### 0



## dKC de la Torre Klausmeier Consulting

_____________________________________ 1401 Foxtail Cove Austin, TX 78704 (512) 447

- 3077

E

- mail: delaklaus@aol.com



## DRAFT REPORT

ANALYSIS OF FUTURE OPTIONS FOR CONNECTICUT’S GASOLINE

DISPENSING FACILITY VAPOR CONTROL PROGRAM

December 8 , 2011

Prepared for:

Connecticut Department of Energy and Environmental Protection

79 Elm St.

Hartford, CT 06106

- 5127

Prepared by:

Rob Klausmeier

de la Torre Klausmeier Consulting, Inc.

### 1

1. INTRODUCTION

Under purchase order # DEPM1

- 0000031039, de la Torre Klausmeier Consulting, Inc. (dKC) is assisting the Connecticut Department of Environmental Protection ( DEEP ) in evaluating the Gasoline Dispensing Facility (GDF) Vapor Control Program. T he primary objec tives of this project are listed below :

Determine when onboard refueling vapor recovery (ORVR) systems in Connecticut’s vehicle fleet have met a particular threshold described as widespread use (WSU). ORVR systems were phased into the motor

vehicle fleet b eginning with the 1998 model year. After Connecticut reaches WSU, EPA will allow it to terminate the Stage II portion of the Vapor Recovery program, provided it does not need the emission reductions from Stage II.

Estimate the cost and benefits of termina ting or enhancing the Stage II

program.

Estimate the cost and benefits of enhancing the Stage I program.

Determine the best way to decommission Stage II systems.

This report present s the results of this project.

Summary of Results: Depending on the definition of WSU and assumed effectiveness of Stage II systems, Connecticut has passed or will soon pass the WSU threshold. Continuing the current program beyond WSU will achieve mini mal emission reductions,

and will in fact increase emissions after 2014

. Adopting the Stage II provisions of the California Enhanced Vapor Recovery (EVR) program does not appear to be cost effective. However, emissions from GDFs can be significantly reduced for a reasonable cost by enhancing DEEP ’s Stage I program

. DEEP should consider regulations to terminate the Stage II program and require GDF’s to be equipped with vapor leak monitoring systems and tank vent control systems. These regulations will increase the

emission reductions from the GDF Vapor Control Program. They also will help assure the State that any leaks that result from removing or capping Stage II systems will be promptly identified and repaired

. These regulations should exempt GDFs that dispense

rel atively low volumes of gasoline from pressure monitoring and ta nk vent control
systems.

2. SUMMARY OF GDF SURVEY

To collect data on the characteristics of GDFs in Connecticut, dKC contracted Eastern Research Group ( ERG ) to conduct a comprehensive survey. ERG designed the survey sample from GDF data obtained from the Conn ecticut DEEP . ERG filtered out facilities
that were closed or inactive, or only handled non

- gasoline materials. 2,033 surveys were mailed out on February 17. Of these, 23 were undeliverable.

Survey responses were received for a total of 908 GDFs located in Connecticut. Based on the number of delivered surveys (i.e., 2,010 surveys), the survey response rate was 43.4%. For purposes of comparison, a survey was conducted for a similar GDF sample

### 2

size in Texas in 2008 and the return rate was only 27.4%. 1 

### T he high survey response rate increases confidence that the findings of this study are applicable to GDFs across

the entire state of Connecticut.

ERG designed a Microsoft Access database to house the received survey data. All survey returns that were sent in via mail, fax, or PDF format were input into the database manually. Significant findings are shown below:

The 96 facilities that do not have Stage II vapor control are limited to the smallest throughput classification.

The facilities that did not ident ify whether or not they have Stage II vapor control are primarily limited to the smallest throughput classification (i.e., 73 out of 80

non

- respondents to this question).

Of the facilities that did identify that Stage II vapor control was present, 80

perce nt (i.e., 540 out of 675 facilities) had vacuum

- assisted systems, while the remaining 20 percent (i.e., 135 facilities) had balance systems.

The facilities that had balance Stage II vapor control systems were concentrated primarily in the smaller throughpu t classifications.

The overall yearly gasoline throughput derived from the survey results was estimated to be 745,413,813 gallons , which is about half annual fuel consumption . The disaggregation of this based upon Stage II control technology is as follo ws:

Vacuum

- assisted

– 696,954,309 gallons (93.5% of total)

Balance

– 38,502,475 gallons (5.2% of total)

Do not know

– 6,966,505 gallons (0.9% of total)

None

– 2,990,523 gallons (0.4% of total)

Another way of interpreting the results is that vacuum assist systems account for 95% of the gasoline dispensed at GDFs with Stage II systems.

The survey helps us describe the distribution of GDFs in terms of gasoline throughput. This distribution is used later in this report to evaluate the costs and effectiveness o f enhancements to the State’s Stage I and Stage II programs. We calculated two distributions of the GDFs. Results shown in Table 1 are disaggregated into five monthly facility throughput classifications that have previously been used in Stage II analyses

c onducted by the California Air Resources Board (ARB). 2 

### Results shown in Table 2 are disaggregated into 15 yearly facility throughput classifications that have previously been used in Stage I analyses conducted by the New York Department of Environmental

C onservation (DEC) 3



### . As shown on Tables 1 and 2, 336 out of 908 GDFs (37%) fell into the smallest gasoline throughput group, less than 300,000 gallons per year (less than 25,000 gallons per month).

1 Stage I and Stage II Gasoline Dispensing Emissions Inventory . Final. Prepared for the Texas Commission on Environmental Quality by Eastern Research Group, Inc. (ERG), Sacramento, CA. August 31, 2008.

2 Enhanced Vapor Recovery Technology Review . Staff Report. Prepared by the California Air Resources Board, Monitoring and Laboratory Division. October 2002.

3 Stage I and Stage II Vapor Recovery Analyses. PowerPoint presentation. Prepared by the New York Department

of Environmental Conservation.

### 3 Table 1

– Summary of Survey Results

– California ARB Classifications

Group Average

Monthly Throughput by Facility (gallons) Number of

Facilities Stage II Present? Type of Stage II System Number of USTs

Yes No Do Not

Know Vacuum Assisted Balanced 1 2 3 4 5 Blank

1 0

- 25,000 336 167 96 73 70 97 221 48 54 4 1 8

2 25,001

- 50,000 98 95 0 3 78 17 3 45 45 4 0 1

3 50,001

- 100,000 213 209 0 4 193 16 3 92 110 7 0 1

4 100,001

- 200,000 127 127 0 0 122 5 1 51 72 3 0 0

5 > 200,000 77 77 0 0 77 0 0 43 31 3 0 0



### Table 2

– Summary of Survey Results

– New York DEC Classifications

Group (gallons) Yearly Throughput

by Facility (gallons) Number

of

Facilities Stage II Present? Type of Stage II System Number of USTs

Yes No Do Not

Know Vacuum

Assisted Balanced 1 2 3 4 5 Blank

A (120,000) 0

- 300,000 336 167 96 73 70 97 221 48 54 4 1 8

B (400,000) 300,001

- 500,000 71 69 0 2 55 14 3 33 30 4 0 1

C (600,000) 500,001

- 700,000 71 68 0 3 65 3 1 31 36 2 0 1

D (800,000) 700,001

- 900,000 75 75 0 0 65 10 0 33 40 2 0 0

E (1,000,000) 900,001

- 1,100,000 60 60 0 0 56 4 2 27 29 2 0 0

F (1,200,000) 1,100,00

- 1,300,000 51 49 0 2 46 3 1 21 27 2 0 0

G (1,400,000) 1,300,00

- 1,500,000 31 31 0 0 29 2 0 14 16 1 0 0

H (1,600,000) 1,500,001

- 1,700,000 22 22 0 0 21 1 0 10 12 0 0 0

I (1,800,000) 1,700,001

- 1,900,000 25 25 0 0 24 1 0 9 16 0 0 0

J (2,000,000) 1,900,001

- 2,100,000 15 15 0 0 15 0 0 5 10 0 0 0

K (2,400,000) 2,100,001

- 2,700,000 36 36 0 0 36 0 0 13 22 1 0 0

L (3,000,000) 2,700,001

- 3,300,000 19 19 0 0 19 0 0 12 6 1 0 0

M (3,600,000) 3,300,001

- 3,900,000 15 15 0 0 15 0 0 11 4 0 0 0

N (4,000,000) 3,900,001

- 4,100,000 7 7 0 0 7 0 0 3 4 0 0 0

O (5,000,000) >4,100,000 17 17 0 0 17 0 0 9 6 2 0 0

### 4

3. WIDESPREAD USE (WSU) ANALYSIS

Widespread use (WSU) occurs when on

- board refueling vapor recovery (ORVR) systems provide the same benefits as Stage II systems. dKC estimated when GDFs in

Connecticut pass the WSU threshold. Appendix A presents the report dKC provided

DEEP on the WSU

. Results of the WSU analysis are summarized below:

a. Condition of Vapor Recovery Systems

– The WSU date is sensitive to the assumed effectiveness of Stage II. Data from Connecticut and other states indicate that Stage II systems quickly develop leaks and othe r malfunctions that cause them to fail system performance tes ts. It’s unlikely that Stage II systems have the 86% control efficiency that is assumed in Connecticut’s State Implementation Plan (SIP) . The actual Stage II control efficiency is likely to be 60% or less. dKC used two estimates of Stage II effectiveness: 86% and 60%. Corrected for rule penetration and rule effectiveness, this translates into an overall Stage II effectiveness of 82%

and 57%.

o Connecticut Test Results

– dKC reviewed two sources of

information on the con dition of GDFs in Connecticut: r esults of

official certification tests and results of additional GDF tests performed by dKC :

 Table 3 summarizes the initial results of GDF inspections that were witnessed by DEEP since December 20, 201 0. Overall, 70% of the GDFs failed inspection. The most common failure reasons were the tank decay test (45%), followed by air/liquid test ( A/L ) (14%).

 dKC commissioned additional GDF tests to help determine when key components of the vapor control system start to

deteriorate. These tests we re performed approximately 2

months and 4 months after the station receive d its certification test. Two stations participat ed : one i s a government station with a balance system; the other is a private station with a vacuum assist system. Table 4

summarizes results of these tests

. N one of the tests had an overall result of pass.

Table 3

– Results of Triennial GDF Inspections in Connecti cut

Parameter # and % of Failures

System

Pass/Fail Decay Dry Blockage Wet

Blockage P/V

Cap A/L 6

Click

# 111 72 5 6 10 23 13

% of Tests 70% 45% 3% 4% 6% 14% 8%

### 5 Table 4

– Results of Bi

- monthly GDF Inspections in Connecticut

Station /Stage II Type Test date Overall Result Failed items

J and A Gas

Vacuum Assist 6/2/11 Fail A/L Test

8/23/11 Fail A/L Test

DOT Newington

Balance 4/25/11 Fail P/V valve

7/14/11 Fail Decay, P/V valve, torn

hose

11/9/11 Fail Decay, P/V valve



### o Massachusetts Test Results

– Massachusetts DEP requires GDFs to report the initial results of their annual Stage II Certification

tests. Table 5 summarizes the percent of stations that f ail their initial Stage II test in Massachusetts. As shown, from 2001 through 2010, 66% to 82% of the GDFs fail the initial annual Certification tests. The primary problem causing test failures were seal caps and fittings that needed tightening.

o From May 2002 through October 2003, Massachusetts required

new GDFs with vacuum assist Stage II systems or significantly modified GDFs with vacuum assist systems to receive a Certification test 120 days after they were initially certified. Results

of these tests are shown on Table 6 . Results indicate that over half (56%) of the recen tly certified GDFs failed Certification tests 120 days later. The most common failure was for the pressure decay

test.

