p.1 

OAR Box 1147 

Prepped by Ollie Stewart 

Document Number: 

133) IV-E-6 

Docket Number: 

A-87-11 

Printed 4/22/2008 2:42:55 PM Sheet 133 of 242 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

SEP I 4 I987 

OFFICE OF 

AIR AND RADIATION 

MEMORANDUM 

SUBJECT: Hearing on California Onboard Bill 

FROM: John F. Anderson, Senior Project Manager 

Standards Development and Support Branch 

TO: 

THRU: 

Public Docket A-87-11 

Chester J. France, Chief 

Standards Development and/&upp 

IA' I 

On August 26, 1987 I attended hearings on the above bill, 

in response to a request from Assembly Speaker Willie Brown for 

a technical expert (see 8-13-87 letter attached). I did not 

actually testify, but in conversations with other parties I 

obtained some new information concerning breathing and emptying 

Attached 

measurements 

is a brief presentation of the Sun Oil 

conducted recently, "Service Station Vent 

Emissions", which I obtained from the author, Mr, Walter 

Douthit. Sun believes that this data shows that, at least for 

stations using pressure relief valves, there are no 

significant breathing or emptying emissions. 

I also met and spoke with Dr. Richard A. Nichols, who 

indicated to me that he was aware of substantial data on 

emptying loss measurements, with and without Stage II systems. 

His belief, which he claimed is substantiated by the data, is 

that the vapor space inside the underground tank is highly 

stratified, with the uppermost portion being essentially air 

without hydrocarbons. It is this air which moves in and out 

during tank emptying, and little or no vapor emissions result, 

either with or without Stage II controls. Dr. Nichols 

identified one specific report from the South Coast Air Quality 
P.3 

Management District ("phase II Vapor Recovery Evaluation 

Program", 1979) and said that he had other reports which he 

would send to me. Dr. Nichols also criticized the recent NIPER 

emptying loss measurements as being both flawed (because of 

improper fuel tank conditioning) and non-representative 

(because of the underground tank size and configuration). 

Attachments 

cc: Glenn Passavant 
P.4 

" A " CAP'TOL 

5*Cf**»"r.*.*C C*v'Fi«ftr-ilA&«jd14 

•&;*>: 4J5-B077 

I DISTRICT OfTlCE 

*ds V* N N£5S AVENUE 

5*NFHA*-C:SC 0 CALIFORNIA 94102 

MTSi 3570794 

Z DISTRICT OfFICE 

;c? SOUTH BROADWAY 

SUITE 8009 

Los ANGELES CA 90012 

(213> 620-4356 

(tfalifanria iGegtHlature 

WILLIE LEWIS BROWN , JR. 

SPEAKER OF THE ASSEMBLY 

.m^m . 

August 13 , 1987 

Mr. Richard Wilson 

Director, Office of Mobile Sources 

U.S. Environmental Protection Agency 

401 M Street, S.W. 

Washington, D.C. 20460 

Dear Mr. Wilson: 

As you know, I am carrying legislation (AB 792) that would require 

all light duty vehicles sold in California to be equipped with 

onboard controls for the recovery of refueling vapors. The bill 

will be heard in the Senate Governmental Operations Committee on 

August 26. 

I understand the Agency must remain neutral on state control 

strategies such as onboard controls and will not take any position 

cn AB 792. I would, however, greatly appreciate technical 

assistance from your Office of Mobile Sources on August 25 and 26. 

During these two days we will need a technical expert who can brief 

legislators and administration officials on the technical 

feasibility of onboard controls and the details of your proposed 

vapor recovery regulations as well as respond to questions that may 

come up during the August 26 hearing. 

If you have any questions or need additional information please do 

not hesitate to contact Kent Stoddard, my environmental consultant, 

at (916) 445-8077. 

Thank you for your assistance. 

Sincerely, 

WILLIE LEWIS BROWN, JR 

Speaker of the Assembly 

WLB:ksm 
P.5 

SERVICE STATION 

VENT EMISSIONS 

WALT DOUTHIT 

< 

I 

SUN REFINING AND MARKETING COMPANY 

8/26/87 . 
P.6 

PURPOSE 

TO QUANTIFY THE VOLUME OF 

BREATHING LOSSES FROM UNDERGROUND 

TANKS AT SERVICE STATIONS WHILE 

GASOLINE IS DISPENSED TO VEHICLES 

AND DURING OFF-HOUR DIURNAL 

CONDITIONS. 

-1-
P.7 

TEST PROCEDURES 

o Conducted monitoring of vent emissions 

at typical service stations. 

o Monitored venting of vapor/air during 

vehicle refueling with Singer dry gas 

meters . 

o Monitored venting during diurnal 

conditions. 

o Monitored venting with and without 

pressure/vacuum caps on vents. 

o Compared vapor/air Singer meter readings 

with amount of dispensed fuel. 

o Prior to monitoring: 

- Conducted routine mechanic check of 

service station dispensing units, 

hoses, caps, etc. 

- Checked all tank and Stage I 

manifolds for tight sealing. 

- Recorded underground tank fuel 

temperatures. 

- Determined gasoline RVP. 
P.8 

FIGURE 1 

SERVICE STATION LAYOUT 

MULTI-GRADE DISPENSER 

CAS METER 

VENT 

UNDERGROUND STORAGE 

TANKS 

-3-
P.9 

—^-Iffrrv+f; •• •" *• r~ : 

FIGURE 2 

TEST EQUIPMENT 

VENT 

CHECK 

VALVE 

OUTFLOW INFLOW 

CHECK 

VALVE 

DRY TEST METER 

DRY TEST METER 

-4-
P.10 

TABLE I 

VENT MONITORING - CHICHESTER SUNOCO 7/21/87 

SERVICE STATION INFORMATION 

o Three 8,000 gallon underground tanks 

o Tank gauges prior to test: 

- Economy Unleaded 3021 gal. 

- Ultra Super Premium 3134 gal. 

- Leaded Regular 3276 gal. 

o Tank gasoline temperatures 83 ± 1 

o Ambient temperature range - 90 to 95 F 

o Test time - 11:00 A.M. to 2:00 P.M. 

o Stage I Vent Cap in place (Island vent). 

Single meter in use. 

DATA: 

Vol. of Vol. of Vol. of 

Fuel Air Drawn Vapor/Air 

Dispensed Thru Vent Exhaled 

340.3 gal. 128.3 gal. 0 

RATIO: 128.3 = .38 

340.3 

-5-
P.11 

TABLE II 

VENT MONITORING - PHILADELPHIA PIKE SUNOCO 7/24/87 

SERVICE STATION INFORMATION 

o Three 6,000 gallon underground tanks 

o Tank gauges prior to test: 

- Economy Unleaded 3173 gal. 

- Ultra Super Premium 3258 gal. 

- Leaded Regular 3469 gal. 

o Tank gasoline temperatures 80 ±1 

o Ambient temperature range, 91 - 100 F 

o Test time - 10:00 A.M. to 2:00 P.M. 

o Stage I vent cap in place (roof vent). 

Dual Singer meter setup. 

1 

DATA: 

Vol. of 

Fuel 

Dispensed 

520.9 gal. 

RATIO: 

• 

Vol. of 

Air Drawn 

Thru Vent 

228.1 gal. 

228.1 .44 

Vol. of 

Vapor/Air 

Exhaled 

0 

520.9 

-6-
P.12 

TABLE III 

CONTINUOUS VENT MONITORING 

PHILADELPHIA PIKE SUNOCO . 

ADDITIONAL SERVICE STATION INFORMATION 

Fuel Tank 

RVP Temp 

o Economy Unleaded 11.3 psi 84 F 

o Ultra Super 

Premium 11.4 psi 84 F 

o Leaded Regular 11.0 psi 84 F 

- / -
TABLE III (continued) 

DATA: 

) 

, ^ 7/27 

High 

8500 

2:00 

7/27 

4PM to 9PM 

ambient temp. 94 F 

gal fuel drop at 

P.M. 

9PM to 7/28 7AM 

Vol of 

Fuel 

Dispd 

.(«"•!• ) 

211.08 

-

Vol of 

Air 

Drawn 

thru Vent 

.(K*l.) 

15.16 

0 

Vol of 

Vapor 

Emitted 

(Rai.) 

25.30 

29.66 

Low ambient temp. 72 F 

7/28 7AM-to 9PM 

High ambient temp. 89 F 

7/28 9PM to 7/29 7AM 

Low ambient temp. 70 F 

7/29 7AM to 9PM 

High ambient temp. 90 F 

7/29 9PM to 7/30 7AM 

Low ambient temp. 68 F 

7/30 7AM to 9PM 

High ambient temp. 90 F 

7/30 9PM to 7/31 7AM 

Low ambient temp. 69 F 

2135.68 681.50 

1599.47 450.38 

1673.33 655.21 

2.40 

.33 

1.58 

21 

RATIO: (Volume Fuel Dispensed from 7/28 = 1787 = .33 

Volume of Air Thru Vent) 5407 

NOTE: Atmospheric Pressure Range: 29.95 to 30.16 

*' Stage I certified greater than 9055 efficiency. 

-8-
P.14 

TABLE IV 

VENT MONITORING BROOKHAVEN SUNOCO 

SERVICE STATION INFORMATION 

o Three 8,000 gallon underground tanks 

o No pressure/vacuum vent valve 

o Ambient Temperature 75 - 84 F 

Atmospheric Pressure 30.3" Hg 

Tank 

RVP Temp. 

o Economy Unleaded 11.8 psi 83 F 

Ultra Super Prem 11.2 psi 82°F 

Leaded Regular 10.5 psi 83 F 

o Test time - 11:30 A.M. to 3:00 P.M 

r' 

DATA: 

t 

l[ Vol. of 

i Fuel 

* Dispensed 

381.5 gal. 

Vol. of 

Air Drawn 

Thru Vent 

116.3 gal. 

Vol. of 

Vapor/Air 

Exhaled 

0 

RATIO: 116.3 = 0.3 

381.5 

-9-
P.15 

SUMMARY AND CONCLUSIONS 

o During normal fueling of vehicles no 

vent emissions observed. 

Insignificant vent emissions during nonoperating diurnal conditions at service 

stations. 

Volume of air in-breathing through the 

vent to underground tanks is 

significantly less than the amount of 

gasoline dispensed - suggesting 

equilibrium conditions are preserved in 

the underground tank during refueling. 

Fuel delivery to underground tanks cause 

vent emissions within efficiency limits 

> 90%. Expect significant variation in 

emissions dependent on Stage I system 

and delivery procedures. . 

Pressure/Vacuum caps beneficial. 

-10-