1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

DATE:

SUBJECT: Technical Support Document for the Revisions to the Attainment Plans for the

Commonwealth of Virginia Portion of the Washington, DC

- MD

- VA 1990 1

- Hour

and 1997 8

- Hour Ozone Nonattainment Areas and the Maintenance Plan for the Fredericksburg 1997 8

- Hour Ozone Maintenance Area to Remove the Stage II Vapor Recovery Program

FROM: Asrah Khadr, Environmental Engineer, EIT /s/

Office of Air Program Planning

TO: File

THRU: Cristina Fernandez, Associate Director /s/

Office of Air Program Planning

I. Introduction

On March 18, 2014 , the Comm onwealth of Virginia (Virginia) submitted revision s to the Virginia State Implementation Plan (SIP) through the Virginia Department of Environmental Quality (VADEQ) to amend the SIP

- approved ozone attainment plans for the Virginia portion of

the Wa shington

, DC

- MD

- VA 1990 1

- H our and 1997 8

- H our Ozone Nation al Ambient Air Quality Stan dard (NAAQS) Nonattainment Area s (Northern Virginia Area s ) and the maintenance plan for the Fredericksburg 1997 8

- Hour Ozone NAAQS Maintenance Area (Fredericksburg Area) ( collectively referred to as the Virginia Areas or Areas) . The revision s also address the impact on the attainment/ maint enance plans due to the removal of Virginia’s Stage II vapor recovery equipment from subject gasoline dispensing facilities in the subject

areas . The SIP revision s contain a demonstr ation that removal of the Stage II vapor recovery program will not interfere with attainment or maintenance of the NAAQS in accordance with section 110(l) of the Clean Air Act (CAA). Th e analysis in these SIP revisions also contains a

demonstration that m eets the requirements of section 184(b)(2) of the CAA which requires areas in the Ozone Transport Region (OTR) to implement the Stage II va por recovery program or a comparable measure.

II. Background

Stage II Vapor Recovery and Onboard Vapor Recovery System s

Stage II vapor recovery (hereafter referred to as Stage II) is a means of capturing gasoline vapors2

displaced during transfer of gasoline from the gasoline dispensing unit to the motor vehicle fuel tank during vehicle refueling at a gasoline dispe nsing facility (GDF). Stage II vapor recovery involves use of special refueling nozzles and coaxial hoses for vapor collection at each gasoline pump at a subject GDF. Gasoline vapors belong to a class of pollutants known as volatile organic compounds (VO C). Gasoline is made up of a number of toxic compounds, and gasoline dispensing operations emit gasoline vapor that contains air toxics (also known as “hazardous air pollutants”) that can cause cancer and other serious health effects. These include benze ne, 1,3

- butadiene, formaldehyde, acrolein, napththalene, and polycyclic organic matter (POM), all of which are gas

- phase hydrocarbons that exist in gasoline vapor (except POM, which exists in gas and particle phases).

Stage II gasoline vapor recovery systems have been a required emission control measure in areas
classified as serious, severe, and extreme for the ozone NAAQS. 1 With the amendment of the CAA in 1990, Stage II controls were required for moderate ozone areas, under CAA section 182(b)(3).

However, under section 202(a)(6) of the CAA, 42 U.S.C. 7521(a)(6), the requirements of section 182(b)(3) would no longer apply in moderate ozone nonattain ment areas after EPA promulgation

of standards for onboard refueling vapor recovery (ORVR) as part of new motor vehicl es’
emission control systems

, 2 and after EPA determines that ORVR is in widespread use throughout

the motor vehicle fleet. Under implementation rules issued in 2002 for the 1997 8

- Hour O zone standard, EPA retained the Stage II

- related r equirements under section 182(b )(3) as they applied

for the 1

- Hour O zone standard (see 40 CFR 51.900(f)(5) and 40 CFR 51.916(a)).

