PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES



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PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR THE CALIFORNIA STATE IMPLEMENTATION PLAN

SECTION III CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

Release Date: August 25, 2003 Hearing Date: September 24-25, 2003PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

TABLE OF CONTENTS

CHAPTER A. CONSUMER PRODUCTS ........................................................... III-A-1 CHAPTER B. FUELING AND VAPOR RECOVERY .......................................... III-B-1 CHAPTER C. PESTICIDES ................................................................................ III-C-1PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES



### Staff Contact List

Chapter Contact Email Phone A: Consumer Products Janette Brooks jbrooks@arb.ca.gov (916) 322-7072 B: Fueling and Vapor Recovery Cindy Castronovo ccastron@arb.ca.gov (916) 322-8957
C: Pesticides Michael Benjamin mbenjami@arb.ca.gov (916) 323-2915PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

CONSUMER PRODUCTS III-A-1 

## CHAPTER A Consumer ProductsPROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

CONSUMER PRODUCTS III-A-2 CHAPTER A. CONSUMER PRODUCTS 1. Category Description As part of the 1988 California Clean Air Act, the California State Legislature gave the Air Resources Board (ARB) the authority and responsibility to achieve the maximum technologically and commercially feasible reactive organic gas (ROG) emission reductions from consumer products. A consumer product is defined as a chemically formulated product used by household and institutional cons umers. Consumer products include, but are not limited to: detergents, cleaning compounds, polishes, fl oor finishes, cosmetics, personal care products such as antiperspirants and hairs prays, home, lawn and garden products, disinfectants, sanitizers, automotive specia lty products, and aerosol paints. Other paint products, such as furniture or architectura l coatings, are not part of ARB’s consumer products program because local air districts regulate them. C onsumer products can come in different product formsincluding aerosol, liquid, so lid, or gel. California law includes a provision that stat es that the ARB’s regulationscannot eliminate any product form. Consumer products are a significant source of ROG emissions in California and contribute to the formation of both ozone and particulate matter pollution. Although each consumer product may seem to be a sm all source of emissions, the cumulative use of these products by nearly35 million Californians result s in significant emissions. Consumer products accounted for approxim ately 267 tons per day (tpd) of ROG emissions in the year 2000, which comprise d about eight percent of the total man-made ROG emissions statewide. ARB staff (sta ff) acknowledges t hat the ROG emissions from consumer products are relatively less reactive when compared to some other ROG emission sources. For example, on a pound for pound basis, the ROG emissions from vehicle exhaust are estimated to lead to t he formation of more than twice as much ozone than the ROG emissions from consumer products. However, this does not mean that consumer products should not be cont rolled. ROG emissions from consumer products do lead to the formation of ozone and are a significant source of air pollution in California. Further reductions in ROG em issions from consumer products and other ROG sources are needed if ozone standards are to be achieved. As a result of several regulations adopt ed by the ARB over the last ten plus years, emissions from consumer productsand aerosol coatings have decreased, and continued reductions are projected through 2005. Table III-A-1 lists the various regulations adopted by the ARB with respect to consumer products. Each regulation has been amended at least once since it was orig inally adopted. Table III-A-2 presents current and projected emissions from consum er products reflecting the benefits of all adopted regulations. Due to population growth and without additional controls, staffPROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

CONSUMER PRODUCTS III-A-3 expects the trend of emissions reductions to reverse once the last of the already adopted standards takes effect in 2005. Wi th a projected 1.4 percent population increase per year in California, consumer product emissions are expected to increase by more than 3.5 tpd annually after 2005.
Table III-A-1 California Consumer Products Regulations Regulation Adoption Year Antiperspirants and Deodorants 1989 Consumer Products Phase I Amendments Phase II Amendments Midterm Measures Amendments I Midterm Measures Amendments II 1990 1993 1996 1997 2000

Alternative Control Plan 1994 Aerosol Coatings 1995 Hairspray Credit Program 1997

Table III-A-2 Baseline Emissions for Consumer Products (Statewide Emissions, Summer, tpd) 1990 2000 2005 2010 2015 2020 ROG 320 267 244 260 277 295 (South Coast Air Basin Emissions, Summer, tpd) 1990 2000 2005 2010 2015 2020 ROG 142 117 105 108 116 121 2. Existing Control Program ARB has adopted five regulations affe cting consumer products. The first regulation reduced ROG emissions from ant iperspirants and deodorants in 1989. This was followed in 1990 by the first phase of regulations for 16 other consumer product categories. The regulations have been amended several times including, Phase I in 1993, Phase II in 1996, Midterm Measures I in 1997, and Midterm Measures II in 2000,PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