Table 5

– Results of Annual GDF Certification Tests in Massachusetts

Year % Fail

2001 82%

2002 78%

2003 75%

2004 67%

2005 76%

2006 78%

2007 78%

2008 73%

2009 71%

2010 66%

### 6

Table 6

– Results of 120 Day GDF Certification Tests in Massachusetts

Failure Reason # % Fail
Air/Liquid Ratio 17 17%
Pressure Decay 45 46%
P/V Cap 2 2%
Any Failure 55 56%



### o New Hampshire Test Results

-- According to vapor release research conducted by New Hampshire, Stage II repairs last an average of 58 days. Overall findings of New Hampshire’s research

found:

 Inspections and testing failed to fix key leaks.

 Most leaks re quired the station to upgrade the hardware (i.e. hoses, nozzles, breakaways).

 Gasoline deliveries triggered leaks

b. EPA’s WSU Determination

– On July 8, 2011, EPA published a Proposed Rule on WSU determination for Onboard Refueling Vapor Recovery ( ORVR) systems. EPA will consider that widespread use (WSU)

has occurred when emissions with Stage II systems alone equal

emissions with ORVR alone. In th e absence of state specific analysis

, EPA has set a WSU date of July 1, 2013.

dKC used EPA’s current e mission factor model, MOVES, to determine

WSU dates for Connecticut . Following are estimates based on MOVES of when emissions with Stage II systems alone equal emissions with ORVR

alone:

82 % Stage II efficiency: July 2012

57 % Stage II efficiency: 2007

- 2008

Figure 1 shows g/gal estimates for ORVR alone by model year vs. Stage II alone. WSU occurs when g/gal for ORVR alone drop below the Stage II lines.

### 7 Figure 1

c. Implications of EPA’s proposed rule

– EPA’s proposed WSU rule has implications for this analysis and future strategies for controlling emissions

at GDFs in Connecticut:

o Stage II Effectiveness: EPA lists the effectiveness of Stage II as

follows:

 Semi

- annual inspections: 92%

 Annual inspections: 86%

 Minimal or less frequent inspections: 62%

EPA assumes that 90% of gasoline is dispensed at GDFs with Stage II systems. ERG’s GDF survey determined that in Connecticut, 99% of gasoline is dispensed at GDFs with Stage II
systems. Based on GDF tests in Connecticut, Massachusetts, and New Hampshire, S tage II effectiveness is likely to be lower than

EPA’s estimates.

o ORVR/Stage II Incompatibility: The Proposed Rule acknowledges the incompatibility between ORVR and vacuum

- assist Stage II systems, saying that it reduces the effectiveness of Stage II by 1% to 10%. Incompatibility was not considered in the widespread use
determination, but EPA did mention that states should require Stage II systems to be upgraded to be ORVR compatible, if they opt to continue the requirement. Emissions resulting from the

inco mpatibility between ORVR and v acuum

- assist Stage II systems

are termed incompatibility excess emissions (IEE). Published IEE 0.000 0.200 0.400 0.600 0.800 1.000 1.200 1.400 1.600 1.800 2.000

2005 2010 2015 2020 Refueling Emissions: HC -- g/gal 

## Refueling Emissions: ORVR Alone vs. Stage II Alone
(MOVES)

ORVR

Stage II

-- 82%

Stage II

-- 57%

### 8 rates vary from a low of 0.42 lb/1000 gallons to a high of 2.5 lb/1000 gallons. dKC used 0.86 (California’s estimate) in its IEE

ca lculations.

o Backsliding : The Proposed Rule says that ozone non

- attainment areas must make up for any emission reductions that are lost due to terminating Stage II progra ms. The Rule does not state if IEE

can be factored into calculations of lost emissions reductions. If IEE is considered, continuing the current Stage II program without ORVR compatibility provides minimal benefits, and in fact, may increase emission in the future. Accounting for I EE, Connecticut must make up 0.48 tons/day VOC in 2013. By 2015, emissions increase if Stage II is continued due to IEE. Without considering

I EE, Connecticut must make up 1.8 tons/day in 2013 and 1.3 tons/day in 2015. IEE is discussed in greater detail below.

o Stage I Improvements: EPA ha s stated that states can make up

for the shortfall by improving Stag e I systems, even if these improvements only bring the system up to assumed SIP

effectiveness.

4. POSSIBLE STAGE II ENHANCEMENTS

If DEEP decides to continue the Stage II program it should co nsider the following

enhancements:

a. End ORVR Incompatibility

– Currently, vacuum assist Stage II systems in Connecticut are not compatible with on

- board refueling vapor recovery (ORVR). When a vehicle with ORVR is refueled at a GDF with a vacuum assist system, ambient air from the vicinity of the GDF nozzle will be

dr awn back into the GDF storage tank. This air dilutes the concentration of gasoline vapors in the headspace of the storage tank, causing some of the liquid gasoline in the storage tank to evaporate, which increases the storage tank pressure. If the tank pre ssure increases above the positive setting of the P/V valve, the storage tank will vent to the atmosphere. As
mentioned earlier, t he increased emissions that occur due to the dilution of the storage tank with air from ORVR vehicles is termed incompatibilit y excess emissions (IEE). IEE is limited to vacuum assist systems. Balance systems are generally compatible with ORVR systems. Almost all (94%) of the gasoline dispensed in Connecticut is dispensed at GDFs with vacuum assist systems.

IEE can be mitigated o r eliminated by the following measures:

a. Install n ozz les that sense ORVR vehicles,

b. Add devices called processors to capture or incinerate vapors at the vent, or

c. Convert to balance type systems.

### 9 b. Other Possible Stage II Enhancements

– In addition to addressing IEE with vacuum assist systems, other enhancements could be made to Stage II systems. These enhancements have been included in California’s Enhanced Vapor Recovery (CA EVR) program , and are listed below:

California EVR Module 2

– General Stage II improvements and tightened performance standards.

California EVR Module 6

– In

- Station Diagnostics (ISD) : ISD require GDFs to install systems that monitor tank pressure and air/liquid (A/L) and set alarms when there are problems

that could lead to excessive emissions. ISD is s imilar in concept to onboard diagnostic (OBD) systems that have

been on vehicles since 1996. A lot of concerns have been raised by industry over the reliability of ISD with regard to

m onitoring A/L. Monitoring GDF s for the presence of vapor

leaks appears to be reliable. Data from Veeder

- Root, which installs ISD systems in California , indicate that A/L alarms occur much more frequently than alarms for GDF vapor
leaks

.

c. Gasoline Dispensing Improvements

– The CA EVR program includes two modules that are theoretically applicable to GDFs with and without Stage II systems:

California EVR Module 4

– Liquid Retention and Spitting

California EVR Module 5

– Dripless Nozzles

Based on discussions with OPW, it’s uncertain if dripless nozzles are

feasible.

Appendix B summarizes the CA EVR program.

5. POSSIBLE STAGE I ENHANCEMENTS

DEEP ’s Stage I control program could be improved by implementing measures that go beyond current Stage I requirements:

a. Add vapor leak monitoring system

– Continuous monitoring of GDF tank pressure and other parameters that indicate the presence of vapor

leaks has the potential for significant emissions reductions . Based on GDF inspections, actual Stage I control efficiencies are much low er than the 96% control efficiency assumed in the SIP. In addition, the control efficiencies for breathing losses assumed for Pressure Vacuum (PV) valves are likely to be lower than the 90% control efficiency assumed in

the SIP. This measure could reduce S tate oversight costs if it were coupled with self

- certification of compliance. In this case, the requirement for State supervised inspections could be dropped , assuming EPA will revise its inspection requirements for Stage I systems to allow continuous

mon itoring as an alternative to periodic inspections

. Requiring these systems also will help assure the State that any leaks that result from

### 10 removing or capping Stage II systems will be promptly identified and repaired, should the State decide to terminate t he Stage II program.

b. Add pressure management system (emissions processors) to

eliminate vent emissions

– Managing the pressure with a vapor processor reduces breathing losses and maintains the tank pressure close to ambient to avoid fugitive emissions. Los ses are proportional to GDF gasoline sales volume. New York State is proposing to require stations

that dis pense more than 1,1 00,000 gallons per year to be equipped with
pressure management systems.

In addition to the above options, the CA EVR program outlines additional Stage I improvements in Module 1

. GDFs in Connecticut have most of these improvements. Following are additional enhancements included in CA EVR that could be made to Connecticut’s Stage I program:

c. Spill Containment Boxes

– California requires spill containment boxes to meet leak rate limits and prohibit standing fuel. Vendors have developed

double

- wall spill containers that meet CA EVR requirements.

d. Drop tube with Overfill Protection Specification

– California require s drop tube s to be equipped with devices that shut off liquid flow when the underground storage tank is being filled. These drop tube s also must meet leak rate specifications.

6. EMISSION REDUCT IONS FOR STAGE I AND STAGE II SYSTEM

IMPROVEMENTS

a. Gasoline Consumption

i. Emissions an d emission reductions are proportional to gasoline consumption

ii. Statewide consumption is based on Department of Revenue
reports.

Table 7

– Statewide Gasoline Consumption (2010)

MONTH GALLONS CONSUMED

JAN 119,417,253

FEB 109,313,343

MAR 124,366,769

APR 124,549,371

MAY 132,812,176

JUN 129,606,224

JUL 134,879,449

AUG 130,328,001

SEP 125,097,789

OCT 130,473,564

NOV 124,071,272

DEC 129,706,355

TOTAL 1,514,621,566

### 11 b. Current Stage II program

i. dKC estimated emissions reductions for :

1. C ontinuing the current Stage II program

2. Decommissioning the current Stage II program, with ORVR solely providing vapor recovery.

ii. Note on Figure 2 that c ontinuing Stage II (without ORVR compatible nozzles) increas es emissions after 2015 due to IEE.

Figure 2

Table 8

– VOC Emission Reductions (Tons/Day) for C ontinuing Current Stage II Controls (Negative Values mean that keeping Current Systems increase

emissions due to IEE 4 

### )

Year ORVR only Additional Reductions with Stage II

82% Control Efficiency 57% Control Efficiency

2012 11.194 0.833 0.579

2013 11.558 0.485 0.337

2014 11.869 0.189 0.131

2015 12.137

- 0.063

- 0.044

2016 12.313

- 0.233

- 0.162

2017 12.500

- 0.405

- 0.281



### c. M aking all Stage I I systems in CT ORVR compatible

. Two Stage II

control scenarios were evaluated:

4 IEE: Incompatibility Excess Emissions (0.86 lb/1000 gallons)

0.000 0.200 0.400 0.600 0.800 1.000 1.200 1.400 1.600 1.800 2.000

2005 2010 2015 2020 Refueling Emissions: HC -- g/gal 

## Refueling Emissions: ORVR Alone vs. Stage II + ORVR

(MOVES, 0.86 lb/1000 gal IEE)

ORVR Alone

ORVR+Stage II

-- 82%

ORVR+Stage II

-- 57%

### 12 i. Upgrading nozzles in the current program to be ORVR compatible. With this option, the current program will be retained with the requirement that stations must upgrade to ORVR compatible nozzles.

1. This option eliminates incompatibi lity excess emissions ( IEE )

2. Control efficiencies are based on current program data

3. Two efficiencies were modeled: 82% and 57%.

Emission estimates were calculated by multiplying g/gal estimates without Stage II (derived from MOVES) times annual gasoline

con sumption times estimated control efficiency.

4. By 2015, ORVR compatible Stage II systems have minimal

benefits

, as shown on Figure 3.

