### RE: Stage II Decertification Shepard, Dave to

: Glenn Passavant, Jones, Christian
Cc : Lynn Dail, "lrector@nescaum.org"



### Glenn, As a first step I’ll answer the questions you posed in your email as best as I can. It sounds like these issues may be the topic of a conference call with NESCAUM. If you’d like to schedule a separate phone call just let me know.
(1) how many GDFs in VT have Stage II.? I realize that it only applies to stations exceeding 400,000 gal/ yr. 

### In Vermont approximately 394 GDFs were equipped with Stage II before we started phasing out the program. The number that currentl y have Stage II is probabl y around 340. (2) for a ty

pical GDF, say

1.2 1.4 million gal/yr what are the estimated costs for dec ommissioning Stage II ? We haven’t made an attempt to estimate the cost of decommissioning Stage II and so far I haven’t seen an y invoices or other information for any of the GDFs that have been decommissioned so far to provide any cost figures. (3) befo re decommissioning what were the average annual inspection,testing, and hardware maintenance costs for this ty pical station due to Stage II ? We don’t have a good estimate of the annual cost of compliance as we have only anecdotal knowledge of the hardware maintenance costs for GDFs. The Stage II regulation was amended in 2001 to require GDFs to perform specified maintenance of their tank top fittings annuall y (including replacement of the vapor adaptors) or to perform an annual pressure decay test. At that time we estimated the cost of the pressure decay test to range from $350 to $800 and the cost to replace vapor adaptors at $100 per adaptor (typi cally a GDF has between one and three adaptors). There wasn’t an estimate of the labor costs. In addition to the annual maintenance/pressure decay test requirement the Vermont Stage II regulations require Stage II testing every

five ye ars. The required tests include a pressure decay test for all GDFs equipped

### with Stage II and either an air to liquid ratio test ( for vacuum
- assist equipped GDFs) or a

dy namic backpressure test (balance equipped GDFs). (4) Is it correct to assume that essentially all GDFs in VT are vacuum assist. In Vermont approximately 90% of the GDFs with Stage II are/were equipped with vacuum

- assist systems.
Dave Shepard Vermont Department of Environmental Conservation Air Pollution Control Division 103 South Main Street Wa terbury, VT 05671
- 0402 Phone: (802) 241
- 3857 Fax: (802) 241
- 2590

From: Passavant.Glenn@epamail.epa.gov [mailto:Passavant.Glenn@epamail.epa.gov] Sent: Tuesday, April 26, 2011 12:38 PM To: Jones, Christian; Shepard, Dave Cc: Dail.Lynn@epamail.epa.gov; lrector@nescaum.org Subject: Stage II Decertification

Hi Chris and Dave I am Glenn Passavant of EPA's Office of Transportation and Air Quality. I have worked the ORVR/Stage II control areas for EPA for over 20 years. As you may be aware, EPA is now developing a rule to relieve the states of their legal obligation to ma int ain Stage II controls. Wehope to propose that rule this Spring. As we have been developing the rule, a few questions have come up which I hope you might be able to help us answer since VT has already acted to remove Stage II and you have a fairly rigor ous process and checklist. I will summarize below and perhaps we can have a follow
- up teleconference. (1) how many GDFs in VT have Stage II.? I realize that it only applies to stations exceeding 400,000 gal/ yr.(2) for a typical GDF, say 1.2 1.4 mil lion gal/y r what are the estimated costs for decommissioning Stage

II? (3) before decommissioning what were the average annual inspection,testing, and hardware maintenance costs for this typical station due to Stage II? (4) Is it correct to assume tha t essentially all GDFs in VT are vacuum assist. Thank you for your help. GLENN W . PASSAVANT CENTER DIRECTOR ASSESSMENT & STANDARDS DIVISION OFFICE OF TRANSPORTATION AND AIR QUALIT Y US EPA ANN ARBOR, MI 734
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- 4408