# Guidance on Removing Stage II Gasoline Vapor Control Programs f

rom Sta t e Implementation Plans and Assessing Comparable MeasuresEPA

- 457/B

- 12

- 001 August 7

, 2012

Guidance on Removing Stage II Gasoline Vapor Control Programs f rom Sta t e Implementation Plans and Assessing Comparable Measures

Prepared By:

H. Lynn Dail, Environmental Scientist State and Local Programs Group Air Quality Policy Division

Glenn W. Passavant, Senior Mechanical Environmental Engineer

Assessment and S tandards Division Office of Transportation and Air Quality

U. S. Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park, NC 27711ii



### List of Selected Acronyms and Abbreviations

A/L a ir to liquid ratio

ARB Air Resources Board (California)

CAA Clean Air Act

CAPCOA California Air Pollution Control Officers Association

CF Compatibility Factor

EE Excess Vent Emissions

EPA Environmental Protection Agency

EVR California enhanced vapor recovery program
FR F ederal Register

GDF gasoline d is pensing f acility

GPM gallons per month

GVWR gross vehicle weight rating

IUVP Input Use V e rification Program

MOVES Motor Vehicle Emissions Simulator NAAQS National Ambient Air Quality Standards

NESHAP National Emission s Standards for Hazardous Air Pollutants

NO X 

### nitrogen o xide s OBD o nboard d iagnostics

ORVR o nboard r efueling v apor r ecovery OTR Ozone Transport Region

RFP r easonable f urther p rogress RFG r eformulated g asoline

R V P Reid v apor p ressure SIP s tate i mplem entation p lan

VOC v olatile o rganic c ompound

UST u nderground s torage t ank

VMT v ehicl e m iles t raveled

VRS v apor r ecovery s ystemsiii

Preface

On May 9, 2012, the EPA Administrator sign ed a notice of final rulemaking determining that onboard refueling vapor recovery (ORVR) systems are in widespread use throughout the motor

vehicle fleet which was published in the Federal Register on May 16, 2012 (77 FR 28772) . In that notice the Administrator also exercised her authority to waive the statutory requirement th at
S erious , Severe, and Extreme ozone nonattainment areas adopt and implement EPA programs requiring Stage II gasoline vapor recovery systems (VRS) at certain gasoline dispensing facilities (GDFs). Many states and local areas have previously adopted Stage II programs into their state implementation plans (SIPs). This guidance document provides both technical and policy

recommendations to states and local areas on how to develop and submit an approvable SIP

revision seeking to remove or phase

- out an existi ng Stage II program. This guidance introduces methods and equations that could be used to calculate the emissions consequences of discontinuing Stage II control programs for purposes of demonstrating compliance with specific

CAA provisions in sections 110 (l) and 193 governing EPA approval of SIP revisions . This

document also includes new technical and policy guidance , updating that previously issued by EPA in 1995, for areas of the Ozone Transport Region (OTR) on implement ing measures capable of achieving emissions reductions comparable to those achievable by ongoing implementation of Stage II controls.



### Table of Contents

1. Introduction

................................ ................................ ................................ ................................ .............. 1

2 . When can a state or a GDF stop implementing existing Stage II programs?

. ................................ ... 3

2.1 What are the CAA requirements that govern EPA approval of a Stage II removal SIP revision?

.... 3

2.2 Complying with the “noninterference” clause (CAA section 110(l))

................................ ................ 3

2.3 Complying with the OTR “comparable measures” requirement (CAA section 184 (b)(2))

............... 5

2.4 Complying with the “general savings clause” for pre

- 1990 Stage II control programs (CAA section 193)

................................ ................................ ................................ ................................ ........................... 7

3. Assessing Ar ea

- Wide Impacts on Vehicle Refueling Emissions

................................ ............................. 7

3.1 Discussion of Terms

................................ ................................ ................................ .......................... 8

3.2 Parameters and Variables Related to Implementing Stag e II VRS and ORVR

............................... 10

3.2.1 Terms for Estimating Area

- Wide Stage II VRS Control Efficiency

................................ ......... 10

3.2.2 Terms for Estimating Area

- Wide OR VR Control Efficiency

................................ ................... 13

3.3 Calculating Impacts on the Refueling Emission Inventory

................................ .............................. 13

3.3.1 Key Equation for Assessing and Demonst rating Compliance with the Noninterference Provisions of CAA Section 110(l) and the Comparable Measures Requirement of CAA Section 184(b)(2)

................................ ................................ ................................ ................................ ............. 13

3.3.2 Key Equation for Assessing and Demonstrating Compliance with CAA Section 193

............. 14

3.3.3 Developing Area

- Specific Values for the Terms Used in Equations 1 and 2

........................... 14

3.4 Example Cal culations for Equations 1 and 2

................................ ................................ ................... 16

3.4.1 Example Scenario #1

................................ ................................ ................................ ................ 16iv

3.4.2 Example Scenario #2

................................ ................................ ................................ ................ 17

3.4.3 Example Scenario #3

................................ ................................ ................................ ................ 17

3.5 Calculating the Impact on the Area

- Wide VOC Inventory

................................ .............................. 19

3.5.1 Terms for Cal culating Tons VOC

................................ ................................ ............................. 19

3.6 States/Areas with Stage II but not Affected by 182(b)(3) or 184(b)(2)

................................ ............ 21

4. Strategies and Considerations f or Phasing Out Stage II Controls

................................ ......................... 22

4.2 Cost Considerations

................................ ................................ ................................ ......................... 22

4.3 Decommissioning issues

................................ ................................ ................................ .................. 23

4.4 Potential Emission Reduction Programs for GDFs

................................ ................................ .......... 23

5. Submission, Review and Approval of SIP Revisions

................................ ................................ ............ 24

5 .1 Elements of SIP Revision Package

................................ ................................ ................................ .. 24

5.2 EPA SIP Review Process

................................ ................................ ................................ ................. 24

Table A

- 1

- Projected Penetration of ORVR in the National Gasoline Fueled Vehicle Fleet by Ye ar

...... 25

Table A

- 2

- Monthly Average Dispensed Liquid Temperature

................................ ................................ .. 26

Table A

- 3

- Seasonal Variation In Temperature Difference Between Veh icle Fuel Tank and Dispensed

Fuel

................................ ................................ ................................ ................................ ........................... 27

Table A

- 4

- Percent of 50 State Gasoline Consumption for Areas Covered by CAA Sections 182(b)(3) or 184(b)(2)

................................ ................................ ................................ ................................ ..................... 28

Table A

- 5

- Applicability of Clean Air Act Requirements to Areas Implementing Stage II Gasoline Vapor Recovery Programs for the Ozone NAAQS

................................ ................................ ............................... 30

Table A

- 6

- Percent of State/Area GDF Dispensers Using Vacuum Assist Stage II Technology (June 2012)

................................ ................................ ................................ ................................ ........................... 32

Table A

- 7

- Five

– Month (May

- September) Uncontrolled Displacement (non

- ORVR) Refueling Emission Factors (g/gal)

................................ ................................ ................................ ................................ ............. 33

Table A

- 8

- Input Data for States/Areas with Stage II but not Affected by 182(b)(3) or 184(b)(2) (July 2012)

................................ ................................ ................................ ................................ ........................... 34

Table A

- 9

– MOVES 2012 Vehicle C lass Age Distribution

................................ ................................ ...... 35

### 1. Introduction

Stage II VRS were adopted by some states beginning in the 1980s to meet the ozone

N ational A mbient A ir Q uality S tandards (NAAQS)

. Stage II and ORVR are two types of

emission control systems that capture fuel vapors from vehicle gas tanks during refueling. Stage

II and vehicle ORVR we re initially both required by the 1990 Amendments to the CAA u nder sections 182(b)(3) and 202(a)(6), respectively. In some areas Stage II VRS ha s been in place for over 25 years, but was not widely implemented by the states until the early to mid

- 1990s as a

result of the CAA requirements for Moderate, Serious, Severe, and Extreme ozone

nonattainment areas and for states in the Northeast Ozone Tran sport Region ( OTR ) under CAA section 184(b)(2)

. CAA section 202(a)(6) require d EPA to promulgate regulations for ORVR for light

- duty vehicles (passenger cars)

. The EPA adopted these requirements in 1994; at which point Moderate ozone nonattainment areas were no longer subject to the section 182(b)(3) Stage II requirement. However, some Moderate areas retained Stage II VRS requirements to provide a control method to comply with rate

- of

- progress emission reduction targets. 1 ORVR equipment has been phased in for new passenger vehicles beginning with model year 1998, and starting in

2001 for light

- duty trucks and most heavy

- duty gasoline

- powered vehicles

. ORVR equipment

has been install ed o n nearly all (~99%) new gasoline

- powered light

- duty vehicles , light

- duty trucks and heavy

- duty vehicles since 2006.

During the phase

- in of ORVR controls , which began in 1997 , Stage II vapor recovery has provided volatile organic compound ( VOC ) reductions in ozone nonattainment areas and certain

attainment areas of the OT R. Congress recognized that ORVR and Stage II would eventually become largely redundant technologies, and provided authority to the EPA to allow states to remove Stage II from their SIPs after EPA finds that ORVR is in widespread use. Effective May

16 , 2 012, the date the final rule was published in the Federal Register (77 FR 28772), the EPA

determined that ORVR is in w idespread nationwide use for control of gasoline emissions during refueling of vehicles at gasoline dispensing facilities (GDFs). Current ly, more than 75 percent of gasoline refueling nationwide occurs with ORVR

- equipped vehicles, so Stage II programs have become largely redundant control systems and Stage II VRS achieve an ever

- declining emissions

benefit as more ORVR

- equipped vehicles con tinue to enter the on

- road motor vehicle fleet

. In fact, in areas where certain types of vacuum

- assist Stage II control systems are used, the limited compatibility between ORVR and some configurations of this Stage II hardware may ultimately

result in an area

- wide emissions disbenefit. The refore, EPA also exercised its authority under

CAA s ection 202(a)(6) to waive certain federal statutory requirements for Stage II gasoline vapor recovery at GDFs. 2 This decision exempts all new ozone nonattainment areas classified Serious or above from the requirement to adopt Stage II control program s

. Similarly, any state currently implementing Stage II programs may decide to seek SIP revisions that, once approved by EPA, would allow them to phase out Stage II control systems

. Appendix Table A

- 5 provides

a list of s tates currently implementing Stage II programs under sections 182(b)(3) and 184(b)(2)

.

1 Kentu cky, Tennessee, Michigan, Ohio, Virginia, West Virginia, Nevada, California, Oregon and Washington have implemented Stage II for some areas

. If these states/areas included Stage II vapor control programs in their SIPs, they will have to amend their SIPs i f Stage II is no longer required, and will have to address the provisions of CAA section 110(l).

2 77 FR 28772, May 16, 2012. Widespread Use for Onboard Refueling Vapor Recovery and Stage II Waiver.2

O zone nonattainment areas previously required under the CAA to have Stage II gasoline

VRS on GDFs may choose to remov e the requirement from their SIPs , but states may also retain their Stage II requirements if they wish. A small fraction of the on

- road vehicle fleet is not covered by EPA’s ORVR regulations, so Stage II controls would not be redundant for such

vehicles r efueling in areas subject to existing Stage II programs. Even though Stage II controls are capable of achieving some small level of area

- wide benefit for non

- ORVR refueling events, they may become a less cost

- effective method than other alternatives for a ddressing area

- wide

VOC emissions and, as noted above, may ultimately result in a disbenefit to air quality in the

areas

.