Figure 3

ii. Add California EVR elements that pertain to Stage II, including ORVR compatibility and in

- station diagnostics (ISD).

1. This option eliminates IEE

2. Control efficiency based on California EVR corrected for rule

effectiveness.

3. 90% control efficiency was modeled

4. This option gets slightly greater emission reductions than adding ORVR compatibility to the current Stage II program,
as shown on Table 9 below. 0 2 4 6 8 10 12 14 16

2005 2012 2015 2017 HC (tons/day) 

## Incremental Reduction in Refueling Emissions 82% Stage II Control Efficiency (tons/day)

ORVR Alone Stage II

### 13

Table 9

– Emission Reductions from Enhancing Stage II Systems to add ORVR

Compatibility and Other Enhancements (Tons/Day)

Year ORVR Alone Stage II Efficiency (Increase over ORVR alone)

90% (CA EVR) 82% (ORVR High) 57% (ORVR Low)

2012 11.194 2.252 2.052 1.426

2013 11.558 1.924 1.753 1.219

2014 11.869 1.644 1.498 1.041

2015 12.137 1.403 1.279 0.889

2016 12.313 1.245 1.134 0.788

2017 12.500 1.077 0.981 0.682



### d. Stage I Improvements

i. Continuous monitoring for GDF vapor leaks

– T he emission

reductions from real

- tim e monitoring for vapor leaks were estimated

as follows :

1. Estimated improvement in Stage I efficiency was applied to

e mission estimate s for GDF tank filling losses . No data has been identified on the improve ment in Stage I efficiency from eliminating leaks; 10% is assumed. As previously mentioned, GDF tanks quickly develop leaks that impact vapor containment, and increase filling losses.

2. T ank breathing loss estimates for New Y ork State were adjusted for Conne cticut’s GD F population by gasoline

volume (see Table 11 ) . The distribution of Connecticut’s GDFs is based on the GDF survey.

About 40% of the GDFs dispense less than 300,000 gallon s per year. As shown on Table 12 , exempting these GDFs from these requirements has a small impact on estimated benefits.

Table 10

– Assum ptions for Determining Reductions in Tank Filling Losses for

Continuous Monitoring for Vapor Leaks

Parameter Value

Uncontrolled Tank Filling losses (g/gal) 3.314

Stage I Efficiency Improvement 1 0%

### 14

Table 11

– Breathing Loss Reductions for Continuous Monitoring for Vapor Leaks

(Containment) and Pressure Management System (PMC) 5

Yearly Throughput

intervals # gas

stations

CT Recovery

factor from

containment (tons/GDF/Yr.) Containment

recovery (tons/year) Recovery factor

from

Containment &

PMC (tons/GDF/Yr.) Total

containment

& PMC

recovery (tons/year) Additional

from PMC (tons/year)

<300,000 803 0.06 47 0.06 47 0

300,000

- 500,000 170 0.18 30 0.19 33 2

500,000

- 700,000 170 0.17 29 0.29 49 20

700,000

- 900,000 179 0.26 47 0.39 70 23

900,000

- 1,100,000 143 0.28 41 0.49 70 29

1,100,000

- 1,300,000 122 0.28 34 0.58 71 37

1,300,000

- 1,500,000 74 0.27 20 0.68 50 31

1,500,000

- 1,700,000 53 0.41 22 0.78 41 19

1,700,000

- 1,900,000 60 0.40 24 0.87 52 28

1,900,000

- 2,100,000 36 0.40 14 0.97 35 20

2,100,000

- 2,700,000 86 0.55 47 1.16 100 53

2,700,000

- 3,300,000 45 0.61 28 1.46 66 39

3,300,000

- 3,900,000 36 0.58 21 1.75 63 42

3,900,000

- 4,100,000 17 0.64 11 1.94 32 22

>4,100,000 41 0.68 28 2.43 98 71

TOTAL 2,033 4 41 435



### Table 12

-- Emission Reductions for Continuous Monitoring for Vapor Leaks (Tons/Day)

Pollution

Source All GDFs GDFs with 300,000+ gal/year

Filling losses 1.51 1.47

Tank Breathing 1.21 1.08

Total 2.72 2.55



### ii. Require pressure management system ( emissions processors )

– GDFs will have breathing losses corresponding to the amount of air ingested in the tank and the evaporation rate.

1. Estimated benefits from requiring pressure management systems on high volume stations are based on information provided by Veeder

- Root. Losses are greatest in stations that dispense a lot of gasoline (see Figure 4 )

.

2. Based on available data, exempting stations that dispense

less than 1,1 0 0,000 gal/yr will reduce implementation costs by 72% while program benefits are only reduced by 17 % (from 1.2 to 1.0 tons/day ) (see Table 13 )

.

5 Personal Communication between Rob Klausmeier, dKC and Kristine Anderson, Veeder Root,
Vapor Emissions Workbook, November 8, 2011.

### 15 Figure 4

Table 13

– Breathing Loss Reductions for Pressure Management Controls (PMC)

Scenario Tons/day

All GDFs 1.2

GDFs with 1,1 00,000+ gal/yr 1.0



### iii. Other Stage I Enhancements

– Data were not available on the emission reductions from CA EVR requirements for spill

containment boxes and sp ecifications to reduce leaks in drop tubes with overfill protection devices installed

. These measures are likely to reduce tank leaks that would be identified by continuous vapor

leak monitoring systems, so they are unlikely to resu lt in significant additional benefits over tank pressure monitoring systems. This

does not mean these measures do not have merit. GDFs could install CA EVR approved drop tubes and spill containment devices to reduce incidents of pressure monitoring alarms.

e. Impact on Air Toxics

– The primary air toxic of concern with GDF operations is benzene. dKC used MOVES to estimate benzene emissions in vehicle refueling vapors. According to MOVES, benzene is 0.54% (mass percent) of refueling vapor. Reducing or increasin g gasoline vapor emissions will have a proportional impact on benzene emissions. 0 0.5 1 1.5 2

0 100,000 200,000 300,000 400,000 500,000 Tons VOC/GDF/yr

GDF Volume (gals/month) 

## Estimated Benefit of Pressure Management

System vs. GDF Volume

### 16

7. IMPLEMENTATION AND OPERATING C OSTS FOR CONTROL

ALTERNATIVES

a. Current Costs

i. Costs to Continue Stage II Systems

1. Annual cost for continuing Stage II. Cost sources:

a. New York State

-- $2,000 per GDF.

b. A PI: $4,410 per GDF.

c. EPA

-- $3,277 per GDF.

Table 14

-- Annual Costs to GDFs for Continuing Current Stage II Program

Low: New York State 6 High: API 7 EPA 8

Annual Stage II Cost/Station $2,000 $4,410 $3,277

Total Annual Stage II Cost $3,559,728 $7,849,343 $5,832,614



### b. Cost to Make all Stage I I systems in C onnecticut ORVR compatible

i. Costs to make Stage II systems compatible with ORVR systems are based on two sources: OPW and the CA EVR spreadsheet for
modules 2, 3, and 6.

1. OPW’s cost quotes were used as the basis of the costs for upgrading equipment to be compatible with ORVR systems. Upgrade costs are estimated to be $ 2,000 to $14 ,000 per

GDF 9



### .

2. Costs to continue the program (with ORVR compatibility) are

based on EPA’s cost estimate for continuing the current program plus the cost for ORVR upgrades based on OPW’s
cost quotes.

Table 1 5

– Annual Costs for ORVR Compatible Stage II Systems

Cost Component Annual Cost

Cost for Continuing Current Program (EPA Estimate) : Not including DEEP oversight) $5,832,614

ORVR Upgrade (source OPW) $3,797,338

Total $9,629,951

6 Part 230

-- Gasoline Dispensing Sites and Transport Vehicles, Stakeholder Meeting; New York Department of Environmental Pr otection, December 7, 2010.

7 REFUELING EMISSION CONTROLS AT RETAIL GASOLINE DISPENSING STATIONS AND COST

BENEFIT ANALYSIS OF STAGE II IN CONNECTICUT; Tech Environmental, Inc., September 24, 2007

8 Widespread Use for Onboard Refueling Vapor Recovery and Stage II Waiver; USEPA, July 8,

2011.

9 Personal Communication between Rob Klausmeier, dKC and Jeff Steel, OPW, August 8, 2011

### 17 c. Costs for Enhanced Stage II Systems: ORVR compatibility plus CA

EVR enhancements

i. The CA EVR spreadsheet 10 

### was used as the basis for the costs of a higher efficiency program that includes all the CA EVR Stage II upgrades.

1. California’s costs per GDF in different monthly throughput categories were multipl ied times the projected number o f

GDFs in Connecticut in these categories to estimate total

costs.

2. Costs were adjusted for inflation since 2001, when the CA EVR spreadsheet was last updated.

Table 1 6

– Fixed Costs per GDFs for Enhanced Stage II Systems (Source: California EVR Spreadsheet)

Group Average Monthly

Throughput by Facility (gallons) Vacuum

Assisted Balance

1 0

- 25,000 $22,678 $23,360

2 25,001

- 50,000 $24,056 $25,086

3 50,001

- 100,000 $29,305 $31,365

4 100,001

- 200,000 $34,549 $37,638

5 > 200,000 $39,549 $41,783



### Table 1 7

-- Total Annual Costs to CT GDFs for Enhanced Stage II Systems

(Source: California EVR Spreadsheet)

Group Average Monthly Throughput by Facility (gallons) Total Annual Cost

1 0

- 25,000 $2,844,983

2 25,001

- 50,000 $1,723,774

3 50,001

- 100,000 $5,028,657

4 100,001

- 200,000 $3,820,741

5 > 200,000 $2,885,281

TOTAL $16,303,440

10 EVR Cost Analysis Spreadsheet ; California Air Resources Board

, October 16, 2002

. Results adjusted for inflation using Marshall and Swift Equipment Cost Index.

### 18 d. Costs for Improving DEEP ’s Stage I control program by implementing measures that go beyond current Stage I requirements

i. R equiring real

- time monitoring for GDF vapor leaks

Two sources were used to define the costs for real

- time monitoring

for GDF vapor leaks :

New York State: Supporting data provided by Veeder

- Root f or proposed New York Part 230 Regulation 11



### . California EVR spreadsheet: Costs for the vapor leak monitoring portion of the California EVR program.

California’s and New York’s costs per GDF were multiplied times

the number of GDFs in Connecticut to estimate total costs. Both

sources yield similar estimates for fixed costs. Subsequent cost analysis is based on New York’s estimates.

As discussed above, exempting GDFs that dispense less than 300,000 gallons per year reduces emission reductions of this

mea sure by 7%; as shown on Table 19 , exempting these GDFs

red uces costs of this measure by 39 %.

Table 18

-- Fixed Costs for Continuous Monitoring for Vapor Leaks

Parameter Source

New York California

Cost/GDF $6,000 $6,105

Total Fixed Cost $12,198,000 $12,410,973



### Table 19

– Annual Costs for Continuous Monitoring for Vapor Leaks

Parameter Annualized Equip Costs Fuel

Savings Net Cost

Annual Cost per GDF $1,476
Costs for installing in all GDFs $3,001,668 $1,310,479 $1,691,190

Costs for installing in GDFs with 3 00,000+ gal/yr $1,816,521 $1,228,681 $587,839



### ii. Requiring GDF Tank Pressure Control System s

Costs for requiring GDFs to be equipped with tank pressure control
systems are based on estimates prepared by Veeder

- Root for New

York State DEC 10



### . Total costs are reduced by 72% by exempting

stat ions that dispense less than 1,1 00,000 gallons per year. This exemption re duces emission benefits by 16%.