CONSUMER PRODUCTS III-A-4 and contain a total of nearly 200 emission lim its affecting 82 categories of consumer products. In 1995, ARB adopted a separate regulation that included mass emission limits for 35 categories of aerosol coatings . The aerosol coatings regulation was recently amended to replace the mass limits with photochemical reactivity limits for 36 aerosol coating categories. Photochemical reactivity limits are designed to restrict the amount of ozone likely to be formed from reactions of the reactive organic compounds used in each aerosol coating product. On the other hand, mass emission standards limit the quantity of ROG emissions from a given product. Both methods are effective control strategies. As a result of these measures, em issions from regulated categories have been reduced 50 percent, and in total, statewide consumer product emissions will have been reduced by over 130 tpd ROG (37 percent reduction) in 2005, compared to uncontrolled levels with growth. This 130 tpd reduction from consumer products comes despite the fact that a significant portion of consumer product emissi ons is not easily available for reduction. Categories of consumer products compri sing approximately 100 tpd ROG have not yet been regulated. Of these emissions, approx imately 22 tpd are represented by very small categories, each emitting less than 0. 1 tpd, which makes setting cost-effective limits difficult. Multi-purpose solvents compri se 20 tpd of the 100 tpd total. Consumers purchase these products for the solvent effe ct; therefore, repl acing a hydrocarbon solvent with water or exempt solvents may not always be a viable option. Nevertheless, we are currently conducting a survey for thiscategory to determine if reductions in either mass or reactivity are feasible. Further, the remaining 58 tpd are comprised of other categories, such as r ubbing alcohol, which are difficult to regulate due to health or efficacy concerns. Another complicating factor is that emissions from all categories of consumer products, both regul ated and unregulated, are growing yearly because of California’s burgeoning population. ARB has attempted to provide manufacture rs with compliance flexibility in the regulations by incorporating market-based components such as the Innovative Products Exemption (IPE) provision ( 1990), Alternative Control Plan (ACP) (1994), and Hairspray Credit Program (1997). The I PE allows manufacturers to market products with a higher percentage of ROG than the regul ation limit as long as they can demonstrate that, due to some characteristic of the product fo rmulation, design, delivery system or other factor, the use of the product will result in less ROG emissions than a representative, complying product. The ACP employs the c oncept of emissions averaging to provide additional flexibility when formulating c onsumer products. The Hairspray Credit Program allows manufacturers to generate emission reduction credits by introducing low-ROG based hairspray prior to the effe ctive date of a regulatory limit or by formulating products with a ROG content lowe r than the regulatory limit. Manufacturers could then use credits to defer complianc e with other consumer products emission limits, so long as emission reduction obligations are met in the aggregate.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

CONSUMER PRODUCTS III-A-5 3. Proposed Strategies As part of the revised SIP for the S outh Coast, ARB would evaluate two measures to reduce the emissions associat ed with consumer products. The strategies ARB staff proposes to pursue are listed in Table III-A-3.
Table III-A-3 Proposed Strategies for Consumer Products Timeframe Strategies Action Implementation CONS-1 Set New Consumer Products Limits for 2006 2003 - 2004 2006 CONS-2 Set New Consumer Products Limits for 2008 – 2010 2006 - 2008 2008 - 2010PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