In order to phase out existing Stage II programs in SIPs, s tates would need to submit SIP

revision s to EPA meeting applicable CAA req uirements and receive approval from the EPA. States in the OTR remain obligated under CAA section 184(b)(2) to implement either a Stage II program or other measures capable of achieving emissions reductions comparable to those achievable by Stage II. The EPA issued guidance on this latter requirement in 1995, and is now updating that guidance to account for ORVR’s widespread use in the motor vehicle fleet and its
increasing displacement of Stage II as the primary means of controlling refueling emissions

This guidance document contains the information needed for a state to conduct an
emissions inventory analysis related to phasing out an existing Stage II program and is designed

to facilitate this assessment. The ORVR phas e

- in and fuel consumption data pr esented here are derived from the same core approach as used in EPA’s MOVES model and incorporates all major elements of that work. Furthermore, i t relies on the latest technical information and data

available to EPA o n both ORVR and Stage II

, and in some cases incorporates information not yet in MOVES models. Given these differences, even though the ORVR phase

- in and fuel consumption data presented here are derived from the same core approach as used in MOVES, it is expected that the results from using M OVES to assess the inventory impact would be different than the approach suggested below. This is further discussed in Section 3.

How is this guidance document organized? Section 2 discusses the statutory and regulatory framework governing removal of St age II control programs from SIPs . S ection 3 provides technical information that s tates may consider us ing to calculate the impact of phasing out Stage II control programs. Section 4 discusses general strategies and considerations for phasing out Stage I I control programs

. Section 5 presents information on developing SIP

revisions for submission to EPA for r eview and approval. The appendix contains look up tables

associated with the equations presented in this guidance and a chart indicating the specifi c CAA requirement applicable to each state.3



### 2. When can a state or a GDF stop implementing existing Stage II programs?

The CAA section 182(b)(3) requirement s for Stage II have been waived as a result of EPA’s exercise of waiver authority under CAA sect ion 202(a)(6). This waiver extends to areas

classified as Serious or above for the 1997 or 2008 8

- hour ozone NAAQS, and to those that were

classified Serious or above for the 1

- hour ozone NAAQS at the time that the 1

- hour NAAQS was

revoked. 3 However, are a s where a Stage II program i s part of an EPA

- approved SIP need to continue implementing Stage II until EPA approves a SIP revision that remove s the requirement

from the SIP

.

The EPA is aware that new GDF construction undertaken prior to the a pproved phas e

- out date may incur capital costs for installing Stage II that may only be required for a short time. It is evident from the public comments on the EPA’s proposed waiver rule and other materials that states and members of the regulated industry are seeki ng to curtail Stage II installations at newly

constructed GDFs

. Changing Stage II applicability requirements contained in state rules that have been approved into SIPs is ultimately an issue that each state would need to address

. The

EPA cannot unilatera lly change existing state regulations or lawfully

- adopted SIPs containing Stage II requirements , and the May 16 , 2012, waiver does not directly a lt e r those state regulations or revise SIPs

.

2. 1 What are the CAA requirements that govern EPA approval of a Stage II removal SIP

revision?

There are three main CAA provisions that affect EPA’s ability to propose approval of any SIP revision seeking to discontinue an existing SIP

- approved Stage II control program. Section 110(l) governs EPA approval of all SIP revisions, including SIP revisio ns involving phase out of Stage II controls. Section 193 applies to any current nonattainment area that adopted a Stage II control program into its SIP prior to November 15, 1990. Section 184(b)(2) applies to any area

of the northeast OTR

.
2.2 Complying with the “noninterference” clause (CAA section 110(l))

Under CAA section 110(l), the EPA cannot approve a SIP revision if it would interfer e with attainment of the NAAQS

, reasonable further progress toward attainment

, or any other applicable requirement o f the Clean Air Act

. Therefore, the EPA could propose to approve a SIP

revision that removes or modifi es Stage II gasoline refueling v apor control measure(s) in the SIP only if there is a basis in the state ’ s submittal for concluding that approval of the revision would

3 The EPA codified anti

- backsliding provisions governing the transition from the revoked 1

- hour ozone NAAQS to

the 1997 8

- hour ozone NAAQS in 40 CFR part 51.905 (a)

. These provisions indicate that some control measures may not be removed from a SIP even if their removal would not interfere with air quality goal s. These measures are listed as “applicable requirements” because the CAA requires that they be included in a SIP for an area based on the area’s designation status and classification. The authority in CAA section 202(a)(6) makes it possible for EPA to

w aive Stage II control programs such that they are no longer an “applicable requirement” or a required contingency

measure.4

not interfere with attainment of the NAAQS, reasonable further progress (RFP) or any other applicable requirement of the CAA.

Specifically, section 110(l) states:

Each revision to an implementation plan submitted by a State under this Act shall be adopted by such State after reasonable notice and public hearing. The Administrator shall not approve a revision of a plan if the rev ision would interfere with any applicable requirement concerning attainment and reasonable further progress (as defined in section 171), or any other applicable requirement of this Act.

A Federally approved SIP is viewed as the s tate’s blueprint for maint aining clean air, and

f rom time to time a state may choose to revise its SIP and demonstrate that the revision would

not interfere with air quality goals

. Accordingly, s tates should explain how the SIP revision that modifies an existing SIP

- approved Stage II control program does not interfere with attainment of all applicable ozone NAAQS, including the 2008 NAAQS, and any applicable reasonable further progress requirements. In evaluating whether a given SIP revision would interfere with

attainment or main tenance, as required by section 110( l ), the EPA generally considers whether

the SIP revision will allow for an increase in actual emissions into the air over what is allowed

under the existing EPA

- approved SIP

. The EPA has not required that a state produce a new complete attainment demonstr ation for every SIP revision

, provided that the status quo air quality is preserved. See, e.g., K entucky Resources Council, Inc., v. EPA, 467 F.3d 986 (6th Cir. 2006); see also, 61 FR 16,050, 16,051 (April 11, 1996) (actions on which the Kentucky

Resource s Council case were based). Section 3 of this guidance document provides information

that s tates may consider using to develop noninterference demonstrations, including methods to assess the VOC emissions impact in the affected area during the Stage II ph ase

- out period.

As one considers this non

- interference assessment, i t should be noted that the potential emission control losses from removing Stage II VRS are transitional and relatively small.

ORVR

- equipped vehicles will continue to phase in to the fle et over the coming years and will exceed 80 percent of all highway gasoline vehicles and 85 percent of all gasoline dispensed during 2015. As the number of these ORVR

- equipped vehicles increase

, the control attributed to Stage II VRS will decrease even fu rther , and t he potential foregone Stage II VOC emission reductions are generally expected to be no more than one percent of the VOC inventory in the

area

.

Substituting new control measures

. The EPA believes that a planned Stage II phase

- out
that is shown not to result in an increase in area

- wide VOC emissions would be consistent with the conditions of CAA section 110(l). A planned Stage II phase

- out that would otherwise result

in an area

- wide VOC emissions increase could also be consistent with the condi tions of CAA section 110(l) if the state offsets the increase in emissions by adopting and implementing

additional emissions controls into the SIP. One example of substitution is where a state or area may substitute refueling emissions at GDFs with statio nary source controls or area source

controls , including additional controls on other gasoline vapor emissions points at GDFs (See

section 4.4 )

. States have wide latitude to select additional emissions controls to make up for the absence of Stage II VRS , i ncluding substituting NO

x controls

. T he offsetting emissions controls

should be generally contemporaneous with the Stage II VRS phase

- out period.5

Offset of emissions due to excess emission reductions not accounted for in the current

SIP . An additi onal factor that may be relevant in evaluating whether a SIP revision removing Stage II vapor recovery program s is consistent with the provisions of section 110( l ) is the consideration of emission reductions not otherwise included in the current SIP. Changes i n an

area ’ s stationary or area source inventories resulting from changes in industrial population or activity in that area could result in a decrease in VOC emissions compared to that the emissions

considered in the SIP. There are too many potential examp les to list, but this could include a plant closure or the continued decline in GDF population. Also, there may be changes in the

motor vehicle fleet VMT or fleet population s that provide VOC and NO

x emission reductions not

accounted for in the SIP. With an increased penetration of newer model year ORVR

- equipped vehicles, the amount of additional emission reduction achieved by S tage II over time is small er in comparison to areas with lower percentages of ORVR penetration into the fleet. In these

circumst ances it may also be true that the lower exhaust and evaporative emission rates from these newer vehicles in the fleet relative to those being scrapped will offset any transitional VOC

emission increases from phasing out Stage II VRS . Furthermore, there m ay be additional VOC

and NO

x emission reductions from non

- road sources that could be considered if states have not already sought SIP credit for them

.

Emissions increases that do not interfere with attainment

. Under the circumstances created by the CAA' s widespread use waiver, a planned Stage II phase

- out that is shown to result

in an area

- wide VOC emissions increase may al so be consistent with the conditions of CAA section 110(l). A phase

- out plan that would result in very small foregone emissions reductions in the near term that continue to diminish rapidly over time as ORVR phase

- in continues, may result in temporary inc reases that are too small to interfere with attainment or progress toward

attainment. This may be particularly evident in areas that are already attaining the ozone NAAQS or where emissions and/or air quality projections already demonstrate that an area i s likely to maintain the NAAQS into the future. Similarly, in areas where ozone formation is limited by the availability of NO

x emissions, a small (and ever

- declining) increase in VOC emissions may have little or no effect on future ozone levels. The EPA would consider any air quality analyses and supporting information provided by a state to show that a proposed SIP revision would not interfere with attainment and maintenance of the NAAQS.

2. 3 Complying with the OTR “comparable measures” requirement ( CA A section 184(b)(2) )

All areas of the Northeast OTR, both attainment and nonattainment, are subject to the requirements of CAA section 184(b)(2) , commonly referred to as the “comparable measures requirement.” 4 Section 184(b)(2) directs t hese areas to ado pt and implement either Stage II

controls meeting the general requirements for Stage II gasoline vapor recovery programs under

CAA section 182(b)( 3 )

, or “control measures capable of achieving emissions reductions comparable to those achievable” by Stage II

. Section 3 of this guidance document provides

information that s tates may consider in develop ing a comparability analysi s that includes an estimat e of lost Stage II reductions incremental to ORVR during the Stage II phase out period.

4 The States of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Isla nd, Vermont, Virginia and the District of Columbia are in the OTR and are subject to these provisions.6

States in the OTR c an conduct comparability analyses on a s tate

- wide basis

, or separately for

nonattainment and attainment area s within the s tate

.
Demonstrating Comparability

. The CAA does not require OTR s tates to implement measures that would achieve reductions “equival ent” to a Stage II control program; the CAA requires that the reductions be “comparable.” Now that O RVR is in widespread use in the motor vehicle fleet, the EPA believes it may be appropriate for s tates to demonstrate that the comparable measures requirem ent is satisfied if phasing out a Stage II control program in a particular area is estimated to have no, or a de minimis , incremental loss of area

- wide emissions

control

– i.e., when no alternative reductions are needed to achieve reductions comparable to

t hose achievable in the area by the Stage II control program stipulated in CAA section 182(b)( 3 )

.
As the fraction of total gasoline dispensed into ORVR

- equipped vehicles continues each year to increase in relation to the fraction of total gasoline dispens ed into non

- ORVR vehicles,

the incremental emission reduction benefit achieved by Stage II controls over ORVR controls declines. Accordingly, i n the specific context of the comparable measures requirement, EPA

believes it is reasonable to conclude that th e incremental emissions control that Stage II achieve s beyond ORVR is de minimis if it is less than 10 percent of the area

- wide emissions inventory associated with refueling highway motor vehicles

. Th is is because the Stage II control program stipulated b y Congress in CAA section 182(b)( 3 ) exempts some GDFs from Stage II controls

, such that even where Stage II was required approximately 10 percent of the gasoline throughput was not subject to the statutory requirement . Specifically, GDFs that sell 10,000 gallons or less per month, and GDFs identified as independent small business marketers that sell 50,000 gallons or less per month, a re exempt from the statutory Stage II control requirements. For a typical area implementing the CAA

- based exemption program EPA estimates that about 10 percent of highway motor vehicle fleet gasoline consumption wa s therefore exempted from the statutory requirement for Stage II controls

. 5 In light of the Congressional judgement that Stage II controls need only apply to 90 per cent of gasoline sales, no new control measure m ay be necessary to demonstrate comparability to Stage II when the difference between retaining Stage II and removing Stage II affects less than 10 percent of the refueling emissions from area

- wide gasoline

co nsumption.

