ATTACHMENT D-5 

Emission Reduction Calculations for 

Portable Fuel Containers 

R.C.S .A. Section 22a-174-43 

Background 

New R.C .S .A. Section 22a-174-43 requires portable fuel containers (PFC) and spouts 

sold on or after May 1, 2004 to meet specified permeation and fuel flow rates and to have 

automatic shut-offs to prevent tank overflows during refueling. The regulation includes a 

pass through provision allowing units manufactured prior to May 1, 2004 to be sold 

through May 1, 2005 . In addition, the regulation specifies labeling requirements and test 

procedures to be used by manufacturers to demonstrate product compliance. 

Connecticut's regulation has requirements equivalent to those specified in the model rule 

developed by the Ozone Transport Commission (OTC), as contained and described in 

Connecticut's State Implementation Plan (SIP) revision: Update to the Ozone Attainment 

Demonstration for the Southwest Connecticut Severe Ozone Nonattainment Area dated 

October 15, 2001 .1 Emission reduction calculations for Connecticut were determined 

based on the methods used by the OTC and are summarized below. 

Emission Calculations 

OTC's methodology for determining volatile organic compound (VOC) emissions from 

PFC is based on testing results and calculation methods developed by the California Air 

Resources Board (CARB),2 as modified to include state-specific data for the Ozone 

Transport Region. The Department's calculations account for implementation of the rule 

in Connecticut in May 2004 (versus January 2003 for the OTC Model Rule). In addition, 

Connecticut's emission calculations substitute updated 2007 projections of population 

and occupied housing units for Connecticut, developed by extrapolating U.S . Census 

Bureau data from the period 2000 through 2003 . Finally, the Department's calculations 

correct typographical errors found in OTC's spreadsheet formulas related to the 

determination of transport and permeation emissions from commercial operations . 

Complete spreadsheet calculations for PFC emissions in Connecticut can be accessed at 

the internet link referenced in the cover letter for this package. Summaries of those 

calculations are provided below. 

The following sections present summaries of uncontrolled and controlled emissions in 

2007 from portable fuel containers, a quantification of emission reductions due to 

' A general description of OTC's model rule is provided in Section 4.4 of Attachment 2 to that SIP 

revision. The OTC model rule and associated emission reduction calculations can be found in Enclosures 

D and C, respectively, of the same SIP revision . Applicable OTC calculation methods have been 

incorporated into CTDEP's emission reduction estimates presented above. The complete SIP document 

can be accessed on the internet at : h-ptt ://www.dep .state .ct.us/air2/siprac/2001/sup2.htm . 

See Appendix A to Enclosure C of the SIP revision mentioned in the above footnote . 

Alternatively, see CARB's Mail-Out MSC 99-25. The Department's emission estimates were developed 

using these CARB formulas. 
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R.C.S.A. section 22a-174-43 and a brief discussion addressing comments made by EPA 

Region 1 regarding emission inventory issues . 

2007 Uncontrolled Emissions 

Uncontrolled emissions of VOC from PFC can be attributed to five different components : 

permeation, diurnal, transport-spillage, refueling-spillage and vapor displacement. 

Emissions occur from cans used in residential and commercial applications . The 

Department addressed each component as follows: 

" Permeation emissions are produced after fuel has been stored long enough in a 

can for fuel molecules to infiltrate and saturate the can material . CARB testing 

determined that average daily permeation rates are 1 .57 grams per gallon per day 

(g/gal-day) for plastic cans and 0 .06 g/gal-day for metal cans. 

" Diurnal emissions result when stored fuel vapors escape from any opening in a 

PFC due to the daily cycle of ambient temperature change. CARB testing 

determined that diurnal emissions 1 .38 g/gal-day from closed plastic cans and 

0.44 g/gal-day for metal cans . For open plastic or metal cans, the CARB emission 

factor is 21 .8 g/day. Note that all these diurnal factors have been adjusted for 

permeation emissions. 

" Transport-spillage emissions result from fuel spills occur when PFCs are in 

transit. CARB emissions factors range from 23 grams per gas can refill at the 

pump (g/refill) for closed containers to 32 .5 g/refill for open containers. CARB 

surveys indicate that residential PFCs are refilled at the pump 6 .4 times per year. 

Surveys indicate commercial lawn-and-garden PFCs are refilled 351 times per 

year, while commercial PFCs not used for lawn-and-garden operations are refilled 

43.8 times per year. 

" Refuel-spillage emissions result from spillage while transferring fuel from a PFC 

to an equipment fuel tank. CARB uses an EPA emission factor of 17 grams per 

refill for refuel-spillage emissions. 

