- 1

- FEDERAL CLEAN AIR ACT SECTION 110(l) DEMONSTRATION

TO SUPPORT AMENDMENTS TO RULE 61.4

EPA Memoranda

In 2006

- 2007

, EPA issued two memoranda authorizing s tates to eliminate the requirements for Pha s e II vapor recovery at gasoline dispensing facilities (GD Fs) that exclusively service rental or corporate fleet vehicles if (1) it is demonstrated that On Board Refueling Vapor Recovery (ORVR) in these fleets is in widespread use , and (2) eliminating this requirement would not interfere with attainment or reason able further progress or any other requirement of the Clean Air Act

. 1 EPA also recommended apply ing the se same considerations for refueling flexible fuel vehicles at E

- 85 fuel (85% ethanol

- 15% gasoline) dispensing pumps.

EPA defined ORVR widespread use a s a situation where at least 95% of vehicles refueled at a given station have ORVR . Since car rental companies and corporate entities operate mostly late model vehicles

, t hey will be able to demonstrate 95% or larger ORVR penetration. EPA also stated tha t States which provide exemption s from the Phase II vapor recovery requirement must demonstrate that the widespread use benchmark has been achieved at facilities being exempt ed and their eligibility for the exemption is continuously maintained.

For flexi ble fuel vehicle s operating on E85

, EPA did not define a widespread use threshold because the majority of such vehicles are already equipped w ith ORVR and this percentage is increasing with time. EP A further indicated that the air quality impact of allowi ng E85 refueling facilities to operate without Phase II vapor recovery would likely be minimal

, and therefore will not interf ere with the attainment of the N ational Ambient Air Quality S tandard (NAAQS) for

ozone.

Rule 61.4 Amendments

San Diego County Air

Pollution Control District’s Rule 61.4 (Volatile Organic Compounds Transfer into Vehicle Fuel Tanks ) requires all facilities that dispense more than 2

, 000 gallons of fuel per month to install and maintain Phase II vapor recovery system s . The rule was las

t amended in 1990 and approved by EPA into the State Implementation Plan ( SIP ) in 1993.

On M arch 26, 2008, the San Diego County Air Po llution Control Board amended the rule to provide an exemption from the Phase II vapor recovery requirements for non

- reta il gasoline dispensing facilities (GDFs) where at least 95% of vehicles re fueled are equipped with ORVR

. The rule required an owner or ope rator of a facility qualified for the exemption to maintain records of the make, model year, vehicle identification n umber and any other information indicating whether a vehicle is equipped with ORVR. In addition, the same exemption was provided to facilities or pump s where E

- 85 is dispensed

.

1 “Removal of Stage II V

apor Recovery in Situations Where Widespread Use of Onboard Refueling Vapor Recovery is Determined,” Stephen D. Page, Director, Office of Air Quality Planning and Standards, and Margo Tsirigotis Oge, Director, Office of Transportation and Air Quality, Dece mber 12, 2006; “Removal of Stage II Vapor Recovery from Refueling of Corporate Fleets,” Stephen D. Page and Margo Tsirigotis Oge, November 28, 2007.- 2

-

Emissions Impact Analysis

The following analysis demonstrate s that these a mendments to Rule 61.4 will not interfere with the atta inment of the NAAQS for ozone in San Diego County.

I. Non

- retail GDFs that may chose to apply for exemption from Rule 61.4.

There are presently 136 non

- retail stations in San Diego County, with 20 of them belonging to military establishments. Some of these stations dispense a significant amount of gasoline, more than three million gallons per year each. These facilities

, while non

- retail by definition (they do not pay state sale s tax), also refuel private vehicles of active military personnel and military retirees. Consequently, t hese sources will not qualify for the exemption from Rule 61.4.1 because their operators do not control the make or age of vehicles they refuel

, and therefore it is impos sible for them to determine with certainty whether ORVR equipped vehicles are in widespread use. The same conditions appl y to GDFs at car dealerships (5 GDFs belong to those). The remaining 111 facilities with a total annual gasoline throughput of approx imately 18 million gallons may qualify for the exemption.

