p.1 

OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

152) IV-E-25 

Docket Number: 

A-87-11 

Printed 4/22/2008 2:42:55 PM Sheet 152 of 242 
P.2 

T**f " 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

FEB 8 I988 

MEMORANDUM 

SUBJECT: Briefing to Department of Commerce 

FROM: 

TO: 

THRU: 

John F. Anderson, Senior Project Manager 

Standards Development and Support Branch 

Docket A-87-11 

Chester J. France, Chief 

Standards Development a 

On January 28, 1988 a briefing was presented to Department 

of Commerce staff reviewing the onboard refueling control 

proposal. A list of attendees is attached. Also attached is a 

copy of the briefing materials used. During the course of the 

presentation we were able to resolve a number of concerns which 

Department of Commerce had concerning our proposal. 

Attachments 

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P.3 

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P.4 

Overview of EPA Proposal for 

Refueling Emission Control 

January 1988 
P.5 

Overview 

Description of the Problem 

Description of Technologies Available 

Analysis of Technologies 

Conclusions 
P.6 

Description of the Problem 

Automotive refueling emissions: 

Vapor displacement from vehicle tank (90%) 

- Spillage (5%) 

Vapor displacement from underground tank vent (5%) 

Uncontrolled emission levels are - 6.5 g/gallon of 

dispensed fuel 

This is equivalent to about 0,25 g/mile 

Represents - 21 of total VOC emission inventory (450,000 

tons/year) 

Two reasons for concern with vehicle refueling emissions: 

1) Ozone precursors 

2) Healths effects of emissions 
P.7 

' Ti 

The Ozone Problem 

Ozone air quality continues to be a substantial problem in 

many parts of the country 

76 major metropolitan areas exceeded the National Ambient 

Air Quality Standard during 1983-1985 (Figure 1) 

Total population of these areas in excess of 77 million 

EPA's preliminary assessment indicates that many more 

areas failed to meet the ozone standard by the December 

1987 deadline 

Substantial deterioration in air quality projected by late 

1990s 

VOC reductions of 10 to 70 percent are needed to reach 

attainment with the standard (Figure 2) 
P.8 
Figur e 2 

APPROXIMATE PERCENT REDUCTION NECESSARY FOR 

ATTAINMENT OF OZONE NAAQS 

2 O 

o 

3 

Q 

Ui 

a 

u 

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80 

70 

60 

50 

40 

30 

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MEDIUM 

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P.10 

ADDRESSING THE OZONE PROBLEM 

The Refueling and Volatility controls represent two 

national programs that will provide VOC reductions of 10 

percent 

This 10 percent reduction combined with the 20 percent 

reduction expected from current Federal Motor Vehicle 

Control Programs will provide enough of the needed 

reductions for some areas to reach the ozone standard (see 

Figure 2) 

Many other areas will need significant additional 

reductions 

The States have a major responsibility in implementing 

local control measures to address the ozone problem 
P.11 

WHY CONTROL REFUELING EMISSIONS? 

Provides a two percent VOC reduction 

Few remaining VOC control strategies can provide more 

reduction 

Reduction can be achieved cost effectively when compared 

to other available control alternatives 

Reduces exposure to toxic vapors during refuelling -

benzene is a known human carcinogen and gasoline vapors in 

general are a concern 

Our annual incident reduction estimates for controlling 

refueling emissions are 4 with just benzene, 14 if benzene 

and C6 above, and 42 if benzene and all gas vapors 
P.12 

Description of Technologies 

• Stage II Controls 

Onboard Controls 
FIGURE 2 

STAGE II VAPOR RECOVERY BALANCE SYSTEM 

METER 

GASOLINE FILL LINE 

V 

run* 

GASOLINE STORAGE TANK 

Tl 
Typical Current Evaporative System 

PRESSURE/VACUUM 

RELIEF CAP 

EXTERNAL VENT LINE 

• \ 

FLOAT/ROLLOVER 

VALVE WITH .05" 

LIMITING ORFICE 

/ 

3/8" DIA. 

8' LONG 

^ 

14 GALLON FUEL TANK 

PURGE VALVE 

1 LITER 

CARBON 

CANISTER 

TO PURGE 

INDUCTION 

POINT 
Onboard Modifications 

REMOVE 

EXTERNAL 

VENT LINE 

/ 

SHORTEN 

VAPOR LINE 

MODIFIED 

3 LITER 

CARBON 

CANISTER 
Onboard Plus Evaporative System 

PRESSURE/VACUUM 

RELIEF CAP 

REMOVE 

EXTERNAL 

VENT LINE 

SHORTEN 

VAPOR LINE 

MODIFIED 

FLOAT/ROLLOVER 

VALVE WITH .05" 

LIMITING ORFICE 

I 

14 GALLON FUEL TANK 

^ 

PURGE VALVE 

TO PURGE 

INDUCTION 

POINT 

3 LITER 

CARBON 

CANISTER 

TJ 
P.17 

Implementation Issues 

Onboard 

• 49 - state or nationwide strategy 

• No exemptions 

• 2 to 3 years of manufacturers' leadtime 

• Phased in as fleet turnover occurs - 501 in 5 years 

Stage II 

• Nationwide or non-attainment areas only strategy 

• Federally mandated exemptions in Clean Air Act of 10,000 gpm 

majors/50,000 gpm independents. States could impose less 

generous exemption levels 

• Minimal upfront leadtime 

• Installed in 3 to 7 years 
.... . ., J..... . ..^ .. 