Beginning with model year 1998, ORVR equipment has been phased in for newly manufactured light duty passenger cars and trucks, and has been required on nearly all new vehicles since

2006. 3 ORVR is an emission control system contained in the vehicle that captures gasoline vapors during refueling. The gas tank and fill pipe are designed to capture refueling

- related

vapors and contain them in an onboard, activated carbon canister. When the vehicle is running and warmed up, the vapors are drawn out of the canister and transferred to the engine to be combusted as fuel. The ORVR system is very efficient and is monitored by th e vehicle’s on

board diagnostic system. Unlike Stage II systems, which are geographically limited to moderat e and above nonattainment areas, ORVR is applicable to all new vehicles everywhere those vehicles operate.

Over time, non

- ORVR vehicles continue to be replaced by ORVR

- equipped vehicles. On May 16, 2012, EPA issued a final rule determining that ORVR technology was in widespread use throughout the U.S. vehicle fleet and waived the requirement for states to implement Stage II vapor recovery at GDFs in nonattainment areas classified as serious or above for the ozone NAAQS (77 FR 28772). EPA determined that emission reductions from ORVR

- equipped

vehicles a re essentially equal to and would soon surpass the emission reductions achieved by

1 See CAA section 182(b)(3), 42 U.S.C. 7511a(b)(3)

2 See 59 FR 16262 (April 6, 1994), codified at 40 CFR Parts 86 (including 86.098

- 8), 88, and 600.

3 Under the current regulatory construct, motorcycles and heavy

- duty gasoline vehicles not manufactured as a complete chassis are not required to install ORVR , so they may be some small percentage of gasoline refueling emissions from new vehicles not captured by ORVR controls.3

Stage II alone . EPA determined that a state previously required to implement a Stage II vapor recovery program may take appropriate action to r emove the measure from its SIP. 77 FR

28772

. EPA hereafter refers to this action as the “widespread use determination” or th e “Stage II

waiver.”

III

. Stage II As A Control Measure in the Attainment/Maintenance Plans

Stage II vapor recovery was originally required by the CAA in 1990 in two Virginia ozone

nonattainmen t areas . Virginia adopted and published its Stage II vapo r recovery regulations as

Rule 4

- 37 of VR 120

- 01, entitled “Emission Standards for Petroleum Liquid Storage and Transfer Operations” in the November 2, 1992 edition of the Virginia Register of Regulations (Vol 9, Issue 3), effective January 1, 1993. Virgi nia’s Stage II rules applied to the Northern Virginia and Richmond VOC Emission Control Areas, as defined under 9 VAC 5

- 40

- 5200(B)(2)

and 9 VAC 5

- 20

- 206.

Virginia submitted its Stage II regulation to EPA as a SIP revision on November 5, 1992. EPA

appro ved Virginia’s Stage II SIP revision on June 23, 1994 (59 FR 32353).

Stage II and the Virginia portion of the Washington

, DC

- MD

- VA 1990 and 1997 Ozone NAAQS Nonattainment Areas Attainment Plan s

Under the 1990 1

- Hour O zone NAAQS, EPA originally designated the OTR portion of Virginia

as serious nonattainment as a part of the Washington

, DC

- MD

- VA 1990 Ozone NAAQS

Nonattainment Area . The Virginia portion of the OTR include the following areas: Stafford County, Arlington C ounty, Fairfax County, Loudon County, City of Alexandria, City of Falls Church, City of Manas sas, and City of Manassas Park. On December 19, 1997

, the District of Columbia, Maryland and Virginia (the three states)

, submitted an attainment plan for the Washington

, DC

- MD

- VA 1990 Ozone NAAQS Nonattainment A rea . On April 17, 2003 (68 FR 19106), EPA gave the attainment plan conditional approval. On November 13, 2002 (67 FR 68805), EPA reclassified the area as severe nonattainment; to meet the requirements of this classification, a severe area attainment plan was submitted on February 24, 2004. This attainment plan was approved on May 13, 2005 ( 70 FR 25688 ) . The 1990 ozone NAAQS was then revoked on June 15, 2005.