Accordingly, t wo scenarios were compared assuming that in the worst case

, 111 GDFs will actually apply for the exemption and be approved by the District . These stations must also remove Phase II v

apor recovery equipment as required by the rule. It was further assumed that in

- use control efficiency of Phase I I vapor recovery equipment is 8 4 %, 2 the present Phase II vapor recovery system is dismantled, and at least 95% of vehicles refueled at each GD F are equipped with ORVR. The ARB emission factor of 8.4 lbs VOC/1000 gallons of gasoline was used for the uncontrolled refueling system.

Scenario 1. All vehicles that would be subject to the exemption are refueled at GDF’s wi th Phase II VR control in p lace wit h 8 4 % in

- use control efficiency. The vehicles do not have ORVR.

VOC emission reductions = = 18,000,000 gal/ yr x 8.4 lbs VOC/1000 gal x 0. 8 4 x 1ton /2 000 lbs = 6 3 .5 tpy

.

Scenario 2 . All vehicles that would be subject to the exemption are refuel ed at GDF’s with no Phase II VR , and 95% of vehicles have ORVR systems installed , which control emissions by 95% . The rest of the vehicles (5% )

, or approximately 5% of gasoline dispensed will be refueled without any VOC control in place, i.e.

VOC emis sion reductions from vehicles equipped with ORVR = = 18,000,000 gal/yr x 8.4 lbs VOC/1000 gal x 0.95 x 0.95 x 1ton /2000 lbs = 68.2 tpy.

VOC emissions increase from non

- controlled refueling of vehicles without ORVR = =18,000,000 gal/yr x 0.05 x 8.4 lbs VOC/1000 gal = 3.8 tpy.

2 This value is consistent with the methodology for the emission estimates in the 2002 baseline emission i nventory and emission forecasts in San Diego’s 2007 Eight

- Hour Ozone Attainment Plan.- 3

-

Overall emission reductions = 68.2

- 3.8 = 64.4 tpy

.

These calculations show that th ere will be a slight gain in VOC emission reductions (0.9 tpy) if stations refueling at least 95% ORVR

- equipped vehicles remove the Phase II vapor recovery , due to a h igher control efficiency of ORVR

, provided that the ORVR works as expected.

II. Flexible Fuel Vehicles

Presently, there is only one active retail station in San Diego County that refuels f lexible fuel vehicles servicing approximat ely 1300 vehicles per month, with monthly E85 throughput between 10,000 and 20,000 gallons. The facility has both Phase I and Phase II VR systems installed. The Phase I system was recently certified by ARB, whereas the Phase II system is not certified.

As stated above

, the majority of vehicles fueled on E85 are equipped with ORVR

. However, according to ARB information some E85 light duty trucks manufactured between 1997 and 2002 were not equipped with ORVR. ARB staff estimated the possible VOC emission increases from removing Phase II vapor recovery at stations that were refueling such trucks. They assume that some of these trucks would remain in use by 2015 using survival fraction of vehicles as a function of vehicle age. Average age of vehicles not having ORVR in 2005 was four years. The estimated statewide emissions from refueling these vehicles at E85 pumps not equipped with Phase II VR were approximately 0.10 tons/day (36

. 5 tons/year) in 2015. ARB staff concluded that this emission increase will not impact the attainment of the federal air quality standard for

ozone.

Similarly, no impact

on ozone attainment is anticipated in San Diego

. Base d on these statewide estimates and the proportion of estimated San Diego County population vs. Californi a population in 2015 (8% )

, the excess of VOC emissions from such vehicles in the county will be 0.10 tons/day x 0.08 = 0.0 0 8 tons/day or 2.9 tons/year.

III. Net Impact

Net VOC emissions change = 2.9 tons/year (increase from stations dispensing E85)

- 0

. 9 ton/year (decrease from stations refueling 95% ORVR equipped vehicles ) = 2 tons/year or 0. 00 55 tons/day ( region

- wide VOC emissions increase).

In light of such an insignificant VOC emissions increase

, it is reasonable to conclude that the proposed exemp tions in Rule 61.4 for fleet vehicles and vehicles fueled with E85 at qualified fueling stations will not adversely affect the attainment of the NAAQS for ozone in San Diego County , or any other requirement of the Clean Air Act

.