11 Personal Communication between Rob Klausmeier, dKC and Kristine Anderson, Veeder Root, Vapor Emissions Workbook, November 8, 2011

### 19 Table 2 0

-- Fixed Costs for GDF Tank Pressure Control Systems

Parameter Costs
Fixed Cost per GDF $12,250

Costs for installing in all GDFs $24,904,250

Costs for installing in GDFs with 1,1 00,000+ gal/yr $6,964,996



### Table 2 1

– Annual Costs for GDF Tank Pressure Control Systems

Parameter Annualized Equip Costs Fuel

Savings Net Cost

Annual Cost per GDF $3,219

Costs for installing in all GDFs $6,543,477 $573,374 $5,970,103
Costs for installing in GDFs with 1,100,000+ gal/yr $1,830,021 $475,408 $1,354,613



### 8. COST PER TON OF POLLUTANT REDUCTIONS FOR CONTROL

ALTERNATIVES

a. M aking current Stage I I systems in Connecticut ORVR compatible

Table 2 2 shows the calculation of the emission reductions from improving Stage II systems to make them ORVR compatible. Emission estimates were calculated by multiplying g/gal estimates without Stage II ( derived

from MOVES ) times annual gasoline consumption times estimated control efficiency. Two Stage II control efficiencies were modeled: 82% and 57%. Regardless of the assumed control efficiency, by 2015 this option is expensive and results in relatively few emission reductions.

T able 2 2

– Cost Effectiveness of Improving Stage II Systems to m ake them Compatible with ORVR Systems

Annual Cost (2011$)

Includes DEEP Oversight Tons/

Yr Reduction Fuel Savings ($/yr.) $/Ton

Year g/gal

without Stage II (MOVES) 82% 57% 82% 57% 82% 57%

2011 0.669 $10,448,781

1 914 636 $1,205,20 3

3 $837,76 3

3 $10,108 $15,120

2012 0.547 $10,448,781 749 521 $986,968 $686,063 $12,635 $18,755

2013 0.468 $10,448,781 640 445 $843,418 $586,278 $15,010 $22,171

2014 0.400 $10,448,781 547 380 $720,661 $500,948 $17,791 $26,172

2015 0.341 $10,448,781 467 324 $615,095 $427,566 $21,071 $30,890

2016 0.303 $10,448,781 414 288 $545,486 $379,179 $23,928 $35,000

2017 0.262 $10,448,781 358 249 $471,845 $327,990 $27,868 $40,668



### b. Enhanced Stage II Systems: ORVR compatibility plus CA EVR

enhancements

dKC assumes that Stage II

, with all the CA EVR enhancements

, has a 90% control efficiency. This option results in slightly greater emission

### 20 reductions than just making Stage II s ystems compatible with ORVR systems, and is more costly in terms of $/ton.

Ta ble 2 3

– Cost Effectiveness of Implementing CA EVR Enhancements Including

ORVR Compatibility

– 90% Overall Control Efficiency

Year g/gal Annual Cost

(2011$)

Includes DEEP Oversight Tons/ Yr

Reduction Fuel Savings ($/yr.) $/ton

2011 0.669 $17,122,269 1,004 $1,322,784 $15,742

2012 0.547 $17,122,269 822 $1,083,258 $19,514

2013 0.468 $17,122,269 702 $925,702 $23,060

2014 0.400 $17,122,269 600 $790,970 $27,212

2015 0.341 $17,122,269 512 $675,104 $32,109

2016 0.303 $17,122,269 454 $598,704 $36,374

2017 0.262 $17,122,269 393 $517,879 $42,257



### c. Enhance Stage I: Requiring real

- time monitoring of GDF s for vapor
leaks

The calculation of the cost

- effectiveness of real

- time monitoring for vapor

leaks is shown on Table 2 4

. Cost effectiveness and emission reductions are shown graphically on Figure 5 . Exempting GDFs that dispense less than 300,000 gallons per year reduces $/ ton from $1, 701 to $ 631

. As mentioned above, dKC did not have access to data on the re duction in filling losses from real

- time monitoring for vapor leaks

. Emission reductions assume a 10% reduction in filling losses. Table 2 5 presents the

cost

- effectiveness of this measure when the only benefit is reduction in breathing loses. This measure still appears to be cost

- effective for GDFs that dispense mor e than 300,000 gallons per year.

### 21 Table 2 4

– Cost/Ton Estimates for Vapor Leak Monitoring Systems

Yearly Through put

intervals # gas

stations

CT $/Yr

Pressure Monitoring Cumul

$/yr (%) Filling Loss

Reduction

from

Pressure Monitoring tons/year Breathing

Loss

Reduction

from Pressure Monitoring tons/year Emissions

Reduction

from

Pressure Monitoring tons/year Cumulative

Reductions

from

Pressure Monitoring (%) Fuel Savings from

Pressure Monitoring $/ton

Pressure Monitoring

<300,000 803 $1,185,148 39% 15 47 62 7% $81,797 $17,778

300,000

- 500,000 170 $250,433 48% 21 30 51 12% $67,786 $3,551

500,000

- 700,000 170 $250,433 56% 32 29 61 19% $80,919 $2,761

700,000

- 900,000 179 $264,542 65% 45 47 92 27% $120,633 $1,572

900,000

- 1,100,000 143 $211,633 72% 45 41 85 36% $112,612 $1,159

1,100,000

- 1,300,000 122 $179,888 78% 45 34 78 45% $103,157 $980

1,300,000

- 1,500,000 74 $109,344 82% 32 20 52 51% $67,913 $804

1,500,000

- 1,700,000 53 $77,599 84% 26 22 48 55% $63,322 $297

1,700,000

- 1,900,000 60 $88,181 87% 33 24 57 61% $75,536 $221

1,900,000

- 2,100,000 36 $52,908 89% 22 14 37 64% $48,490 $120

2,100,000

- 2,700,000 86 $126,980 93% 64 47 111 75% $146,338

- $174

2,700,000

- 3,300,000 45 $67,017 95% 42 28 69 81% $91,524

- $353

3,300,000

- 3,900,000 36 $52,908 97% 40 21 60 88% $79,736

- $443

3,900,000

- 4,100,000 17 $24,691 98% 21 11 32 91% $41,536

- $535

>4,100,000 41 $59,963 100% 70 28 98 100% $129,180

- $706

Total All 2,033 $3,001,668 553 441 994 $1,310,479 $1,701

Total 300,000+ 1,230 $1,816,521 538 395 932 $1,160,896 $631

### 22

Table 2 5

– Cost/Ton Estimates for Vapor Leak Monitoring Systems Assuming

Only Benefit is Reduction in Breathing Losses

Yearly Throughput

intervals # gas

stations

CT $/Yr

Pressure Monitoring Breathing

Loss

Reduction

from

Pressure Monitoring tons/year Fuel Savings

from Pressure Monitoring $/ton Pressure

Monitoring

<300,000 803 $1,185,148 47 $61,570 $24,051

300,000

- 500,000 170 $250,433 30 $40,196 $6,893

500,000

- 700,000 170 $250,433 29 $38,176 $7,328

700,000

- 900,000 179 $264,542 47 $61,557 $4,346

900,000

- 1,100,000 143 $211,633 41 $53,769 $3,869

1,100,000

- 1,300,000 122 $179,888 34 $44,253 $4,040

1,300,000

- 1,500,000 74 $109,344 20 $26,017 $4,221

1,500,000

- 1,700,000 53 $77,599 22 $28,634 $2,254

1,700,000

- 1,900,000 60 $88,181 24 $31,828 $2,334

1,900,000

- 2,100,000 36 $52,908 14 $19,097 $2,334

2,100,000

- 2,700,000 86 $126,980 47 $62,475 $1,361

2,700,000

- 3,300,000 45 $67,017 28 $36,284 $1,116

3,300,000

- 3,900,000 36 $52,908 21 $27,365 $1,230

3,900,000

- 4,100,000 17 $24,691 11 $14,189 $975

>4,100,000 41 $59,963 28 $36,454 $850

Total All 2,033 $3,001,668 441 $581,863 $5,481.01

Total 300,000+ 1,230 $1,816,521 395 $480,097 $3,283.48



### Figure 5

### 23 d. Enhance Stage I: Requiring GDF tank pressure control systems

The calculation of the cost

- effectiveness of tank pressure cont rol systems

is shown on Table 2 6 . Cost effectiveness and emission reductions are shown graphically on Figure 6 . New York’s proposed exemption limit of 1,100,000 gallons/year makes sense. Exempting GDFs that dispense less than 1,100,000 gallons per year reduces costs by about 72% while emission reductions are reduced by only 16%, so $/ton is reduced from $1 4 ,000 to $3, 8 00.

Table 2 6

-- Cost/Ton Estimates for Tank Pressure Control Systems

Yearly Throughput

intervals # g as

stations

CT Additional

from PMC tons/year Cumulative

Reductions

from PMC (%) $/Yr PMC Cumul $/yr (%) Fuel

Savings $/yr $/ton

PMC

<300,000 803 0 0% $2,583,558 39% $0 NM

300,000

- 500,000 170 2 1% $545,931 48% $3,172 $225,517

500,000

- 700,000 170 20 5% $545,931 56% $26,876 $25,454

700,000

- 900,000 179 23 10% $576,687 65% $30,065 $23,962

900,000

- 1,100,000 143 29 17% $461,350 72% $37,853 $14,745

1,100,000

- 1,300,000 122 37 26% $392,147 78% $49,202 $9,186

1,300,000

- 1,500,000 74 31 33% $238,364 82% $40,257 $6,486

1,500,000

- 1,700,000 53 19 37% $169,162 84% $25,118 $7,558

1,700,000

- 1,900,000 60 28 44% $192,229 87% $36,889 $5,550

1,900,000

- 2,100,000 36 20 48% $115,337 89% $26,715 $4,372

2,100,000

- 2,700,000 86 53 60% $276,810 93% $69,462 $3,934

2,700,000

- 3,300,000 45 39 69% $146,094 95% $50,758 $2,475

3,300,000

- 3,900,000 36 42 79% $115,337 97% $55,096 $1,441

3,900,000

- 4,100,000 17 22 84% $53,824 98% $28,568 $1,165

>4,100,000 41 71 100% $130,716 100% $93,344 $528

Total All 2,033 435 $6,543,477 $573,374 $13,723

Total 1,100,000+ 569 361 $1,830,021 $475,408 $3,755

### 24 Figure 6

### 25

9. PROCEDURES FOR DECOMMISSIONING STAGE II SYSTEMS

Following is a summary of how to decommission the major components of Stage II

vapor recovery systems:

Vapor recovery piping

Hanging hardware for dispenser

Dispenser decals for instructions and proper use

Vacuum pump (only for vacuum

- assist systems)

Liquid drop

- out tank (if necessary)

The vacuum pump is a component unique to vacuum

- assiste d systems. Aside from the disabling these pumps, the steps to decommission both vacuum

- assisted and balance
systems are congruent.

Drawn from implemented procedures in Vermont and New York, as well as standard protocols from the Petroleum Equipment Instit ute’s (PEI) Recommend Practices for Installation and Testing of Vapor

- Recovery Systems at Vehicle

- Fueling Sites PEI RP

300

- 09, the steps to decommission each component of Stage II vapor recovery systems

are summarized below.

a. Vapor recovery piping

1. Disconnec t piping from dispenser(s). Purge any liquid from piping. Seal

with vapor

- tight cap or plug.

2. If accessible without excavation, disconnect piping from tank and seal.
Check for liquids and, if necessary, discard properly. Remove piping.