On July 18, 1997 (62 FR 38856), EPA prom ulgated the 1997 Ozone NAAQS. On April 30, 2004 (69 FR 23941), EPA desi gnated the Washington

, DC

- MD

- VA A rea as moderate

nonat tainment. The Virginia portion of this area include s Arlington County, Fairfax County,

Loudon County and Prince William County as well as the City of Alexandria, City of Fairfax, City of Falls Church, City of Manassas, and City of Manassas Park. On June 12, 2007, the three

states submitted an attainm ent plan which was proposed for approval by EPA on March 20, 2013 (78 FR 17161). O n February 28, 2012 (77 FR 11739), EPA determined that the Washington

, DC

- MD

- VA area was attaining the 1997 Ozone NAAQS and published a clean data

determination as well as a de termination that the area attained the 1997 Ozone NAAQS by its statutory attainment date

. The attainment plan was approved by EPA on April 10, 2015 (80 FR4

19206 ).

Stage II and the Fredericksburg 1997 Ozone Maintenance Area Maintenance Plan

On April 30, 2004 (69 FR 23941), EPA designated Stafford County, Spotsylvania County, and the city of Fredericksburg as the Fredericksburg 1997 Ozone Nonattainment Area. Since the air quality in the Fredericksburg 1997 Ozone Nonattainment Area met the 1997 ozone NAAQS, a redesignation request and maintenance plan were submitted by Virginia on September 28, 2005; EPA approved the redesignation request and maintenance plan on December 23, 2005 (70 FR 76165).

Even though the 1990 1

- Hour O zone NAAQS was revoked on June 15, 2005, EPA’s subsequent implementation rules for the 1997 8

- Hour O zone NAAQS retained the Stage II

- related requirements under section 182(b)(3) , b ut only as they applied to the Area for the A rea’s

classification for the 1

- H our Ozone NAAQS at designation for the 8

- H our Ozone NAAQS (see 40 CFR 51.900(f)). 4 Therefore the attainment plan for the Washington

, DC

- MD

- VA 1997 Ozone NAAQS Nonattainment Area and the maintenance plan for the Fredericksburg 1997 Ozone NAAQS Nonattainment Area also contain Stage II as a control measure, in addition to the attainment pl an for the Washington

, DC

- MD

- VA 1990 Ozone NAAQS Nonattainment Area.

At the time of the development of the Washington

, DC

- MD

- VA 1990 ozone NAAQS attainment plan SIP, Stage II was still a mandatory measure for areas classified as mode rate ozone
nonattainm ent under section 182(b) ( 3) of the CAA. Although EPA had adopted ORVR rules for light

- duty vehicles in April 1994, ORVR vehicles were not int roduced for sale until model year 1998, with nearly all new gasoline

- powered vehicles being equipped with O RVR by model year

2006. Under s ection 202 (a)(6) of the CAA, Stage II requirements for areas classified as moderate “shall not apply” upon E PA’s promulgation of ORVR rules, and determination of widespread use o f ORVR throughout the motor vehicle fleet. Although after ORVR promulgation Stage II was no longer a mandatory measure under the CAA, Virginia had relied upon reductions from Stage II in its ozone plans. Although Virginia was no longer obligated to retain Stage II as a mandatory measure under the CAA, the Commonwealth is required under section 110(l) of the CAA to demonstrate that a SIP revision to remove Stage II would not interfere with the applicable requirements to attain the NAAQS.

IV. EPA Evaluation of Virg inia’s SIP Revision s to Remove Stage II Vapor Recovery

A. Requirements

The removal of Stage II gasoline vapor control programs from the SIP has to meet certain requirements. Any SIP revision that may relax the SIP must meet the requirements of section 110(l) of the Clean Air Act. Section 110(l) requires a demonstration proving that the SIP would not be relaxed if the measure in question is removed. Additionally

, and specific to the removal of Stage II, certain areas must meet the requirements of CAA sections 184(b)(2) an d 193. CAA