CONSUMER PRODUCTS III-A-6 a. CONS-1: Set New Consumer Products Limits for 2006
Time Frame: Adopt 2003-2004; Implement 2006 Responsible Agency: ARB Proposed Strategy: Adopt new consumer product category limits in 2003-2004 and implement these new limits in 2006. To adopt new limits for addressing emissionsgrowth from consumer products, staff plans to target previously unregulated categories or regulated categories that staff has not evaluated for further emissions reductionsduring the last five years. Additional reductions may be achieved through both mass-based and reactivity-based limits. Using survey data from the 2001 calendar y ear, staff will consider proposal of new mass-based or reactivity-based limits in t he 2003 to 2004 timeframe for implementation in 2006.
In order to ensure ARB reaches a c onsumer product emission reduction goal of at least five tpd ROG statewide by 2006 (about two tpd in the South Coast) to mitigate the projected emissions increase due to growth , staff proposes to evaluate solvents and many other regulated or unregulated categories. However, staff would pursue additional reductions beyond the target if they prove to be technologically and commercially feasible. As part of this effort, staff is proposing to evaluate the various unregulated solvent categories that may contain up to100 percent ROG. These product categories include multi-purpose removers, graffiti removers, electronic cleaners, adhesive removers, and other packaged solvents. Within the solvent categories, we intend to investigate the feasibility of using reactivity-based strategies to reduce the ozone forming potential of the products. However, we also propose to evaluate mass-based strategies, which may include reducing the ROG content of the products by reformulating with water or exempt solvents, using low vapor pressure ROG, or by replacing propellants with exempted hydrocarbons or compressed gases. Staff is conducting a detailed survey to obtain 2001 sales and formulation data to better understand the variety of products available, the basic functions of these products, and potential reformulation alternatives. ARB may also seek reductions from manyof the smaller regulated or currently unregulated categories of consumer products. For example, toilet/urinal care products, several categories of personal care products, such as nail polishes, certain hair styling aids, and other cleaning products that are not currently regula ted will be evaluated toPROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

CONSUMER PRODUCTS III-A-7 determine if it is feasible to establish ROG limits. Some other categories we may consider are special purpose adhesives, f ootwear care products, and other products that were not included in the 1997 Consumer and Commercial Products Survey.
Potential Emission Reductions: The potential emission reductions for this measure are 5 t pd ROG statewide by 2006, growing to 5.3 tpd ROG by 2010 and 6.1 tpd ROG by 2020. For the South Coast, the potential emission reduction s are 2.2 tpd ROG by 2006, growing to 2.3 tpd ROG by 2010 and 2.5 tpd ROG by 2020.

SIP Commitment for Measure CONS-1 South Coast 2003 SIP Commitment: ARB staff proposes to commit to bring this measure to the Board between 2003 and 2004. The measure as proposed to the B oard will, at a minimum, achieve 2.3 tpd of ROG reductions in the South Coast Air Basin in 2010. Commitments for Future SIPs: As other areas of the St ate develop attainment SIPs that require additional emission reductions to show progress and/or attainment, we will work with the appropriate local air districts to determine which State and/or federal measures are appropriate to include for federal approval.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

CONSUMER PRODUCTS III-A-8 b. CONS-2: Set New Consumer Products Limits For 2008 – 2010
Time Frame: Adopt 2006-2008; Implement 2008-2010 Responsible Agency: ARB Proposed Strategy: Adopt new consumer product category lim its in 2006 and 2008. Implement these new limits in 2008 and 2010. To adopt new limits for consumer products in 2006, ARB staff will need to update inventories detailing product ingredients and product sales. Staff plans to conduct a survey in 2004 for the 2003 calendar year. Survey categories would include those with limits effective by January 1, 2003, as well as previously unregulated categories. From data collected in the 2003 calend ar year survey, staff would consider adoption of new mass-based or reactivity-based limits in 2006, for implementation in 2008. To adopt new and/or lower limits for cons umer products in 2008, staff will need to further update inventories detailing product i ngredients and product sales. We plan another survey in 2006 for the 2005 calendar year. Categories would include products with limits effective between 2003 and 2005 and all aerosol coatings. Based on the survey results, ARB staff will evaluate both mass-based and reactivity-based control options for adoption of new limits in 2008, with implementation by 2010. There are several possible approaches t hat will be evaluated for reducing ROG from consumer products in the 2006-2010 timeframe. One possible regulatory approach would be to adopt mass-based limits based on reformulation. In addition, mass or reactivity-based limits may be set for new categories and for small categories that have grown significantly (in terms of product sales) over the last five to ten years. Reactivity limits would be set for those categories where mass-based limits may not be a feasible option. Some solvent categorie s, for example, are purchased by consumers for their solvent effect. A reactivity- based limit in these ca tegories would allow manufacturers to reformulateusing less reactive compounds that would maintain the product’s efficacy and result in a reduction of the formation of ozone. The feasibility of adopting a single limit for a product category could also be evaluated. For example, if technologically and commercially feasible, all products within a category, irrespective of product form, could meet the same limit w hether the products were dispensed from a pump spray, squeeze bottle, or aerosol can. Staff will also evaluate the technical and commercial feasibility of adopting general em ission limits to cover broad ranges of consumer products to keep up with industry changes to product lines. Another approach that could be evaluated is to limitthe use of hydrocarbon propellants. Lower limits may be set while still allowing the use of hydrocarbon propellants, such as in post-PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

CONSUMER PRODUCTS III-A-9 foaming products or by blending with exem pt propellants. S pecific exemptions contained in the regulation may be re-eval uated to see if they are still warranted.
Potential Emission Reductions: The potential emission reductions for th is measure are 20 to 35 tpd ROG statewide by 2010, growing to 23 to 40 tpd by 2020. For the Sout h Coast, the potential emissions reductions are 8.5 to 15 tpd ROG by 2010, growing to 9.7 to 17 tpd ROG by 2020.

