling emissions for the last five years. In addition to presenting a 

major cost/effectiveness study of onboard and Stage II controls in 1987, and detailed 

analytical comments on EPA's August 1987 rulemaking proposal, we have, since then, 

monitored technological developments and State and local regulatory developments 

with regard to Stage II controls. Moreover, being located in the District of Columbia, 

an area which has required Stage II controls on its service stations since the 1970s, 

we have acquired substantial first-hand experience with the systems. 

We are appearing here today to present information on recent developments 

regarding Stage II controls. We have reviewed the Department of Transportation's 

July 1991 assessment ofthe safety of onboard systems, and we noted its conclusion 

that the relative safety and effectiveness of Stage II controls should be considered a 

relevant and important factor in making the final determination on whether to 

promulgate onboard requirements. NHTSA concluded that because onboard systems 

would increase safety risks, and Stage II systems would not, while achieving the 

same emission control objectives, it would be reasonable for EPA to conclude that the 

risks posed by onboard systems are unreasonable. 

In the Federal Register notice announcing this hearing, EPA also noted that 

paragraph 202(a)(4) of the Clean Air Act prohibits the use of mobile source emission 

control systems that pose an unreasonable risk to public safety, and that in 

determining whether an unreasonable safety risk exists, the Administrator of EPA 

must consider, among other factors, the availability of alternative systems that would 

not cause or contribute to such safety risks. We would add that apart from the 

specific language of paragraph 202(a)(4), in general the concepts of unreasonable risk 
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Multinational Business Services, Inc. 

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and safety, as both a legal matter and a matter of common sense, would appear to 

require consideration of practicable alternatives that would avoid increasing risks to 

public safety, especially since Stage II controls are already required by the Clean Air 

Act for "moderate" and worse ozone nonattainment areas. 

EPA's notice of this hearing referenced an August 1991 document entitled "Summary 

of Changed Circumstances". We have reviewed that document. The stated purpose 

of the document is to provide a summary of relevant changed circumstances since 

August 1987, when the Agency issued its rulemaking proposal and draft Regulatory 

Impact Analysis for onboard controls. The Agency's 1987 analysis contained 

extensive discussion of the relative cost and effectiveness of Stage II controls; 

however, the "Summary of Changed Circumstances" document does not update the 

Stage II portion of the analysis. Thus, there is a clear need for such an update. We 

note that EPA's Office of Air Quality Planning and Standards has recently developed 

a draft technical guidance document for Stage II controls that addresses many ofthe 

relevant factors that we are going to discuss. 

In considering the safety risks associated with onboard controls, the following factors, 

among others, relating to required Stage II systems are relevant: 

The effectiveness of Stage II controls in reducing refueling vapor emissions, 

and related emissions such as underground tank emptying losses; 

the timeliness of Stage II in reducing those emissions; 

the reasonableness ofthe costs of installing and maintaining Stage II systems; 

the public's ability to use Stage II nozzles without undue inconvenience; and 

the relative safety of Stage II controls. 

The Effectiveness of Stage II Equipment and Programs 

In recent years, Stage II effectiveness has been proven to be very high under realworld conditions, and it is improving. Perhaps the best testament to this fact is that 

more and more portions of the country have been adopting Stage II programs on the 

basis of their proven practicality and effectiveness. At the time of EPA's 1987 

rulemaking proposal for onboard controls, Stage II programs had been adopted in 

California urban areas, the District of Columbia, the St. Louis, Missouri metropolitan 

area, and Fairfax County, Virginia. Since then, the following additional areas have 

adopted programs: The entire State of New Jersey, the entire Commonwealth of 

Massachusetts, the remainder of California, the New York metropolitan area 

(including Long Island), the State of Wisconsin, the City of Philadelphia, the Seattle, 

Washington and Portland, Oregon metropolitan areas, and Dade County, Florida (the 
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Miami area). At the time of this hearing, regulatory proposals for Stage II programs 

are pending for the Commonwealth of Pennsylvania, and Broward County, Florida, 

and several other areas are actively developing regulatory proposals. 

It is noteworthy that implementation of Stage II controls has continued to spread 

through State and local action despite the possibility that the federal government 

might issue onboard control requirements. In examining the publicly-stated 

rationales for the this activity, it can be observed that one of the principal bases is 

that Stage II programs can be implemented at a high level of effectiveness within a 

few years, whereas a federal onboard program can be fully implemented only at the 

rate that new vehicles replace the existing fleet, which would require a time frame 

of twenty years or more. This is an important point with regard to effectiveness, 

since even if onboard controls could achieve effectiveness close to that achieved with 

Stage II controls in the long term, in the interim they would suffer from a substantial 

effectiveness disparity that could never be made up. 

At the present time, areas that have already adopted Stage II programs account for 

approximately 36 percent of the gasoline pumped in all ozone nonattainment areas. 

Our calculations for this estimate are attached. Not only does this attest to the 

effectiveness of the systems, it also reduces the air quality benefits that could be 

gained by requiring onboard controls. And, even if EPA were to decide to require 

onboard controls, this trend of adoption of Stage II controls would be required to 

continue under the Clean Air Act in order to achieve attainment of the ozone 

standard within the near term. 

With regard to the effectiveness of Stage II programs, there are three elements that 

influence the outcome: (1) The effectiveness of the hardware in capturing refueling 

vapors when new and properly maintained; (2) the actual effectiveness of the 

equipment in day-to-day use, taking into account wear and tear and failures to 

perform maintenance; and (3) the extent to which smaller stations are exempted from 

the requirements. 

With regard to the effectiveness of new and properly maintained equipment, at 

present all areas with Stage II programs are relying on the California certification 

program which requires that Stage II equipment perform at a minimum effectiveness 

of 95% under actual operating conditions at commercial service stations where it is 

tested by the State. In reality, the equipment often tests out at higher than 95% 

effectiveness. For example, the new Amoco vacuum assist system which utilizes a 

bootless nozzle has been tested at virtual 100 percent effectiveness, according to 

California officials. 

With regard to the in-use effectiveness of Stage II equipment, there have been 

significant advances during the last few years. Since 1987, nozzle manufacturers 

have developed boots that are substantially more durable, and many older cars with 
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Multinational Business Services, Inc. 

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sharp projections around the fillpipe opening have been retired from the fleet. 

According to Emco Wheaton, sales of its replacement boots dropped precipitously 

after introduction of its widely-used 4000 series nozzles with the more durable boots. 

In addition, MBS personnel have monitored a service station with the Emco Wheaton 

nozzles over the last three years and have observed that the boots now appear to be 

almost tear-proof and will often last for over two years or more. 

Of course, the new system being installed at Amoco stations achieves high 

effectiveness without any boot at all, thus eliminating the possibility for any loss of 

effectiveness due to boot tears. As a result of the stimulus from Amoco, Stage II 

equipment manufacturers and dispenser manufacturers are actively working on 

competitive designs that should be coming on the market within the next year or two. 

In addition, in recent years State and local governments have acquired greater 

sophistication in enforcement and public education, two inter-related factors that can 

influence effectiveness. Those officials have found that when the public understands 

the benefits of the equipment, they can actively assist in assuring proper 

maintenance by reporting problems they see to service station personnel, or to 

enforcement officials via an 800 number. Public education also can minimize any 

abusive mishandling of equipment and spillage of gasoline and engender a more 

cooperative attitude in station personnel. 

