P.1 

OAR Box 1818 

Prepped by Ollie Stewart 

Document Number: 

55) ll-D-27 

Docket Number: 

A-87-11 

Printed 11/6/2008 3:12:45 PM Sheet 55 of 79 
f JOHN ASHCROFT 

tkiwmor 

FREDERICK A. BRl'NNER 

Dirrcior STATE OF MISSOIRI 

DEPARTMENT OF NATURAL RESOURCES 

,9-97-2:/ ]j:-Q>-mvr 

Division of Energy 

IMvision of Environmental Quality 

Division of (ieology and UIKJ Sunry 

DiviMon iif Management Services 

Division of Parts. Recreation. 

and Historic Preservation 

P.2 

MEMORANDUM 

DATE: 

TO: 

FROM: 

SUBJECT: 

June 10, 1987 

AGCNCv

R0,ECT/0W 

m ;> o m 

G$.hi "WAL 13 . ,:

 JOCKET 

Mr. Wil C. Ford, P.E., Director, Division -of-Environmental! Quality 

Mr. Nibfr-tfTkkila, Staff Director, Air Pollution Control Program 

Actual Cost of Stage II Vapor Recovery Installations 

To obtain the most current information on the actual cost of Stage II 

Vapor Recovery installation, the staff as contacted the major oil 

companies located in St. Louis, the installation contractors, and 

individual stations which have completed installation of Stage II 

Vapor Recovery equipment. These companies include: Amoco Oil 

Company, Vickers Petroleum, Mobil Oil. Company, Shell Oil Company, 

Texaco Oil Company, Superior Equipment Company, General Equipment 

Company, Neumayer Equipment Company, Carder Industries, Siemens 

Petroleum Products, and Simmons Petroleum. 

The most significant piece of information we obtained is that the 

majority of these facilities have at this time only projected or 

estimated costs rather than actual costs. This is because the oil 

companies have used the requirement to install Stage II equipment as 

an opportunity to concurrently install new underground storage tanks 

in anticipation of new regulations and new electronic data capturing 

equipment, in addition to the Stage II hardware. We were told by the 

oil companies involved that when this decision was made, requests for 

estimates, as well as actual contracts, were designed in such a way 

that all 3 of these activities were projected as one single 

expenditure rather than as separate tasks. As a result, neither the 

oil companies nor the contractors were able to provide specific 

information regarding the actual costs of the installation of only 

Stage II Vapor Recovery equipment. This situation applied to both 

cases in which stations completed installation of Stage II as well as 

those that elected to install just the underground portion of vapor 

recovery systems at this time with the above-ground portion to be 

installed at a later date. The exceptions to this situation appear to 

be limited to the stations which we assisted in obtaining complete 

Stage II Vapor Recovery systems, in particular, the Siemens Petroleum 

station listed below. 
P.3 

Due to this situation, I have included in this memo these projected 

costs, even though I understand you have requested actual cost data. 

The best cost information we are therefore able to provide is as 

follows: 

Amoco $1,250 per nozzle 

Vickers Petroleum $1,125 per nozzle 

Mobil Oil Company $1,500 per nozzle 

Shell Oil Company $1,562 per nozzle 

Texaco Oil Company $2,100 - 2,600 per nozzle 

Superior Equipment Company $800 - 3,000 per nozzle 

General Equipment Company $1,200 per nozzle 

Neumayer Equipment Company $1,200 per nozzle 

Carder Industries $1,350 per nozzle 

Siemens Petroleum $877.27 per nozzle 

Simmons Petroleum 

(Please refer to attached memo of 2/19/87) 

I have also included cost projections we received in February from 

Siemens Petroleum for stations they owned other than their station 

which installed a complete vapor recovery system. The vapor recovery 

systems at these stations are currently in various stages of 

construction and therefore no actual cost data from them is available. 

The staff has requested from each of these owners or operators of 

gasoline stations that they provide actual cost data on the 

installation of Stage II Vapor Recovery equipment as soon as it is 

available. However, it appears that in those cases where additional 

work was contracted along with vapor recovery installation that we 

will not be able to accurately obtain actual costs associated strictly 

with installation of Stage II, at least not without dedicating a major 

research effort to doing so. The companies we have contacted 

indicated that they expect this same situation to occur in other 

cities that implement Stage II because it is a cost effective approach 

to compliance with new regulations. This situation is also consistent 

with experiences of private contractors such as the Radian Corporation 

who have been hired to perform Stage II cost analyses. Please let me 

know if I can be of further assistance in this matter. 

NN/CL/ji 

Attachments 

-2-
P.4 

. . JOHN ASHCROFT 

( ii t\ ITT* ir 

FREDERICK A. HRINNER 

DllTUiT STATE OF MISSOITII 

DEPARTMENT OF NATURAL RESOURCES 

Division ul Incrgi 

IMision ni Hmiriinmcnul (Jiulm 

Division ol (•eulogy and Und survey 

Division ol Mjrugemrnt Vmccs 

Division of Cark.s. Reireatmn. 

and llistonc I'resers-jnon 

MEMORANDUM 

DATE: February 19, 1987 

TO: Chuck Lamb 

FROM: Dave Litchfield 

SUBJECT: Stage II Vapor Recovery Installation Costs at 

Bellefontaine Amoco 

The Stage II Vapor Recovery installation costs for 

Bellefontaine Amoco cannot be calculated accurately because 

Stage II Vapor Recovery is being installed as part of a more 

comprehensive project involving new dispensers and a 

canopy. The labor involved in installing new piping has 

been included in the total labor cost for this project. The 

additional cost for Stage II Vapor Recovery piping is $1290 

and the cost of 24 retractor assemblies and coaxial hoses is 

$3000. Twelve coaxial hoses were supplied at no charge by 

the Goodyear Company. The cost for twelve nozzles is 

$2702.50, with Emco Wheaton supplying the other twelve 

nozzles. 

DL/ji 
-

STATION 

St. Charles Fina 

531 Boonslick Road 

St. Charles, MO 63301 

C & D Citgo 

370 Meramec St. Rd. 

Valley Park. MO 63088 

270 Citgo 

117 3 Dam Road 

St. Louis. MO 63138 

House Springs Fina . 

4685 Old Gravois Rd. 

Hwy. 30 

House Springs, MO 63051 

U-Punvp #4 

1100 E. Hwy. 100 

Washington, MO 63090 

U-Pump #6 

12149 Bellefontaine 

St. Louis. MO 63138 

Siemens Pet. Prod. Inc. 

905 S. Kirkwood Rd. 

Kirkwood, MO 63122 

• 

SIEMENS 

NOZZLES 

8 

5 

8 

8 

8 

11 

* 

8 

PETROLEUM 

CAPITAL 

$ 5,380.67 

4,003.06 

5,546.01 

5,025.82 

5,369.71 

7,275.40 

5,695.80 

LABOR 

$ 4,880.00 

3,820.00 

4,640.00 

(Permit-$250) 

4,220.00 

3,660.00 

6,300.00 

(Permit-$325) 

2,066.35 

(Permit-$309) 

TOTAL 

$ 10,260.67 

7,823.06 

10.186.01 

9,245.82 

9,029.71 

13.575.40 

7,762.15 

2/19/87 

PER NOZZLE 

$1,282.58 

1,564.61 

1,273.25 

1,155.73 

1,128.71 

1,234.13 

970.27 

1 
-

STATION 

Geyer Citgo 

11120 Bend Road 

Kirkwood, MO 63122 

West 50 

802 W. Hwy. 50 

Union, MO 63084 

East End Fina 

1901 E. 5th 

Washington, MO 63090 

1-44 Interstate 

Rt. 2, Box 548 

Union, MO 63084 

Villa Ridge Citgo 

Hwy. 10 

Villa Ridge, MO 63089 

Pacific Citgo 

1708 W. Osage 

Pacific, MO 63069 

TOTALS 

(All retrofit balance 

NOZZLES 

4 

8 

6 

8 

9 

8 

99 

systems J 

CAPITAL 

3,091.04 

5,794.70 

3,697.75 

5,638.81 

6,058.00 

5,462.34 

$68,039.11 

LABOR 

1,560.00 

800.00 

1,500.00 

4,000.00 

4,500.00 

2,500.00 

$44,446.35 

TOTAL 

4,651.04 

6,594.70 

5,197.75 

9,638.81 

10,558.00 

7,962.34 

$112,485.46 

PER NOZZLE 

1,162.76 

824.34 

866.29 

1,204.85 

1,173.11 

995.29 

$1,136.22 

2 
P.7 

MCELRO Y 

&ASSOCIATE S 

April 16, 1987 

Mr. William Ball r 

Assistant to the President 

for Legislative Affairs 

The White House 

Washington, D.C. 20500 

Subject: Gasoline Vehicle Refueling Emissions 

(Stage II controls vs. Onboard canisters) 

Dear Will: 

I would like an opportunity to talk with Wendy Gramm about the 

current debate over how to control the hydrocarbons that escape into 

the air each time a driver "fills up" at the pump, hydrocarbons that 

contribute to the smog problem and thus endanger public health. 

Would you help me gain that appointment? 

To make a long story short, EPA has until the end of the year 

to come up with workable measures for our cities to employ in complying 

with the Federal ozone levels mandated by the Clean Air Act of 1971. 

Refueling vapors account for about two percent of the hydrocarbon 

emissions in the air. In an effort to get that two percent of harmful 

emissions, EPA is trying to decide whether to require all service 

stations to add special equipment to capture vapors at the nozzle 

(Stage II controls), or whether to require all new cars be equipped 

with an enlarged activated carbon canister onboard the vehicle (Onboard 

controls). 

This one pits the oil industry against the auto industry, EPA 

against OMB. 

EPA recently sent OMB a draft of a Proposed Rulemaking which would 

require the installation of Onboard canisters. I understand that OMB 

is opposed to the canister on the grounds that it cost too much for 

the marginal benefit to be derived. 

My client, North American Carbon of Columbus, Ohio, agrees with 

OMB. Please understand that North American Carbon, a major supplier 

of activated carbon to the auto industry, stands to gain significantly 

from a decision to adopt the Onboard solution, but they are opposed 

to the Onboard approach. 

Their motive is simple: they want to make sure the Federal Government arrives at the best solution to the problem. Based on their 

analysis, the Onboard approach would be (1) more costly, (2) less 

efficient, (3) energy intensive, (4) would require unacceptable lead 

time to implement, and (5) the technology has not been fully developed 

and tested. 
P.8 

page 2 

Would you forward the attached analysis from North American 

Carbon to Wendy Gramm with a request that I be given 5 minutes of 

her time to discuss the matter and receive her reaction. 

Thank you for any help you are able to give me on this matter. 

Will, we missed you at the special Washington meeting of the 

Gridiron Secret Society held on the Sequoia, but all members understood that the vagaries of your schedule precluded your participation. 

We were pleased that Senator Nunn and Congressmen Ray, Hatcher, 

Rowland and Thomas could join us. I am confident that Congressman 

Hatcher and Bill Alverez will acquit themselves well at the 

Saturday meeting in Athens. 

^Sincerely, 

Roland McElroy 
P.9 

noRTH RmERicon cflRBon inc. 

COLUMBUS OHIO 43213- 1580 

CONTROL OF GASOLINE VEHICLE REFUELING EMISSIONS 

Introduction 

Gasoline vapors - hydrocarbons - are displaced into the atmosphere from 

a vehicle tank when liquid gasoline is added during refueling. These 

hydrocarbons (HC), as well as other HC emissions, contribute to urban 

air pollution as one of the major classes of precursors to photochemical 

smog. The severity of photochemical smog is measured and legally defined 

by the concentration of ozone in the ambient air. As directed by the 

Clean Air Act, the Environmental Protection Agency (EPA) in 1971 established 

a National Ambient Air Quality Standard (NAAQS) for ozone (In addition to 

several other "criteria" pollutants). 

Those areas of the country which do not meet the NAAQS for ozone are designated "Non-Attainment Areas" for ozone. The Clean Air Act currently 

requires that all states comply with the ozone NAAQS on or prior to 

December 31, 1987. 

The national control strategy for improvement in ozone air quality is based 

on the reduction of HC emissions. Since a number of areas currently 

exceed the ozone NAAQS, there is a need in some areas to seek more stringent 

control of HC emissions. Thus, although vehicle refueling emissions 

represent less than 5 percent of the HC "emission inventory" of most 

cities, there is motivation to bring this source under control. 

The five principal sources of gasoline vapor emissions are summarized 

below: 

1. Vapor displacement from gasoline cargo trucks during loading at 

terminals and bulk plants. 

2. Vapor displacement during the filling of service station storage 

tanks by gasoline cargo trucks. 

3. Evaporative losses from vehicle fuel systems. 

4. Vapor displacement during the filling of vehicle fuel tanks at 

service stations. 

5. "Breathing Losses" from the service station storage tank associated with 

the filling of vehicle fuel tanks. 

The first two emission sources are currently being controlled by means 

of "Stage I" vapor recovery systems. Stage I systems recover vapors 

displaced from the receiving tank by venting them back into the delivering 

tank. 

The third source is currently being controlled by means of activated 

carbon evaporative emission control canisters on vehicles. 
P.10 

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The two remaining sources (4 and 5), usually referred to as "refueling 

emissions", have yet to be controlled on a nationwide basis. The two 

methods which have been proposed for the control of these sources are 

the subject of this paper. 

Description of Refueling Emissions 

When gasoline having a Reid Vapor Pressure of 9 is pumped from the 

service station tank into a vehicle fuel tank, vapor emissions occur 

at the nozzle-fill pipe interface which amount to approximately 10 pounds 

per 1,000 gallons delivered; and at the storage tank.vent, which amount 

to approximately 1 pound per 1,000 gallon dispensed. This latter 

emission is termed a "breathing loss". 

Thus, total refueling emissions amount to approximately 11 pounds of 

vapor per 1,000 gallons of gasoline delivered. 

Proposed Methods for Control of Refueling Emissions 

Two methods have been proposed for control. 

The first method requires the installation of "Stage II" vapor recovery 

systems at gasoline service stations. Stage II systems operate on the 

same principal used in Stage I systems, and involve the use of gasoline 

dispensing nozzles which collect vapor displaced from the vehicle tank 

and return them to the service station storage tank. 

Stage II systems also control "breathing loss" emissions since the return 

of vapors to the storage tank eliminates the ingestion of air which 

otherwise occurs when gasoline is pumped from the storage tank. 

Stage II systems represent a proven technology. They are currently 

installed on nearly all gasoline service stations in the metropolitan 

areas of California. Tests of these systems have shown them to be operating 

at more than 90 percent of theoretical efficiency. 

The second method requires the installation of "Onboard" vapor recovery 

systems on gasoline powered motor vehicles. Onboard systems involve 

the use of a sealing device at the vehicle fill pipe to prevent the escape 

of displaced vapors and force them to be vented instead to an enlarged 

activated carbon canister on board the vehicle. Vapors adsorbed by the 

carbon would be subsequently purged and burned in the engine. 

It should be noted that Onboard systems do not control storage tank 

"breathing losses" since the vapors which are displaced from the vehicle 

fuel tank are not returned to the storage tank. 

While the technology of Stage II systems has been proven in California, 

the technology of Onboard control systems is still in the development 

stage. Although several prototype systems have provided effective control 

of fill pipe emissions, the engineering problems associated with the 
P.11 

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purging of large quantities of vapor into the Induction system of a 

gasoline engine have yet to be resolved satisfactorily. 

It should be noted that service durability tests of Onboard systems have 

not yet been performed. 

It should also be noted that no Onboard system has yet been demonstrated 

which provides a fail-safe pressure relief mechanism to prevent 

- the rupturing of the vehicle fuel tank, 

- the flooding of the activated carbon canister, 

- the spraying of gasoline onto the pump operator 

in the event of failure of the nozzle shut-off device. 

Efficiencies of Stage II and Onboard Systems 

As stated earlier, total refueling emissions amount to approximately 11 

pounds of vapor per 1,000 gallons of gasoline dispensed. The table below 

summarizes the recovery efficiencies, and the quantities of vapor recovered 

and lost per 1,000 gallons of fuel dispensed for the two systems. 

Recovery Efficiency, Z Pounds of Vapor/1,000 gallons 

Fill Pipe Breathing Total Recovered Lost 

Stage II 

Onboard 

95 

95 

90 

0 

94.5 

86.4 

10.4 

9.5 

0.6 

1.5 

While the higher efficiency of the Stage II system should not be ignored, 

the real significance of these figures is that vapor weight losses from 

the Onboard system are 2 1/2 times greater than those of the Stage II 

system. 

Lead Time to Implement Control 

If Stage II controls would be installed in the remaining states at the 

same rate at which they were installed in California, 80 percent of refueling emissions could be controlled within two years and 92 percent 

could be controlled within three years after the adoption of the regulation 

by the EPA. 

In the case of Onboard controls, however, previous experience with vehicle 

emission control systems has shown that four years are required to prove 

the feasibility of a control system concept, and to design, develop, certify 

and produce the emission control system. 

To this design-build lead time of four years for Onboard control must 

be added the time required for EPA to propose and finalize rules; and 

to consult with the Department of Transportation and for that department 

to issue its findings with respect to the safety aspects of Onboard control. 

This review process is likely to require one year, which means that five 

years would be required to begin to install Onboard controls. 
PJ2_ 

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Assuming a vehicle life of ten years, 50 percent of vehicles In service 

would be equipped with Onboard systems five years after the start of their 

production and theoretically control 43.2 percent of refueling emissions. 

The theoretical control limit of 86.4 percent would be realized five years 

later. 

Thus, from the time of decision to proceed with an Onboard approach, ten 

years would be required to obtain a control level of 43.2 percent; and 

fifteen years would be required to achieve the theoretical maximum control 

level of 86.4 percent. 

Cost of Refueling Emissions Control 

Cost comparisons of Stage II and Onboard control systems are based upon 

the actual cost of Stage II controls in California; and the estimated 

cost of Onboard control, since there are no production Onboard systems 

in existence. 

An estimated 516,000 tons per year of refueling emissions remain to be 

controlled. 

(2) The following table summarizes the annual costs of recovery, the quantity 

of emissions controlled, and the recovery cost per pound of vapor for 

the two control systems, after complete implementation. Complete implementation is assumed to require three years for Stage II and fifteen years 

for Onboard control. 

Stage II controls are assumed to be installed at all gasoline service 

stations dispensing more than 2,000 gallons per month. 

Annual Emissions Controlled Recovery Cost 

Cost Tons/Year Percent Per Pound 

Stage II $407,000,000 473,000 91.7 $.43 

Onboard 516,000,000 384,000 74.4 .67 

The annual cost of Stage II control, the cost per pound of vapor controlled, 

and the cost per gallon of gasoline dispensed for service stations of 

different sizes are summarized in the table below. 

Station Size, 

Gallons/month 

14,000 

30,000 

55,000 

100,000 

250,000 

Annual 

Cost 

$1,100 

2,100 

2,250 

3,200 

1,800 

Cost per Pound 

of Vapor 

$.62 

.56 

.33 

.26 

.06 

Cost Per Gallon 

Dispensed 

$.006 

.006 

.003 

.003 

.001 

The weighted average cost of Stage II control amounts to $.43 per pound 

of vapor and $.004 per gallon of gasoline dispensed. 
P.13 

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Energy Requirements of the Two Systems 

The Stage II Balance System does not require energy to operate. The 

negative pressure created in the storage tank by withdrawal of liquid 

gasoline and the positive pressure created in the vehicle tank by the 

Introduction of that gasoline produces a pressure differential sufficient 

to cause the displaced vapor to flow back into the storage tank. 

r 

On the other hand, the energy requirement associated with Onboard Controls 

is significant. For example, two of the unit operations of the activated 

carbon manufacturing process require the consumption of approximately 

16,000 BTU from fuel oil or natural gas per pound of activated carbon 

produced. 

The additional requirement for carbon for Onboard Control, assuming systems 

designed for gasoline having a Reid Vapor Pressure of 9, is estimated 

to be approximately 20 million pounds per year. 

Even assuming all other factors to be equal, the wisdom of a choice which 

requires the unnecessary consumption of a wasting energy resources is 

questionable. 

Regulatory Status 

Section 172 of the Clean Air Act as amended in 1977 specifies that each 

state shall prepare a State Implementation Plan (SIP) for each of its 

ozone non-attainment areas which shall provide for the attainment of the 

ozone NAAQS "as expeditiously as practicable but not later than December 

31, 1987". 

In the nine years which have passed since the passage of the amended act, 

EPA has been unable to decide which of the two vehicle refueling control 

systems should be employed. 

Absent a decision by EPA, and in view of the possibility that EPA might 

decide to employ the Onboard approach and thus obviate the need for local 

controls, most states with non-attainment areas have delayed implementation 

of State II controls. 

Conclusion 

Stage II Control is a simple and straightforward solution in all of its 

aspects: conceptual, design, manufacture, installation, operation and 

maintenance. It consists essentially of a dispensing nozzle modified 

to provide a vapor seal at the nozzle-vehicle fuel tank interface; and 

a second hose to return the displaced vapor to the underground storage 

tank. The Vth Generation Stage II Systems installed in California have 

proven to be reliable, simple to operate, and inexpensive to maintain. 

By contrast, Onboard Control is at least as complex as Stage II is simple, 

Implementation of Onboard Control would require the following major procedural steps to be taken, each having its own set of complex design 
P.14 

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and other problems. 

1. It would be necessary for EPA to 

a. Establish Performance Specifications for the systems; I.e., the 

allowable emission rate per unit volume of fuel dispensed when 

the vehicle is tested under specified test conditions. 

b. Develop a consensus Standard Test Method for Refueling Emissions 

based upon real life conditions such as driving times and usage 

rates which are significantly less than average and thus less 

likely to achieve adequate purge of fuel vapor from the carbon. 

c. Establish the Design Conditions for the systems, conditions which 

would encompass not only the known present, but also the unknown 

future. Such conditions include such factors as fuel volatility 

(Reid Vapor Pressure) and fuel composition, both of which have 

changed significantly in the recent past and can be expected to 

continue to do so in the future. 

It should be understood that the three regulatory steps described above 

are not independent of each other; e.g., a change in a design condition 

is likely to affect the performance result. 

2. The automobile manufacturer must design, test and build not just one 

system, but as many systems as there are combinations of fuel induction, 

engine and fuel tank components. 

3. Finally, it would be necessary for EPA to establish the organization 

and other means to inspect multitudes of in-use vehicles to assure 

conformance to the Performance Specification in real life situations 

as well as on the manufacturer's test stand. 

The problems experienced with testing the existing Evaporative Emission 

Control Systems of in-use vehicles would undoubtedly be several orders 

of magnitude greater with a much larger Onboard System. 

It should be emphasized that the performance of a Stage II System is not 

affected by any of the above mentionned factors which adversely affect 

the performance of an Onboard System. The Onboard concept has been compared, 

appropriately we believe, to an invention of the renowned Rube Goldberg, 

which consisted of a room full of a mechanical apparatus whose sole function 

was to pour coffee from a pot into a cup. 

Aside from the foregoing considerations, it does not seem sensible or 

logical to apply a universal solution, such as Onboard controls, to what 

is essentially a localized problem. 

Stage II control, on the other hand, is a proven solution for those areas 

of the country which have the problem. 
P.15 

-7-

Author's Note 

This paper was prepared by North American Carbon, Inc., a supplier of 

activated carbon to the automotive industry. 

Although a decision by EPA to employ Onboard control would increase the 

size of the automotive carbon market by approximately three times and 

seemingly benefit the company, we are opposed to the use of this control 

system. 

We believe that Onboard controls constitute an inherently bad solution 

to the problem which will ultimately be bad for everyone. 

Revised 

April 22, 1987 

(1) "Evaluation of Air Pollution Regulatory Strategies for Gasoline Marketing 

Industry", EPA-450/3-84-012a, July 1984. 

(2) "Refueling Emissions Control-Onboard Vs. Service Station Controls"; 

March, 1984; by Sierra Research, Sacremento, California.