3. If tank is not access ible, leave piping in place (i.e., connected to tank) until

next excavation.

b. Liquid drop

- out tank

1. Some GDFs, where the slope between the dispensers and tanks is not

sufficient, require a drop

- out tank to collect any liquid accumulated in the
stage II vapor recovery piping.

2. Either remove or decommission the tank (i.e., remove any liquid,
disconnect the line, and seal).

c. V acuum pump

1. For systems with pumps for each dispenser:

i. Disconnect all electronic wiring for pump.

ii. Reprogram dispenser electronics to deactiva te stage II vapor

recovery.

### 26 iii. Drain any liquids from pump. If no gasoline remains in the pump, it
can be left in place. Otherwise, remove pump.

2. For systems with a central pump:

i. Remove the vacuum pump.

ii. Seal vapor piping previously attached to pump.

d. Hanging ha rdware

1. Drain liquid from hardware.

2. Replace stage II hanging hardware with conventional hardware and adjust

adaptors.

e. Dispenser decals

-- Remove stage II operating instructions from dispenser.

f. Final checks and tests

1. Confirm overfill protection device is fully functional. If the stage II vapor
piping is still connected to the tank and the protection device is not
operating correctly, gasoline may be released. If the device is found faulty,

it must be reinstalled.

2. Complete pressure decay and P/V valve test to ensure all components are

vapor

- tight.

3. Once passed, complete a tie

- tank test per ARB procedure TP

- 201.3C to

confirm all vents are functional.

g. Checklist and documentation

1. Complete form with GDF information and checklist.

2. Submit to necessary authorities.

The above procedures should only be administered by trained technicians. Though represented in the summary, we recommend Connecticut refer to PEI RP 300 for detailed steps on decommissioning stage II systems.

Next Steps

– dKC recommends that the following steps be taken if the State adopts regulations to remove the requirement for Stage II :

1. Immediately e xempt new or significantly modified GDFs from Stage II requirements.

2. Give priority to decommissioning Stage II in stations with vacuum

- assist systems

. D ecommission Stage II in GDFs with balance systems after vacuum

- assist systems are decommissioned.

3. Require stations that dispense more than 300,000 gallons per year to implement continuous vapor leak monitoring systems. Require stations below this volume level to continue periodic inspections for tank decay and P/V valve function.

### 27

10. CONCLUSIONS/RECOMMENDATIONS

Table 2 7 summarizes estimates of the emission reductions and cost effectiveness of Stage I and Stage I I options for calen dar year 2015

.

T able 2 7

– Estimates of Emission Reductions and Cost Effectiveness of Stage I and Stage II Options (2015 )

Control Measure Emission Reductions (T/D) Cost/Ton Decommission Stage II Program 0.04 to 0.06 Cost Savings

Make Current Stage II ORVR Compatible 0.9 to 1.3 $21,000 to $31 ,000

Upgrade Stage II to CA EVR Requirements 1.4 $32,000

Enhance Stage I: GDF Vapor Leak Monitoring System (exempt GDFs <300,000gal/yr) 1. 1 to 2.6 $ 630 to $ 3,3 0 0

Enhance Stage I: GDF Tank Pressure Control System (exempt GDFs <1,100,000gal/yr) 1.0 $3, 8 00



### Following are the primary conclusions of this project :

W idespread use (WSU) will take place by at least summer 2012. The State could argue that WSU has already occurred. There are minima l benefits and

in fact after 2014 there will be increases in emissions if GDFs must keep current Stage II systems beyond the WSU date

. Enhancing Stage II systems to make them compatible with ORVR systems is expensive. This measure is estimated to result in 0.9 to 1.3 tons per da y emission red uctions in 2014 at a cost of $21 ,000 to $31 ,000 per ton. Adopting Stage II improvements that are included in the California EVR program increases benefits by 0.1 to 0.5 tons/day at a cost of $32,000 per ton.

Enhancing Stage I systems to requi re continuous monitoring of GDF s for vapor leaks appears to be effective and relatively inexpensive. This measure

is estimated to result in 1. 1 to 2.6 tons per day emission reductions in 2015 at

a cost of $ 630 to $ 3,3 00 per ton. Exempting GDFs that dispense less than 300,000 gallons/year significantly improves the cost

- effectiveness of this

measure , while decreasing emissions reductions by only 7%. Requiring these
systems will help assure the State that any leaks that result from removing or capping Stage II systems will be promptly identified and repaired, should the State decide to terminate the Stage II program.

Adding GDF tank pressure control systems also appears to be cost effective.

This measure is estimated to result in 1 .0 tons per day emission redu ctions in 2015 at a cost of $3, 8 00 per ton. Exempting GDFs that dispense less than 1,100,000 gallons/year significantly improves the cost

- effectiveness of this

measure , while decreasing emissions reductions by 14%.

### 28 APPENDIX A

REPORT ON ANALYSIS OF WIDESPREAD USE (WSU) IN CONNECTICUT

INTRODUCTION

As part of a task to assist the Connecticut Department of Energy and Environmental Protection ( DEEP ) in evaluating the Gasoline Dispensing Facility (GDF) Vapor Control Program., dKC determined when onboard refueling vapor recovery (ORVR) systems in Connecticut’s vehicle fleet have met a particular threshold described as widespread use (WSU). ORVR systems were phased into the motor vehicle fleet beginning with the 1998 model year. Afte r Connecticut reaches WSU, EPA will allow it to terminate the Stage II portion of the Vapor Recovery program, provided it does not need the emission reductions from Stage II.

Results of the WSU analysis are summarized below:

a. Vacuum assist systems are used in 80% of the gasoline dispensing facilities (GDFs) with Stage II systems. From a gasoline throughput standpoint, vacuum assist systems account for 95% of the gasoline dispensed at GDFs with Stage II
systems.

b. Data from Connecticut and other states indicat e that Stage II systems quickly develop leaks and other malfunctions that cause them to fail system performance tests. It’s unlikely that Stage II systems have the 86% control efficiency that is assumed in Connecticut’s State Implementation Plan. The actua l control efficiency is likely to be 60% or less.

c. Recent correspondence between EPA and other states indicate that EPA will consider that widespread use (WSU) has occurred when emissions with Stage II systems alone equal emissions with ORVR alone. dKC used EPA’s current emission factor model, MOVES, and the NESCAUM WSU spreadsheet to determine WSU dates using this and other WSU criteria. Following are estimates of when emissions with Stage II systems alone equal emissions with ORVR

alone:

o MOVES:

 86% Stage I I efficiency: 2012

 60% Stage II efficiency: 2007

- 2008

o NESCAUM SPREADSHEET:

 86% Stage II efficiency: 2011

 60% Stage II efficiency: 2007

This report presents the results of the WSU analysis. First, we summarize the results of a survey of GDFs in Connecticut. The survey provides key inputs into the WSU analysis. Next, we review information on the condition of vapor recovery systems in GDF’s in Connecticut and nearby states. We then use different methods to assess if or

when WSU has occurred.

### 29

RESUL TS OF GDF SURVEY

Eastern Research Group ( ERG ) conducted a comprehensive survey of GDFs located in

Connecticut. ERG designed the survey sample from GDF data obtained from the

Connecticut DEEP . ERG filtered out facilities that were closed or inactive, or that were only handling non

- gasoline materials. 2,033 surveys were mailed out on February 17. Of these, 23 were undeliverable.

Survey responses were received for a total of 908 GDFs located in Connecticut. Based on the number of delivered surveys (i.e., 2,010 surveys), the survey response rate was 43.4%. For purposes of comparison, a comparable survey was conducted for a similar GDF sample size in Texas in 2008 and the return rate was only 27.4%. 12 

### The high survey response rate increases confidence that the findings of this study are applicable

to GDFs across the entire state of Connecticut.

ERG designed a Microsoft Access database to house the received survey data. All survey returns tha t were sent in via mail, fax, or PDF format were input into the database manually. Significant findings are shown below:

The 96 facilities that do not have Stage II vapor control are limited to the smallest throughput classification.

The facilities that d id not identify whether or not they have Stage II vapor control are primarily limited to the smallest throughput classification (i.e., 73 out of 80

non

- respondents to this question).

Of the facilities that did identify that Stage II vapor control was prese nt, 80 percent (i.e., 540 out of 675 facilities) had vacuum

- assisted systems, while the remaining 20 percent (i.e., 135 facilities) had balance systems.

The facilities that had balance Stage II vapor control systems were concentrated primarily in the small er throughput classifications.

The overall yearly gasoline throughput derived from the survey results was estimated to be 745,413,813 gallons. The disaggregation of this based upon Stage II control technology is as follows:

Vacuum

- assisted

– 696,954,30 9 gallons (93.5% of total)

Balance

– 38,502,475 gallons (5.2% of total)

Do not know

– 6,966,505 gallons (0.9% of total)

None

– 2,990,523 gallons (0.4% of total)

Another way of interpreting the results is that vacuum assist systems account for 95% of the ga soline dispensed at GDFs with Stage II systems.

CONDITION OF VAPOR CONTROL SYSTEMS

As part of this project, dKC is collecting information on the condition of Stage I/II vapor control systems in Connecticut. DEEP is providing dKC with the initial results of the triennial GDF inspections. In addition, dKC is commissioning additional GDF tests to

12 Stage I and Stage II Gasoline Di spensing Emissions Inventory . Final. Prepared for the Texas Commission on Environmental Quality by Eastern Research Group, Inc. (ERG), Sacramento, CA. August 31, 2008.

### 30

help determine when key components of the vapor control system start to deteriorate. dKC also has compiled information from other states on vapor control system

deter ioration rates.

Connecticut Test Results

– Table 1 a summarizes the initial results of GDF inspections that were witnessed by DEEP since December 20, 2010. Overall, 79% of the GDFs failed inspection. The most common failure reasons were the tank decay test (50%), followed by A/L (25%) and P/V Cap test (21%).

Table 1 a

– Results of Triennial GDF Inspections in Connecticut

Parameter # and % of Failures

System

Pass/Fail Decay Dry Blockage Wet

Blockage P/V

Cap A/L 6

Click

# 111 72 5 6 10 23 13

% of Tests 70% 45% 3% 4% 6% 14% 8%



### dKC commissioned additional GDF tests to help determine when key components of the vapor control system start to deteriorate. These tests we re performed approximately 2

months and 4 months after the station receive d its certification test. Two stations participat ed : one is a government station with a balance system; the other is a private station with a vacuum assist system. Table 1b summarizes results of these tests. N one of the tests had an overall result of pass.

Table 1b

– Results of Bi

- monthly GDF Inspections in Connecticut

Station/Stage II Type Test date Overall Result Failed items

J and A Gas

Vacuum Assist 6/2/11 Fail A/L Test

8/23/11 Fail A/L Test

DOT Newington

Balance 4/25/11 Fail P/V valve

7/14/11 Fail Decay, P/V valve, torn

hose

11/9/11 Fail Decay, P/V valve



### Massachusetts Test Results

– Other states and organizations have reported on the reliability of vapor control systems. Massachusetts DEP requires GDFs to report the

initial results of their ann ual Stage II Certification tests. Table 2 summarizes the percent of stations that fail their initial Stage II tests in Massachusetts. As shown, from 2001 through 2010, 66% to 82% of the GDFs fail the initial annual Certification tests. The primary problem causing test failures were seal caps and fittings that needed tightening. Note that Massachusetts required GDFs with vacuum assist systems to implement by July 2004 enhancements to improve the integrity of Stage I/II systems, e.g., product and vapor swive l adaptors. It’s hard to tell if these enhancements have lowered the failure

rate.