" Vapor displacement emissions result when vapor from the equipment fuel tank is 

displaced by fuel dispensed from a PFC. CARB's emission factor for vapor 

displacement emissions is 4.52 g/gal. 

Uncontrolled 2007 emission estimates for Connecticut are summarized by county in 

Table 1 . The resulting statewide uncontrolled emission estimate from PFCs in 2007 is 

18.3 tons/day. 

2007 Controlled Emissions with R.C.S.A. Section 22a-174-43 

Portable fuel containers and spouts sold on or after May 1, 2004 must comply with the 

new PFC regulation, R.C.S .A. section 22a-174-43. The regulation includes a provision 

allowing PFCs manufactured prior to that date to be sold in Connecticut until May 1, 

2005 . CARB's testing indicates that compliant PFCs will emit, on average, 73% less 

VOC emissions than uncontrolled units. CARB also estimated that complete turnover of 

all PFC in California would occur over a 5-year period. Both OTC and the Department 

have elected to assume a more conservative turnover period of 10 years. 
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Estimated controlled emissions from PFC in 2007 are summarized by county in Tables 2a 

and 2b for Connecticut. A range of emission estimates is provided to reflect uncertainty 

regarding the effect of the 1-year pass-through period allowed by the regulation and the 

overall rule effectiveness. Table 2a assumes all PFC sold after May l, 2004 are 

controlled and full implementation is achieved in 2014. Table 2b assumes no controlled 

PFC are sold until May 1, 2005, all PFC sold after that date are controlled and full 

implementation is achieved in 2015 . Controlled emission estimates in 2007 range from 

14 .1 tons/day (assuming no pass-through and 100% rule effectiveness) to 16 .0 tons/day 

(assuming full 1-year pass-through and 80% rule effectiveness) . 

Incremental Shortfall Credit Due to Connecticut's Regulation 

Reductions creditable toward the shortfall are the difference between uncontrolled and 

controlled emissions in 2007. The range of creditable emission reductions is also 

presented in Table 2, varying from 2.3 tons/day (assuming full 1-year pass-through and 

80% rule effectiveness) to 4.2 tons/day (assuming no pass-through and 100% rule 

effectiveness). These estimates of VOC emission reductions are beyond those 

incorporated into the Department's ozone attainment plan and EPA's calculation of 

Connecticut's emission reduction shortfall . It is worth noting that, when full turnover of 

PFCs occurs in the 2014/2015 timeframe, estimated emission reductions will exceed 13 

tons/day (assuming 100% rule effectiveness) . 

By the end of 2004, the Department plans to complete a mid-course review evaluating 

progress toward attainment of the 1-hour ozone standard in Connecticut. That document 

will include a discussion of how the combined reductions from the PFC regulation and 

other adopted control measures are sufficient to meet EPA's shortfall requirement for 

Connecticut. 

Supplemental Discussion Regarding EPA Comment on Connecticut's Emission 

Inventory 

In the hearing record for R.C .S .A. Section 22a-174-43, EPA Region 1 commented that a 

large portion of the PFC emissions calculated using the CARB/OTC procedure are not 

included in the Department's emissions inventory. Specifically, the EPA methods used 

by the Department for the inventory only account for emissions from fuel spillage and 

vapor displacement that occur when equipment is refueled using PFCs. Permeation, 

diurnal and transport-spillage emissions are not accounted for in the Department's 

inventory. These unaccounted emissions represent 13 .2 tons/day of the 18 .3 tons/day 

total PFC statewide emissions calculated using the CARB/OTC procedures. (Fairfield 

County contributes 3.37 tons/day of the unaccounted emissions in 2007.) EPA notes that 

these additional emissions should be addressed. 

The Department's inventory estimates played a direct role in EPA's calculation of the 

emission reduction shortfalls that must be addressed to fulfill the Department's 

commitments in the approved 1-hour ozone attainment demonstration.3 The emission 

reduction shortfalls were calculated, in part, using 1990 and 1999 emission inventory 

"Addenda to the Ozone Attainment Demonstrations for Greater Connecticut and Southwest 

Connecticut;" dated January 14, 2000; submitted by the Department to EPA on February 8, 2000. 
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estimates . Those inventories do not include the additional VOC emissions from portable 

fuel containers, as described above. 

When the additional PFC emissions are included in the 1990 and 1999 inventories, EPA's 

step-by-step shortfall calculation methodology results in the values set forth below. 