Since the 1987 notice of proposed rulemaking, MBS and Sierra Research have 

submitted to EPA new data on the size distribution of service station populations 

which shows that the Agency's preliminary estimates of effectiveness lost through 

exemptions for smaller stations was greatly overstated. EPA's 1987 estimate was 

that exemptions would reduce effectiveness by approximately 23 percent. The newer 

data shows that the exemption factor would reduce effectiveness by a maximum of 

approximately six to ten percent. These reduction estimates are based on the 

assumption that the exemption levels specified in the statute would be adopted by the 

State and local governments. However, the statute allows State and local 

governments to adopt stricter exemption levels, or none at all, and to date the areas 

that have adopted Stage II programs have specified exemption levels stricter than the 

maximum allowed by the statute. Moreover, many areas do not allow stations to 

retain exemptions if they are substantially modified or perform underground tank 

work, and new stations often are excluded from exemptions. Therefore, in the longer 

term of fifteen or twenty years, which is the implementation time frame for onboard 

controls, almost all service stations in those areas are likely to have Stage II controls, 

regardless of their size. 

With regard to the potential effects of spillage, approximately two years ago the 

American Petroleum Institute commissioned a study of whether more gasoline 

spillage occurs with Stage II equipment, thereby reducing its effectiveness. The study 

compared spillage observed at stations equipped with Stage II controls and 
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Multinational Business Services, Inc. 

conventional equipment in the District of Columbia area. API's study concluded that 

Stage II controls cause more spillage, but the resulting reduction in overall 

effectiveness works out to only approximately two percent. 

The API study caught the attention of California officials, and they decided to conduct 

their own study at California stations. At this time, California's Air Resources Board 

has issued a draft final report, which we will submit to the record. Its finding is that 

Stage II controls result in less spillage than conventional equipment. The difference 

in outcome between the two studies, though not of great import, could be accounted 

for by the fact that the API study was conducted in the District of Columbia, where 

older equipment has been more prevalent and there has been virtually no public 

education. 

Finally, since we are located in the District of Columbia and have a great deal of 

familiarity with the Stage II program there, we should address what might be 

referred to as the "lower bound" of Stage II effectiveness that was presented by EPA 

in its 1987 rulemaking proposal. The Agency used the District of Columbia program 

to illustrate a "minimal enforcement" scenario, and this scenario yielded a very low 

effectiveness estimate. After investigating this point extensively, we have concluded 

that the District's past experience cannot be considered relevant to a realistic 

assessment of Stage II effectiveness. We have previously commented on this issue, 

but the following points regarding the District of Columbia situation bear repeating, 

since EPA's lower-bound estimate has been frequently emphasized by opponents of 

Stage II controls: 

• EPA can require effective enforcement programs and plans to do so. 

• Although there was virtually no enforcement of the Stage II program in the 

District until several years ago, the District nov/ has an effective enforcement 

program. 

There has been virtually no education of the public or service station personnel 

in the District, and stations have not posted operating instructions. 

• The failure of adjacent suburban areas to implement Stage II programs 

engendered great resentment and resistance towards the program on the part 

of service station personnel. 

• The District is a very small and isolated market, and consequently equipment 

manufacturers did not make efforts to educate service station personnel 

regarding equipment improvements and proper maintenance. 

Because adjacent populous areas do not have Stage II programs, and because 

the District has a great influx of tourists, many motorists who pump their own 
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gasoline in the District have no previous experience with the operation or 

benefits of Stage II controls. 

MBS has prepared a chart that takes into consideration all of the above factors that 

bear on Stage II effectiveness and that have undergone changes since the 1987 

rulemaking proposal, and compares the Stage II effectiveness with onboard 

effectiveness that would be expected if regulations were promulgated under the 1990 

Amendments. The chart is based on the most recent available government 

projections of gasoline consumption and fleet replacement, and detailed notes 

concerning assumptions and data sources are attached. 

This is the EPA chart from its 1987 proposed analysis; this is the chart showing the 

new MBS estimates. The Stage II curve assumes that onboard requirements are not 

promulgated. It can be seen that even making more favorable effectiveness 

assumptions for onboard controls, there is no way that they can achieve effectiveness 

comparable to Stage II programs, particularly when the huge onboard time lag is 

taken into consideration. This picture does not improve as a result of onboard being 

essentially a nationwide program, since Stage II can also be required on a nationwide 

basis if the Agency were to determine that it is needed for control of air toxics in 

addition to ozone, and Stage II controls can be implemented much faster than 

onboard controls. 

The Reasonableness of Stage II Costs 

The State and local governments that have adopted Stage II programs to date have 

all carefully examined Stage II costs and have found them to be reasonable and very 

attractive. Cost estimates by virtually all sources translate to a fraction of a cent per 

gallon of gasoline. It can be expected that this situation will continue at the least, and 

costs are likely to come down when one looks to the future. 

• The recent development of single-hose multi-product dispensers ("MPDs") will 

eventually reduce the number of nozzle/hose units that must be outfitted with 

Stage II equipment and maintained. 

New dispensers will incorporate Stage II piping and vacuum-assist devices. 

• The growing market for Stage II controls is stimulating competition in the 

development of equipment which is more durable and cheaper, and larger and 

longer production runs could allow price reductions. 

• Continuing changeover to current-generation equipment with better durability 

is reducing maintenance costs. 

• Inspection/enforcement programs are becoming more efficient. 
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A frequently overlooked cost advantage of Stage II controls is their fuel conservation 

attribute. This is referred to by EPA as "recovery credits" in its cost calculations. 

Unlike onboard controls, where any fuel conservation is very speculative, the fuel 

conservation benefits of Stage II controls are definite - approximately one gallon for 

every one thousand pumped - due to suppression of evaporation in the storage tanks 

by the recovered vapors. This translates into cost savings for service stations and 

energy conservation for the country. On a nationwide basis, the fuel savings would 

be over ninety million gallons of gasoline per year. 

Ease of Operation and Consumer Acceptance of Stage II Controls 

At the time EPA developed and issued its 1987 rulemaking proposal, there were 

concerns raised by the Agency and some other interested parties regarding possible 

difficulties posed for self-serve motorists. Some believed that much Stage II 

equipment was heavy, awkward, and required substantial insertion force. These 

concerns have almost completely vanished with introduction of design improvements 

over the last few years, as demonstrated by the continuing spread of Stage II 

programs. 

Two years ago MBS produced an educational video on Stage II controls that shows 

some of these improvements. We are going to show that video now. The video we are 

showing was updated just last year. MBS will submit several copies of the video to 

Docket A-87-11, and interested parties can obtain additional copies by contacting us 

directly. 

The bootless nozzle shown in the video was a prototype of trie nozzle now being used 

on the Amoco system. Clearly, the use of such a system virtually eliminates any 

noticeable handling differences between Stage II and conventional systems. This a 

newspaper ad that Amoco has run in the Washington, D.C. area, and it illustrates 

how competition is stimulating further improvements. (In connection with this ad, 

we would note that although it asserts that other Stage II nozzles are difficult to use, 

we believe such an assertion is not justified if the other nozzles are up-to-date 

equipment; however, there is some validity to the assertion for the District of 

Columbia, since just the other day one of our staff checked over thirty of the District 

stations and found that many still had not completed the transition to modern 

hardware.) Stage II equipment manufacturers have also informed us that they are 

working on balance system boots which will require even less insertion force than the 

best now available, possibly as much as fifty percent less. 