SIP Commitment for Measure CONS-2 South Coast 2003 SIP Commitment: ARB staff proposes to commit to bri ng measures to the Board between 2006 and 2008. The measures as proposed to the B oard will, at a minimum, achieve between 8.5 tpd and 15 tpd of ROG reductions in the South Coast Air Basin in 2010. Commitments for Future SIPs: As other areas of the St ate develop attainment SIPs that require additional emission reductions to show progress and/or attainment, we will work with the appropriate local air districts to determine which State and/or federal measures are appropriate to include for federal approval.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY III-B-1 

## CHAPTER B Fueling and Vapor RecoveryPROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY III-B-2 CHAPTER B. FUELING AND VAPOR RECOVERY 1. Category Description ARB and districts share responsibility for controlling emissions from the storage and transfer of gasoline. ARB certifies prototype vapor recovery systems. District rules and State law require that only ARB-cert ified systems be used for gasoline storage, transfer, and refueling operations. Districts inspect and test the vapor recovery systems upon installation during the permit process and conduct regular inspections to check that systems are operating as ce rtified. ARB provides di stricts with these inspection procedures and test methods. ARB is also responsible for controlling ai r toxics that pose harm to public health. For this reason, air toxics from gasoline storage and transfer also fall under the State’s authority to control air toxic emissions. The storage and transfer of gasoline for vehicl e refueling is a significant source of ROG emissions in California. Vapor re covery systems are used to capture vapors during the transfer of gasoline between storage tanks and tanker trucks and during the refueling of vehicles at gasoline pumps. Storage tanks can either be sited above ground or underground. Transfers of gasoline for pleasure craft refueling can be a significant source of emissions, particularly during the summe r months when the potential for ozone formation is highest. Emissions can be releas ed when the operator transfers the nozzle from the vessel to the dispens er, tries to overfill or “top off” the vessel, or when the vessel “spits back” fuel from overfill. When working properly, the emission reduction benefits of these systems are significant. Unfortunately, in many case s, systems have not worked in the field to control emissions at the certified leve l, and consequently, significant emission reductions have been forgone. In recent years, ARB and the districts have taken many steps to improve the perform ance and reliability of vapor recovery systems, including ARB’s adoption of the Enhanced Vapor Recove ry (EVR) program in 2000. ARB staff believes there are additional opportunities toreduce emissions from gasoline storage, transfer, and vehicle refueling. Emissions from petroleum marketing have dropped significantly since 1980 as a result of the installation of vapor recove ry systems. In 2000, petroleum marketing operations still accounted for about 40 tpd of ROG emissions in the South Coast, but emissions are projected to drop as the enhanced vapor recovery program is implemented. Table III-B-1 presents baseline emissions projected for fueling and vapor recovery operations.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY III-B-3 Table III-B-1 Baseline Emissions for Fueling and Vapor Recovery Operations (South Coast, Summer, tpd)
2000 2005 2010 2015 2020 ROG 42 22 22 23 23 2. Existing Control Program Vapor recovery systems have been used in California to control ROG for over 20 years. State law enacted in 1975 required ARB to “adopt procedures for determining the compliance of any system designed for t he control of gasoline vapor emissions during gasoline marketing operations, includ ing storage and transfer operations, with performance standards, which are reasonable and necessary to achieve or maintain any applicable ambient air quality standard.” Since then, ARB has adopted the certification and test procedures to ensure vapor recovery systems meet minimum standards. Phase I Vapor Recovery As each gasoline transfer will lead to displaced vapors, vapor recovery is used throughout the gasoline marketing chain. Phas e I vapor recovery is applied to gasoline transfer operations involving cargo tank trucks. The first transfer occurs when the cargo tank is filled with product at the loading rack of a refinery terminal or a bulk plant. While the cargo tank is filled, gasoline vapor from the cargo tank is recovered and normally condensed back to liquid fuel. The vapor recove ry units at the terminal or bulk plant are certified under ARB procedures. There is al so an ARB certification procedure for cargo tanker trucks. ARB assists districts by conducting certification tests at terminals and bulk plants. Phase I vapor recovery also incl udes the transfer from t he cargo tank to the gasoline dispensing facility, or service stat ion. Phase I vapor recovery is required throughout California and in most other