Agencies can consider us ing the calculations explained in this guidance document to determine the point in time at which de minimis incremental benefits are reached in a specific area, based on the area’s fleet profile and Stage II control progr am parameters. T he EPA is

aware that some s tates are implementing Stage II control programs that are nominally more stringent than the minimum program requirements in CAA section 182(b)(3). For example, in

some s tates exemptions are provided only for GDF s dispensing 10,000 gallons or less per month. For the purposes of addressing comparability under CAA section 184(b)(2)

, s tates only need to consider the reductions achievable by the minimum program required by CAA section 182(b)(3)

, as section 182(b)(3) defined the scope of applicability of Stage II within the GDF source
category

– and therefore the scope of expected emissions reductions from Stage II

– against which alternative control measures were to be compared under section 184(b)(2)

.

5 See “Technical Guidance

– Stage II Vapor Recovery Systems for Control of Gasoline Refueling Emissions at Gasoline Dispensing Facilities Vol. 1,” EPA

- 45 0/3

- 91

- 022a, November 1991.7

2. 4 Complying with the “g eneral s avings c lause ” for pre

- 1990 Stage II control program s ( CAA section 193 )

Section 193 prohibits modification of any control requirement in effect before November 15, 1990 in a current nonattainment area, unless modification “ i nsures equi valent or greater

emissions reductions. ” Th is means that

, in areas currently designated nonattainment for ozone,

any Stage II control program implemented under a SIP prior to November 15, 1990 could not be

removed from the SIP until the ORVR control requir ement (or some other requirement or set of requirements ) is shown to achieve equal or greater emissions reductions compared to the

emissions reductions attributable to Stage II vapor recovery. Alternatively, States can show that removing the area’s pre

- 19 90 Stage II control program w ould have no impact on area

- wide

emissions reductions. The EPA anticipates that the later showing is inherently more

conservative than the former.

Agencies can consider us ing the assessment method described in Section 3 to de termine the point in time the ORVR control requirement achieves equivalent emissions reductions to the reductions credited to the pre

- 1990 Stage II vapor recovery program. The assessment method is

similar to the method the E PA used for establishing the na tional ORVR widespread use finding

and waiver of the section 182(b)(3) requirement , except that here it would be applied on a state

or local area level rather than a national level.



### 3

. Assessing Area

- Wide Impacts on Vehicle Refueling Emissions

This secti on cover s many of the technical issues states may need to address in developing SIP revisions to phase out existing Stage II programs

. Note that the analyses for purposes of section 110( l ) and section 193 may not be identical

. However, i n some cases
, an area may be able to show that, due to disbenefits from simultaneous implemen ta tion of Stage II and ORVR, phasing out Stage II will result in a net improvement in emissions reductions , satisfying the provisions of both section 110( l ) and section 193.

Sect ion 3 .1 describes some key terms. S ection 3 .2 identif ies and describe s a series of parameters and variables related to the implementation of Stage II and ORVR. S ection 3.3 combines these parameters and variables into two equations that states can conside r us ing to evaluate and compare the emission reduction impacts of various combinations of Stage II and ORVR control technologies in the context of the provisions of CAA section s 110(l) , 184(b)(2),

and 193. Sec tion 3.4 provides guidance on selecting parameter values and ways to determine the variables in the equation s

. Section 3.5 presents a series of examples of how this information can

be used to conduct SIP

- related analyses.

States may be accustomed to running the MOVES model in support of SIP revisions. And, while the use of the MOVES model is certainly allowed, without additional analyses and inputs from outside the model, it may not yield outcomes similar to those obtaine d using Equations 1, 2 and 3 that are presented in this section . For these reasons, and the fact that all previous EPA ORVR/Stage II inventory comparison analyses have been conducted in a similar8

manner, EPA believes the approach discussed in this documen t would be preferable for these

assessments. 6

3

. 1 Discussion of Terms

The EPA’s emission factors document divides vehicle refueling emissions into three broad categories. 7 These include vehicle fuel tank displacement emissions, gasoline spillage,

and un derground storage tank (UST) breathing and empting losses. 8 In a previous analysis EPA concluded that removing Stage II vapor recovery would potentially impact overall vehicle fuel tank displacement emissions and breathing/emptying losses from UST vent pi pes where Stage II vacuum assist technology is used. The analysis further concluded that removing Stage II would

neither increase n or decrease gasoline spillage during refueling and that with appropriate measures such as the pressure/vacuum valves now wid ely employed on UST vent pipes, breathing/emptying losses from non

- Stage II nozzles and balance type Stage II nozzles would be

similar. 9

, 10 Thus, this guidance need only address impacts on vehicle fuel tank displacement emissions and impacts on UST vent pi pe emission rates from non

- ORVR compatible Stage II

nozzles. 11

Described below are key terms used in the calculations and discussions which follow.

Gasoline dispensing facility (GDF) : A location which dispenses gasoline to highway

motor vehicles and ser ves as a fueling point for nonroad engines and equipment . It includes all

retail outlets such as traditional service stations

, convenience stores , truck stops, and hypermarkets (e.g., warehouse clubs and big box stores) as well as private and commercial

o utlets such as those for centrally

- fueled fleets, government operations, and private businesses as well as private outlets such as centrally

- fueled fleet and government operations. For these purposes, it generally does not include marinas and general avia tion airports dispensing aviation gasoline

. Note that some lower throughput GDFs are exempt from Stage II vapor recovery by state regulations.

6 In previous publications, ( footnote 9 below) EPA concluded that for these purposes factors such as spillage emission rates and traditional breathing/emptying loss emision rates would not be affected by removing Stage II

vapor recovery. MOVES runs should not include spillage. Also, it is important to note that the gasoline consumption data in Appendix Table A

- 1 includes ORVR for Class III HDGVs beginning in 2006. When the last version of the MOVES model was released, EPA was n ot aware that manufacturers had voluntarily incorporated

ORVR on these vehicle models. T his guidance document does not include every potential minor emission impact

that has been identified for either Stage II or ORVR. For example, vacuum assist Stage II may capture a fraction of the refueling emissions released from an ORVR vehicle fillpipe during a refueling event (~0.0 5g /gal) and through testing

, API has identified that emissions released from the fillpipe immediately after the fuel cap is removed are

lower for ORVR vehicles than non

- ORVR vehicles. The delta in emissions (about 0.1 0 g/gal ) depends on RVP and fuel tank temperature

. These offsetting minor differences are not included in the calculations in this guidance.

7 AP

- 42, Fifth Edition, “Compilat ion of Air Pollutant Emission Factors

– Volume 1, Stationary Point and Area Sources” January 1995. The EPA’s emission factors document, identifies three sources of refueling emissions: displacement, spillage, and breathing losses..

8 See Chapter 5 of AP

- 4 2, http://www.epa.gov/ttn/chief/ap42/ch05/final/c05s02.pdf

9 See EPA memorandum, “Onboard Refueling Vapor Recovery Widespread Use Assessment, ” June 9, 2011.

10 There would still be brea thing and emptying losses from some systems at various times. These could be addressed by one of the post

- processor technologies now being marketed for addition to the GDF UST vent pipes

11 Dispensers using traditional gasoline nozzles, balance

- type Stage I I nozzles, and specially certified ORVR compatible vacuum

- assist type nozzles would not be expected to increase UST vent emissions.9

Stage II Vapor Recovery System (VRS) : A system designed to capture displaced vapors that emerge from inside a v ehicle’s fuel tank, when gasoline is dispensed into the tank . There are two basic types of Stage II systems, th e balance type and the vacuum assist type.

Balance

- type Stage II system : The balance system transfers vapors from the vehicle tank to the GDF UST based on pressure differentia l. A key feature in the balance system is a hose nozzle that makes a tight connection with the fill pipe on the vehicle fuel tank. The nozzle spout

is fitted with an accordion

- like b ellows that presses snugly against the fill pipe lip. The vapors flow into the port, through the nozzle bellows, through a coaxial hose that connects the nozzle to the dispenser, an d finally on through a vapor

- return pipe back into the UST.

Vacuum assist

- type Stage II system : This system relies on a vacuum source to help move the vapors out of the vehicle tank and into the UST. Current designs do not rely on a tight

- fit t ing

seal at the nozzle

- fillpipe interface. T raditional vacuum systems are of two types: passive and

active . In a passive vacuum

- assist system, which is the dominant approach today, an electrically

driven vacuum pump, typically in the dispenser cabinet, provides th e vacuum power. A n active
system maintains a vacuum on the entire Stage II vapor recovery system through a central pump (jet pump) to recover vapors from the entire system to the tank

. A key feature of vacuum assist system design and operation is the des ign air/liquid (A/L) volume ratio which is a measure of the volume of air returned to the tank to the volume of liquid dispensed. (When refueling a non

ORVR vehicle this “air” also contains gasoline vapor.) The larger the design A/L ratio the greater the amount of fresh air returned to the UST. Some passive vacuum assist systems employ loose

- fitting mini

- bellows to help reduce the design A/L ratio. Sometimes these are called hybrid systems. Active vacuum assist systems often have A/L ratios somewhat gr eater than unity and employ a post

- processor to reduce excess vent pipe emissions created by the higher A/L ratio with these systems.

Vent pipe : A pipe from the UST to the atmosphere which allows the tank to “breathe ” during normal operation. This allows the tank to bring in fresh air to relieve negative pressure or release vapor to reduce positive pressure in the UST as needed. Vent pipes are generally 12 feet in height and two inches in diameter.

Pressure vacuum vent valve : A device, usually referred to as a "P/V vent valve," installed at the discharge end of a vent pipe connected to a gasoline storage tank, to regulate the pressure at which vapor is allowed to escape from the tank , and the vacuum at which outside air

is allowed to enter the tank. The inflow/outflow of air through the vent pipe is controlled at specified pressures. These vent valves generally inhibit vapor release and are used to ensure the proper operation of Stage II balance systems. These P/V vent valves are now widely required as

a result of EPA’s GDF “Stage I” NESHAP regulation (40 CFR 63 CCCCCC)

.
Onboard Refueling Vapor Recovery (ORVR) : A system employed on gasoline

- powered highway motor vehicles to capture gasoline vapors displaced from a vehicle fuel tank during refueling events. These systems a re required under section 202(a)(6) of the CAA and implementation of these requirements be gan in the 1998 model year. Currently they are now used on all gasoline

- powered passenger cars, light trucks, and complete heavy trucks of less than 14,000 lbs GVWR. ORVR systems typically employ a liquid fill neck seal to block vapor escape

to the atmos phere and otherwise share many components with the vehicle ’ s evaporative emission control system including the onboard diagnostic system (OBD) sensors.10

ORVR/Stage II Compatibility : Compatibility problems can result in an increase in

emissions from the UST vent pipe and other system fugitive emissions related to the refueling of ORVR vehicles with some types of vacuum assist

- type Stage II systems. This occurs during refueling an ORVR vehicle when the vacuum assist system draws fresh air into the UST rather

than a n air vapor mixture from the vehicle fuel tank. Vapor flow from the vehicle fuel tank is blocked by the liquid seal in the fill pipe which forms at a level deeper in the fill pipe than can be reached by the end of the nozzle spout. The fresh air d rawn into the UST enhances gasoline evaporation in the UST which increases pressure in the UST. Unless it is lost as a fugitive emission, any tank pressure in excess of the rating of the pressure/vacuum valve is vented to the atmosphere over the course of a day. The magnitude of these emissions at a specific GDF is primarily a function of the fraction of total gasoline throughput dispensed to the ORVR vehicles and the A/L ratio of the dispensers.

The compatibility factor is an especially important conside ration in calculating the emissions impacts of Stage II controls. Even if a state/local area wishes to keep Stage II controls

to address non

- ORVR equipped vehicles being refueled at Stage II GDFs, for non

- ORVR compatible Stage II vacuum assist systems the re will come a point where the emissions impact of the compatibility factor surpasses any gain from controlling non

- ORVR vehicles. After that point

, Stage II would lead to a net area

- wide loss in emissions control. The point in time w hen this occurs depe nds on the nature of the Stage II program and the rate of ORVR penetration into

the fleet.