Until recently, public education through use of visual materials such as video public 

service announcements and handouts was minimal. However, the consequences were 

not very significant from a convenience standpoint. The experience in areas where 

Stage II controls have been introduced without widespread public education has been 

that there is an initial slight negative reaction until people have used the equipment 
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several times and become familiar with it, and then complaints disappear. In areas 

where the populace has become familiar with the equipment and its benefits, such 

as California, people have told us that they prefer Stage II stations over conventional 

stations because they appreciate its air quality benefits and because they notice that 

they do not have to smell the vapors when they fill up. 

Incidentally, in this era of increased public awareness of environmental problems, we 

see active participation by consumers in reducing pollution to be a point in favor of 

the Stage II approach rather than the opposite. 

Safetv of Stage II Controls 

In showing the MBS video to audiences we have noticed that they seem to acquire 

a much better grasp of the potential safety problems when they see the animated 

portion of the video, because they become aware of how a large volume of vapors is 

displaced from the tank very quickly. 

The Senate report in connection with the recent Clean Air Act Amendments notes 

that a study by Failure Analysis Associates found that Stage II systems "can prevent 

about half of all gasoline fires (both refueling and non-refueling) at gas stations." 

(S.Rep. 101-228 at 40-41.) MBS has not conducted any independent study of this 

issue, but we have questioned Stage II equipment manufacturers and State and local 

officials in areas with Stage II programs as to whether they know of any safety 

problems caused by modern Stage II equipment, and the answer has always been a 

negative. In addition, we are not aware of any documentation that would reflect 

safety incidents related to modern Stage II controls. One would expect to see some 

data, whether anecdotal or statistical, if there were problems, given the extent of 

real-world experience with Stage II systems. Therefore, it appears that at the least 

Stage II controls do not create safety problems, and at best they improve safety. 

In summary, we agree with the Department of Transportation that it is necessary to 

consider the inadvisability of imposing the safety risks related to onboard controls in 

the context of the availability of Stage II controls and their proven effectiveness and 

safety, as well as their ease of operation and affordability. 

Attachments 
P.13 

Federal Regiater / Vol. 52, No. 160 / Wednesday, August 19.1987 / Proposed Rules 31179 

K 

tn 00 

K 

to 

to 

fc? 

• 3 

•UU3 6ujX}duu3 ap 6ujpn^oy >o uoj^onpoy % 
FIGURE 1 9/26/91 

100% 

90% 

80% 

70% 

60% 

50% 

40% 

30% 

20% 

10% 

Percent Of Nonattainment Area 

Gasoline Throughput Potentially Controlled 

By Onboard And Stage II Controls Over Time 

STAGE II 

o%4—+—+—+—f -

'91 '92 '93 '94 '95 '96 '97 '98 '99 '00 '01 '02 '03 '04 '05 '06 '07 '08 '09 '10 

— 90% In-Use 

Effectiveness 

80% In-Use 

Effectiveness 

For details concerning principal assumptions and data sources, see attached notes. 

Multinational Business Services, Inc. 
NOTES TO FIGURE 1 

In all estimates, gasoline throughput is treated as a proxy for refueling emissions. 

Onboard effectiveness estimates: 

The estimates assume minimum 95% effectiveness on new cars. 

• The in-use effectiveness scenarios of 90% and 80% represent a range for the effectiveness reductions that could occur 

during the life of the vehicles due to wear and tear, malfunctions, and tampering. The 80% scenario appears more likely, 

based on EPA data for current evaporative systems analyzed by MBS in rulemaking comments prior to the legislation. 

• Estimates of new vehicle production, survival rates, gasoline mileage, and vehicle miles travelled for every model year 

of each vehicle type for each year of the projections were derived from The Motor Fuel Consumption Model: Fourteenth 

Periodical Report (December 1988), prepared by Energy and Environmental Analysis, Inc. for the Department of Energy. 

• Both estimates assiune that regulations would extend only to Light-Duty Vehicles, since only LDVs are covered by section 

202(a)(6) as amended in 1990. 

Stage II effectiveness estimate: 

Assumes 95% effectiveness for new equipment, the minimum required by the California certification program, which all 

other areas have so far followed. 

• In-use effectiveness (IUE) reflects reductions due to inadequate maintenance and malfunctions. IUE is assumed to be 88% 

currently with annual enforcement inspections, although some data indicates that an IUE of at least 90% or higher should 

be expected with more frequent inspections or with up-to-date Stage II technology. IUE is projected to increase to 90% 

over time as a result of improved equipment, more efficient enforcement and better public education. See the MBS 

comments on this point submitted during the rulemaking prior to the 1990 Amendments, and Sierra Research, Inc., "An 

Analysis of Stage II and Onboard RefueUng Emissions Control" (1988). 

The net effectiveness estimate of 81% takes into account exemptions for independent stations pumping not more than 

50,000 gal. per month and other stations pumping not more than 10,000 gal. per month. Sierra Research, supra, found 

in analyzing 1988 data on service station populations in metropolitan areas that these smaller stations accounted for about 

7.5% of the gasoline pumped. The actual reduction due to exemptions might turn out to be considerably smaller, since 

areas that have so far adopted Stage 11 requirements without federal compulsion have opted for exemption levels of 

between zero and about 20,000 gal. per month. 

Multinational Business Services, Inc. 

XI 
The Stage II starting point of 25% in 1991 reflects an MBS calculation (attached) showing that ozone non-attainment areas 

that have already adopted Stage II requirements comprise (conservatively) 35.55% of non-attainment area gasoline 

throughput, but not all of the equipment has been installed yet in these areas. County-by-county fuel consumption 

information for areas subject to Stage II controls is 1982 data from Appendix G of EPA's July 1987 Draft Regulatory Impact 

Analysis: Emission Regulations for Gasoline-Fueled Motor Vehicles -Volume 1, Analysis of Gasoline Marketing Regulatory Strategies. 

Total gasoline throughput in non-attainment areas is 1989 data provided by EPA's Office of Air Quality Planning and 

Standards (copy attached). 

It is assumed that onboard requirements are not promulgated and that all non-attainment areas classified as "moderate" 

or worse comply with the Acf s Stage II requirements within five years. 

It is assumed that non-attainment areas classified as "marginal" will either reach attainment without Stage II or implement 

Stage n. 

Stage II effectiveness of 81% by 1996 is assumed to increase gradually to 83.8% by 2006 as a result of assumed 

improvement in IUE to 90%, as noted above, and at least partial loss of exemptions by new and modified smaller stations, 

as noted above. 

Multinational Business Services, Inc. 
Multinational B usiness Services, Inc. 

STAGE II REQUIREMENTS IN PLACE 

State 

California 

D.C. 

Florida 

Massachusetts 

Missouri 

New Jersey 

County 

Alameda 

Butte 

Contra Costa 

El Dorado 

Fresno 

Imperial 

Kern 

Kings 

L.A. 