states. Phase II Vapor Recovery Phase II vapor recovery controls emissions resulting from gasoline transfer from the gasoline dispensing facility to vehicles. This is the vapor recovery equipment that many of us operate routinely when filling up our cars. The two main types of Phase II vapor recovery systems are balance and assist. The balance systems can be identified by the long bellows or boot on the nozzle. The end of the bellows must make a good seal when the nozzle is dispensing fuel into t he vehicle. This is important to ensure the vapor pushed out while filling the vehicle t ank is routed back through the nozzle to thePROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY III-B-4 underground vapor space. Assist system nozzles, in contrast, are often “bootless.” The vapors are collected through a series of holes in the spout which vacuum up the vapors during a refueling. This requires use of an active vapor pump. Some assist systems also have processors to manage the underground vapor space pressure. Two currently certified systems operate with v apor incinerators on or near the vent pipe in order to reduce emissions.
Benzene Airborne Toxi c Control Measure In 1987, ARB adopted an airborne toxic c ontrol measure (ATCM) for benzene. This measure requires use of Phase II v apor recovery at all gasoline dispensing facilities in California, except those with very low throughput. Previous to implementation of the ATCM, P hase II vapor recovery was required only if specified in a district rule as an ROG control measure. Usually, those districts were in nonattainment of the ambient ozone standard. Thus, the ATCM resulted in the expansion of Phase II vapor recovery in all districts within Ca lifornia and reduced exposure to benzene while fueling vehicles. On-Board Refueling Vapor Recovery In 1994, U.S. EPA set vehicle-based or onboard refueling vapor recovery (ORVR) standards to control refueling emi ssions as required under the federal Clean Air Act. In 1995, ARB adopted the federal ORVR regulations, with minor modifications, to promote a consistent vehicle design for a ll 50 states and reduce the testing burden for vehicle manufacturers. ORVR works by rout ing refueling vapors to a carbon canister on the vehicle. The routing of the vapor to the canister requires a few hardware changes to the vehicle. The fuel tank vent line mustbe rerouted from the vehicle fill-pipe to the canister, and a seal must be established atthe fill-pipe to ensure the vapor is not emitted at the fill-pipe outlet. Vehicle manufacturers use different designs to meet these requirements, but there are two basic types of fill-pipe s eals. The most common is a “liquid” seal, which is formed by the gasoli ne itself as it enters the fill-pipe, which has been reduced in diameter to ensure a good seal. The other type is a “mechanical” seal, which is similar to a gasket that seals closely to the nozzle. After U.S. EPA adopted the ORVR requi rements, concerns were raised regarding compatibility of Phase II vapor re covery and ORVR. The main concern was that since vapor was not returned to the underground storage tank when fueling an ORVR vehicle, air would be drawn into the underground vapor space as liquid was dispensed. Gasoline evaporation would l ead to vapor growth and possible excess emissions.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY III-B-5 Enhanced Vapor Recovery In 2000, ARB adopted enhanced vapor recove ry (EVR) requirements to improve equipment reliability and achieve additional emission reductions. New requirements include more stringent standards and new equipm ent specifications for both Phase I and Phase II vapor recovery systems. The new standards will reduce spillage and gasoline evaporation from gasoline nozzles, make vapor recovery systems compatible with the ORVR systems on motor vehicles , and require computerized monitoring equipment for vapor recovery systems to self-diagnose and alert operators when repairs are needed. These requirements are being phased- in over the next several years. In addition to these regulatory changes, ARB is wo rking with districts to improve inspection and compliance test procedures to aid in the enforcement of vapor recovery regulations. 3. Proposed Strategies ARB would evaluate a number of measures to reduce the evaporative emissions associated with fuel storage, transport, and vehi cle refueling. The strategies ARB staff proposes to pursue are listed in Table III-B- 2. ARB is also proposing a measure to control evaporative emissions from cargo t anker trucks, as described in Chapter B of Section II.
Table III-B-2 Proposed Strategies for Fueling and Vapor Recovery Timeframe Strategies Action Implementation FVR-1 Increase Recovery of Fuel Vapors from Aboveground Storage Tanks 2003 2007 FVR-2 Recover Fuel Vapors from Gasoline Dispensing at Marinas 2006 - 2009 2006 - 2010 FVR-3 Reduce Fuel Permeation Through Gasoline Dispenser Hoses 2004 2007PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY III-B-6 a. FVR-1: Increase Recovery of Fuel Vapors from Aboveground Storage Tanks
Time Frame: Adopt 2003; Implement 2007 Responsible Agency: ARB