### 31

Table 2

– Results of Annual GDF Certification Tests in Massachusetts

Year % Fail

2001 82%

2002 78%

2003 75%

2004 67%

2005 76%

2006 78%

2007 78%

2008 73%

2009 71%

2010 66%



### From May 2002 through October 2003, Massachusetts required new GDFs with vacuum assist Stage II systems or significantly modified GDFs with vacuum assist systems to receive a Certification test 120 days after they were initially certified. Results

of these tests are shown on Table 3. Results indicate that over half (56%) of the recently certified GDFs failed Certification tests 120 days later. The most common failure was for the pressure decay test.

Table 3

– Results of 120 Day GDF Certification Tests in M assachusetts

Failure Reason # % Fail

Air/Liquid Ratio 17 17%

Pressure Decay 45 46%

P/V Cap 2 2%

Any Failure 55 56%



### New Hampshire Test Results

– According to vapor release research conducted by New Hampshire, Stage II repairs last an average of 58 days. Overall findings of New Hampshire’s research found:

1. Inspections and testing failed to fix key leaks

2. Most leaks required the station to upgrade t he hardware (i.e. hoses, nozzles, breakaways)

3. Gasoline deliveries triggered leaks

Summary

– Based on available data, it’s unlikely that Stage II systems in Connecticut are achieving the 86% control efficiency assumed in Connecticut’s State Implementation P lan (SIP). Data were not available that relate specific failure modes to a reduction in control efficiency. Assuming that stations that fail GDF inspections see a 50% drop in control efficiency, the actual control efficiency is less than 60%. The WSU analy sis uses a range between 60% and 86% for control efficiency.

### 32

PREDICTIONS OF WHEN WSU OCCURS

Definition of Widespread Use

Four general definitions have been proposed to determine when widespread use (WSU)

has occurred:

a. When “x” percent of the vehicles in s ervice are ORVR

- equipped. 75% and 85% have been proposed for “x”.

b. When “x” percent of the vehicle miles traveled (VMT) are from ORVR

- equipped

vehicles.

c. When total VOC emissions with ORVR

- equipped vehicles are equal to total VOC emissions with Stage II VRS programs:

1. When emissions with Stage II alone equal emissions with ORVR

alone.

2. When emissions with Stage II and ORVR combined including Incompatibility Excess Emissions (IEE) equal emissions with ORVR

alone.

d. When “x” percent of gasoline sold is dispensed to ORVR

- equipped vehicles.

EPA ’s recent WSU analysis is based on definition c. 1 (When emissions with Stage II alone equal emissions with ORVR alone). dKC calculated WSU using all of the above

methods.

Incompatibility Excess Emissions (IEE) Factors

-- The as sumed incompatibility excess emissions (IEE) factor is a key parameter in estimating when WSU occurs using method c.2. ( When emissions with Stage II and ORVR combined including IEE equal emissions with ORVR alone). IEE refers to the increase in GDF emissio ns from using vacuum assist systems to refuel vehicles with on

- board refueling vapor recovery (ORVR) systems. When a vehicle with ORVR is refueled at a GDF with a vacuum assist system, ambient air from the vicinity of the GDF nozzle will be drawn back into the GDF storage tank. This air dilutes the concentration of gasoline vapors in the headspace of the storage tank, causing some of the liquid gasoline in the storage tank to evaporate, which increases the storage tank pressure. If the tank pressure increas es above the positive setting of the P/V valve, the storage tank will vent to the atmosphere. Almost all (94%) of the gasoline dispensed in Connecticut is dispensed at GDFs with vacuum assist systems.

Table 4 documents different estimates of IEE. Based on their research, California Air Resources Board uses an IEE factor for vacuum assist systems of 0.86 lb/1000 gallons of fuel dispensed. The American Petroleum Institute (API) believes that the IEE facto r
should be lower based on their studies. Recent tests by Veeder

- Root place the IEE factor between 1.5 and 2.5 lb/1000 gallons. dKC analyzed WSU using two IEE factors: 0.42 lb/1000 gallons and 0.86 lb/gallons.

### 33 Table 4

– IEE Factors 13

Data Collected by Nozzle Type Excess Emissions (lb/1000 gallons)

CARB Standard (no boot) 0.86

CARB Mini

- booted 0.43

API Standard (no boot) 0.72

API Standard (no boot) 0.42*

API Mini

- booted 0

Veeder

- Root Not

- specified 1.5

- 2.5 (2.0 most likely)

*Rate is for total incompatibility emissions. Total incompatibility emissions are the difference between all refueling emissions (pressure

- related fugitives, P/V valve and fill pipe emissions) for an ORVR vehicle

versus a non

- ORVR vehicle.



### Estimating When WSU Occurs

dKC too k two approaches to estimate when WSU occurs:

1. Modify and run the NESCAUM widespread use (WSU) spreadsheet.

2. Use EPA’s latest vehicle emissions model, MOVES, to determine refueling emissions with and without Stage II.

WSU Spreadsheet

– The Northeast States for Coordinated Air Use Management (NESCAUM) developed a spreadsheet model for calculating when WSU occurs. NESCAUM modified a model that was initially developed by Todd Tamura who was a

consultant for the American Petroleum Institute (API). The model calculates refueling emissions using algorithms from EPA’s MOBILE6 model. It also calculates Incompatibility Excess Emissions (IEE). The model calculates composite refueling emissions in g/gal and total emissions in tons/day. The spreadsh eet model has been used by NESCAUM and other organizations for ORVR WSU analyses. In 2007, Ariel Garcia updated the spreadsheet with Connecticut specific parameters. These parameters include Stage II effectiveness and vehicle registration distributions. Th e vehicle registration distribution was based on 2007 Connecticut vehicle registration data from the Department of Motor Vehicles (DMV).

dKC has updated the spreadsheet model using 2009 vehicle registration data and the fraction of gasoline dispensed at v acuum assist stations, based on results of the recently completed survey of GDFs in Connecticut.

MOVES

-- dKC also used EPA’s latest emission factor model, MOVES, to estimate when WSU occurs based on Definition c): W hen total VOC emissions with ORVR

equip ped vehicles are equal to total VOC emissions with Stage II VRS programs. EPA is now requiring states to use MOVES to estimate vehicle emissions and the impact of controls such as Stage II and Inspection/Maintenance (I/M) programs. MOVES is much

13 Reference: REFUELING EMISSION CONTROLS AT RETAIL GASOLINE DISPENSING STATIONS

AND COST

- BENEFIT ANALYSIS OF STAGE II IN CONNECTICUT, Tech Environmental, Inc., September

24, 2007.

### 34

different than EPA’s past “MOBILE” models, and requires complex data input files.

DEEP provided dKC with MOVES input files by county for years 2007, 2013, 2017 and 2020. For this analysis, dKC modified 2013 input files for Fairfield County for all the years evaluate d. Using information outputted by MOVES, dKC calculated composite refueling emissions in g/gal.

WSU Predictions based on NESCAUM spreadsheet

dKC used the NESCAUM spreadsheet to determine WSU dates based on the percent

of vehicles with ORVR and emissions wi th and without Stage II.

WSU based on the percent of vehicles with ORVR

-- Table 5 presents the WSU dates (in calendar year) based on the WSU spreadsheet for definitions:

a) percent of vehicles,

b) percent of VMT, and

d) percent of gasoline consumed.

Table 6 shows the ORVR percentages by calendar year.

Table 5

– Widespread Use (WSU) Dates Based on % of Vehicles, VMT, and

Gasoline Sales

Method Calendar Year

a. When “x” percent of the vehicles in service are ORVR

- equipped

75% 2012

- 2013

85% 2015

- 2016

b. When “x” percent of the vehicle miles traveled (VMT) are from ORVR

- equipped vehicles

75% 2009

- 2010

85% 2012

d. When “x” percent of gasoline sold is dispensed to ORVR

- equipped vehicles

75% 2010

- 2011

85% 2012

- 2012



### Table 6

-- Fraction of Fleet with ORVR

Calendar

Year Vehicle Basis,

Definition a VMT Basis,

Definition b Fuel Usage Basis,

Definition d

2001 13% 17% 14%

2002 18% 22% 19%

2003 23% 28% 25%

2004 29% 35% 31%

2005 35% 43% 39%

2006 42% 51% 47%

### 35 Calendar

Year Vehicle Basis,

Definition a VMT Basis,

Definition b Fuel Usage Basis,

Definition d

2007 49% 58% 55%

2008 55% 65% 62%

2009 61% 71% 69%

2010 66% 77% 74%

2011 70% 81% 79%

2012 74% 85% 83%

2013 78% 88% 87%

2014 81% 91% 89%

2015 83% 93% 92%

2016 85% 94% 93%

2017 87% 96% 95%

2018 88% 96% 96%

2019 89% 97% 96%

2020 90% 97% 97%



### WSU Based on Emissions with and without Stage II

-- In addition to the three methods based on the percent of vehicles, VMT or gasoline consumption for ORVR equipped vehicles, a fourth method has been proposed for WSU determination. With this method, WSU is said to occur when total VOC emissions with ORVR

- eq uipped vehicles are equal to total VOC emissions with Stage II vapor recovery programs. Two ways of doing this calculation have been proposed:

1. When emissions with Stage II alone equal emissions with ORVR alone.

2. When emissions with Stage II and ORVR includi ng Incompatibility Excess Emissions (IEE) equal emissions with ORVR alone.

As mentioned earlier, EPA appears to be leaning towards definition 1 for WSU

determination.

The WSU spreadsheet allows users to input Stage II control efficiencies. Connecticut’s

S tate Implementation Plan (SIP) assumes that the Stage II systems have 86% control efficiency. The SIP also assumes that Rule Penetration for Stage II is 99% and that Rule Effectiveness is 96.8%. Based on information on the condition of the Stage II
systems at representative GDFs, dKC believes that the Stage II effectiveness factor for Connecticut should be lower than 86%. For the WSU analysis, dKC used two control efficiency factors: 86% and 60%. When these factors are adjusted for Rule

Effectiveness and Ru le Penetration, the overall control efficiencies for the two scenarios

are 82% and 57%.

Table 7 presents the calculated WSU dates when WSU is defined as when emissions with Stage II systems alone equal emissions with ORVR alone. This calculation is not

aff ected by the assumed IEE factor. As shown, with 86% Stage II effectiveness, the

### 36

WSU date is 2011; with 60% effectiveness the WSU date is 2007. Figure 1 shows refueling emissions in g/gal for ORVR alone and Stage II alone.

Table 7

– WSU Date When Emissions with Stage II Systems Alone Equal Emissions with ORVR Systems Alone (Definition c.1)

– Spreadsheet Results

Assumed Stage II Effectiveness WSU Date

82% (86% Adjusted for Rule Penetration and Effectiveness) 2011

57% (60% Adjusted for Rule Penetration and Effectiveness) 2007



### Figure 1

Table 8 presents the calculated WSU dates when WSU is defined as w hen emissions with Stage II and ORVR combined (including IEE) equal emissions with ORVR alone.

This definition determines the time when overall VOC emission s will increase due to IEE. It assumes that ORVR compatible Stage II systems are not used in Connecticut. Total IEE are sensitive to the assumed percentage of balance vs. vacuum assist systems. Based on ERG’s survey of GDFs, dKC assumes that 94% of the gas oline is dispensed at stations using vacuum assist systems and 5% is dispensed at stations using balance systems. dKC analyzed WSU using two IEE factors: 0.42 lb/1000 gallons and 0.86 lb/gallons, and two Stage II effectiveness factors, 82% and 57%. As show n on Table 8, the WSU date by this definition is effected by the IEE factor, but not the assumed Stage II effectiveness factor.