Madera 

Marin 

Merced 

Monterey 

Napa 

Orange 

Placer 

Riverside 

Sacramento 

San Benito 

San Bernadino 

San Diego 

San Francisco 

San Joaquim 

San Mateo 

Santa Barbara 

Santa Clara 

Santa Cruz 

Solano 

Sonoma 

Stanislaus 

Sutter 

Tulane 

Ventura 

Yolo 

Yuba 

Dade 

All 

Franklin 

Jefferson 

St. Charles 

St. Louis 

St. Louis City 

All 

Throughput (000) 

490,261 

75,363 

304,044 

50,289 

216,141 

46,951 

168,446 

36,440 

3,347,921 

36,511 

110,880 

68,796 

118,965 

54,024 

933,206 

83,167 

280,851 

368,936 

14,639 

360,464 

788,407 

247,113 

146,574 

320,471 

66,990 

625688 

82,506 

96,772 

167,587 

144,773 

29,463 

124,019 

226,154 

47,093 ; 

26,979 

271,629 

646,936 

2,226,859 j 

45,169 ! 

86,835 

88,647 ', 

148,148 j 

475,836 j 

3,133,102 | 

i 

i 

J 
Multinational Business Services, Inc. 

New York 

Oregon* 

Pennsylvania 

Virginia 

Washington* 

Wisconsin** 

Total Throughp 

Areas W/ Stage 

Total Throughp 

Areas w / Stage 

New York 

Kings 

Queens 

Richmond 

Bronx 

Rockland 

Westchester 

Nassau 

Suffolk 

Clackamus 

Multnomah 

Washington 

Philadelphia (City) 

Fairfax 

Clark 

Snohomish 

Pierce 

King 

Kenosha 

Milwaukee 

Ozaukee 

Racine 

Sheboygan 

Washington 

Waukesha 

utln 

II Requirements 

nt In Non-Attainment 

II Requirements 

Throughput In Non-Attainment Areas 

120,657 

276,753 

382,686 

100,191 

140,952 

98,708 

321,343 

548,607 

483,613 

87,038 

262,836 

80,856 

397,930 

197,318 

76,920 

118,330 

176,794 

523,087 

55,552 

333,638 

34,770 

66,407 

47,723 

47,540 

110,637 

22,520,931 

21,195,070 

59,623,654 

% of Non-Attainment Throughtput 

Subject To Stage II 35.55% 

Current Ozone Standard Attainment Status Uncertain. 

* Stage II Requirements Enacted But Coverage Not Finalized. 
P.19 

SEP-20-1991 15=09 FROM ORQFS.ESD.CPB/1SB RTP NC TO 82029396969 P.02 

TABLE 2 - 2 . ESTIMATED GASOLINE CONSUMPTION 

FOR OZONE NONATTAINMENT AREAS 

* 

I 

j 

STATE I 

ALABAMA | 

ALASKA 1 

ARIZONA | 

ARKANSAS I 

CALIFORNIA I 

COIORAOO 1 

CONNECTICUT | 

DELAWARE I 

OISTRICT OF COL. | 

FLORIOA | 

GEORGIA I 

HAWAII | 

IDAHO | 

ILLINOIS | 

INDIANA | 

IOUA 

KANSAS 

KENTUCKY 

LOUISIANA 

MA IHE 

MARYLAND 

MASSACHUSETTS 

MICHIGAN 

MINNESOTA 

MISSISSIPPI 

MISSOURI 

MONTANA 

NEBRASKA -

NEVADA 

•- NEW HAMPSHIRE 

NEW JERSEY 

NEW-MEXICO 

NEWYORK 

NORTH CAROLINA 

NORTH OAKOTA 

OHIO 

OKLAHOMA 

OREGON 

PENNSYLVANIA 

RHOOE ISLAND 

SOUTH CAROLINA 

SOUTH OAKOTA 

TENNESSEE 

TEXAS 

UTAH 

VERMONT 

VIR6INIA 

WASHINGTON 

WEST VIRGINIA 

WISCONSIN 

WYOMING 

NATIONWIDE 

SOURCES: ( 

( 

I PERCENTAGE OF 1985 1 1 

1 THROUGHPUT IN | 1 

TOTAL 1989 I NONATTAINMENT 

THROUGHPUT (1) 1 AREAS (2) • 

2,1221380 I 281 

239,017 | OK 

1.709,888. | OX 

1,277,910 | 2ft 

13,338,831 | 90* 

1,535,449 | Oft 

1,498,244 | 100* ] 

349,255 j 10W | 

182,324 | IOCS I 

6,162,552 | 47ft | 

3,673,874 I 431 I 

392,49S 1 Oft | 

487,784 | Qft | 

4,994,276 I 68X I 

2,642.271 1 45ft ! 

1.409,914 j Oft 

1,298.792 1 Z2ft 

1,851,136 : 4SX 

2,040.067 | 18ft 

638.289 ! 65ft 

2.157.848 ' 87ft 

2,521.208 1 100ft 

4,378.611 . 55ft 

2,102.362 i Oft 

1.258,285 | 2ft 

2,758*383 1 SIS 

452,889 1 OS 

801.115 1 Oft 

633.267. | Oft 

527,297 I 71ft 

3,479,752 1 100ft 

820,566 j Oft 

5,769,796 i 67ft 

3,369,498 ! 41* 

361,259 | Oft 

4,951.185 | 72ft 

1.751.590 | Oft 

1,368.250 | Oft 

4,709,003 | 81ft 

384,987 1 100ft 

1,503,672 | 24% 

398.125 | QS 

2.634.776 I 52X 

8,792.628 1 47% 

640,858 | 52ft 

283*993 | Oft 

3,044,441 | S4S 

2.337.041 | Oft 

836,891 1 29ft 

NONATTAIKNENT | 

THROUGHPUT 1 

585.734 

0 

0 

22.606 

12.009,483 

0 

1,498,244 

! 

349.255 1 

182,324 | ! 

2,868.914 I ! 

1.580.795 | 

0 

0 

3,381.924 

1,187,516 

0 

280,695 

839,009 

372,271 

415.041 

1.867.013 

2.521.208 

2,423,167 

0 

29,998 

| 1,417.395 

! 0 

I o 

1 ° | 376,200 

| 3,479,752 

I o 

| 3,877,649 

| 1,384.089 

1 ° | 3.586,490 

0 

0 

3.818.013 

384,987 

360,686 

0 

1,373,430 

4,127,699 

340,196 

0 

1,652,370 

0 

242,590 

2.121,968 I 37S 1 786,911 

I 

1 

288.302 | Oft | ° 

1 115,292.695 | S2S | 59,623,654^ 

1) Ftdanl Hlajnray Adartnistntlon, Monthly Gasol Ina Reports 

1 

Ai Raportad 1n NPN 1990 Factbook _ 

2) Calculated fron 1985 NEDS Gasol Ina Contraction Rw * 

Using Monattalnam araa* as listed in •Ozona and Carbon 

Monoxida Aroas Vlolitlno tha NAAOS' 

2*8 
P.20 

THE ' 0 0 £ A/gW NOZZLB 

Only Amoco makes pumping gasoline easier on jou and easier on the environment. The bulky vaporrecovery nozzles at other stations are dfficult and iriitating to use. But Amoco's new nozzle is sleek and 

streamlined. And no other vapor-recovery system does a better job of colecting ozone-causing 

hydrocarbons. So give yourself and the environment a break. 

Try Amoco's new nozzle. 
P.21 

Technical Paper 

FINAL DRAFT 

Caffomia Air Resources Board 

91-CD-TP-1 

September 1991 

COMPARISON OF SPILL FREQUENCIES 

AND AMOUNTS AT VAPOR RECOVERY 

AND CONVENTIONAL SERVICE STATIONS 

IN CALIFORNIA 

by 

Robert L. Fricker 

James J. Morgester 

G. Henry Jordan 

California Air Resources Board 
P.22 

Comparison of Spill Frequencies and Amounts at 

Vapor Recovery and Conventional Service Stations in California 

Robert L. Fricker 

James J. Morgester 

G. Henry Jordan 

Abstract 

Based on a survey conducted in 1989 and 1990 at 21 conventional-nozzle 

and 33 vapor-recovery nozzle equipped service stations in California, 

California Air Resources Board staff conclude that conventional nozzles in 

California produce a greater number of quantifiable spills (>. 1 ml) and a 

greater average volume per spill than do vapor-recovery equipped nozzles. 

This conclusion is based on survey results showing conventional nozzles 

having spills 30.3% of the time at four fueling intervals vs 22.3% for vapor 

recovery nozzles, and having an average spill volume of 13.1 ml vs 10.6 ml 

for vapor recovery nozzles. However, if an extraordinary spillage event for 

a conventional nozzle noted during the survey is subtracted from the total 

quantified spill volume, the average volume per quantifiable spill for a 

conventional nozzle would drop to 10.8 ml, which is very close to the 10.6 

ml average volume per quantifiable spill with a vapor recovery nozzle. In 

addition, conventional nozzles in California produce about 14 percent more 

drop (< 1 ml) spillage than do vapor recovery nozzles. Drop spillage has 

not been quantified as to the volume of gasoline it represents. 

INTRODUCTION 

Starting in 1976, air pollution control districts (APCDs) in California 

with major metropolitan areas began adopting rules to control the release of 

gasoline vapors (a precursor to the formation of ozone) during the filling 

of vehicle gasoline tanks at retail service stations in the districts. 

APCDs requiring such equipment typically had not attained the California or 

federal ambient air quality standard for ozone. Equipment controlling the 

release of gasoline vapors during the fueling of vehicles is referred to as 

"Phase II vapor recovery equipment." Most vapor recovery nozzles can be 

distinguished from conventional nozzles by a rubber-type boot around the 

nozzle spout that is used to capture gasoline vapors escaping from a vehicle 

fuel tank. By 1986, 90 percent of the gasoline sold in California was 

dispensed through retail service stations equipped with Phase II controls. 

In 1988 the California Air Resources Board (CARB) required aJJL APCDs in 

the State to adopt rules that required the Installation of Phase II vapor 

recovery equipment at new retail service station and at existing retail 

stations with an annual gasoline throughput of greater than 480,000 gallons. 

Such equipment was required in order to control the release of emissions of 

benzene, which had previously been identified by the CARB as a toxic 

and cancer-causing pollutant. Thus, those districts in California that had 

not previously required installation of Phase II equipment were now required 

to do so. Compliance with this requirement by affected existing stations 

was to be accomplished within two years after adoption of an appropriate 

rule by a district. As noted above, many of California's districts were 

already complying with the new requirements. 
P.23 

What the new requirements mean is that by the beginning of 1991, a very 

large majority of retail service stations in California will not have 

conventional nozzles but will have vapor recovery nozzles. This trend will 

increase as the years go by. 

Since the first installation and use of Phase II vapor recovery nozzles 

in California, the CARB initially received a considerable number of 

complaints about the difficulty in-using these nozzles and about possible 

excess spillage with their use. Consequently, suppliers of the Phase II 

equipment have been in a continual process of refining the design of this 

equipment in order to increase its ease of use and to decrease spillage. 

Because in the near future only a relatively small number of retail 

service stations in California will be equipped with conventional nozzles, 

CARB management decided it was time to conduct a comparison study on the 

spillage potential of conventional and vapor recovery nozzles in California. 

The purpose of the study was to determine the spillage frequency and amounts 

associated with the two types of nozzles. 

Subsequently, from July 1989 to February 1990, staff of the Compliance 

Division of CARB, after receiving proper training, were dispatched to 

numerous service stations in California in order to observe and document 

fuelings at these stations and any related spills. The methodology and 

results of this study are documented in this paper, along with subsequent 

conclusions. 

METHODOLOGY 

PRE-SURVEY EXPERIMENTATION 

Defining a Gasoline Spill 

In theory, a gasoline spill at a service station can be defined in many 

ways: that it is the point in the refueling process where the spillage 

occurs (pre-fuel, fueling, shutoff, post-fuel) and that each point 

constitutes a separate spill; that spilled gasoline on the side of a vehicle 

constitutes a separate spill; that small drops the sizes of dimes, quarters, 

and half dollars that have fallen onto the concrete surface constitute a 

spill; that only a certain measurable area of spilled gasoline on the 

concrete surface that can be easily, accurately, and consistently related 

back to a specific volume of spilled gasoline constitutes a spill; and that 

spillage of any kind at any point during the fueling process should be 

agglomerated and constitute one spill. 

In order to help define a spill, staff of the California Air Resources 

Board's (CARB's) Compliance Division conducted experiments at service 

stations in the Sacramento area of California, where various volumes of 

gasoline were spilled from a graduated cylinder, from a set height (30 in.), 

onto the concrete surface. Staff discovered that the smallest, best 

continuous measurable spill (in square inches) that was quantifiable (in 

milliliters) was 1 ml. Below that volume, the gasoline, falling from a 

height of 30 in., tended to stick to the walls of the graduated cylinder, 

and the amount that did spill tended to disperse into scattered spots on the 

- 2-
P.24 

concrete surface. It was also noted that spills of 1 ml or greater produced 

a temporary stain that could be measured after the person finished refueling 

her or his vehicle. Consequently, staff decided to define a spill, in part, 

as that volume of spilled gasoline that produced on the concrete surface a 

stained area (sometimes with gasoline on it) that was equivalent to 1 ml or 

greater of gasoline. 

Staff was also very concerned about when in the fueling cycle a spill 

occurred; so staff decided to define a spill in terms of when it occurred: 

pre-fuel, which includes removing the nozzle from the dispenser and 

inserting it into the vehicle fill pipe; fueling, which includes the 

dispensing process from start to the nozzle shut-off phase; shut-off, which 

includes any spills which occur at nozzle shut-off either by automatic or 

customer controlled shut-off; and post-fuel, which includes any spillage 

occurring during removal of the nozzle from the vehicle to hanging the 

nozzle up on the dispenser. Furthermore, staff also decided that spillage 

at any one of these intervals would constitute a separate spill. 

Another phenomenon observed during experimentation of measuring spills 

was gasoline that spilled on the side of a vehicle during the refueling 

process but never fell to the drive surface. Experimentation was conducted 

on vehicles to see if gasoline spilled on the vehicle from the fill pipe 

opening to the bottom of the body of the vehicle could be measured and 

quantified. It was discovered that such variables as the fill pipe height, 

shape of the vehicle's body, amount of roll-under of the vehicle (the point 

where the body of the vehicle slopes inward), condition of the vehicle's 

paint, and how much dirt was on the vehicle influenced the retention of any 

gasoline spilled on the vehicle downward from the fill pipe opening. It was 

not possible, however, to obtain a constant measurable amount that spilled 

on the vehicle surface. 

Nevertheless, it was determined from the experimentation that the 

spills varied from one to three milliliters before they would drip off onto 

the drive surface as drips or measurable spills. Therefore, to account for 

spills on the vehicle, staff decided to use a symbol "V" on the survey form 

to indicate a vehicle spill of from one to three milliliters. In 

quantifying the volume associated with "V" spills, Compliance Division 

management decided that an average of two milliliters per spill would be 

used. 

Although drops of gasoline (less than 1 ml) that fall from the nozzle 

or possibly from the side of a vehicle constitute spillage, our pre-survey 

experimentation indicated it was difficult to relate drop area size to a 

known volume of spilled gasoline. In addition, spilled drops on the surface 

evaporated quickly. To address in some way the phenomenon of drops spilled, 

staff decided to simply count them during the survey and enter, on the 

survey form, the number of drops that occurred at each of the fueling 

intervals. 

Variables Affecting or Not Affecting 

Spill Surface Area 

The variable that had the greatest effect on the area of any gasoline 

spilled was the drive surface surrounding the gasoline dispenser islands 

-3-
P.25, 

where the vehicles parked while being refueled. This was due to the 

porosity and surface condition which affected the absorbency of the drive 

surface. This was always concrete. We found that there was no constant 

regarding the concrete conditions; therefore, we decided to do a measured 

spill at each service station prior to conducting the survey. 

The other variable that influenced the spill surface area was the 

height at which the measured gasoline was poured onto the concrete drive 

surface. Accordingly, we decided to use a constant measured spill height of 

30 inches. This height takes into account the various heights of vehicle 

fill pipes and the various locations of the fill pipes on different 

vehicles. 

It was also determined during experimentation that temperature and wind 

did not play an effective variable in the spill process, but did effect the 

speed in the evaporation of the spilled gasoline. Therefore, staff decided 

not to collect temperature and wind data as part of the data collected for 

the survey. 

GASOLINE SERVICE STATION SELECTION 

The process of selecting service stations having either vapor recovery 

or conventional nozzles was made as economically as possible by choosing 

stations as close to the ARB Compliance Division office as possible. This 

office is located in Sacramento, California. By driving around, the project 

leader for the survey developed a list of vapor recovery stations for the 

City of Sacramento (a large metropolitan area) and a list of conventional 

nozzle stations located in smaller cities and communities in the Sacramento 

Valley from Arbuckle to Redding, California (Redding was the largest). The 

only selection criteria used was that the service station be close to a 

major road or freeway to help ensure that the station would be busy and that 

a cross-section of the types of people in California would be using the 

pumps at the stations. Service stations in Sacramento have been required to 

use vapor recovery nozzles and related equipment since 1980. So people in 

this city have been exposed to using the equipment for a considerable length 

of time. 

TRAINING OF OBSERVERS 

The training included classroom and field training at service stations 

for all the members of the survey team (nine people). The training was 

conducted solely by the project leader in order to minimize any variables in 

the data collection. Team members were instructed on how to fill out the 

two types of forms to be used in the survey: The "Service Station Surface 

Spill Survey Form" and the "Vehicle Fuel Spill Survey Form," Figures 1 and 2 

of this paper. The service station form contained entry spaces for such 

information as inspector name, date, station name, type of surface at the 

station, and results of spill testing of various volumes of gasoline. The 

spill survey form contained entry spaces for such information as station 

data, types of nozzles used, type of vehicle that refueled, fill pipe 

location, gallons dispensed, did customer top off, type of spillage, etc. 

All members practiced spilling measured volumes of gasoline (1, 2, 3, 

5, 10, 20, and 50 ml) and measuring the surface area of the ensuing spill. 

M t *in-»i** » *»•" * 
Figure 1 

STATE OF CALIFORNIA 

AIR RESOURCES BOARO 

COMPLIANCE DIVISION 

P.26 

Pane 

ARB Inspector , , 

Station Name. _ 

Address 

Nozzle Number(s) and Amount 

Surface: Concrete 

Snooth 

Size: 

Drained 

Asphalt 

Rouqh 

AT 30 INCHES 

SO. 

SO. 

so. 

SO. 

so. 

so. 

so. 

Oate 

APCD 

Citv 

Other 

Inches • 1 Milliliter 

Inches . 2 Hi 11 i 1 iterj 

Inches • 3 Milliliters 

., ,. Inches • S Milliliters 

,., Inches . 10 Milliliters 

_„ Inches . ?0 Milliliters 

Inches • SO Milliliters 
P.27 

Figur e 2 

Side 1 

irate a» CAilraama 

aia KMwn i aeaao 

CWUU H .ITIII M 

T.al.l . ' " «•'«•. >•'• 

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Side 2 

ruci -

i 

i i 

t s 

t i 

tT 

t l 

Iff 

t l 

H 

•« 

I t 

11 

VCMICt C 

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i«ra*t* A 

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-6-
P.28 

These benchmark surface areas and related volumes, when done at the station, 

would serve as guides for judging the area and volume of any spill. Team 

members were also told to document on the spill survey form: (1) all spills 

of 1 ml or greater, (2) the number of drops that were spilled at each phase 

of the fueling process, and (3) gasoline spilled on the side of a vehicle 

with a "V" symbol. 

The project leader informed the- team that he would monitor each 

member's methodology during the first time at a service station in order to 

ensure that all members conducted the benchmark spill tests, and that they 

measured and recorded any spills according to the established procedure. 

Periodically, the project leader expected to monitor the performance of the 

survey members in order to ensure consistency in the methodology. 

One important final point: Compliance Division management had decided 

that it wished to obtain "real world" data at a station~i .e., with the 

station in the "as is" condition. Consequently, team members were 

instructed not to give station operators advance notice of the survey. This 

no-notice criterion is based on prior experience that advance notice can 

cause excessive maintenance to be performed on the equipment prior to a 

survey. In addition, the service station operators were to be told that an 

inspection of the use of the refueling equipment was being conducted rather 

than a gasoline spill survey. This statement was to be made in order to 

reduce the chance of bias results of any full-serve refueling operation. 

FIELD OBSERVATIONS 

During the period of July 25, 1989 through January 11, 1990, teams of 

one, two, and three persons were sent by the spill project team leader to 33 

vapor recovery stations in the Sacramento, California area to observe for 

spillages of gasoline and to record their findings. Thirty-seven separate 

visits were made at these stations because some stations were visited more 

than once. All of the vapor-recovery nozzle equipment that was observed for 

spills was in good working order. Ninety-seven percent of the observed 

fuelings were at self service pumps. 

The vapor-recovery-nozzle-equipped service stations were predominately 

balance type systems. Of the 33 vapor-recovery-equipped service stations, 

31 were of the balance type, 1 Hirt vacuum assist type, and 1 Healy assist 

type. Of the 31 balance-equipped service stations, 7 were equipped or 

partially equipped with OPW balance equipment while the remainder used Emco 

Wheaton balance equipment. 

During the period of September 19, 1989 through November 17, 1989, one 

and two person teams were sent to 21 conventional-nozzle stations along 

Interstate 5 freeway in the Sacramento Valley to observe for spillages of 

gasoline and to record their findings. One station was visited in Arbuckle, 

3 in Williams, 1 in Orland, 13 in Redding, and 3 in Red Bluff, California. 

All of the conventional nozzle equipment that was observed for spills was in 

good working order. Ninety-seven percent of the observed fuelings were at 

self service pumps. 

The conventional-nozzle equipped service stations used equipment 

manufactured by Emco Wheaton, OPW, Husky, Catlow, Carder, Viking and other 

-7-
P.29 

equipment which could not be identified. It was also observed that in 

conventional nozzle equipped stations a mix of nozzle manufacturers' 

equipment was used as a normal practice, whereas in vapor recovery nozzle 

equipped service stations, one manufacturer's equipment was usually used. 