Table III-B-3 Baseline Emissions for Aboveground Storage Tanks 1 (South Coast, Summer, tpd)
2000 2005 2010 2015 2020 ROG 0.1 0.1 0.1 0.2 0.2

Proposed Strategy: Regulations controlling the transfer and marketing of fuel in California were initiated in the 1970s in two phases. Phas e I regulates gasoline transfer from cargo tank to dispensing facility storage tank, and Phase II regulates gasoline transfer from the dispensing facility to the motor vehicle. EVR for facilities with underground storage tanks was approved by the Board in March 2000 and is being implemented. The purpose of EVR is to seek additional emission reductions by increasing the stringency of performance standards and specifications and to improve the perfo rmance and reliability of vapor recovery equipment. The approved EVR regulations do not apply to vapor recovery systems used on aboveground storage tanks (ASTs). Therefore, the Board is developing a new EVR rulemaking package specific to vapor recovery systems for this category. Vapor recovery systems for aboveground tanks are currently certified by ARB with an allowed 90 percent control efficiency versus 95 percent proposed for EVR. This regulation would address the increasing number of aboveground storage tank dispensing systems used at private and public facilities and some retail sites. There has been an increasing demand for ASTs for fleet operators in both the public and private non-retail sectors, such as em ergency response operations, public works, school districts, marinas, car rental agenc ies, and car dealerships. This demand has been due to increased compliance costs a ssociated with underground storage tank

1 The current inventory does not differentiate between UST and AST dispensing fa cility emissions. Therefore, the baseline inventory is estimated. Data on AST emissions would be collected over the next year.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY III-B-7 operations. ARB staff is t herefore proposing to apply as many of the current EVR standards as feasible to ASTs, including an increase in overall system efficiency from 90 to 95 percent vapor recovery. If ARB’s data collection and testing determine that this measure is technically feasible, staff woul d schedule this for ARB consideration as a rule in 2003.
Potential Emission Reductions: Assuming that one percent of the state wide gasoline throughput is dispensed via ASTs and that these tanks are equipped with vapor recovery systems operating at 90 percent efficiency, then the current emissi ons are about 0.3 tpd st atewide (about 0.1 tpd in the South Coast). U pdated inventories will be used to refine emission estimates. By reducing Phase I and Phase II transfer and vent emissions, this strategy would reduce emissions by about 0.2 tpd statewide (0 -0.1 tpd in the South Coast). However, fugitive emissions for aboveground storage tan ks are expected to be higher than for underground storage tanks and amenable to contro l. Therefore, reductions could be even greater. The proposed regulation increas es the certification evaluation period, which will more effectively ensure that vapor recovery systems operate properly.

SIP Commitment for Measure FVR-1 South Coast 2003 SIP Commitment: ARB staff proposes to commit to bring th is measure to the Board in 2003. The measure as proposed to the Board will, at a minimum, achieve between 0 and 0.1 tpd of ROG reductions in the South Coast Air Basin in 2010. Commitments for Future SIPs: As other areas of the St ate develop attainment SIPs that require additional emission reductions to show progress and/or attainment, we will work with the appropriate local air districts to determine which State and/or federal measures are appropriate to include for federal approval.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY III-B-8 b. FVR-2: Recover Fuel Vapors from Gasoline Dispensing at Marinas
Time Frame: Adopt 2006-2009; Implement 2006-2010 Responsible Agency: ARB Table III-B-4 Baseline Emissions for Marinas: Vapor Recovery 2 (South Coast, Summer, tpd)
2000 2005 2010 2015 2020 ROG 0.1 0.1 0.1 0.1 0.1

Proposed Strategy: Unlike vehicle fueling emissions contro lled by vapor recovery systems, vapors released during marina fueling are uncontro lled. As marina gasoline is dispensed primarily during the summer months, these ROG emissions are contributing to smog levels during the ozone season. The South Coast District considered vapor recovery controls at marinas in the 1980s, but did not pursue the rule due to te chnical difficulties and cost. Existing certified vapor recovery systems cannot be easily applied at marinas as the storage tank is usually located uphill and quite a di stance away from the gasoline dispenser. Under this strategy, ARB staff proposes to determine if new technology may be feasible and cost-effective in reducing ROG emissions from gasoline dispensing operations at marinas. The State Water Resources Control Board (SWRCB) is also considering new requirements for marinas and has already distributed a marina survey that includes requests for information pertinent toestimating air emissions. Survey data for 80 percent of the marinas statewide indicate that approx imately 0.10 percent of the total statewide throughput, or about 14 m illion gallons of gasoline annually, are dispensed at marina fueling facilities.