Figure 2 shows refueling emissions in g/gal for ORVR alone and Stage II plus ORVR (including IEE) when an IEE factor of 0.86 lbs/1000 gal is input into the spreadsheet.

0.000 0.500 1.000 1.500 2.000 2.500

2005 2010 2015 2020 Refueling HC -- g/gal 

## ORVR Alone vs. Stage II Alone

(WSU Spreadsheet)

ORVR

Stage II

-- 82%

Stage II

-- 57%

### 37

After approximately 2013, emissions for the ORVR + Stage II scenarios are greater than for the ORVR only scenario.

Table 8

– WSU Date When Emissions with Stage II Systems plus ORVR Equal

Emissions with ORVR Systems Alone (Definition c.2)

Assumed Stage II

Effectiveness Assumed Incompatibility Excess Emissions (IEE)

(#/1000 gallons)

0.86 0.42

82% 2013 2015

57% 2013 2015



### Figure 2

WSU Predictions Based on MOVES

MOVES can be used to determine when WSU occurs according to definition c, when emissions with Stage II equal emissions with ORVR alone. To use MOVES to estimate emissions for the different WSU scenarios, dKC did the following:

1. Developed input files. DEEP p rovided input files for different counties and calendar years. dKC used the 2013 Fairfield County file with appropriate calendar year modifications for all the MOVES runs. Fairfield County has the most vehicles miles traveled (VMT) in Connecticut. All runs were made for July.

2. Ran MOVES for the following scenarios: 0.000 0.500 1.000 1.500 2.000 2.500

2005 2010 2015 2020 Refueling HC -- g/gal 

## ORVR Alone vs. Stage II+ORVR

(WSU Spreadsheet) 0.86#/1000 gal IEE

ORVR Alone

ORVR+Stage II

-- 82%

ORVR+Stage II

-- 57%

### 38 a. On

- board vapor recovery (ORVR) only: Compared refueling emissions estimates in g/gal with uncontrolled estimates.

i. Uncontrolled estimates in g/gal were derived by running MOVES for calendar year 1 990 without vapor controls.

ii. Emissions with ORVR only (no Stage II) were estimated for calendar years 2005, 2011, 2012, 2012, 2013, 2014, 2015, 2016

and 2017. dKC edited the CountyYear file in the MOVES database to set the vapor control program effectiveness to 0%.

b. ORVR + Stage II with appropriate effectiveness inputs. dKC ran the same years using the following Stage II effectiveness factors:

i. 57% Stage II effectiveness (60% adjusted for Rule Penetration and Effectiveness)

ii. 82% Stage II effectivene ss (86% adjusted for Rule Penetration and Effectiveness)

3. Using the following procedure based on energy consumption estimates outputted by MOVES, dKC calculated incompatibility excess emissions (IEE).

a. Calculate gasoline consumption (1 gallon=115,000 MMBtu)

.
b. Calculate IEE for a range of IEE factors:

i. 0.42 #/1000 gal

ii. 0.86 #/1000 gal

c. Add IEE to the estimates for the ORVR + Stage II scenario.

Predictions of when ORVR alone provides the same emission reductions as Stage II

– MOVES provides a means of calculating when ORVR alone will provide the same emission reductions as Stage II alone. The user can set the effectiveness of a region’s vapor control program to 0% and calculate refueling emissions. The drop in refueling emissions will be due to phase

- in of vehicles with ORVR.

Table 9 shows the WSU date for this definition based on MOVES. Table 10 presents MOVES estimates for refueling emissions in g/gal for the non

- Stage II scenarios. The percent control column can be directly compared to Stage II control efficiency . For example, in 2012, ORVR alone provides 82% control efficiency, which is equivalent to applying 82% efficient Stage II controls to a non

- ORVR fleet. Results for the ORVR alone case are compared with the two Stage II effectiveness scenarios on Figure 3.

Table 9

– WSU Date When Emissions with Stage II Systems Alone Equal Emissions with ORVR Systems Alone (Definition c.1)

– MOVES Results

Assumed Stage II Effectiveness WSU Date

82% (86% Adjusted for Rule Penetration and Effectiveness) 2012

57% (60% Adjusted for Rule Penetration and Effectiveness) 2007

- 2008

### 39 Table 10

– MOVES Refueling Emission Estimates

– ORVR Alone

Year Refueling Vapor Distance

(miles) g/mi Gallons MPG g/gal %

Control

1990 328,677 696,461,824 0.2143 49,790,737 13.988 2.997 0%

2005 158,985 695,594,368 0.1038 40,254,445 17.280 1.793 40%

2011 58,217 695,284,544 0.0380 39,534,749 17.587 0.669 78%

2012 46,982 695,322,688 0.0307 38,959,823 17.847 0.547 82%

2013 39,571 695,322,688 0.0258 38,399,333 18.108 0.468 84%

2014 33,168 695,334,432 0.0217 37,668,001 18.460 0.400 87%

2015 27,780 695,346,176 0.0181 36,964,029 18.811 0.341 89%

2016 24,048 695,301,600 0.0157 36,081,156 19.270 0.303 90%

2017 20,316 695,257,024 0.0133 35,239,367 19.73 0.262 91%



### As shown on Table 9 and Figure 3, the WSU date is between 2007 and 2008 for the 57% Stage II effectiveness case, and 2012 for the 82% Stage II effectiveness case. These are about one year higher than the WSU dates derived from the WSU spreadsheet. Note tha t the WSU spreadsheet uses 2009 registration data, while the MOVES files provided by DEEP appear to use 2007 registration data. In December 2010, when dKC investigated the sensitivity of the WSU dates to the registration data, we found that using 2009 data lowered WSU dates by about one year, because the 2009 data projected a younger light

- truck fleet.

Figure 3

0.000 0.200 0.400 0.600 0.800 1.000 1.200 1.400 1.600 1.800 2.000

2005 2010 2015 2020 Refueling HC -- g/gal 

## ORVR Alone vs. Stage II Alone (MOVES)

ORVR

Stage II

-- 82%

Stage II

-- 57%

### 40

Predictions of when ORVR alone provides the same emission reductions as Stage II plus ORVR

– In order to use MOVES to determine when emissions with ORVR alone are lower than emissions with ORVR plus Stage II, it is necessary to separately calculate incompatibility excess emissions (IEE). MOVES estimates petroleum energy consumption from which we derive estimated gasoline consumption. Then, IEE fa ctors are applied to gasoline consumption estimates to estimate total IEE. Total IEE is then added to MOVES estimates of refueling emissions with Stage II controls.

Table 11 shows WSU dates for the scenario where emissions with Stage II begin to

increase o ver the ORVR scenario alone. Table 12 shows the calculation of total refueling emissions for the Stage II plus ORVR scenario, accounting for IEE. Results are shown graphically on Figure 4. The WSU date using an IEE factor of 0.86 lb/1000 gal is between 201 4 and 2015. The WSU date using an IEE factor of 0.42 lb/1000 gal is estimated to be 2018. The WSU date by this definition is not sensitive to the assumed Stage II effectiveness factor.

Table 11

– WSU Date Based on MOVES When Emissions with Stage II System s plus ORVR Exceed Emissions with ORVR Systems Alone (Definition c.2)

Assumed Stage II

Effectiveness Assumed Incompatibility Excess Emissions (IEE)

(#/1000 gallons)

0.86 0.42

82% 2014

- 2015 2018

57% 2014

- 2015 2018



### Table 12

– MOVES Refueling Emission Estimates

– ORVR Alone vs. Stage II +

ORVR

-- With Incompatibility Excess Emissions (IEE)

Scenario Year Refueling

Vapor

ORVR only (#) Refueling

Vapor

ORVR only (g/gal) Refueling

Vapor ORVR + Stage II (g/gal)

No IEE gallons %

ORVR IEE (g/gal) Total Refueling Stage II w/IEE (g/gal)

0.42 0.86 0.42 0.86

82%

Control 2005 158,985 1.793 0.323 40,254,445 39% 0.061 0.125 0.3837 0.4476

2011 58,217 0.669 0.120 39,534,749 79% 0.124 0.253 0.2441 0.3738

2012 46,982 0.547 0.099 38,959,823 83% 0.130 0.267 0.2288 0.3653

2013 39,571 0.468 0.084 38,399,333 87% 0.136 0.278 0.2198 0.3618

2014 33,168 0.400 0.072 37,668,001 89% 0.140 0.286 0.2119 0.3584

2015 27,780 0.341 0.061 36,964,029 92% 0.143 0.294 0.2048 0.3550

2016 24,048 0.303 0.054 36,081,156 93% 0.146 0.299 0.2006 0.3536

2017 20,316 0.262 0.047 35,239,367 95% 0.148 0.303 0.1952 0.3503

57%

Control 2005 158,985 1.793 0.771 40,254,445 39% 0.042 0.087 0.8134 0.8578

2011 58,217 0.669 0.287 39,534,749 79% 0.086 0.176 0.3735 0.4637

### 41

Scenario Year Refueling

Vapor

ORVR only (#) Refueling

Vapor

ORVR only (g/gal) Refueling

Vapor ORVR + Stage II (g/gal)

No IEE gallons %

ORVR IEE (g/gal) Total Refueling Stage II w/IEE (g/gal)

0.42 0.86 0.42 0.86

2012 46,982 0.547 0.235 38,959,823 83% 0.091 0.185 0.3260 0.4208

2013 39,571 0.468 0.201 38,399,333 87% 0.094 0.193 0.2954 0.3941

2014 33,168 0.400 0.172 37,668,001 89% 0.097 0.199 0.2691 0.3710

2015 27,780 0.341 0.147 36,964,029 92% 0.100 0.204 0.2464 0.3508

2016 24,048 0.303 0.130 36,081,156 93% 0.102 0.208 0.2317 0.3380

2017 20,316 0.262 0.113 35,239,367 95% 0.103 0.211 0.2155 0.3233



### Figure 4

0.000 0.200 0.400 0.600 0.800 1.000 1.200 1.400 1.600 1.800 2.000

2005 2010 2015 2020 Refueling HC -- g/gal 

## ORVR Alone vs. Stage II + ORVR (MOVES)

0.86#/1000 gal IEE

ORVR Alone

ORVR+Stage II

-- 82%

ORVR+Stage II

-- 57%

### 42 APPENDIX B

DESCRIPTION OF CALIFORNIA ENHANCED VAPOR RECOVERY PROGRAM (CA EVR)

Module 1: Phase I Vapor Recovery

ARB Staff proposes to increase efficiency requirements to gain additional emission reductions as well as require more stringent leak requirements for Phase I components to ensure these efficiencies are achievable at all installations. The proposed certification requirements for Phase 1 vapor recov ery system certification are set forth in CP

- 201, “Certification Procedure for Vapor Recovery Systems for Gasoline Dispensing Facilities.” Proposed changes to Phase I certification consist of an increase in the efficiency requirement from 95% to 98%, a new specification for Phase I couplers to reduce leaks, new performance specifications for drain valves in spill containment boxes and other improved Phase I equipment specifications.

A. Increase from 95% Efficiency to 98% Efficiency Standard

B. Phase I Ada ptor Specifications : Phase I adaptors are the connection points for the cargo tank truck to the service station underground storage tank. The adaptors tend to become loose during the bulk drop as the cargo tank driver connects and disconnects the hoses for the fuel transfer. This is one of the commonly identified causes of leaks from vapor recovery systems, as well as a contributing factor to reduced effectiveness of the Phase I system. Staff has added a requirement for 360 degree rotatable Phase I vapor an d product adaptors.