All the members of the survey team were equipped with safety equipment, 

proper forms, and measuring devices for conducting spills and measuring 

spills during refueling of vehicles: The members were also equipped with 

clean-up equipment for the gasoline that was spilled in order 

spill size. In observing the fueling operation, staff placed 

close to the vehicle as possible without interfering with 

process. When a spill judged to be greater than or equal to one milliliter 

was observed, staff measured its dimensions with a tape measure, calculated 

the surface area, and then compared that area with the benchmark surface 

areas established for 1, 2, 3, 5, 10, 20, and 50 milliliter spills when the 

staff first arrived at the station. This comparison was done to arrive at 

the closest approximation of the volume of the spill. "V" spills and number 

of drops observed were also documented on the survey form. 

to determine 

themselves as 

the fueling 

RESULTS 

SPILL FREQUENCIES AND AMOUNTS OF SPILLS 

Spills One Milliliter or Greater (Measurable Spills^ 

Table 1, as follows, presents the number and percentage of fuelings 

with measurable spills at the four fueling intervals for vapor recovery and 

conventional nozzle systems: 

Table 1. Number and Percentage of Fuelings with Measurable Spills. 

Number of Percent of 

Service Number of Measurable Spills at Fuelings with 

Station Type Fuelings Four Fueling Intervals Measurable Spills 

Vapor Recovery 1515 

Conventional 1496 

232 

249 

15.3 % 

16.6 % 

As Table 1 indicates, a greater percentage of conventional nozzles had 

measurable spills associated with them at the four fueling intervals than 

did vapor-recovery equipped nozzles. 

Table 2, as follows, presents the total volume of the measurable spills 

that occurred during the four fueling intervals and the volume of an average 

measurable spill for both conventional and vapor recovery nozzle systems: 

-8-
P.30 

Table 2. Total Volume of Measurable Spills and Average Volume per Spill 

Type of 

Fueling 

Vapor Recovery 

Conventional 

Number of Total Volume 

Measurable Spills at of Measurable 

Four Fueling Intervals Spills 

232 

249 

3373 ml 

5555 ml 

Average Volume 

per Spill 

14.5 ml 

22.3 ml 

As Table 2 indicates, conventional nozzles had a greater volume of 

measurable spillage associated with them than did vapor-recovery equipped 

nozzles. 

An extraordinary spillage event occurred while observing conventional 

fuelings. This event produced two large spills (one during fueling, one 

during shutoff at a single fueling) that accounted for approximately 19i of 

the total amount of measurable gasoline spilled for conventional nozzles. 

However, even had this event not occurred, the total measurable amount 

spilled would be 4512 milliliters, and an average measurable spill would be 

18.1 milliliters, which is still greater than the measurable spillage from 

vapor recovery nozzles. 

A description of this event follows: During the fueling process the 

customer had control of the nozzle, but the nozzle kept slipping out of the 

vehicle fill pipe, allowing a large amount of gasoline to be spilled on the 

concrete. Subsequently, after the customer got the nozzle to stay inserted, 

he put the fillpipe cap under the trigger of the nozzle to keep it operating 

by itself. When the nozzle was supposed to shut off because the tank was 

full of gasoline, the nozzle did not shut off, and gasoline kept spilling on 

the concrete surface until the customer took action to stop the flow from 

the nozzle. 

Vapor recovery nozzles have latching devices which keep the nozzle 

inserted in the vehicle fillpipe. In addition, vapor recovery nozzles have 

a secondary shutoff system in case the primary fails. Also, vapor recovery 

balance nozzles have an interlock system which prevents gasoline from being 

dispensed unless the boot is compressed, such as occurs when the nozzle is 

inserted into a vehicle fill pipe. These design features of vapor recovery 

nozzles help reduce spillage. 

" V Spills 

In addition to the measurable spillage on the concrete that occurred, 

there was also spillage that occurred on the vehicle itself during some of 

the refuelings. As noted earlier, these spills were called "V" spills. 

Table 3, as follows, presents the number and percentage of "V" spills that 

occurred during the four types of fueling intervals. 
P.31 

Table 3. Number and Percentage of Fuelings with "V" Spills. 

Service Number of 

Station Type Fuelings 

Vapor Recovery 1515 

Conventional 1496 

Number of "V" Fuelings 

Spills at Four with "V" 

Fueling Intervals Spills. % 

106 

205 

7.0 % 

13.7 % 

Total 

Volume of 

"V" SPillS 

212 ml 

410 ml 

Measurable and "V" Spills 

Combined (Ouantifiable Spills) 

Combining the measurable spills that reach the concrete of the service 

station surface with the "V" spills that occur of the side of the vehicle 

gives one the total percentage and volume of spills, greater than one 

milliliter, that staff observed during the survey. This combination is 

referred to as quantifiable spills. Table 4, as follows, presents the 

number, percent, and average volume of quantifiable spills observed during 

the four fueling intervals of the survey. 

Table 4. Number, Percent, and Average Volume of Quantifiable 

Spills Observed During the Survey. 

Number & Percent 

Fueling Intervals 

with Quantifiable 

Spills 

338 (22.3*) 

454 (30.335) 

Type of 

Fueling 

Vapor Recovery 

Conventional 

Total Amount of 

Quantified Spin 

3585 ml 

5965 ml 

Average Volume 

per Spill 

10.6 ml 

13.1 ml 

As can be seen in Table 4, conventional nozzles produce a greater 

number of quantifiable spills and a greater average volume per spill than do 

vapor-recovery equipped nozzles. However, if the extraordinary event 

spillage for a conventional nozzle noted in the discussion under Table 2 

above is subtracted from the total quantified spill volume of Table 4 (5965 

ml - 1043 ml = 4922 ml), the average volume per quantifiable spill for 

conventional nozzles would drop to 10.8 ml, which is very close to the 

average volume per quantifiable spill with a vapor recovery nozzle. 

Drops of Fuel 

One of the observations made by the staff during the survey was to 

document the number of drops of gasoline that splattered on the concrete 

surface of the service station during the survey. The majority of these 

drops were the size of a dime to a quarter but some were larger. All were 

judged to have a surface area equivalent, usually, to much less than one 

milliliter, which was the spill size counted by the staff. However, drops 

were very numerous, as is depicted in Table 5 that follows. 

•10-
P.32 . 

Table 5. 

Type of 

Fueling 

Vapor Recovery 

Conventional 

Instances and Number of Drops of Gasoline Observed 

During the Survey. 

Number of 

Fuelings 

1515 

1496 

Instances of Drops 

During the Four 

Fueling Intervals 

511 (34*)* 

688 (46*)* 

Total Number of Drops 

Occurring During the 

Four Fueling Intervals 

2497 (43*)** 

3352 (57*)** 

* Calculated as a percentage of total fuelings 

** Calculated as a percentage of total drops that occurred with both 

conventional and vapor recovery nozzles 

As Table 5 indicates, the instances of drops occurring during the four 

fueling intervals and the total number of drops that occurred during these 

intervals happened more often with conventional nozzles than with the vapor 

recovery nozzles. 

