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# Stage II Vapor Recovery Systems — Options Paper

U.S. EPA Office of Air Quality Planning and Standards Emissions Monitoring and Analysis Division Emissions Factors and Policy Applications Group (C339-02)

February 7, 2006

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## Disclaimer

This document contains opinions and r ecommendations expressed by the Emissions Factors and Policy Application Group to the Oz one Policy and Strategies Group within EPA. These recommendations are tentative in nature a nd do not necessarily represent current Agency policy. These recommendations may or ma y not be adopted based upon further study.

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### ii 

## Table of Contents

Section Page I. Executive Summary........................................................................................................... .... 7

II. Introduction............................................................................................................... ............. 8 III. Background................................................................................................................ ............ 9 A. Description of Stage II Vapor Recovery Systems 6, 8, 9 

### .................................................. 10 B. Description of ORVR..................................................................................................... 11 C. Description of Stage II/ORVR Issues ............................................................................ 12 D. Continued Use of Stage II VRS ..................................................................................... 12 E. Underground Storage Tank Emissions........................................................................... 13 F. Fugitiv e Emissions......................................................................................................... . 13 G. GDF Emissions Monitoring, In spections, and Maintenance ......................................... 14 H. Widespread Use Determinations.................................................................................... 15 I. Description of SIP Credit Opportunities ......................................................................... 17 1. SIP Option for States to Include Stage II VRS in Additional Areas. ....................... 17 2. Other SIP Credit Options.......................................................................................... 18 IV. Stage II Discussion Meetings w ith Stakeholders and Vendors ........................................... 21 A. Hertz Meeting Summary................................................................................................ 21 B. Alliance of Automobile Manuf acturers (AAM) Meeting Summary.............................. 21 C. ARID Technologies Meeting Summary......................................................................... 22 D. Vapor Systems Technologies, Inc. (VST) Meeting Summary....................................... 22 E. Healy Systems, Inc. (Healy) Meeting Summary............................................................ 22 F. EMCO Wheaton Retail Meeting Summary.................................................................... 23 G. American Petroleum Instit ute (API) Meeting Summary ............................................... 23 V. Public Meeting – September 2004....................................................................................... 24 A. Comments from the Public Meet ing and on EPA’s Issues Paper.................................. 25 B. Stage II Vapor Recovery System s – Balance vs. Vacuum Assist.................................. 27 1. Comment Overview.................................................................................................. 27 2. Discussion and Recommendation............................................................................. 28 C. On-Board Refueling Vapor Rec overy (ORVR) Control Efficiency .............................. 28 1. Comment Overview.................................................................................................. 29 2. Discussion and Recommendation............................................................................. 30 D. ORVR and Stage II VR S Compatibility Issues ............................................................. 33 1. Comment Overview.................................................................................................. 33 2. Discussion and Recommendation............................................................................. 34 E. Widespread Use Calculation and Date........................................................................... 38 1. Comment Overview.................................................................................................. 38 2. Discussion and Recommendation............................................................................. 39 F. Phase Out of Stage II Vapor Recovery Systems ............................................................ 47 1. Comment Summary .................................................................................................. 47 2. Discussion and Recommendations ........................................................................... 48 G. Phase Out of Stage II Vapor Recovery Systems in the OTR......................................... 51 1. Comment Summary .................................................................................................. 51

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### iii 2. Discussion and Recommendations ........................................................................... 51 H. Stage II State Implemen tation Plan (SIP) Credits.......................................................... 52 1. Comment Summary .................................................................................................. 52 2. Discussion and Recommendations ........................................................................... 53 I. Enhanced Vapor Recovery (EVR) .................................................................................. 58 1. Comment Summary .................................................................................................. 58 2. Discussion and Recommendations ........................................................................... 58 J. Monitoring/Inspections of GDF and Stage II VRS......................................................... 60 1. Comment Summary .................................................................................................. 60 2. Discussion and Recommendations ........................................................................... 61 K. Emissions Factors a nd Emissions Testing ..................................................................... 63 1. Comment Summary .................................................................................................. 63 2. Discussion and Recommendations ........................................................................... 64 L. Exemptions for Rental Car Facilities ............................................................................. 65 1. Comment Summary .................................................................................................. 65 2. Discussion and Recommendations ........................................................................... 66 M. Stage I and II Equipment and UST Emissions.............................................................. 66 1. Comment Summary .................................................................................................. 66 2. Discussion and Recommendations ........................................................................... 67 N. MTBE Groundwater Contamination from UST ............................................................ 70 1. Comment Summary .................................................................................................. 70 2. Discussion and Recommendations ........................................................................... 70 VI. Emissions Monitoring and Testing Data.............................................................................. 72 A. Previous Data Collected by EPA ................................................................................... 72 1. CARB’s Preliminary Test Report, June 1999 (GDF) ............................................... 73 2. Phase 1 of API’s ORVR Compatibility Study (GDF) .............................................. 73 3. Phase 2 of API’s ORVR Co mpatibility Study (Outside).......................................... 74 4. Phase 2 of API’s ORVR Compatibility Study (SHED)............................................ 74 B. Data Provided by Stakeholders ...................................................................................... 81 1. California GDF Testing, Site 1 .................................................................................. 81 2. California GDF Testing, Site 2 ................................................................................. 82 3. California GDF Testing, Site 3 ................................................................................. 84 4. Florida GDF Testing, Site 1...................................................................................... 84 5. Missouri GDF Testing, Site 1 ................................................................................... 85 6. Missouri GDF Testing, Site 2 ................................................................................... 86 7. Missouri Automobile Manufactur er GDF Testing, Site 3 ......................................... 87 8. Missouri Automobile Ma nufacturing GDF, Site 4 ................................................... 88 9. New Hampshire GDF Data....................................................................................... 89 10. Multi-State GDF Data............................................................................................. 89 11. Vermont GDF Data................................................................................................. 93 12. EPA’s Initial In-Use Evaporat ive Testing of ORVR Vehicles............................... 95 13. EPA’s IUVP............................................................................................................ 95 B. Other Data Found within Literature............................................................................... 96 1. WSPA – UST vent emissions ................................................................................... 96 2. ORS Pilot Study........................................................................................................ 96 C. Planned Testing............................................................................................................ .. 97

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### iv 1. Florida GDF Testing, Site 2...................................................................................... 97 2. Hertz Testing, Rental Car Facilities.......................................................................... 97 3. New Hampshire GDF Testing .................................................................................. 97 4. Arizona GDF Testing................................................................................................ 98 VII. NESCAUM Widespread Use Study .................................................................................... 98 A. Methodology for Determining Widespread Use............................................................ 99 B. NESCAUM Provided Data ............................................................................................ 99 C. