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OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

146) IV-E-19 

Docket Number: 

A-87-11 

Printed 4/22/2008 2:42:55 PM Sheet 146 of 242 
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V

o s% 

M 2 0 1988 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

MEMORANDUM 

SUBJECT: 

FROM: 

Meeting with API and MVMA on the Joint Proposal on 

Vapor Recovery 

John F. Anderson, Senior Project Manager 

Standards Development and Support Branch /, J^J^a . 

TO: Docket A-87-11 and Docket A-85-21 

On December 14, 1987 a meeting was held between EPA and 

members of API and MVMA to discuss the joint proposal which was 

being advanced by those groups in response to the onboard and 

volatility proposals. A list of attendees is attached. Also 

attached is a copy of the material submitted by API and MVMA. 

Discussion at the meeting centered upon clarifying questions by 

EPA related to the analyses used to generate the figures in the 

handout. The API and MVMA staff indicated that a future 

updating of their analyses was planned. 

Attachments 
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P.4 

JOINT PROPOSAL ON VAPOR RECOVERY 

BACKGROUND 

The Clean Air Act requires that the National Ambient Air 

Quality Standards for ozone be attained by December 31, 1987. 

Using models and monitoring data, the Environmental Protection 

Agency (EPA) has concluded that as many as 62 metropolitan areas 

may not comply with the standard for ozone by that date. 

Hydrocarbon emissions are one of the primary contributors to the 

formation of ozone. EPA is proposing severe restrictions on 

gasoline "volatility" (a measure of its tendency to evaporate) 

and regulations requiring refueling vapor recovery control 

equipment onboard vehicles. Additionally, other refueling 

emission reductions are to be achieved through Stage II controls 

at service stations in some areas. 

THE PETROLEUM AND AUTOMOBILE INDUSTRIES JOINT PROPOSAL 

In order to provide a regulatory solution that would 

accelerate the objectives of the EPA program in meeting national 

air quality standards and be more cost effective, the petroleum 

and automobile industries are proposing an alternative program 

for reducing hydrocarbon emissions. The proposal must be 

accepted by government officials and enforcing provisions 

incorporated into federal legislation and/or regulation by the 

end of 1987. The proposal, the provisions of which must be 

enforced in toto, consists of the following: 

1) That the volatility of all motor fuels be reduced from 

May 16 to September 15 beginning in 1988 according to the 

following volatility limits: 

ASTM Regions EPA Proposal Current Joint Proposal 

Guidelines Limits 

1989 1992 1988 

ASTM Class A Areas 8.2 7.0 9.0 lb RVP 9.0 lb RVP 

ASTM Class B Areas 9.1 7.8 10.0 lb RVP 9.5 lb RVP 

ASTM Class C Areas 10.5 9.0 11.5 lb RVP 10.5 lb RVP 

Both industries strongly oppose RVP reductions beyond these limits 

and propose that these reductions preempt further Federal reductions 

or reductions by any individual state government, other than existing 

California regulations. 

2) That effective January 1, 1990 lead would be eliminated for 

on-highway vehicle gasoline use. 

3) That vehicle manufacturers certify their evaporative emission 

control systems using 10.5 lb RVP certification fuel at sea 

level and 9.5 lb RVP at high altitude beginning 1991 model 

year. 
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4) That EPA mandate that all ozone nonattainment areas adopt an 

improved inspection and maintenance program patterned after 

the existing programs in Arizona and Oregon. It is important 

that intentional or accidental malmaintenance of vehicle 

emission control systems not result in slowing progress toward 

the nation's clean air goal. 

5) That Stage II vapor recovery emission control would continue 

in effect in current California jurisdictions, in Washington, 

D.C, and in St. Louis, Missouri, but Stage II controls will 

not be extended beyond these localities. 

6) That onboard vapor recovery systems will not be required 

nationwide or by any state. 

Both industries strongly oppose additional refueling controls. 

Refueling emissions are a minor contribution to the nation's ozone 

problems, and controlling these emissions is not a cost-effective 

means of solving the problem of ozone nonattainment. The joint 

proposal is a substitute for additional refueling controls mandated by 

either EPA or individual state governments. 

ANALYSIS OF THE JOINT PROPOSAL COMPARED TO EPA'S PROPOSAL 

o The cost-effectiveness of the joint proposal is far superior 

to the EPA proposal, especially in the long-term (as noted in 

Attachment A) . The joint oil/auto proposal ranges from 

$2,900 to $4,000/ton per year. The incremental cost of 

reducing the additional emissions in EPA's proposal is 

approximately §13,000/ton per year for the same period. 

o In the short-term (1988-91), the joint oil/auto proposal has 

the advantage of producing more immediate benefits in the 

reduction of hydrocarbons (see Attachment A) . The cumulative 

total for the joint proposal is 876 K tons compared to 712 K 

tons for the EPA proposal. The joint proposal provides 123% 

of the EPA program. 

o In the long-term, the joint oil/auto proposal compares 

favorably to EPA's proposal in reducing exceedances of the 

ozone standard and reducing the number of nonattainment areas 

as indicated by the following tables. 