ORVR

- compatible vacuum assist

- type Stage II system : A vacuum assist type Stage II
system that is designed to sense when an ORVR vehicle is being refueled and reduc es the A/L ratio to near zero to avoid compatibility emission effects. Current ORVR compatible nozzles are certified to meet ARB requirements for Stage II enhanced vapor recovery ( EVR ) efficiency with up to 80 percent ORVR vehicles in the fleet mix. Bala nce type nozzles are ORVR compatible as

well.

3.2 Parameters and Variables Related to Implementing Stage II VRS and ORVR

To conduct analyses of the impact of phasing out Stage II VRS, several key pieces of

information and data are needed for the equatio ns used in the assessments , which are presented

in section 3.3 . Each of these is described below, first for Stage II VRS, and then for ORVR.

3. 2.1 Terms for Estimating Area

- Wide Stage II VRS Control Efficiency

η iuSII - Stage II VRS in

- use control effici ency : This is the current best estimate of the average in

- use control efficiency for Stage II VRS in the state/area when applied to vehicles that

are no t equipped with ORVR

. It is expressed as a fraction of 1. This value considers not only
vapor capture at the vehicle fillpipe opening but also its transmittal to and storage in the UST. This value likely varies somewhat by state/area depending on how well GDF operators follow the inspection, testing, and maintenance activities specified in the state’s imp lementing regulations and the frequency of inspection and follow

- on enforcement actions by state/local authorities in implementing the regulations. This judgment should be informed by test data if

available either from within the state/area or from other sources if no local data is available.

P ublicly available data suggests typical current values are in the range of 60

- 75 percent (0.60

–11

0.75)

. 12

, 13

, 14

, 15 As a result, it may be appropriate to identify significantly lower Stage II in

- use control efficiencies than were identified in EPA’s 1991 technical guidance on Stage II systems (see footnote 5 )

.

Q SII - Fraction of highway gasoline throughput covered by Stage II VRS : The fraction of gasoline that is sold through dispensers equipped with Stage II VRS equipm ent expressed as a fraction of 1. This likely varies somewhat by state/area and can be derived from state data. Typical default values are 0.9 for states/areas that adopted the CAA allowed exemption value of 10,000 gallons per month ( gpm ) for private GDF s and 50,000 gpm for independent small

business marketers and 0.95

- 0.97 for states/areas that adopted 10,000 gpm exemption criteria for

all GDFs.

Q SIIva
– Fraction of highway gasoline t hroughput dispensed through vacuum

- assist type Stage II VRS : The fract ion of annual gasoline consumption in the state/area dispensed through vacuum assist type Stage II VRS expressed as a fraction of 1. This would not include gasoline dispensed through dispensers with traditional nozzles, balance

- type Stage II VRS nozzles, o r ORVR

- compatible Stage II nozzles. If the fraction dispensed through traditional vacuum assist VRS is not known, then the fraction of GDFs with traditional vacuum assist Stage II VRS may be substituted based on the assumption that throughput is evenly di stributed across the various

GDFs that are not exempt from Stage II requirements

.

VMT ORVR i - ORVR V ehicle M iles T raveled : The fraction of annual area

- wide VMT traveled by ORVR

- equipped vehicles. The subscript i denotes that this term varies by calendar

year.

CF i - Compatibility Factor : This is an increase in UST vent pipe emissions over the normal breathing/emptying loss emissions. As discussed above, this is a function of the fraction of gasoline dispensed to ORVR vehicles in any given year (using VMT of ORVR vehicles as a surrogate), the design features of the traditional vacuum assist Stage II nozzles, and the proportion of vacuum assist Stage II stations with various A/L ratios

. This term may be calculated as the product of VMT ORVR i and a constant term 0.07645

. It should be noted that for a

state / area with all balance systems or with a requirement for ORVR compatible nozzles , the CF term is zero because there is no compatibility problem by definition.

12 “Stage II Vapor Recovery Systems Issues Paper,” U.S. EPA, Office of Air Quality Planning and Standards, August, 2004.

13 “A nalysis of Future Option’s for Connecticut’s Gasoline Dispensing Facility Vapor Control Program,” Connecticut Department of Energy and Environmental Protection, December 2011.

14 “Draft Vapor Recovery Test Report,” CARB and CAPCOA, April, 1999. This data wa s used in CARB’s analyses of their Enhanced Vapor Recovery rules. See, “Enhanced Vapor Recovery Emissions Reduction Calculations” (available at http ://www.arb.ca.gov/regact/march2000e vr/march2000evr.ht m ) , Appendix D to “Enhanced Vapor Recovery: Initial Statement of Reasons for Proposed Amendments to the Vapor Recovery Certification and Test Procedures for Gasoline Loading and Motor Vehicle Gasoline Refueling at Service Stations,” Feb ruary 4, 2000; and CARB, “Updated ISD Emission Reductions” (available from http://www.arb.ca.gov/regact/evrtech/isor4d.pdf ), Appendix 3 to “Enhanced Vapor Recovery Technology Review”, Staff Rep ort, October 2002.

15 “Performance of Balance Vapor Recovery Systems at Gasoline Dispensing Facilities,” San Diego Air Pollution Control District, May 18, 2000.



### CF i 

### = (0.07645)(VMT ORVR i 

### )12

Th e constant term 0.07645 is an estimate o f the control efficiency loss with vacuum assist
systems derived by weighting two technologies tested in a California ARB study

. 16 This testing

was conducted with the P / V valve in place on the vent pipe and with frequent monitoring of the

A/L ratio to be c ertain that it stayed close to the design values. The technologies are weighted by about 65 percent for the higher A/L ratio dispenser and 35 percent for the lower A/L ratio dispenser. 17

, 18

, 19 The results in lbs/1000 gallons are divided by the uncontrolled emission factor

for the area where and when this testing occurred (7.6 lbs/1000 gal) . The equation yields a term expressed as a fraction of the displacement emission factor ( dimension less) thus allowing it to be

used in calculations with the other fractio ns above. 20 The subscript i denotes that this term varies by calendar year.

The compatibility factor can also be calculated as a function of annual gallons of highway motor gasoline dispensed to ORVR

- equipped vehicles

, where the constant term 0.0777 is der ived based on the national average gasoline throughput that corresponds to the ORVR VMT data.

For completeness sake, it should be noted that the excess vent emissions (EE) on a lb/1000 gal basis can be estimated using the equations:

16 EPA Memorandum “ Calculating Stage II Vacuum Assist Stage II VRS and ORVR Excess Emissions ,” Gl enn W. Passavant, May 2012.

17 California ARB, Preliminary Draft Test Report, Total Hydrocarbon Emissions from Two Phase II Vacuum Assist Vapor Recovery Systems During Baseline Operations and Simulated Refueling of Onboard Refueling Vapor Recovery (ORVR) E quipped Vehicles, Project Number ST

- 98

- XX, June 1999.

18 See Letter from William Loscutoff, Chief, Monitoring and Laboratory Division ARB to Prentiss Searles, Senior Marketing Issues Associate, American Petroleum Institute, “Comments on Enhanced Vapor Reco very (EVR) Technology Review.” August 5, 2002, p.6.

19 Keeping the in

- use A/L ratio close to the design value is very important. A significant variation upward in the A/L ratio would increase CF because more air would be ingested while a significant decre ase could decrease capture efficiency and send less vapor to the UST and thus perhaps also increase CF.

20 This approach gives a different value than that presented in a previous EPA report titled “Stage II Vapor Recovery Systems

- Option Paper,” February 2 006, because t his methodology allows for an estimation of the compatibility factor as a function of the fraction of gasoline dispensed to ORVR vehicles rather than at full fleet turnover, and because the results for the two technologies tested in Californ ia are weighted by an estimate of their relative fraction of use in the GDF population rather than using only the higher value . Finally, the result is divided by the displacement refueling emission factor in the area of California where and when this test ing was conducted to get a factor expressed in the same terms as control efficiency. (see California ARB, Uncontrolled Vapor Emission Factor at Gasoline Dispensing Facilities, January 5, 2000)

. 

### EE i 

### = 0.581(VMT ORVR i 

### ) or

EE i 

### = 0.591(Q ORVR i 

### ) CF i 

### = (0.0777 )( Q O RVR i 

### ) . . .defined below1 3

3.2 .2 Ter ms for Estimating Area

- Wide ORVR Control Efficiency

Q ORVR i - Fraction of annual gallons of highway motor gasoline dispensed to ORVR

equipped vehicles : This is likely to vary by state/area depending on the fleet turnover/scrappage rate, annual VMT, and fu el economy of the vehicles involved in the analysis. The subscript i denotes that this term varies by calendar year. Table A

- 1, column 4 in the Appendix shows national average values that a state could use or adapt by extrapolation or interpolation as

ap propriate. For example, if the fleet in the state was one year newer than the national average then the analysis would use the data for the next calendar year (e.g., 2014 for 2013). Conversely, for example, if the fleet in the state was on average six mo nths older than the national average then the analysis would interpolate between the current and past year (e.g.

, halfway between 2012 and 2013). Data on the fleet average age distributions by vehicle class for 2012 used in these calculations is provided in Appendix Table A

- 9.

η ORVR - In

- use control efficiency for ORVR : EPA recommends a value of 0.98. 21 States may use a lower or higher value, if justified. This value is based on testing of over 1

, 600 in

- use vehicles with mileages ranging from about 6 ,000

– 135,000. This value does not reflect other adjustments found in the MOVES emissions model . The current MOVES model does not fully

consider the in

- use verification program (IUVP) test results as mentioned above. Other MOVES

model efficiency adjustment s are based on data from older vintage evaporative emission control systems and do not fully reflect the benefits derived from OBD, I/M, or improved durability resulting from the integrated ORVR/evaporative control systems used in vehicles meeting the

prog ressively more stringent evaporative emission standards which were implemented in the

mid

- 1990s and later.

3 .3 Calculating Impacts on the Refueling Emission Inventory

This section presents the two main equations that use the terms discussed in section 3.2 as inputs to calculate area

- wide control efficiency impacts of Stage II VRS and ORVR. States can

consider us ing the results of these equations to support SIP actions phasing out Stage II control

programs.

3.3.1 Key Equation for Assessing and Demonstr ating Compliance with the Noninterference

Provisions of CAA Section 110(l) and the Comparable Measures Requirement of CAA Section 184(b)(2 )

Overall Stage II

- ORVR increment : The overall increment identifies the annual area

- wide

emission control gain from S tage II installations at GDFs as ORVR technology phases in. Thus, it also indicates the emission reduction potential loss (in year i ) from removing Stage II.

21 EPA Memorandum, “Updated ORVR In

- Use Efficiency,” Glenn W. P assavant. February, 2012. 

### Equation 1

i ncrement i 

### = (Q SII 

### )(1

- Q ORVR i 

### )(η iuSII 

### )

- (Q SIIva 

### )(CF i 

### )14

Under the current regulatory construct for ORVR, there is a small and declining number

of n on

- ORVR equipped vehicles and thus a small level of future emission reduction achievable from Stage II. However, due to the vacuum assist compatibility factor , this emission reduction will eventually go to zero and become negative for states/areas that do not use properly

calibrated ORVR

- compatible nozzles because the incompatibility effect will be larger than the Stage II increment. If the value is greater than zero for the year under consideration there is still a remaining emission reduction benefit fo r Stage II for the year relative to ORVR. If it is zero there is no net difference in the inventory. If it is zero or negative, t his would indicate that removing Stage II would not increase the refueling emissions inventory because the higher efficiency from ORVR and the incompatibility emissions offset the increment due to non

- ORVR vehicles being refueled at Stage II GDFs. It should be noted that for a state / area with all balance

systems or with a requirement for ORVR compatible nozzles, the CF term is zero.

3.3.2 Key Equation for Assessing and Demonstrating Compli a nce with CAA Section 193

Overall Stage II

- ORVR delta : The overall delta is the comparison between the Stage II efficiency and the ORVR efficiency with both technologies in place.

Thi s is not the same as the increment calculation in Equation 1 above because it considers the greater efficiency of ORVR relative to non

- ORVR vehicles refueling at Stage II equipped GDFs

.