In-Use Effectiveness 

System 

• Theoretical* 

(which they are 

able to control) 

• In-Use 

(including tampering 

and maintenance) 

• Actual Control Achieved 

(including exemptions) 

Control Efficiency 

Stage II 

95% 

62-86%** 

48-66% 

Onboard 

98% 

93% 

83% 

* Stage II controls Displacement and Breathing Losses 

Onboard controls Displacement Losses 

** Stage II range is a result of the implementation period 

(3 or 7 years) and maintenance 
F,gure 4. PERCENT VOC EMISSION REDUCTION 

100% 

90% -

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fr 

a 

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UJ 

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a> 

c 

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3 HV 

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80% 

70% 

• 

60% 

50% 

40% 

30% 

20% 

10% 

0% 

1985 

For 61 Nonattainment Areas 

Onboard 

83% 

Stage II (Ann. Enf.. Low Dif.) 

T—i—i—i— r 

66% 

Stage II (Min. Enf.. High Dif.) 

48% 

"i—r—i—i—i—i—i—i—r ]—i—i—i—i—i—i—i—i—i—|—i—i—i—i—i—i—i—i—i—p -i—i—i—i—i—i—r 

1990 1995 2000 2005 2010 

Beginning of Year 

T l 

CO 
Risk Reduction for Refueling Controls 

Baseline 

Stage II Nationwide 

Onboard 

Average Annual Reduction 

GV 

60 

23-33 

38 

Stage II Non-Attainment 10-15 

'\ 

15 

5-8 

10 

2-4 

Bz 

7 

3-4 

. 

1 
P.21 

Average Stage II Cost for Existing Stations 

Total Capital Cost 

Annual Costs 

Fuel Recovery Credit 

Net Annual Cost 

Averaqe 

Service Station Throughput (qal/month) 

5,000 

5,700 

1,460 

130 

1,330 

Onboard System 

35,000 185,000 

12,200 23,200 

3,350 7,300 

880 4,670 

2,470 2,630 

Cost Per Vehicle 

(incremental to evaporative controls) 

First Price 

Recovery Credit 

LDV 

$ 17 

4 

LDT HDGV 

$ 23 $ 31 

6 15 

Lifetime Cost $1 3 $ 17 $ 16 
P.22 

'. 

Strategy 

Stage II 

Onboard 

Strategy 

Stage II NA 

Onboard 

* Includes 

cost 

Cost Effectiveness 

Nationwide 

Annual VOC 

Reduction 

(1000 Mq/Yr 

190-270 

290 

Program 

Annualized 

Cost 

(fl/Yr) 

190-220 

200 

Non-Attainment Program 

Annual VOC 

Reduction 

(1000 Mq/Yr 

66-100 

110 

approximately \H 

Annualized 

Cost 

(flM/Yr) 

58-92 

(195-295)* 

180 

per refueling 

Cost 

Effectiveness 

($/Mg) 

860-1120 

850 

Cost 

Effectiveness 

($/«q) 

850-1100 

(2700-3600)* 

2200 

event inconvenience 
P.23 

Onboard Incremental Cost Effectiveness 

$/Mq 

61 Areas 

NA area VOC reduction only 2200 

In NA areas, if benzene incidence 1900 

reductions are valued at $7,5 MM 

In NA areas, if $250/Mg benefit 1500 

for AA reduction and benzene 

incidence reduction is valued at 

$7,5 1 

In NA areas, if $250/Mg benefit 850 

for AA reductions and benzene and >C 

6 

incidence reductions are 

valued at $7,5 1 

In NA areas, if $250/Mg benefit for NEG, 

AA reductions, and all incidence 

reductions are valued at $7.5 MM 
Other Aspects of Comparison 

Consumer Reaction 

ONBOARD: Consumer should see no difference in the 

refueling operation 

STAGE II: The vapor recovery nozzles are larger and 

more difficult to operate, Problems in filling 

non-vehicle related tanks 

Distribution of Costs 

ONBOARD: The vehicle purchaser will bear the 

onboard cost of about $19 per vehicle 

STAGE II: The service station owner will bear the 

average vapor recovery system cost of about 

$11,500, Many small businesses 

Maintenance/Enforcement 

Onboard: Onboard controls should be maintenance-free 

and not dependent on enforcement 

Stage II: The efficiency of Stage II controls is 

dependent on routine maintenance and enforcement 
Safety 

Onboard: Some concern that adding an onboard system could 

create or enhance safety hazards of motor vehicles 

Stage II: Safety not yet evaluated, Similar concerns 

likely 

EPA studying safety issues 

Comparative risk assessment for onboard hardware 

Service station risk assessment 

Analysis of NHTSA recall data 

EPA will not adopt a refueling requirement unless it is 

convinced that it can be done without increasing safety 

risk 
P.26 

Key Safety Questions 

How do we assess the increase in safety risk (if any) that 

can be expected to result from the installation of onboard 

refueling control hardware? 

How do these risks compare in general with other safety 

risks and in particular with other fuel system changes 

(such as fuel injection)? 

What safety engineering solutions are available to 

eliminate or minimize these risks? 

How much leadtime is necessary to provide for necessary 

safety engineering? 

How do we assess the benefit of eliminating existing 

safety risks which might occur in conjunction with onboard 

installation (e.g., excess canister capacity, rear to side 

fill, exposed vent lines)? 

How do we evaluate the benefits of the potential reduction 

in service station safety risks (from reduced spillage and 

containment of vapors)? 

What safety benefits can we expect from the volatility 

rule? 
Conclusions 

Refueling emission controls (onboard or Stage II) are 

necessary for ozone attainment 

Both onboard and Stage II are technologically feasible and 

cost effective 

Each approach has merits in different key parameters: 

Geographic coverage 

Implementation Rate 

In-Use Effectiveness 

Control Achieved 

Distribution of Costs 

Consumer Reaction 

Onboard controls are more favorable when all is considered