Oil industry costs for both the joint proposal and the EPA proposal 

are estimates and will be adjusted as necessary on or around 

October 15 when an in depth analysis based on a refinery by 

refinery survey is completed. 
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TOTAL NUMBER OF EXCEEDANCES OF THE 

OZONE NAAQS IN 61 NON-CALIFORNIA URBAN 

NONATTAINMENT AREAS* 

PROJECTION YEAR 

No Further Controls 

1990 

246 

1995 

239 

2000 

250 

2010 

292 

Control Scenarios 

Joint Oil/Auto Proposal* 

EPA Proposal 

Net Difference 

232 

232 

-0-

218 

200 

-18 

222 

208 

-14 

260 

256 

-4 

COMPARISON OF THE 

PROJECTED NUMBER OF NON-CALIFORNIA URBAN 

OZONE NONATTAINMENT AREAS* 

PROJECTION YEAR 

1990 

40 

1995 

38 

2000 

41 

2010 

51 

36 

36 

0-

33 

29 

-4 

34 

30 

-4 

41 

39 

-2 

No Further Controls 

Control Scenarios 

Joint Oil/Auto Proposal* 

EPA Proposal 

Net Difference 

* The projections for nonattainment areas in the joint proposal are 

based on the less stringent volatility controls, plus the proposed 

lead ban, and the I&M/anti-tampering program. The projection for 

nonattainment areas for EPA's proposal is based on more stringent 

volatility limits plus refueling controls. All projections are 

based on 73 nonattainment areas nationwide [61, Non Calif; 12, 

Calif.] 

Basis: Draft RIA July 1987 
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COMPARISON OF VOC REDUCTION PROPOSALS 

p 

R 

0 

J 

E 

C 

T 

E 

D 

N 

A 

A 

s 

BENEFIT COMPARISON 

1988 - 91 1995 2000 2010 

YEAR 

P 

R 

0 

J 

E 

C 

T 

E 

D 

E 

X 

C 

E 

E 

D 

E 

N. 

C 

E 

S 

JOINT 

SOLUTION 

H EPA 

1988 - 91 1995 2000 2010 

YEAR 

B 

I 

L 

L 

I 

0 

N 

S 

0 

F 

D $4.000-r 

° $3,000 • 

L $2,000 • 

K $1,000 -

S $0,000 

COST COMPARISON 

JOINT 

SOLUTION 

Di EPA 

1988 - 91 1995 2000 2010 

YEAR 
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COMPARISON OF THE 

PROJECTED REGULATORY CONTROL COSTS 

PROJECTION YEAR 

CONTROL SCENARIO 1990 1995 2000 2010 

Joint Oil/Auto Proposal $750 $ 979 $ 985 $ 989 

EPA Proposal 925 3600 3600 3600 

Net Difference 175 2621 2615 2611 

* Note: All values are in millions of current dollars 

ADDITIONAL STEPS NEEDED: A COMPREHENSIVE ASSESSMENT OF OZONE 

o Both industries believe EPA should conduct a comprehensive 

assessment of the ozone problem, with particular focus on the 

magnitude of the problem and the best means of alleviating it. 

o EPA's current approach of using design values to designate 

nonattainment areas may overstate the problem. A recent study of 

EPA ozone monitoring data indicates that 23 of the 25 "major urban 

areas" achieved the ozone standard more than 99% of the time. 

o The substantial and immediate reduction provided by the joint 

oil/auto proposal allows policy-makers the time needed to obtain a 

realistic assessment of the magnitude of the problem while 

continuing to make significant strides toward reducing total 

hydrocarbons. 
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A comprehensive assessment of the ozone problem should include an 

examination of existing State Implementation Plans to determine 

what worked, what did not, and why. This evaluation should examine 

all emission sources and their contribution to ozone. A complete 

and up-to-date emissions inventory, by nonattainment area, is badly 

needed. Finally, EPA should continue to improve the 

representativeness of air quality measurements, as well as its 

understanding of the relationship of these measures to health 

effects. 

We believe a more comprehensive assessment of the problem, together 

with the immediate benefits realized in the joint oil/auto 

proposal, other control measures already in place, and fleet 

turnover, compel the conclusion that stringent and costly control 

measures are neither necessary nor appropriate. 
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ATTACHMENT A 

SUMMARY OF COMPARATIVE EMISSION REDUCTIONS AND COST * 

1988-91 1995 2000 2005 

Joint Proposal 

VOC's Reduced 876 244 285 335 

(K Tons) %l£* 

Cost ($ Billions) 3.000 .979 .985 .989 

Cost Effectiveness 3,400 4,000 3,400 2,900 

($/Ton) 

2 

EPA Proposal 

VOC's Reduced 712 463 488 534 

(K Tons) 

Cost ($ Billions) 3.700 3.600 3.600 3.600 

Cost Effectiveness 5,000 7,800 7,400 6,700 

($/Ton) , 

Incremental Cost/Ton NA

 J $12,000 $13,400 $13,600 

The costs of the joint proposal include RVP reductions starting 

in 1988, the I&M/anti-tampering program in 1989, the enlarged 

evaporative canister 1991 model year, and the ban on lead in 

1990. Anti-tampering and inspection and maintenance estimates 

are based on projections contained in EPA Draft RIA dated July 

1987. The data has been adjusted to account for volatility 

levels contained in the joint proposal and vehicle miles 

traveled/gasoline demand. Data for-1995 and 2000 were 

interpolated from 1988-2010 projections. Emission reduction 

estimates do not include a factor for weathering. Both 

industries agree that weathering (normal reductions in the 

volatility of fuel in the vehicle tank) is a factor and when 

incorporated would reduce the emission reduction estimates in 

both the joint proposal and EPA proposal. 

2 

Emission reductions in the EPA proposal are calculated using 

Mobile 3 and utilizing data from the EPA 1985 volatility 

document and adjusted to current DOE high gasoline demand of 7.2 

million barrels per day. Costs for the EPA proposal include 

lower RVP, onboard refueling canister, and Stage II in selected 

areas. 

3 An incremental cost for the EPA proposal cannot be calculated 

since the joint proposal produces greater emission benefits at a 

lower cost than the EPA proposal. 

Evaporative canister and refueling costs were determined by auto 

industry representatives; volatility, Stage II and lead costs 

were determined by oil industry represenatives (9/30/87).