4 See 69 FR 23966 (April 30, 2004), as amended at 70 FR 30604 (May 26, 2005) and 70 FR 71702 (November 29, 2005)5

section 184(b)(2) applies to areas that are in the Northeast Ozone Transport Region (OTR); these areas in the OTR are required to implement Stage II or another program with comparable emissions reductions referred to as the “comparable measures ” r equirement. Additionally, CAA

s ection 193, also referred to as the “general savings clause,” requires areas trying to modify control measures approved prior to November 15, 1990 to prove that modification of the control measure “insures equivalent or g reater emissions reductions.” The Area did not hav e Stage II approved into its SIP prior to No vember 15, 1990, therefore CAA s ection 193 does not app ly.

The Area is a part of the OTR

, there fore CAA s ection 184(b)(2) does apply. These SIP revision s d emonstrate compliance with CAA s ection s 110(l) and 184(b)(2)

.

B. State Submittal

VA DEQ submitted an analysis to satisfy the requirements of CAA section s 110(l) and 184(b)(2)

. VADEQ used the EPA guidance document Guidance on Removing Stage II Gasolin e Vapor Control Programs from State Implementation Plans and Assessing Comparable Measures in developing its analysis to meet the requirements of CAA section s 110(l) and 184(b)(2)

.

The EPA guidance document, Guidance on Removing Stage II Gasoline Vapor C ontrol Programs from State Implementation Plans and Assessing Comparable Measures provides direction to states on the calculations necessary for the analysis of the emissions impact of Stage II removal. To analyze the emissions impact of Stage II removal, the area wide impact on the VOC inventory must be calculated. As recommended by the guidance document, there are several methods that can be used to demonstrate compliance with the req uirements of CAA section 110(l); the method to be used depend s on how th e removal of Stage II would affect the area in question. The first method replaces Stage II with a new control measure that would offset any emissions increases that would result from the removal of Stage II. The second method involves substituting Stage II with excess emissions reductions not accounted for in the SIP. In the event that the removal of Stage II does cause an emissions increase, reductions in the VOC inventory since the previously approved SIP inventory can be used to offset any potential emissions increases resulting from the removal of Stage II. The third method does not involve substitution for any emissions increases in the event of an increase in VOC emissions from Stage

II r emoval; this method allows the A rea to provide a phase

- out plan that would allow a minuscule amount of emissions increases that decreases rapidly as ORVR continues to increase

in the vehicle fleet. This minuscule amount of emissions increases would be too small to interfere with attainment or progress towards atta inment. This noninterference can be demonstrated in several ways. The area can provide its most recent air quality data showing attainment of the NAAQS; if the NAAQS has yet to be attained, air quality projections showing attainment can be provided. Addi tional air quality analyses showing that the removal of Stage II

does not interfere with attainment or maintenance of the NAAQS will also be considered. To meet the requirements of CAA section 184(b)(2) comparability must be demonstrated by the

S tate . In removing Stage II and trying to prove comparability, EPA be lieves that it is reasonable for states to demonstrate that the removal of Stage II has no impact on VOC emissions or has de

minimis (minimal) impact on VOC emissions. EPA has defined de minimis impact as any additional incremental control achieved by Stage II beyond ORVR that is less than 10 percent (%) of the are wide VOC inventory.6

To calculate the area wide VOC inventory impact, two important equations must be used. Equation 1, presented be low, provides the overall Stage II

- ORVR increment. This increment provides the percentage impact on the annual area

- wide emissions control gain from Stage II as ORVR is phased into the vehicle fleet. Equation 2, also presented below, calculates the

emiss ions benefits of Stage II on the VOC inventory in tons per year (tpy). Equations 3 and 4 provide the variables necessary to calculate the Stage II impact on the VOC inventory, these equations are also provided below.