2 ARB’s current official inventory assumes that gasoline dispensed for off-road pur poses is uncontrolled and represents two perce nt of statewide throughput, but does not identify the emissions associ ated with marinas specifically. This table contains prelimi nary estimates of emissions at marinas, assuming negligible growth in gas consumption at marinas in the next 20 years.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY III-B-9 Potential Emission Reductions: The potential emission reductions associat ed with this proposal are expected to be between 0.1 to 0.2 tpd statewide (0-0.1 tpd in the South Coast) based on the following assumptions: 0.10 percent of the total statewide throughput is dispensed at marinas. If 80 percent control of thes e emissions were achieved, the emission reduction would be about 0.13 tpd.

SIP Commitment for Measure FVR-2 South Coast 2003 SIP Commitment: ARB staff proposes to commit to bring this measure to the Board between 2006 and 2009. The measures as proposed to t he Board will, at a minimum, achieve between 0 and 0.1 tpd of ROG reductions in the South Coast Air Basin in 2010. Commitments for Future SIPs: As other areas of the St ate develop attainment SIPs that require additional emission reductions to show progress and/or attainment, we will work with the appropriate local air districts to determine which State and/or federal measures are appropriate to include for federal approval.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY III-B-10 c. FVR-3: Reduce Fuel Permeati on Through Gasoline Dispenser Hoses
Time Frame: Adopt 2004; Implement 2007 Responsible Agency: ARB
Table III-B-5 Baseline Emissions for Gasoline Dispenser Hose Permeation (Statewide, Annual Average, tpd)
2000 2005 2010 2015 2020 ROG 3 NQ NQ NQ NQ Note: Emissions have only been estimated for 2000. Future year emissions will be estimated during measure development. Proposed Strategy: Emission controls for vapors generated from motor vehicle fueling were initiated in the 1970s. ARB's EVR program, adopted in March 2000, constitutes a major overhaul of the vapor recovery program with numerous new standards and specifications aimed at increasing durability and reliability of vapor recovery equipment. However, permeation emissions from dispens er hoses were not targeted in the EVR program. Gasoline dispensing hoses used at ma rinas have stricter standards for hose permeability due to water quality concerns. The goal of FVR-3 is to determine the applicability of applying the st ricter permeability standard for marine gasoline hoses to dispenser hoses at service stations. Spec ifically, this measure would review current permeation requirements for gasoline dispense r hoses and, if feasible, establish lower permeation requirements.
Potential Emission Reductions: Emission reductions of up to 1.7 tpd ROG statewide (0-0.7 tpd ROG in the South Coast) may be achievable if the lower pe rmeation limit associated with marine hoses can be applied to gasoline dispenser hoses at service stations.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY III-B-11 SIP Commitment for Measure FVR-3 South Coast 2003 SIP Commitment: ARB staff proposes to commit to bring th is measure to the Board in 2004. The measure as proposed to the Board will, at a minimum, achieve between 0 and 0.7 tpd of ROG reductions in the South Coast Air Basin in 2010. Commitments for Future SIPs: As other areas of the St ate develop attainment SIPs that require additional emission reductions to show progress and/or attainment, we will work with the appropriate local air districts to determine which State and/or federal measures are appropriate to include for federal approval.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