3.3.3 Developing Area

- Specific Values for the Terms Used in Equations 1 and 2

To conduct analys e s using Equations 1 and 2, a state would first select a base year or date for the analysis. The base year or date would correspond to the date the state is considering for starting to allow decommissioning for affected GDFs. A lternatively, this could be a set of base years/dates if a s tate i s considering phasing

- out Stage II in a specific area over a longer time period such as two or more years.

Second, the s tate would develop the values needed for the equations. The informati on and values in Tabl e 2 are provided for consideration

. 

### Equation 2

d elta i 

### = (Q SII 

### )(η iuSII 

### )

- (Q SIIva 

### )(CF i 

### )

- (Q ORVR i 

### )(η ORVR 

### )15 Table 2 Values and Information Sources for Analysis Terms

Term Values/Sources Other Comments

η iuSII In

- use Stage II control efficiency This refers to the in

- use efficiency of the Stage II vapor recovery system when refueling a non

- ORVR equipped vehicle. State/area specific

value based on best estimate of in

use efficiency when Stage II

decommissi oning begins

. Consider

available test data. 22 Prior EPA guidance links in

- use efficiency to the level of inspection, testing, and maintenance by the GDF and follow up by the state. 23

We recommend an efficiency value

consistent with field test data and the expected future investment of state inspection and enforcement resources during the base year and any subsequent year if a phase

- out is

used. We advise against rely ing solely on prior EPA guidance, new system certification efficiency, or what your state regulations claim regarding efficiency. Q SII Fraction of gasoline throughput covered by Stage II VRS Appropriate d efault values are 0.90

if the state adopted the CAA exemption provisions and 0.95

- 0.97

if the state used 10,000 gpm for all

GDFs Other value s may be justified based

on state data. This fraction has the effect of excluding throughput at exempt GDFs.

Q SIIva Fraction of gasoline throughput covered by traditional vacuum assist Stage II VRS State/area specific value; state could use GDF survey da ta for throughput or GDF population by dispenser
type. Estimated d efault value s are provided in Appendix Table A

- 6 Zero if all GDFs use the balance type approach or dispenser nozzles are required to be ORVR compatible.

VMT ORVR F raction of annual VMT of gasoline

powered highway motor vehicles by ORVR equipped vehicles See Appendix T able A

- 1 , Column 3

. May use state/area specific data or adjust Appendix T able A

- 1 as appropriate (interpolation) if fleet

characteristics are different. Does

not include diesel s or any off road

vehicles.

CF

C ompatibility factor term E P A rec ognizes a value for this

constant of 0.07645 associated with

the VMT ORVR value

, or 0. 0 777 associated with Q ORVR value. CF is zero by definition for balance and ORVR compatible dispensers. Ma y calculate using data derived from traditional vacuum assist Stage II dispensers based on knowledge of the distribution of the different types of Stage II vacuum

- assisted equipment designs (e.g., high A/L

vs

. low A/L ratio) and field test

data

. 24

Q ORVR F r action of annual gallons of highway motor gasoline dispensed

to ORVR

- equipped vehicles See Appendix T able A

- 1 , Column 4

. N ote that Q ORVR i = 0.9826(VMT ORVR i ) May use state/area specific data or adjust Appendix T able A

- 1 as appropriate (interpolation) if fl eet is

older or newer

, or more or less fuel

efficient. Does not include diesels or any off road vehicles.

22 See reference in footnotes 12

- 1 5 above.

23 EPA report, “Enforcement Guidance for Stage II Vehicle Refueling Control Programs,” U.S. EPA, Office of Air and Radiation, Office of Mobile Sources, December 1991

. 24 See reference 16 for an example of how this work could be done.16 Table 2 Values and Information Sources for Analysis Terms

Term Values/Sources Other Comments

η ORVR ORVR in

- use control efficiency EPA recommends 0.98

. May u se a locally derived value if state/local authority believes EPA

in

- use testing data is unrepresentative

.

3.4 Example Calculations for Equations 1 and 2

3

. 4.1 Example Scenario # 1

Calculat e the increment for a potential deactivation of Stage II requirement s in mid

- 2013 assuming 70 percent in

- use Stage II control efficiency, a relatively low Stage II GDF exemption level of 10,000 gpm, a relatively high use of vacuum assist

- type dispensers of 90 percent

, national fleet ORVR penetration values (interpolated between 2012 and 2013 from columns 3

and 4 of Appendix Table A

- 1), and EPA’s recommended 98 percent ORVR control efficiency. The inputs are as follows:

η iuSII = 0.70; Q SII = 0.97; Q SIIva = 0.9; VMT ORVR mid 2013 = 0.8169; Q ORVR mid 2013 = 0.7935; η ORVR = 0.98

Compatibility f

actor c alculation :

CF mid2 013 = (0.07645)(VMT ORVR mid 2013 ) = (0.07645)(0.8169) = 0.0625

Increment c alcu l ation using Equation 1 :

Increment mid2 0 13 = (Q SII )(1

- Q ORVR mid 20 1 3 )( η iuSII )

- (Q SIIva )(CF mid 20 1 3 ) = (0.97)(1

- 0.7935)(0.70)

- (0.9)(0.0625)

= 0.084

In this example the Stage II

- ORVR increment is 8.4 percentage points at the midpoint of

2013 and would decrease over time.

For comp arison, it is interesting to look at the overall delta using the same input values as

above in Equation 2 :

Delta mid2 013 = (Q SII )(η iuSII )

- (Q SIIva )(CF mid2 0 1 3 )

- (Q ORVR mid 20 1 3 )(η ORVR ) = (0.97)(0.70)

- (0.9)(0.0625)

- (0.7935)(0.98)

=

- 0.155

In this case the ORVR control program provides 15.5 percent greater emission reduction benefits than the Stage II control program alone

.17

3.4.2 Example Scenario #2

Calculate the increment for a potential deactivation of Stage II requirement s beginning in

2013 assuming a 75 percent in

- use Stage II control efficiency, a relatively low Stage II GDF exemption level of 10,000 gpm, no traditional vacuum assist

- type pumps , and ORVR penetration in the fleet lags the national average by one year (using end of 2011 values from c olumn s 3 and 4

of Appendix Table A

- 1)

. The inputs are as follows:

η iuSII = 0.75; Q SII = 0.97; Q SIIva = 0.0; VMT ORVR 2013 = 0.76; Q ORVR 2013 = 0.7 385 ; η ORVR = 0.98

Compatibility factor calculation:

CF 2013 = (0.07645)(VMT ORVR 2013 ) = (0.07645)(0.76) = 0.0581

I ncrement calculation using Equation 1 :

Increment 2013 = (Q SII )(1

- Q ORVR 2013 )(η iuSII )

- (Q SIIva )(CF 2013 ) = (0.97)(1

- 0.7 385 )( 0 .75)

- (0)(0.0581)

= 0.1 902

In this example the Stage II

- ORVR increment is 1 9

. 0 2 percentage points at the beginning of 2013 (end of 2012)

. For comparison, it is interesting to look at the overall delta using the same input values as above in Equation 2 :

Delta 2013 = (Q SII )(η iuSII )

- (Q SIIva )(CF 2013 )

- (Q ORVR 2013 )(η ORVR ) = (0.97)(0.75)

- (0.0)(0.0581)

- (0.7 385 )(0.98)

= 0. 00 3 8

In this case the Stage II program provides 0 .3 8 percentage points greater emission reduction benefits than Stage II at the beginning of 2013 (end of 2012)

. The programs are essentially equivalent.

Using the same scenario for the beginning of 2014, (Q SI I )(η iuSII ) would stay the same while (Q ORVR i ) (η ORVR ) would increase from 0.7 237 to 0.7 611 . Thus, Delta 2014 indicates 3

. 3 6 percentage points more reduction from ORVR than Stage II. Similarly, f or 2015, Delta 201 5 indicates 6

. 67 percentage points more reduct ion from ORVR than Stage II. This difference in

effectiveness would be larger if a CF effect from traditional vacuum assist Stage II nozzles was

included.

3.4.3 Example Scenario # 3

Calculate the increment for a potential deactivation of Stage II requir ement beginning in 2013 for GDFs dispensing less than 100,000 gpm, beginning in 2014 for GDFs dispensing between 100,000 and 200,000 gpm

, and beginning in 2015 for all larger throughput GDFs. In

this scenario , the state/area must also know the fraction of covered throughput in these three segments and conduct the analysis for each of the three years. For the sake of this example,

assume that the less than 100,000 gpm segment is 40 percent of throughput, the over 100,000 gpm but less than 200,000 gpm segme nt is 30 percent of throughput, and the over 200,000 gpm segment is 30 percent of throughput. Thus, beginning in 2013 Stage II w ould be deactivated at18

GDFs representing 40 percent of throughput, beginning in 2014 Stage II w ould be deactivated at GDFs repr esenting an additional 30 percent of throughput, and beginning in 2015 at the remaining GDFs. In this example, assume the ORVR fleet in the state /area is t ypical of the national average and 75 percent in

- use Stage II control efficiency

.
For the beginning of 2013 segment of the analysis use the following values:

η iuSII = 0.75 ; Q SII = 0.97; Q SIIva = 0.6; VMT ORVR 2013 = 0. 7997 ; Q ORVR 2013 = 0.7 766 ; η ORVR = 0.98

Compatibility factor calculation :

CF 2013 = (0.07645)(VMT ORVR 2013 ) = (0.07645)(0. 7997 ) = 0.06 11

Increment calculations for 2013 using Equation 1 , in two parts :

2013, Part A: Stage II removed in 2013 at GDFs representing 40 percent of consumption:

Increment 2013 = (0.4)[(Q SII )(1

- Q ORVR 2013 )( η iuSII )

- (Q SIIva )(CF 2013 )] = (0.4)[(0.75)(0.97)(1

- 0.7 766 )

- (0.6)(0.06 11 )] = (0.40)[ (.7275)( 0. 2234

- 0.03 66 )]

= 0.0 54

2013, Part B: Stage II is not removed in 2013 for GDFs over 100,000 gpm, so the

increment would be zero.

In this example the Stage II

- ORVR increment is 5.4 percentage points for 2013. For comparison, note that the increment would be 1 2

. 59 percent if all Stage II VRS w ere removed in

2013.

For the beginning of 201 4 segment of the analysis use the following values:

η iuSII = 0.75 ; Q SII = 0.97; Q SIIva = 0.6; VMT ORVR 2014 = 0.8341; Q ORVR 2014 = 0.8104; η ORVR = 0.98

Compatibility factor calculation :

CF 201 4 = (0.07645)(VMT ORVR 201 4 ) = (0.07645) (0.8341) = 0.0638

Increment calculations for 2014 using Equation 1, in two parts :

2014, Part A: Stage II removed in 2014 at GDFs representing 70 percent of consumption:

Increment 2014 = (0.7)[(Q SII )(1

- Q ORVR 2014 )(η iuSII )

- (Q SIIva )(CF 2014 )] = (0.7)[(0.75)(0.97)(1

- 0.8104)

- (0.6)(0.0638)] = (0.7)[(0.1379)

- (0.0383)]

= 0.070

20 14, Part B: Stage II is not removed in 2014 for GDFs over 200,000 gpm so the increment

would be zero

.
In this example the Stage II

- ORVR increment is 7.0 percentage points for 2014.19

For the beginning of 201 5 segment of the analysis use the following valu es:

η iuSII = 0.75; Q SII = 0.97; Q SIIva = 0.6; VMT ORVR 2015 = 0.8633; Q ORVR 2015 = 0.8397; η ORVR = 0.98

Compatibility factor calculation :

CF 201 5 = (0.07645)(VMT ORVR 201 5 ) = (0.07645) (0.8633) = 0.066

Increment calculations for 2015 using Equation 1 :

Increment 2015 = (Q SII )(1

- Q ORVR 2015 )(η iuSII )

- (Q SIIva )(CF 2015 ) = (0.75)(0.97)(1

- 0.8397)

- (0.6)(0.066) = [(0.1166)

- (0.0 288 )]

= 0.0 8 7 8

In this example the Stage II

- ORVR increment is 8

. 8 percentage points for 2015 and

would continue to decrease over time. To s ummarize, the increment values for scenario #3 are:

2013

– 0.0 54 2014

– 0.070 2015

– 0.0 88

The cumulative Stage II

- ORVR increment for the three years would be 0.21 for the gradual phase

- o u t scenario which is lower than an increment of 0.30 for the same three year period if the controls were fully removed in 2013.