Equation 1: incrementi = (QSII)(1

- Q ORVR i )(ηiuSII)

- (QSIIva)(CF i )

Incrementi: The increment percentage impact on the annual area

- wide emissions control gain from Stage II as ORVR is phased into the vehicle fleet QSII: Fraction of gasoline throughput covered by Stage II QORVR i : Fraction of annual gallons of highway motor gasoline dispensed to ORVR

- equipped

vehicles ηiuSII: In

- use Stage II control efficiency QSIIva: Fraction of gasoline throughput covered by Stage II

CF i : Compatibility factor

Equation 2: Tons i = ( Incrementi )( GCi )( EF )

Tons i : VOC emissions benefit of Stage II (tons)

Incrementi : The increment percentage impact on the refueling inventory from removing Stage

II

GCi : The projected gasoline consumption (gal)

EF : The uncontrolled displacement refueling emissions factor (g/gal)

Equation 3: EF (g/gal) = exp[

- 1.2798

- 0.0049(ΔT) + 0.0203(Td) + 0.1315(RVP)]

EF : The uncontrolled displacement refueling emissions factor (g/gal)

ΔT: Values for this variable are area specific and are located in Appendix A

- 2 of the EPA guidance document (degrees fahrenheit)

Td: Values for this variable are area specific and are located in Appendix A

- 3 of the EPA guidance document (degrees fahrenheit )

RVP: Reid Vapor Pressure of the gasoline used for the area (pounds per square inch (psi))

VA DEQ submitted an analysis quantifying the VOC emissions benefits of Stage II. Equation 1 was utilized to yield the increments provided in Tables 1 and 2. The calculations in Table 1 assumed a Stage II control efficiency of 77% while the calculations in Table 2 assumed a Stage II control efficiency of 56%. Negative increment values are indicative of when excess emissions from non ORVR compatible Stage II syste ms overwhelm the emissions benefits of implementing7

Stage II. Table 1 presents calculated increment values which sh ow that the Area will no longer

see emissions b enefits from Stage II after 2012 . Table 2 presents calculated increment values

which sh ow th at the Area will no longer see emissions benefits from Stage II after 20 11

. VADEQ used the more conservative Stage II efficiency estimate of 77% to determine the date when there will be no emissions benefits from Stage II; ther efore, the A rea will no long er see emissions b enefits from Stage II after 2012

.

Table 1. Increment Calculations for 77% Stage

II Efficiency

Year Increment

2008 0.13760

2009 0.10597

2010 0.07168

2011 0.04235

2012 0.01821

2013

- 0.00128

2014

- 0.01632

2015

- 0.02785

2016

- 0.03673

2017

- 0.04335

2018

- 0.04817

2020

- 0.05428

2030

- 0.06204

Table 2. Increment Calculations for 56% Stage

II Efficiency

Year Increment

2008 0.08684

2009 0.06302

2010 0.03732

2011 0.01534

2012

- 0.00275

2013

- 0.01736

2014

- 0.02862

2015

- 0.03725

2016

- 0.04390

2017

- 0.0 4886

2018

- 0. 05245

2020

- 0.05702

2030

- 0.062798

The emissions benefits of Stage II were calculated using Equations 2 and 3. Using the more conservative increments produced by using the 77% Stage II efficiency estimate, the emissions benefits were calculated and the values tabulated in Table 3, below. The calculations also prove

that there will be no emissions benefits from S tage II implementation past 2012

.

Table 3. Stage II Emissions Reductions in the Are a

- Wide VOC Inventory

Year Emissions Reductions ( tpd VOC )

2008 0.58

2009 0.46

2010 0.31

2011 0.19

2012 0.08

2013

- 0.01

2014

- 0.07

2015

- 0.13

2016

- 0.17

2017

- 0.20

2018

- 0.22

2020

- 0.24

In addition to increment and area wide VOC inventory calculations, VADEQ submitted additional analyses to support its removal of Stage II from the Virginia SIP. VADEQ included an analysis which calculated the non

- ORVR compatible Stage II benefit on a gaso line basis and

a vehicle miles travelled ( VMT ) basis and compared the analysis to the Stage II benefit calculated with the use of the Motor Vehicle Emission Simulator (MOVES2010a). This comparison is provided below in Table 4, and shows that incompatibili ty excess emissions

, which are the emissions that arise from the interaction of a Stage II vapor recovery system (VRS) with ORVR, exceed Stage I I benefits in the 2014 time frame

.