PESTICIDES III-C-1 

## CHAPTER C

PesticidesPROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

PESTICIDES III-C-2 CHAPTER C. PESTICIDES 1. Category Description Pesticides are industrial chemicals produced specifically for their toxicity to a target pest. Any living organism that caus es damage or economic loss or transmits or produces disease may be a target pest. Pests can be animals (e.g., insects or mice), unwanted plants (e.g., weeds), or microorgani sms (e.g., plant diseases and viruses). Many pesticide products contain volatile organic compounds (VOC), either as an active ingredient or other ingredient. T he chemical formulation and application method for pesticides affect the amount of VOC emitted. In the South Coast, pesticides are used primarily to treat structures, as we ll as agricultural products. Integrated pest management practices, other voluntary actions, and regulatory action on methyl bromide in response to health and environment al concerns have all contributed to a significant reduction in reactive emissions from pesticides in the South Coast since 1990, as shown in Table III-C-1. Emissi ons from pesticides in other regions of California may vary significant ly from the trend shown below. Table III-C-1 Baseline Emissions for Pesticides (South Coast, Annual Average, tpd)
1990 1995 2000 2005 2010 2015 2020 ROG 8.2 3.0 2.8 2.0 1.7 1.7 1.7 2. Existing Control Program The Department of Pesticide Regulat ion (DPR) is the California agency responsible for regulating pesticides for co mmercial/structural and agricultural uses. DPR can establish regulations to reduce both toxic and criter ia pollutant emissions from pesticides using the best practicable control techniques available. Control measures may be implemented by several methods, in cluding regulatory actions, local permit conditions, and product substitution or cancellation. Pesticides are also regulated under federal law. Congress, under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), gave the U.S. EPA authority to provide federal control of pesticide distributi on, sale, and use. All pesticides used in the United States must be regist ered (licensed) by the U.S. EPA. Registration helps to ensure that pesticides will be properly labe led and will not cause unreasonable harm to the environment.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

PESTICIDES III-C-3 Pesticides available for sale to househo ld and institutional consumers have been regulated under ARB’s consumer product aut hority since 1995. Currently, ARB has adopted VOC limits for insecticide products targeted for crawling insects, flying insects, fleas and ticks, and wasps and hornets. ARB al so regulates other pesticide products, such as non-selective herbicides and insect repellants. By 2005, when the final tier of adopted VOC limits for consumer pesticides bec omes effective, ARB will have obtained VOC reductions of approximately 60 to 70 percent from the regulated household pesticide categories. As part of the 1994 SIP, DPR commi tted to reduce VOC emissions from pesticides in certain federal ozone nonattain ment areas of the State. The reductions were to be gradually achieved through a shi ft in the application practices and types of pesticides used. In the South Coast, VOC emissions from pesticide use have declined dramatically; as a result, we propose to reta in the existing SIP commitment. As part of the SIP development process for other areas, ARB and DPR will work with each region to identify any additional strategies that are needed based on the nat ure of the problems in that particular region. 3. Proposed Strategy a. PEST-1: Implement Existing Pesticide Strategy
Time Frame: Implement 1996-2010 Responsible Agency: DPR Proposed Strategy: DPR has broad authorities under State law to control the use of pesticides for the purposes of protecting human health and t he environment, including improving air quality (Food & Agriculture Code §§14102, also §§12781, 1282 4-12828, 12976-12977, 12991-12995, 12996-12999, 13101 and 13102.) As described in the 1994 SIP and U.S. EPA’s notice approving that plan, DPR committed to reduce VOC emissions from pes ticides through voluntary measures, with a regulatory backstop. Specifically, DPR committed to adopt and submit to U.S. EPA by June 15, 1997, any regulations necessary toreduce VOC emissions from agricultural and commercial structural pesticides by s pecific percentages of the 1990 base year emissions, by specific years, and in specific nonattainment areas. For the South Coast, the commitment is to reduce VOC emissions from pesticides to a level 20 percent below 1990 base year emissions by the attainment year.PROPOSED 2003 STATE AND FEDERA L STRATEGY FOR CALIFORNIA SIP SECTION III – CONSUMER PRODUCTS , VAPOR RECOVERY, AND PESTICIDES

PESTICIDES III-C-4 Potential Emission Reductions for 2003 South Coast SIP: Based on today’s estimate of 1990 South Coast Air Basin emissions at 8.2 tpd VOC, the target level is 6. 6 tpd VOC emissions remaining in 2010. Current emissions are already below the target level and 2010 emi ssions are projected at1.7 tpd. These projections are reflected in the baseli ne inventory for the 2003 South Coast SIP. 4. Long-Term Advanced Technologies Strategies
ARB will seek to achieve additional ROG reductions from pesticides, beyond those identified in the existing SIP commitm ent, for areas with a demonstrated regional need for such benefits. As part of the development of the San Joaquin Valley Ozone SIP, DPR is taking the lead in working with interested stakeholders to determine how pesticide emissions can be further reduced by the attainment deadline.