Number and Volume of Spills, and Number 

of Props During Fueling Intervals 

As noted earlier in 

the four different fueling 

fuel. At each 

one milliliter or 

following table, 

drops occurred in 

milliliter) are 

Table 7 presents 

interval 

greater 

Table 6 

each fue 

used for 

similar i 

total number of drops that 

the methodology section, staff observed spills at 

intervals: pre-fuel, fueling, shutoff, and post-

, staff documented whether a "V" spill occurred, a 

spill occurred, and whether drops occurred. The 

, presents the number of instances that spills and 

ling interval. The notations "V" and "m" (for 

spills, and "D" is used for drops. Subsequently, 

nformation for the total volume of spills and the 

occurred at each of the fueling intervals. 

Table 6. Number of Instances of Spills and Drops in Each Fueling Interval 

Type of 

Fueling 

Vapor Recovery 

Conventional 

Number of Instances of Spills or Drops 

Pre-fuel Fueling Shutoff Post-fuel 

V M D VM D VMDVM D 

6 

6 

35 30 

11 47 

19 35 

19 38 

2 

4 

21 25 5 

105 138 23 

60 

75 

137 474 

62 614 

Table 7. Total Spill Volume and Number of Drops in Each Fueling Interval 

Type of 

Fueling 

Total Spill Volume (in ml) and Total Number of Drops 

Pre-fuel Fueling Shutoff Post-fuel 

V M D VM D VMDVM D 

Vapor Recovery 12 432 124 38 1121 3 42 839 14 120 981 2356 

Conventional 12 65 173 38 1662 35 210 3500 92 150 328 3052 

As revealed by Tables 6 and 7, conventional nozzles in California are 

most likely, first , to produce measurable spills and "V" spills during the 

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shutoff interval, and, second, during the post-fuel interval. Vapor 

recovery nozzles are most likely, first, to produce measurable spills and 

"V" spills during the post-fuel interval, and, second, to produce measurable 

spills during the fueling interval and "V" spills during the shutoff 

interval. We believe the higher percentage of spills produced by 

conventional nozzles in the shutoff interval may be due (1) to a higher 

gasoline dispensing rate observed v/ith these nozzles during the survey than 

observed with vapor recovery nozzles (8.3 gal/min vs 6.9 gal/min), and (2) 

to the fact that CARB certified vapor-recovery nozzles are required to meet 

more stringent shutoff criteria than conventional nozzles are. 

These tables also indicate that a significantly large number of drops 

produced by both vapor recovery and conventional nozzles occur during the 

post-fuel interval of fueling. 

Soi11 Frequency .and Average Volume Whan All Measurable 

and "V" Soilis (One or Several) Occurring During 

the Fueling Process Are Defined as One Spill Only 

For the spill survey discussed in this paper, the method chosen and 

used for counting the number of spills was to count each measurable or "V" 

spill observed at one of the four fueling intervals as a separate spill. 

After conducting the survey, we discovered that the American Petroleum 

Institute (API) had conducted a spill survey slightly earlier than ours and 

in the Washington D.C. and Baltimore, Maryland areas. However, API counted 

all kinds of spills on the concrete surface—from a single small-drop splash 

to a spill of many milliliters to a combination of spills at various fueling 

intervals—as one spill only per fueling. API did not count "V" spills on 

the side of a vehicle as being spills, however. 

We were curious how using such a methodology would affect the frequency 

and average volume of spills we found with the two types of nozzle systems 

studied (vapor recovery and conventional). So we reviewed our survey data 

and recounted all measurable (M) and "V" spills that occurred during the 

fueling process as one spill only per fueling (i.e., a "V" spill and a one 

milliliter spill at each of the four fueling intervals would equal only one 

spill during the fueling process). As we did with our original counting 

procedure, we added up all volumes associated with individual "M" and "V" 

spills during the fueling process. Our results using the new definition for 

a spill are presented in Table 8 as follows. Because API did a statistical 

analysis of the spill data it developed, we also did a standard statistical 

analysis of the two spill frequency percentages (16.6* vs 20.7*) that we 

found using the API definition of a spill. 

Table 8. Number, Percent, and Average Volume of Spill Using 

Concept of One Spill Only per Fueling 

Fueling 

Type 

Vapor Recovery 

Conventional 

Number 

of 

Fue1ingi 

1515 

1496 

and * 

of Fuelings Total 

with One Spill Spill 

Only per Fueling Volume 

251 (16.6*) 

310 (20.7*) 

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3585 ml 

5965 ml 

Average 

Vo1ume 

per 

Spill 

14.3 ml 

19.2 ml 

, .. ft b.l.lhaJ..-
As shown in Table 8, our using the concept of one spill only per 

fueling produces data that indicates that conventional nozzles engender a 

greater percentage of spills and a greater average volume per spill than do 

the same conclusion reached with our 

a spill. The difference in the percentage 

and vapor recovery nozzles is also 

the extraordinary event spillage for a 

discussion under Tables 2 and 4 is 

vapor recovery nozzles. This is 

survey's original definition of 

of spills between conventional 

statistically significant. If 

conventional nozzle noted in the 

subtracted from the total spill volume for conventional nozzles of Table 8, 

the average volume per quantifiable spill for conventional nozzles would 

drop to 15.9 ml, which is fairly close to the average volume per spill with 

a vapor recovery nozzle (14.3 ml) . This is approximately the same 

conclusion reached with our survey's original definition of a spill. 

SPILLAGE LOSS PER 1000 GALLONS OF THROUGHPUT 

AP-42, the Environmental Protection Agency document containing air 

pollutant emission factors (Supplement C, September 1990), lists spillage of 

gasoline from gasoline service stations as 0.7 lb per 1000 gallons of 

throughput (Table 4.4-7). This spillage loss does not differentiate between 

losses from vapor-recovery nozzle stations and conventional nozzle stations. 

Based on the spillage amounts documented by our survey, we calculated 

the spillage losses per 1000 gallons of throughput for both vapor-recovery 

and conventional nozzle stations. Our calculations are as follows: 

Vapor Recovery Nozzle Stations 

Given: 

3585 ml gasoline spilled per 13,977.7 gal gasoline dispensed 

during survey observations 

1 gal of gasoline = 3785.30 ml of gasoline 

1 gal of gasoline weighs 6.20 lb 

Thus: 

3585 JL 6.20 0.00042 lb spillage/gal disp. 

G i ven: 

13,977.7 * 3785.30

 A 1 

0.00042 x 1000 gal = 0.42 lb spillage/1000 gal throughput 

Conventional Nozzle Stations 

5965 ml gasoline spilled per 15,891.2 gal dispensed during 

survey observations 

1 gal of gasoline = 3785.30 ml of gasoline 

1 gal of gasoline weighs 6.20 lb 

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P.35 

/ -

Thus: 

15 891.2

 x 3785.30 x 1^ = °- 0006 2 lb spillage/gal disp. 

0.00062 x 1000 gal = 0.62 lb spillage/1000 gal throughput 

CONCLUSIONS 

Based on California survey data, conventional nozzles in California 

produce a greater number of quantifiable spills (>. 1 ml) and a greater 

average volume per spill than do vapor-recovery equipped nozzles. However, 

if an extraordinary spillage event for a conventional nozzle noted during 

the survey (producing approximately 19 percent of measurable spillage with 

conventional nozzles) is subtracted from the total quantified spill volume, 

the average yolume per quantifiable spill for a conventional nozzle would 

drop to 10.8 mi, which is very close to the 10.6 ml average volume per 

quantifiable spill with a vapor recovery nozzle. In addition, conventional 

nozzles in California produce about 14 percent more drop (< 1 ml) spillage 

than do vapor recovery nozzles. Drop spillage has not been quantified as to 

the volume of gasoline it represents. 

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