Table 4. Excess and Benefit VOC Emissions Calculations Results

Year Excess Vent Emissions

(tpd VOC) Stage II Benefit (tpd VOC) Stage II Benefit with respect to ORVR (tpd VOC)

Gasoline

Basis VMT

Basis Gasoline Basis VMT Basis

2008 0.5768 0.5790 1.937 1.360 1.358

2009 0.6218 0.6271 1.616 0.996 0.991

2010 0.6669 0.6696 1.343 0.676 0.673

2011 0.7040 0.7042 1.309 0.605 0.605

2012 0.7496 0.7479 1.072 0.323 0 .3259

2013 0.7755 0.7721 0.885 0.110 0.113

2014 0.7933 0.7883 0.730

- 0.063

- 0.058

2015 0.8071 0.8008 0.605

- 0.202

- 0.196

2016 0.8189 0.8115 0.505

- 0.313

- 0.306

2017 0.8211 0.8129 0.434

- 0.388

- 0.379

2018 0.8204 0.8113 0.378

- 0.442

- 0.433

2020 0.8184 0.8081 0. 307

- 0.511

- 0.501

2030 0.8055 0.7926 0.249

- 0.556

- 0.544

Additionally, VADEQ submitted work completed by the Georgia Institute of Technology (Georgia Tech) for the Association for Southeastern Integrated Planning project. Georgia Tech completed emissions sensitivity analyses utilizing the Community Multiscale Air Quality (CMAQ) model, for the sensitivity of ozone concentrations with respect to NO
x and VOC emissions. Three sensitivity analyses were conducted to gauge the sensitivity of ozone formation with respect to a 30% decrease in anthropogenic VOC, ground level NOx and point source NOx in the applicable Virginia areas. It was found that O zone concentrations were most sensitive to decreases in point source NO
x . The sensitivity to point source NO
x is 100 to 1,000 times greater than ozone concentration sensitivity to anthropogenic VOC. The results indicate that NO
x has a much larger impact o n Ozone concentrations than VOC.

Through the CMAQ modeling utilized for the sensitivity analyses, the effect of Stage II on ozone

concentrations was calculated at the monitor in the Virginia Areas . Table 5 , below, presents the Stage II benefit in term s of the change of ozone concentration. The results presented show that Stage II has a very minuscule effect on ozone concentrations in the Virginia Area s

.

Table 5 . Stage II Effect on Ozone Concentration

Area Monitor Stage II Benefit to Ozone Concentrations ( parts per billion ( ppb ) )
Virginia Areas Arlington

- 1.72x10

- 4 to

- 2.87x10

- 4

C. EPA Evaluation and Conclusion

EPA thoroughly evaluated th e submittal made by Virginia through VADEQ . EPA’s detailed

review has led EPA to conclude that VADEQ properly addressed the recommended increment and VOC inventory calculations which prove when Stage II no longer pro v ides a benefit for the Virginia Area s

. EPA agrees with VADEQ that withdrawal of the Stage II requirement i s appropriate on January 1, 2014 . EPA also reviewed additional data provid ed by VADEQ showing ozone formation in the Virginia Area s is much more NO
x dependent. In conclusion, EPA agrees with Virginia’s recommendation that the Stage II requirement be removed on January 1, 2014 , since at t hat point in time, the Virginia Area s will no longer see any emissions benefits from the implementation of Stage II. Also, at t hat point in time, the Virginia Area s will

have met and exceeded the de minimus requirement for removing Stage II. EPA is approving the10

removal of Stage II from the attainment and maintenance plan s for the Virginia Area s because the submitted analysis demonstrates that Stage II removal will not interfere with the attainment or maintenance of the NAAQS in accordance wit h section 110(l) of the CAA and meets the requirements of section 184(b)(2) of the CAA

.