3.5 Calculating the I mpact on the Area

- Wide VOC I nventory

Calculating the impact on the VOC inventory is important in the context of assessing a SIP action against the provisions of CAA sectio n 110(l) , though the methodology in this section can be applied equally to the outputs of either Equation 1 or Equation 2. Th e methodology

involves multiplying three different terms

, which are area/state specific

, as well as appropriate

unit conversion fa ctors , and is shown in Equation 3

.

3 .5.1 Terms for Calculating Tons VOC

Increment : This is the increment percentage impact on the refueling inventory of removing Stage II as discussed above , and is the output from Equation 1

. The delta percentage from Equation 2 can also be substituted here

.

EF : The uncontrolled displacement refueling emission factor (g/gal). This depends on the Reid vapor pressure (RVP), dispensed fuel temperature (T d )

, and the difference between tank fuel temperature and the di spensed fuel temperature ( ΔT )

. While there are various forms of equations used to calculate these values we recommend using the equation presented in EPA’s 

### Equation 3

Tons i 

### = ( I ncrement i 

### )( GC i 

### )( EF

)20

ORVR widespread use determination final rule. 25 This equation reflects a wider variety of

vehicle m odels than used in the data set to develop the equation in AP

- 42

. 26

EF (g/gal) = exp[

- 1.2798

- 0.0049(ΔT) + 0.0203(T d ) + 0.1315(RVP)] where RVP is in psi and temperatures are in °F

There are three terms needed for this calculation. These terms vary by region/state by month or season. Values used by the EPA for ΔT and T d are contained in the A ppendix Table s A

- 2 and A

- 3

. 27 The RVP value is derived from 40 CFR 80.27 unless there are more specific state requirements or lower RVP values such as the 7.0 psi RVP gasoline needed to meet the RFG VOC performance standard. While there is normally some in

- use compliance margin for
RVP, to be conservative we recommend that modeling of emissions assum e that the in

- use RVP

is at the level of the standard. Informatio n on EPA volatility standards and RFG can be found at

the referenced website s

. 28 States should refer to and rely on any governing f ederal and state regulations in lieu of these websites. Default emission factors based on the latest available RVP

i nformati on from footnote 2 8 and temperature information in Tables A

- 2 and A

- 3 are provided in

Table A

- 7 in the Appendix. These were calculated using the equation provided.

GC : The projected gasoline consumption (gal) for the time period(s) and state/area of

inte rest in gallons. A good publicly available source for information on recent consumption is the Federal Highway Administration. 29 This source provides past gasoline consumption by state and by month. Information may also be available from other authoritie s within the state. Forecast information may be derived from the U.S. Department of Energy’s n ational annual forecasts of future gasoline consumption in millions of barrels per day , however, this forecast is not disaggregated to the state/area level. 30 (N ote that 1 barrel equals 42 gallons.) A simple approach for projecting state/area

- level consumption would be to apply the national average growth rate to the latest state

- level reported values. States may develop their own approach for disaggregation or use the state/area gasoline consumption breakouts provided in Table A

- 4 in the Appendix

. The values in Appendix Table A

- 4 are EPA estimates based on the ratio of county

level highway gasoline consumption to national consumption generated from national MOV ES

2010b runs based on Department of Energy Annual Energy Outlook 2011 VMT.

25 See EPA Memorandum Onboard Refueling Vapor Recovery Widespread Use Assessment, Glenn W. Passavant, June 2011. This equation was also used in EPA’s RIA for the original ORVR Final Rule 77 FR 28772, May 16,

2012

. 26 Exp is the root of the natural logarithm e , it has a value of 2.71828. In this case it is e raised to the power of the

term in the brackets.

27 See pp. 3

- 16 to 3

- 18 of, “Technical Guidance

– Stage II Vapor Recovery Systems for Control of Vehicle

Refueli ng at Gasoline Dispensing Facilities Volume I: Chapters” EPA

- 450/3

- 91

- 022a, November 1991 , for basic

information. Additional references are listed in this document.

28 http ://www.epa.gov/otaq/fuels/gasolinefuels/volatility/standards.htm

29 Use the latest version available of the DoT FHWA Highway Statistics; see the table entitled “Monthly gasoline reported by States

– MF33GA.” The 2010 version of “Highway Statistics” is fo und at: http://www.fhwa.dot.gov/policyinformation/statistics/2010/33ga.cfm

30 Use the motor gasoline projection from the latest version available of the D epartment of Energy EI A Annual Energy Outlook (AEO); see the table entitled “Liquid Fuels Supply and Distribution

- Reference Case.” The 2011

AEO is found at: http://www.eia.gov/oiaf/aeo/tablebrowser/#release=AEO2011&subject=0

- AEO2011&table=11

- AEO2011®ion=0

- 0&cases=ref2011

- d020911a21

Example 1: Assume we are conducting this calculation for a S tate in R egion 1 of the EPA fuels temperature matrix for the five

- month ozone season May

- Sept ember, and assume we

are u sing the I

ncrement

mid2013 value from Example Scenario #1 above , which is 8.4 percentage points in mid

- 2013. Since this is an area in R egion 1 of the EPA fuels temperature matrix with an ozone season gasoline RVP of 7. 0 psi, the EF calculates to 3

. 0 g/gal ( T d =74°F and ΔT=11.4 ° F)

. Using Table MF

- 33GA from the 2010 Highway Statistics report

, determine Massachusetts ’ annual gasoline consumption ( i. e.
, 2,795,148,000 gallons per year). For the five month ozone

season the monthly data in the table indicates that a bout 43 percent of gasoline is being

consumed during May

- Sept ember . Growth from 2010

- 2013 is about 3.44 percent. So, GC mid2013 = 2,795,148,000 * 0.43 * 1.0344 = 1,243,259,400 gal/ozone season.

For the five month ozone season selected here the overall emi ssions effect of removing Stage II would be:

Tons mid2013 = Increment mid2013 * GC

mid2013 * EF * (conversion factors )

= ( 0 .084)( 1,243,259,400 gal/season )( 3

. 0 g/gal)[(1 lb/453.59 g)(1 ton/2000 lbs)]

= 341.9 tons/ozone season

In the above equation, in order to obtain an answer in tons per ozone season, we have introduced conversion factors into the equation where 453.59 grams equal 1 pound

, and 2,000 pounds equal 1 ton. These conversion factors are also used in the equation below

.
On a daily basis thi s would be about 2.23 tons per day on average for the 153 days in this

five

- month ozone season. There are approximately 3,200 GDFs in Massachusetts with Stage II VRS. On a daily basis this represents about 1.4 lbs/day per GDF.

States can further disaggre gate these calculations to individual ozone nonattainment areas in the state using the estimates in Appendix Table A

- 4 . The effect would be proportional to gasoline consumption.

Example 2: Looking at this same E xample S cenario #1 above for D elta mid2013 , the emissions impact calculation shows a net gain of tons reduction per ozone season for ORVR over Stage II alone :

Tons mid2013 = ( 0 .155 )( 1,243,259,400 gal/season )(2.97 g/gal)[(1 lb/453.59 g)(1 ton/2000 lbs)]

= 630.9 tons/ozone season

On a daily ba sis this net difference would be about 4.12 tons per day on average for the 153 days in this five

- month ozone season.

3.6 States/Areas with Stage II but not Affected by 182(b)(3) or 184(b)(2)

Portions of six states have implemented Stage II for some area s even though they were not required to do so under the CAA to meet a requirement under s ections 182(b)(3) or 184(b)(2) . These include Kentucky, Tennessee, Nevada, California, Oregon, and Washington. If these states/areas included Stage II

- related emissi on reductions in their SIPs, they will have to amend their SIPs if Stage II is no longer required , and will have to address the provisions of22

CAA section 110(l). To facilitate any assessments for SIP revisions (as discussed above), we

have included the re levant input parameters in Table A

- 8 in the Appendix.



### 4. Strategies and Considerations for Phasing Out Stage II Controls

Even though EPA has determined that ORVR is in widespread use in the motor vehicle fleet, and has wa i ved the statutory requirement t o implement Stage II programs in ozone nonattainment areas, states are not obligated to remove the programs. States and local areas may elect to retain Stage II because i t provi d es VOC and hazardous air pollutant emission reductions

for non

- ORVR equipped vehicles. S tate s that wish to phase out Stage II controls do not necessarily need to wait until the foregone emissions control approaches zero before seeking a

SIP revision. There may come a point where retaining Stage II controls is otherwise unattracti ve for cost and cost

- effectiveness reasons and , as discussed above, the foregone emission reductions are small enough that the loss of control would not affect compliance with the NAAQS . This is especially relevant here since the increment in the first ye ar of Stage II removal will not remain constant in the future but will continue to decrease going forward in time. This will provide

added assurance that any potential impact on air quali ty would also diminish. The s tate would

need to maintain its Stage II program until it is fully phased out and until the s tate has begun implementing any needed new measures to ensure there will not be a harmful gap in area

- wide

emissions control

.

4.1 Gradual P hase

- out S trategy

If a state determines that decommissioning all Stage II control in an area all at one time or by a date certain would result in an unacceptable area

- wide emissions increase, then states might consider a gradual phase

- out strategy. A s trategy of this nature is illustrated in Example

Scenario # 3 abo ve. Using this approach a state might design a phase

- out strategy that first exempts new GDFs from Stage II controls starting in 2013 , and provides for subsequent decommissioning of existing Stage II

- equipped GDFs starting with the lowest throughput

stati ons in 2014 and ending with the highest throughput stations in 2017. An example phase

- out strategy might also use some of the original Stage II program phase

- in parameters in CAA section 182(b)(3) (e.g., new facilities exempted first, then GDFs that dispe nse less than 100,000 gallons per month, and then all remaining GDFs).

4 .2 Cost C onsiderations

To support their decision making, states may wish to conduct a n economic analysis of

their Stage II control program to evaluate the ongoing annualized cost p er ton of VOC removed.

The EPA conducted this type of assessment to support the final widespread use determination

rule

. 31 The EPA estimates that for an average size GDF the annual cost to maintain existing Stage II systems is about $3, 0 00 per year. These total costs would be incurred by GDF operators each year to cover ever decreasing annual emission reduction benefits as measured by the

increment calculation (Equation 1) described above. The EPA also estimates that the additional

31 See Final Regulatory Support Document

- Widespread Use for Onboard Refueling Vapor Recovery and Sta ge II Waiver: Decommissioning Stage II Vapor Recovery, Financial Benefits and Costs

, March 2012

.23

costs of installing Sta ge II vapor recovery equipment at new GDFs , which typically include USTs, associated piping, pumps and ancillary equipment, ranges from $20,000 to $60,000. If this cost is amortized over a short period of time as ORVR continues to phase

- in (e.g., 3 years)

the new control may not be attractive from a cost effectiveness view point

.

4.3 Decommissioning I ssues

Whatever approach a state decides upon for phasing out Stage II controls, consideration should be given to proper decommissioning of Stage II

- related equipment, including the underground vapor piping

, and to e nsur ing that consistent procedures are in place to address liquid and vapor leak issues associated with decommissioning. The EPA recommends that currently available industry association codes and standards be followed (where applicable) to ensure that Stage II systems are properly designed, constructed, installed, and, in this case,

dismantled or decommissioned. These codes and standards of practice provide a means for

states to monitor methods of Stage II system decommissioning and we encourage s tate and local agencies to reference these codes. The EPA realizes that industry codes and standards may be updated periodically

, and the EPA also recognizes that s tate and local requirements may supersed e industry codes and standards or be inherently more stringent. The EPA regulations do not require the use of a particular issue of code. The Petroleum Equipment Institute (PEI) and at least four states have recommended practices or specific requirements for decommissioning Stage II systems. The PEI guidance, “Recommended Practices for Installation and Testing of Vapor Recovery Systems at Vehicle Fueling Sites, PEI/RP300

- 09,” is especially instructive as it was developed by industry experts with a focus on regulatory compliance and safety. It contains the steps involve d in dismantling Stage II hardware and applies to both balance and vacuum assist type systems. Please be aware that there may be other codes or standards not listed here that may also be a ppropriate to ensure proper Stage II decommissioning.

