# 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 OTCand are summarized below . Emission Calculations OTC's methodology for determining volatile organic compound (VOC) emissions from PFCis 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 ofthe rule in Connecticut in May 2004 (versus January 2003 for the OTCModel 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 fromthe 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 fromcommercial 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 fromportable fuel containers, a quantification of emission reductions due to ' Ageneral description of OTC's model rule is provided in Section 4 .4 ofAttachment 2 to that SIP revision. The OTCmodel rule and associated emission reduction calculations can be found in Enclosures Dand C, respectively, of the same SIP revision . Applicable OTCcalculation 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 Ato Enclosure Cof the SIP revision mentioned in the above footnote. Alternatively, see CARB's Mail-Out MSC99-25 . The Department's emission estimates were developed using these CARB formulas .

### 2 D-5 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 VOCfromPFC can be attributed to five different components : permeation, diurnal, transport-spillage, refueling-spillage and vapor displacement . Emissions occur fromcans 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 fromany opening in a PFC due to the daily cycle of ambient temperature change. CARB testing determined that diurnal emissions 1 .38 g/gal-day fromclosed 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 fromfuel spills occur when PFCs are in transit . CARB emissions factors range from23 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 froma 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 fromthe equipment fuel tank is displaced by fuel dispensed froma 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 fromPFCs 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 PFCregulation, 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 VOCemissions 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.3 D-5 Estimated controlled emissions fromPFCin 2007 are summarized by county in Tables 2a and 2b for Connecticut . Arange ofemission 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 from2.3 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 reviewevaluating progress toward attainment ofthe 1-hour ozone standard in Connecticut. That document will include a discussion of how the combined reductions fromthe PFCregulation 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, EPARegion 1 commented that a large portion of the PFCemissions 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 fromfuel 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 .4 D-5 estimates . Those inventories do not include the additional VOC emissions fromportable 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 fromEPA'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 B1 : (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 " VOCreduction needed = 5 ppb x 0 .80%VOCper 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 VOCshortfall " VOC shortfall= (1990VOC)(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 EPAand 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.5 D-5 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 .V

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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 NewLondon 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 NewHaven 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

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