C. Drop tube with Overfill Protection Specification: A new specification is proposed to reduce leaks in drop tubes with overfill protection devices installed. These devices are installed in the Phase I drop tube and use a valve to shu t off liquid flow when the underground storage tank is being filled. The moving parts and the fasteners, which connect the flapper valve to the drop tube, can result in holes that can lead to air ingestion during the bulk drop. All drop tubes

with overfill protection will be required to meet a pressure vs. flow specification of < 0.17 CFH at

2 inches water column.

D. Pressure/Vacuum Relief Valves (P/V Valves) on Vent Pipes: Vent pipes are required for gasoline underground storage tanks to allow venting of vapors if the underground tanks develop significant pressure. The EVR proposal requires P/V valves for all systems.

E. Spill Containment Boxes: Spill containment boxes are required by the State Water Resources Control Board (SWRCB) to contain any spills which occur during the bulk drop. ARB staff have added product containment box standards which limit the leak rate to < 0.17 CFH at + 2.0 inches H2O and prohibit any standing fuel in the containment box of product connectors.

Drain valves would be prohibited in the spill boxes of vapor connectors under this proposal. In addition, any application for certification of a drain valve that requires unreasonable maintenance shall be deemed unacceptable.

F. Connectors and Fittings: Loose connectors and fi ttings can also lead to leaks in the underground tank vapor. This new specification explicitly states that connectors and fittings shall

be leak

- free as determined by either leak detection solution or by bagging the fittings and observing inflation of the bag.

### 43

G. Fuel Blend Compatibility: Phase I components must be demonstrated to be compatible with fuel blends approved for use and commonly used in California, including fuels meeting the recently adopted Phase III fuels requirements.

Module 2: Phase II Vapor Recovery

Field inspections conducted jointly by ARB and district staff have uncovered many deficiencies in installed Phase II systems. ARB staff is working with the districts and equipment manufacturers to resolve these problems, however, it became clear that many reliability concerns could be addressed during the certification process. Staff has proposed extending the certification tests and expanding on the tests required during certification to thoroughly address durability and reliability issues. Staff has also identified new emission points for gasoline vapor emissions and proposed new standards to control these emissions.

Fugitive leaks from the underground storage tank are a concern with existing systems. Staff has proposed pressure profiles t hat would limit underground storage tank pressures and assess leaks in the vapor space. Increased use of processors is expected to maintain desired underground storage tank pressures, but concerns have been raised regarding toxics in the

exhaust of combust ion processors. New limits for selected hazardous air pollutants are included in the proposal. Another proposal to address system deficiencies is to limit the certification to four years with renewal contingent on successfully addressing any problems that have been documented during the four

- year period. Currently, certifications have no expiration date.

A. Include Pressure

- Related Fugitives in Efficiency Standard Calculation

B. Replace Efficiency Requirement with Emission Limit

C. Compatible with Phase I System: Staff proposes a new standard requiring that Phase II vapor recovery systems shall not cause excess emissions from Phase I systems.

D. Underground Storage Tank Pressure Limits

E. Nozzle/Dispenser Compatibility: Staff proposes a new standard fo r nozzle/dispenser compatibility to verify that the vapor check valve and hold

- open latch are closed when the nozzle is properly hung on the dispenser.

F. Unihose MPD Configuration: Gasoline dispensers may have three hoses per fueling point,

one for each grade of gasoline, or just one hose for all grades, which is known as a unihose configuration. The unihose configuration reduces the number of hoses, nozzles and other hanging hardware by two

- thirds. As this equipment has leak sources, such as check valves , the less hanging hardware, the less potential for leaks. Staff proposes that all systems have unihose dispensers to reduce the potential number of leak sources.

G. Liquid Removal

H. Vapor Return Piping: Staff proposes to

establish the maximum allowabl e pipe run lengths during the certification process.

I. Liquid Condensate Traps: A new standard is proposed for liquid condensate traps (also known as knockout pots). These traps are used to keep the vapor lines clear when it is not possible to achieve th e minimum slopes for the vapor recovery piping as discussed above.

### 44

J. Connections and Fittings: This new specification explicitly states that connectors and fittings shall be leak

- free as determined by either leak detection solution or by bagging the fittings and observing inflation or deflation of the bag when the underground storage tank vapor

spac e in under pressure or vacuum.

Sections K through M: Proposed new standards applicable to balance systems:

K. Balance nozzles: Staff propose that the balance nozzle check valve be located in the nozzle to reduce vapor emissions which result if the chec k valve is present in another location between the nozzle and the underground storage tank. A new specification is proposed to determine nozzle bellows insertion force. This will allow a check that the production nozzles are consistent

with the nozzle cert ified as well as provide an evaluation of nozzle bellows durability.

L. Dynamic Backpressure: Staff proposes to modify the existing backpressure requirements to

remove the limit at 40 CFH.

M. Component Pressure Drop Limits : New standards are proposed f or individual balance system components to ensure the overall dynamic backpressure requirements discussed above are met. This is necessary as certified balance system equipment is currently specified in a

matrix that allows different combinations of certif ied balance system components. Staff has learned that some combinations of balance system components are not able to meet the dynamic backpressure limits described above. A pressure drop budget has been suggested to resolve this problem. Staff has develope d component pressure drop limits with input from several vapor recovery equipment manufacturers. The proposed individual component pressure drops are listed below.

N. Assist Nozzles: Staff propose that all “bootless” assist nozzles be equipped with a vapo r guard. This is a small cup or mini

- boot at the base of the nozzle that assists in routing the vapor back through the nozzle. Each assist nozzle must have a vapor check valve. The purpose of the check valve is to keep vapors from exiting the underground v apor space through the vapor return line when the nozzle is not in operation.

O. Air to Liquid Ratio Limits: Staff proposes a new limit on air to liquid ratio, or A/L, for assist
systems.

P. Assist Systems with Common Collection Device: Staff proposes n ew specifications for assist systems utilizing a common collection device. This means that there is one vacuum source for the entire station rather than a separate vacuum pump in each dispenser.

Q. Assist Systems with Destructive Processors: New performance standards provide limits on criteria (CO, NOx) and hazardous air pollutant (HAP) emissions for destructive processors.

Module 3

– ORVR Compatibility

The goal of the ORVR compatibility standard is to eliminate the excess emissions which c an occur during fueling of an ORVR vehicle with a Phase II vapor recovery system. Phase II systems must demonstrate during the certification test period that the Phase II system is compatible with ORVR vehicles. Compatibility is determined by verifying tha t the Phase II system can refuel ORVR vehicles and that the refueling does not cause the vapor recovery system emissions to exceed the 0.38 lbs/1000 gallon standard. The statewide emission reductions (in California) for ORVR compatibility were estimated at 6.3 tons/day.

### 45

There are at least two certified systems that achieve ORVR compatibility. These are the balance system and the Healy system. These systems do not ingest “excess air” when fueling ORVR

vehicles and thus do not cause excess emissions. No mod ifications are necessary for the balance system to achieve ORVR compatibility, as the passive system design only collects vapor actually displaced by fueling of the vehicle. Since the ORVR vehicles collect the vapor in the canister, the dispensing facility with a balance system will dispense fuel without replacing it with vapor, thus leading to negative pressure in the underground storage tank. Even if the balance system station has some leaks, field data shows the underground storage tank tends to

maintain negative UST pressure. This was demonstrated during an ARB field test of a balance system at which 32% of the fuel was dispensed in ORVR simulation.6 The underground storage tank pressure was less than 0.10 inches H2O for 99% of the test, including the bu lk delivery periods.

The Healy assist

- type vapor recovery system recognizes ORVR vehicle fuelings by means of a

pressure

- sensing diaphragm in the nozzle that prevents the ingestion of air when fueling an ORVR vehicle. Other system manufacturers are explo ring hydrocarbon sensing technology. Both of these systems illustrate how differences in the vapor return line can be monitored to detect ORVR vehicles and adjust the vapor collection of the system.

Assist systems with processors may be compatible with ORVR, but have not yet been tested to confirm that the existing processors can handle the excess air from fueling a significant percentage of ORVR vehicles.

Module 4: Liquid Retention and Spitting

Staff is proposing standards for liquid retention and “no zzle spitting”. Liquid detention occurs when liquid gasoline contained in the hanging hardware (nozzles, hoses, etc.) on the dispenser is allowed to evaporate into the atmosphere between vehicle fuelings while the nozzle is hung on the dispenser. Nozzle sp itting is defined as the release of liquid when the nozzle trigger is depressed with the dispenser not actuated.

Module 5: Spillage and Dripless Nozzle

Staff proposes to reduce the spillage limit from 0.42 lbs/1000 gallons to 0.24 lbs/1000 gallon

limit. Staff also proposes to limit the number of drops to one drop per fueling event.

Module 6: In

- Station Diagnostics (ISD)

The goal of in

- station diagnostics is to provide continuous monitoring of important emission

related vapor recovery system parameters a nd to alert the station operator when a failure mode is detected so that corrective action can be taken. It is similar in concept to the current ARB on

board diagnostics regulations for motor vehicles, where every emission

- related component or system must be regularly monitored for proper operation.

General requirements for ISD systems include:

a) Diagnostics that alert the owner/operator to potential problems b) Provide audible and visible alarms upon detection of defect c) Prohibit dispensing if an identified d efect is not repaired within a reasonable period of

time

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d) Monitor critical component performance e) Provide record of system performance

ISD designs are expected to be specific to vapor recovery system type. However, certain minimum design parameters, such as calibration of monitors, frequency of data collection, type of data storage and accessibility, criteria for determining warning and failure conditions and other parameters shall be proposed by the applicant and will be evaluated and verified during the certification process. Other criteria proposed for ISD systems are discussed below.

UST pressure monitoring will be required for all vapor recovery systems. These monitors will detect leaks in the underground storage space indicated by long periods that t he tank remains at atmospheric pressure. Pressure monitors can also indicate if the gasoline delivery was conducted correctly. For example, connecting the product hose, but failing to connect the vapor return hose, would generate a large pressure spike whi ch would lead to escape of the vapors out the vent pipe. Stations which remain at high pressures for significant periods would signal an investigation to correct system operations so that pressure

- related fugitive emissions are

minimized.

Additional requi rements for in

- station diagnostics vary depending on the type of vapor recovery system. The three system categories are balance, assist, and assist with processor.

A. Balance Systems

-- In addition to the pressure monitor, balance systems would be require d to check for liquid blockage at each dispensing point. A high pressure drop would indicate a blockage problem. Another approach is to measure the vapor to liquid ratio, or V/L ratio (also referred to as A/L), in each dispenser with a flowmeter. The flowm eter, installed in each dispenser, would measure the amount of vapor flow during every fueling episode without reducing the vapor recovery system's efficiency. A consistent lack of flow, or low flow, would indicate a blockage.

B. Assist Systems

-- Assist systems would also be required to monitor the vapor to liquid ratio, or V/L ratio in a way that would detect a failure mode at individual dispensers. Recent inspections have discovered that vapor pumps were not operating at some dispensers although gasolin e fueling was normal. Staff proposes that when the monitor detects an A/L of zero, which would mean no vapor recovery, that the dispenser be shut down.

C. Assist Systems with a Processor

-- In addition to monitoring the V/L ratio, vapor recovery
systems w ith processors must have additional ISD sensors to ensure the processors are operating correctly. The hydrocarbon concentration, the flowrate, and other parameters unique to each processor will need to be continuously monitored. This is already required fo r current systems with thermal processors. For vapor recovery systems certified to operate at a continuous vacuum, a pressure switch is used to detect insufficient vacuum. An alarm signals the station operator when the system fails to achieve the certified vacuum level after a prescribed time interval, indicating insufficient system leak integrity or a system failure.