4.4 Potential Emission Reduction Programs for GDFs

By viewing the GDF in it s entirety as a fuel storage and dispensing system, e xisting GDF emissions control systems can be enhanced to achieve a highe r level of in

- use efficiency, and to

deliver more environmental benefit . Of course, additional system design, maintenance, and enforcement provisions add cost to the installation and ongoing operation of the systems. Examples of extra design and monitori ng features include: 1) ORVR compatible Stage II nozzles; 2) systems to help better manage UST pressure and control emission s lost from the UST through vent lines and fugitive leak sources during normal operations ; 3) post processors to

control or eliminat e normal UST breathing/emptying loss emissions ; 4 ) s tandards for specially designed nozzles that reduce emissions from liquid retention, drips, and spills; and 5 ) low permeation fuel hoses.24



### 5. Submission

, Review and Approval of SIP Revisions

When subm itting a SIP revision seeking removal of an existing Stage II vapor recovery

program , the SIP revision package should include the information necessary for the EPA to determine that the action complies with all relevant CAA provisions, including , as applic able

, sections 110(l), 193, and 184(b)(2)

. States are encouraged to work closely with EPA Regional Offices to develop SIP revision packages.

5 .1 Elements of SIP R evision P ackage

The state should coordinate with the appropriate EPA Regional Office on the nec essary format and procedures for submitting a SIP revision. Submittal and cover letters should be addressed to the EPA Regional Administrator (RA) or the Regional Air Division Director (ADD) if the RA has delegated that authority to the ADD to accept SIP revisions submittals. The SIP

revision should clearly identify the portion of the s tate regulation pertaining to the Stage II regulatory program that the s tate is requesting to revise

. If following this guidance document,

the state c ould include the resu lts of area

- wide emissions and emissions control calculations based on Equation 1 ( increment ) and/or Equation 2 ( delta ). The submittal should also include analysis, discussion, and any other relevant materials supporting a request for SIP approval with

re gards to sections 110(l), 184 (b)(2) and 193, as applicable. If new emissions control regulations are being adopted to offset emissions controls forgone by the phasing out of a Stage II program , an analysis of the expected net area

- wide emissions change w ould be appropriate.

5 .2 EPA SIP R eview P rocess

The EPA expects that state submission to revise the SIP should show how the revision

satisf ies the requirement in section 110(l) not to interfere with attainment or maintenance of the NAAQS or any other app licable requirement

. First, the EPA must determine that the submittal is complete within 6 months of the submission date. If deemed complete

, the EPA must either approve or disapprove the submittal within one year of the determination of completeness

. Th e EPA will act on SIP revision s through n otice and comment rulemaking.

The EPA is not limited to only considering the calculations presented in this memorandum when considering a SIP revision seeking to remove Stage II control requirements

. There is no specific value in terms of percentage control or tons of emissions that a state must
meet before EPA can propose to approve a SIP revision. Each SIP revision will be reviewed on

a case

- by

- case basis against the criteria of CAA section 110(l) , and if appli cable, sections 193

and /or 184(b)(2)

, with due consideration to the basis for the values used in supporting

calculations and any related emissions inventory and/or air quality analyses.25 Appendix

Table A

- 1

- Projected Penetration of ORVR in the National Gasoline Fueled Vehicle Fleet by Year [ B ased on MOVES 2010(a) ]

1 2 3 4

End of Calendar

Year Vehicle Population

Percentage VMT Percentage Gasoline Dispensed Percentage

2006 42.6% 51.2% 49.2%

2007 48.4% 57.3% 55.5%

2008 53.3 % 62.3% 60.5%

2009 57.7% 6 6.8% 64.8%

2010 62.4% 71.6% 69.5%

2011 67.1% 76.0% 73.9%

2012 71.4% 80.0% 77.7%

2013 75.3% 83.4% 81.0%

2014 78.7% 86.3% 84.0%

2015 81.8% 88.8% 86.5%

2016 84.5% 90.9% 88.6%

2017 86.8% 92.5% 90.3%

2018 88.8% 93.9% 91.9%

2019 90.5% 95.0% 93.2%

2020 92.0% 95.9% 94.3%

See EPA Memorandum “ Updated data for ORVR Widespread Use Assessment” February 29, 2012, in docket (number EPA

- HQ

- OAR

- 2010

- 1076) addressing details on values in this table and providing more calendar years

. Note: In this table, the colum ns have the following meaning. 1. Calendar year that corresponds to the percentages in the row associated with the year. 2. Percentage of the gasoline

- powered highway vehicle fleet that have ORVR. 3. Percentage of gasoline

- fueled vehicle miles traveled (VMT) by vehicles equipped with

ORVR. 4. Amount of gasoline dispensed into ORVR

- equipped vehicles as a percentage of all gasoline dispensed to highway motor vehicles.26 Table A

- 2

- Monthly A verage D ispensed L iquid T emperature

D ispensed liquid temperatu re (°F)

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Weighted Average

Summer (Apr

– Sep) Winter (Oct

- Mar) Annual

Average

National Average 51 54 54 58 69 76 82 81 76 70 62 54 74 58 66

Region 1 43 45 48 53 66 74 78 78 72 66 59 46 70 51 61

Region 2 69 74 73 80 84 87 90 91 78 85 83 73 85 76 81

Region 3 54 57 61 67 76 82 83 84 79 76 67 54 79 62 70

Region 4 50 51 41 47 63 74 88 85 83 75 63 52 74 56 65

Region 5 54 NA NA NA 72 77 83 83 79 74 67 58 79 63 72

Region 6 NA 48 49 53 59 63 NA 73 71 60 49 42 64 50 57

Regional Boundaries Region 1: ME, VT, NH, MA, CT, RI, NY

, NJ, PA, DE, MD,VA,WV,DC, KY, OH, IN, IL, MI, WI Region 2: NC, SC, GA, FL, AL, MS, AR, LA, TN Region 3: OK, TX, NM, AZ Region 4: MN, IA, MO, ND, SD, NE, KS, MT, WY, CO Region 5: CA, NV, UT Region 6: WA, OR, ID

Source: McNally Michael and Dickerman J.C., "Summary and Analysis of Data from Gasoline Temperature Survey

, " conducted by API, Radian Corporation, May, 1976.27

Table A

- 3

- S easonal V ariation I n T emperature D ifference B etween V ehicle F uel T ank and

D ispensed F uel (

Temperature Difference (

Average

Annual Summer

(Apr

– Sep ) Winter

(Oct

– Mar) 5

- Month

Ozone Season (May

– Sep) 2

- Month

Ozone Season (Jul

– Aug)

National Average 4.4 8.8

- 0.8 9.4 4 9.9

Regi on 1 5.7 10.7

- 0.3 11.5 12.5

Region 2 4 .0 6.8 0.9 7.5 8.2

Region 3 3.7 7.6

- 0.4 7.1 7 .0

Region 4 5.5 11.7

- 2.4 12.1 13.3

Region 5 0.1 3.9

- 4.4 5.1 3.2

Region 6 Use Region 4 data

Regional Boundaries Region 1: ME, VT, NH, MA, CT, RI, NY

, NJ, PA, DE, M D,VA,WV,DC, KY, OH, IN, IL, MI, WI Region 2: NC, SC, GA, FL, AL, MS, AR, LA, TN Region 3: OK, TX, NM, AZ Region 4: MN, IA, MO, ND, SD, NE, KS, MT, WY, CO Region 5: CA, NV, UT Region 6: WA, OR, ID

Source: Rothman, Da le and Johnson, Robert, Technical Repor t, “Refueling Emissions from

U ncontrolled Vehicles

, ” EPA.OMS, EPA

- AA

- SDSB

- 85

- 6

. June 1985.28

Table A

- 4

- Percent of 50 State Gasoline Consumption for Areas Covered by CAA Sections

18 2 (b)( 3 ) or 184(b)(2)

State Counties Historical

Ozone

Nonattainment

Area s Area Name % of 50 Sta t e Gasoline Consumption

AZ 3 1 Phoenix 1.079%

CA 21 8 Sacramento 0.7181% San Joaquin 1.1 40 %

East Kern 0.0532%

LA

- South Coast 4.545%

Southeast Desert 0.676 4 % San Diego 1.096%

Santa Barbara 0.1270%

Ventu ra 0.220 1 %

CT 8 1 All CT 1.06 1 %

Greater CT 1.041%

NY

- NJ

- CT 0.0196%

DC 1 1 DC 0.12 7 0 %

DE 3 2 All DE 0.307 9 % Philadelphia

- Wilmington

Trenton 0.2345%

Sussex 0.0763%

GA 13 1 Atlanta 1.677%

IL 8 1 Chicago

- Gary

- Lake 1.678%

IN 4 1 Chicago

- Ga ry

- Lake 0.29 06 %

LA 6 1 Baton Rouge 0.222 1 %

MA 14 2 All MA 1.92 2 % Boston (Eastern MA) 1.960% Springfield (Western MA) 0.231 4 %

MD 12 3 Baltimore 0.85 85 9 %

DC/MD/VA 0.716 1 % Philadelphia

- Wilmington

Trenton 0.043%

ME 3 0 Portland 0.194 3 %

MO 5 1 St. Louis 0.776 4 %

NH 4 1 Portsmouth

- Dover

- Rochester 0.295 0 %29

State Counties Historical

Ozone

Nonattainment

Areas Area Name % of 50 State

Gasoline Consumption

NJ 21 2 All NJ 2.598%

New York

- New Jersey

- Long

Island 1. 73 6 %

Philadelphia

- Wilming ton

Trenton 0. 862 1 %

NY 10 1 New York

- New Jersey

- Long

Island 2.427%

PA 12 2 Philadelphia

- Wilmington

Trenton 0.848 0 %

Pittsburgh

- Beaver Valley 0.652%

RI 5 1 All RI 0.307%

TX 16 4 Houston

- Galveston

- Brazoria 1.646%

El Paso 0.184 1 %

Dallas

- Ft. Wor th 1.786%

Beaumont

- Port Arthur 0.123 0 %

VA 17 2 DC/MD/VA 0.708 2 %

Richmond 0.339 0 %

VT 14 0 All VT 0.362%

WI 6

4 Milwaukee

- Racine & Kenosha 0.57 79 %

1 Sheboygan 0.038 3 %

1 Manitowoc 0.03 49 %

1 K ewaunee 0.008 4 %30

Table A

- 5

- Applicability o f Clean Air Act Requirements to Areas Implementing Stage II

Gasoline Vapor Recovery Programs for the Ozone NAAQS

State Nonattainment Areas §110( l ) Only 1 §184(b)(2)