Differences from EPA's calculated values are identified : 

Step A1 : (Unchanged) Attainment year average peak = 151 .2 ppb 

Step A2 : (Unchanged) Relative reduction factor = 0.74 

Step A3 : (Unchanged) Base ozone design value = 174 ppb 

Step A4 : (Unchanged) Estimated future design value = 129 ppb 

Step B 1 : (Updated) 

Include additional uncontrolled PFC emissions in 1990 & 1999 inventories 

" Fairfield County additional 2007 VOC emissions = 3 .37 tons/day 

" Fairfield County additional 1990 VOC emissions4 = 3.08 tons/day 

" Fairfield County additional 1999 VOC emissions4 = 3.23 tons/day 

" NY-NJ-CT nonattainment area updated 1990 VOC emissions5 = 2267.4 tons/day 

" NY-NJ-CT nonattainment area updated 1999 VOC emissions5= 1728.8 tons/day 

" Updated percent change in emissions between 1990 and 1999 = -23.75% 

Step B2: (Unchanged) Reduction in design value = 29.7 ppb 

Step B3 : (Updated) Percent VOC per ppb ozone 

" VOC: 23 .75% / 29 .7 ppb = 0.80 

Step B4 : (Unchanged) Additional ozone reduction needed = 5 ppb 

Step B5 : (Updated) Additional necessary emission reductions 

" VOC reduction needed = 5 ppb x 0.80% VOC per ppb 03 = 4.00% 

Step C 1 : (Updated) Additional reductions needed in NY-NJ-CT nonattainment area 

" VOC (tpsd) = 4.00% x 2267.4 = 90.7 tons/summer day (tpsd) 

Step C2: (Unchanged) Tier 2 emission reductions in NY-NJ-CT area = 6.9 tpsd 

Step C3 : (Updated) Remaining reduction needed in NY-NJ-CT after Tier 2 adjustment 

" VOC = 90.7 tpsd - 6.9 tpsd = 83 .8 tpsd or (83 .8 tpsd) / (2267.4 tpsd) = 3 .7% VOC 

Step D: (Updated) Calculate Connecticut portion of the VOC shortfall 

" VOC shortfall= (1990 VOC)(VOC Shortfall %) 

= (128.2 tpsd + 3 .08 tpsd)(0.037) 

= 4.9 tpsd 

Conclusion : The updated calculation, with the additional PFC emissions, results in the 

same shortfall (i .e ., 4.9 tpsd) originally calculated by EPA and included in Connecticut's 

addendum to the attainment demonstration. 3 Note that EPA's eventual approval of the 

attainment demonstration included refinements to the emission reduction shortfall (to 

Extrapolates 2007 emissions back to 1990 and 1999 based on growth rate of 0.55%/year. 

Assumes increase for NY-NJ-CT area is proportional to increase for Fairfield County. 
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5.4 tpsd of VOC). However, those refinements do not affect the conclusion that the 

additional PFC emissions are not significant enough to alter the calculated shortfall. 
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Tables 2a and 2b 

Portable Fuel Containers 

Controlled Emissions for Connecticut 

Table 2a: Assuming all PFC sold startin g May 1 2004 are controlled no 1-year ass thro h 

Full 

2007 2007 2007 Implementation 

Uncontrolled Controlled Emissions Reductions 

Emissions Emissions Reductions in 2014 

Count ( tons/day) (tons/day) (tons/day) (tons/da 

Fairfield 5.232 4.023 1 .210 3.820 

Hartford 4.739 3 .644 1 .096 3.460 

Litchfield 1 .139 0.876 0.263 0.831 

Middlesex 0.889 0.684 0.206 0.649 

New Haven 3.868 2 .974 0.894 2,824 

New London 1 .227 0.943 0.284 0.895 

Tolland 0.642 0.494 0.149 0.469 

indham 0.549 0.422 0.127 0.401 

State of CT 18 .286 14.059 ; 4:227 13 .349 7 

' 14.904 ' 3.382 10 :~'~"9 

Table 2b: Assumln control lea NiFCs are not sold until M a 1, 2005 full 1 

Full 

2007 2007 2007 Implementation 

Uncontrolled Controlled Emissions Reductions 

Emissions Emissions Reductions in 2015 

Count (tons/day) (tons/day) (tons/day) ( tons/day) 

Fairfield 5.232 4.405 0.828 3.820 

Hartford 4 .739 3.990 0 .750 3.460 

Litchfield 1 .139 0.959 0.180 0.831 

Middlesex 0.889 0.749 0.141 0.649 

New Haven 3.868 3.256 0.612 2.824 

New London 1 .227 1 .033 0.194 0.895 

Tolland 0.642 0.541 0.102 0.469 

indham 0.549 0.463 0.087 0.401 

State of CT 18.286 ' 15.394 2.892 " . `13:3491 

15 .972 2 .314 ' 10.679 

p ug provlsion) 

00% Rule Effectiveness 

80% Rule Effectiveness 

-year pass through provision) 

00% Rule Effectiveness 

80% Rule Effectiveness