(OTR Comparable Measures) §193

(Pre

- 1990 Savings Provision) Attaining Ozone NAAQS 2

1

- hour 3 1997

8

- hour 4 2011

DV 2008 8

- hour 5

AZ Phoenix X Yes Yes 0.077 No

CA LA

- South Coast X No No 0.1 07 No

LA

- San Bernardino Co ( West Mojav e Desert ) 6 X No No 0.09 7 No

Sacramento Metro X Yes No 0.0 95 No

San Joaquin Valley 6 X No No 0.0 9 4 No

Riverside Co (Coachella Valley) 6 X Yes No 0.09 3 No

Ventura Co X Yes Yes 0.08 3 No

San Diego X Yes Yes 0.08 2 No

Santa Barbara

- Santa

Ma ria

- Lompoc X Yes Yes 0.076 No

CT NYC

- Long Is., N Y

- NJ

- CT X Yes Yes 0.084 No

Greater CT Area X Yes Yes 0.07 6 No

DE Philadelphia

- Wilmington

Atlantic City, PA

- NJ

- MD

DE X Yes Yes 0.083 No

Sussex County, DE OTR

Area X Yes Yes 0.077 No

GA Atlanta X Yes Yes 0.080 No

IL Chicago

- Gary, IL

- IN X Yes Yes 0.07 7 No

St. Louis, MO

- IL X Yes Yes 0.077 No

IN Chicago

- Gary, IL

- IN X Yes Yes 0.07 7 No

LA Baton Rouge X Yes Yes 0.08 2 No

ME ME OTR Area X Implementing Stage II in 3

Southern ME Counties

. Yes

MD Baltimore X Yes No 0.09 2 No

Philadelphia

- Wilmington

Atlantic City, PA

- NJ

- MD

DE X Yes Yes 0.083 No

Washington DC

- MD

- VA X Yes Yes 0.08 2 No

MA 7 Boston

- Lawrence

Worcester (E. MA) X Yes Yes 0.07 5 Yes

Springfield (W. MA) X Yes Yes 0.07 4 Yes

MO St. Louis, MO

- IL X Yes Yes 0.07 9 No

NH Boston

- Lawrence

Worcester (E. MA) X Yes Yes 0.07 5 Yes

Portsmouth

- Dover

Rochester X Yes Yes 0. 06 3 Yes

Rest of NH OTR Area X Implementing Stage II and RFG to meet comparable

measures. Yes31 State Nonattainment Areas §110( l ) Only 1 §184(b)(2)

(OTR Comparable Measures) §193

(Pre

- 1990 Savings Provision) Attaining Ozone NAAQS 2

1

- hour 3 1997

8

- hour 4 2011

DV 2008 8

- hour 5

NJ NYC

- Long Is., N Y

- NJ

- CT X X Yes Yes 0.084 No

Philadelphia

- Wilmington

Atlantic City, PA

- NJ

- MD

DE X Yes Yes 0.083 No

Rest of NJ OTR Areas X Implementing Stage II in all

counties. Yes

NY NYC

- Long Is., N Y

- NJ

- CT X X Yes Yes 0.084 No

PA Philadelphia

- Wi lmington

Atlantic City, PA

- NJ

- MD

DE X Yes Yes 0.083 No

Pittsburgh

- Beaver Valley, PA (1

- hour Moderate area under §182(b)(3)) X Yes Yes 0.08 0 No

RI Providence and all RI

Areas X Yes Yes 0.07 3 Yes

TX Houston X No No 0.08 9 No

Dallas

- Ft. Worth X Yes No 0.0 90 No

Beaumont

- Port Arthur X Yes Yes 0.074 Yes

El Paso X Yes Yes 0.071 Yes

VT All of VT (OTR) X Implementing Stage II in all

counties. Yes

VA Washington DC

- MD

- VA

(Northern VA) X Yes Yes 0.08 2 No

Richmond, VA X Yes Yes 0.075 Y es

WI Milwaukee

- Racine X Yes Yes 0.07 7 No

1 All states and all areas are required to comply with CAA section 110( l ), chart shows states/areas where 110( l ) is the only constraint.

2 Based on air quality data from 200 9

- 201 1

. 3 The 1

- hour ozone NAAQS was promulgated in 1979 and was 0.12 ppm.

4 The first 8

- hour ozone NAAQS was promulgated in 1997 and is 0.08 ppm and is attained if the area design value is less that or equal to 0.084

ppm . Once an area was designated under the 1997 ozone standard, the 1

- hour standard was revoked for that area. As of April 15, 2008, all areas were designated under the 1997 ozone standard.

5 The 2008 8

- 0hour Ozone NAAQS is 0.075 ppm.

6 History of redistricting and boundary changes between air districts with pre

- 1990 requireme nts. District may have Stage II gasoline dispensing rules in some parts of district prior to 1990

. 7 The MA Stage II program was adopted prior to 11/15/1990 but was not approved into the SIP until 12/14/1992

.32

Table A

- 6

- Percent of State/Area GDF Dispen sers Using Vacuum Assist Stage II Technology (June 2012)

State Number

Counties Area name % GDFs using

Vacuum Assist

ARIZONA 3 Phoenix 85%

CALIFORNIA 32 21 Average Q SIIva 70%

Sacramento ORVR Compatible San Joaquin ORVR Compatible

East Kern ORVR Compatible

LA

- South Coast ORVR Compatible

Southeast Desert ORVR Compatible San Diego ORVR Compatible

Santa Barbara ORVR Compatible

Ventura ORVR Compatible

CONNECTICUT 8 All CT 88%

DELAWARE 3 All DE 88%

DC 1 DC 97%

GEORGIA 13 Atlan ta 95%

ILLINOIS 8 Chicago metro 92%

INDIANA 4 Chicago

- Gary metro 95%

LOUISIANA 6 Baton Rouge 90%

MAINE 3 Portland 95%

MARYLAND 12 Baltimore and Wash DC areas 94%

MASSACHUSETTS 14 All MA 90%

MISSOURI 5 St. Louis 0%

NEW HAMPSHIRE 4 Portsmouth Dover Rochester 93%

NEW JERSEY 21 All NJ 48%

NEW YORK 10 NYC metro 73%

PENNSYLVANIA 12 Philadelphia metro 80% Pittsburgh

- Beaver Valley 96%

RHODE ISLAND 5 All R I 93%

TEXAS 33 16 Average Q SIIva 90%

Houston

- Galveston

- Brazoria ORVR Compatible

El Pas o ORVR Compatible

Dallas

- Fort Worth ORVR Compatible

Beaumont

- Port Arthur ORVR Compatible

VIRGINIA 17 Wash DC metro area 93%

Richmond 85%

VERMONT 14 All VT 95%

WISCONSIN 9 All Counties 85%

32 Estimates for California provided by state sources, all vacuum assist must be ORVR compatible.

33 Estimates for Texas provided by state sources, all vacuum a ssist must be ORVR compatible.33

Table A

- 7

- Five

– Month (May

- September) Uncontrolled Displacement (non

- ORVR) Refueling Emission Factors (g/gal)

State Number

Counties Area name RVP (psi) Emission

Factor

ARIZONA 3 Phoenix 7.8 3.5

CALIFORNIA 58 All CA 7.0 3.4

CONNECTICUT 8 All CT 7.0 3.0

DELAWARE 3 All DE 7.0 3.0

DC 1 DC 7.0 3.0

GEORG IA 13 Atlanta 7.0 4.6

ILLINOIS 8 Chicago metro 7.0 3.0

INDIANA 4 Chicago

- Gary metro 7.0 3.0

LOUISIANA 6 Baton Rouge 7.8 5.1

MAINE 3 Portland 7.8 3.3

MARYLAND 12 Baltimore and Wash DC areas 7.0 3.0

MASSACHUSETTS 14 All MA 7.0 3.0

MISSOURI 5 St. Lo uis 7.0 3.3

NEW HAMPSHIRE 4 Portsmouth Dover Rochester 7.0 3.0

NEW JERSEY 21 All NJ 7.0 3.0

NEW YORK 10 NYC metro 7.0 3.0

PENNSYLVANIA 12 Philadelphia metro 7.8 3.0 Pittsburgh

- Beaver Valley 7.0 3.3

RHODE ISLAND 5 All R I 7.0 3.0

TEXAS 16 All TX 7. 0 3.5

VIRGINIA 17 All VA 7.0 3.0

VERMONT 14 All VT 9.0 3.9

WISCONSIN 6 Milwaukee

- Racine 7.0 3.0 Sheboygan, Manitowoc,

Kewaunee 9.0 3.934

Table A

- 8

- Input Data for States/Areas with Stage II but not Affected by 182(b)(3) or 184(b)(2) (Ju ly 2012)

S tate Number

Counties Area name Percent of 50

State Gasoline Consumption % GDFs

using

Vacuum

Assist 34 RVP

(psi) Five

– Month (May

September Refueling

Emission

Factors (g/gal)

CALIFORNIA 35 37 All AQMDs

& APCDs

not listed in

tables above 2.565% 70% ORVR Compati ble 7.0 3.4

KENTUCKY 3 Jefferson 0.2498% 98% 7.0 3.0

N KY 0.1299% 98% 7.0 3.0

NEVADA 2 Washoe County 0.1087% 40% 7.8 3.9

Clark County 0.430% 70% 9.0 4.4

OHIO 16 Cleveland

Akron 0.8076% 97% 9.0 3.9

Cincinnati 0.4775% 96% 7.8 3.4
Dayton 0.2884 % 94% 7.8 3.4

OREGON 3 Portland 0.426% 50% 7.8 3.7

TENNESSEE 1 Davidson 0. 2409% 98% 7.8 4.6

4 Nashville

Metro 1.16 8 7% 95% 7.8 4.6

WASHINGTON 5 Seattle 1.08 8 % 80% 9.0 4.3

2 Vancouver 0

. 1542% 80% 9.0 4.3

34 Estimates for California provided by state sources; all vacuum assist must be ORVR compatible.

35 This data provided by the Petroleum Equipment Institute.35 Table A

- 9

– MOVES 2012 Vehicle Class Age Dis tribution

Calendar Model Gasoline

Year Age Year ID Motorcycle Pass Car LDT1 LDT2 HDGV

2012 30 1982 0.001966 0.000668 0.002037 0.002037 0.005699

2012 29 1983 0.001689 0.000718 0.002178 0.002178 0.005426

2012 28 1984 0.002310 0.001094 0.003234 0.0032 34 0.006327

2012 27 1985 0.002585 0.001559 0.004318 0.004318 0.008814

2012 26 1986 0.003071 0.002170 0.004989 0.004989 0.011413

2012 25 1987 0.003696 0.002585 0.006043 0.006043 0.009350

2012 24 1988 0.003741 0.003538 0.007146 0.007146 0.011049

2012 23 1989 0.004419 0.004355 0.007774 0.007774 0.011843

2012 22 1990 0.005962 0.005407 0.008745 0.008745 0.010388

2012 21 1991 0.007355 0.006255 0.008972 0.008972 0.009462

2012 20 1992 0.009290 0.008232 0.011363 0.011363 0.011102

2012 19 1993 0.011102 0.011 132 0.014774 0.014774 0.014453

2012 18 1994 0.013623 0.015221 0.018422 0.018422 0.020989

2012 17 1995 0.011840 0.018786 0.020574 0.020574 0.023061

2012 16 1996 0.015718 0.023545 0.024745 0.024745 0.025302

2012 15 1997 0.017935 0.028620 0.028422 0.02842 2 0.027497

2012 14 1998 0.018745 0.034619 0.034691 0.034691 0.032089

2012 13 1999 0.021968 0.044520 0.039503 0.039503 0.045460

2012 12 2000 0.029065 0.054649 0.047137 0.047137 0.048348

2012 11 2001 0.036410 0.056862 0.051960 0.051960 0.052218

2012 10 2002 0.042963 0.057388 0.056257 0.056257 0.047379

2012 9 2003 0.048226 0.056194 0.061399 0.061399 0.052367

2012 8 2004 0.056980 0.057747 0.066770 0.066770 0.058223

2012 7 2005 0.067163 0.060876 0.070393 0.070393 0.064607

2012 6 2006 0.076695 0.063183 0 .068310 0.068310 0.063641

2012 5 2007 0.080950 0.062722 0.068566 0.068566 0.063843

2012 4 2008 0.089568 0.056968 0.046968 0.046968 0.048232

2012 3 2009 0.047643 0.051356 0.037902 0.037902 0.040547

2012 2 2010 0.067916 0.061669 0.054558 0.054558 0.05277 4

2012 1 2011 0.089591 0.070362 0.059917 0.059918 0.057786

2012 0 2012 0.109815 0.076999 0.061931 0.061930 0.060313

Total 1.000000 1.000000 1.000000 1.000000 1.000000

Avg Age 6.9 8.0 8.9 8.9 9.6

LDT1: < 6000 lbs G VWR

LDT2 : >6000 but < 8500 lbs GVWR

HDGV: > 8500lbs GVWR36

United States

Environmental Protection Agency Office of Air Quality Planning and

Standards Research Triangle Park, NC Publication No. EPA

EPA

- 457/B

- 12

- 001 August 7 , 2012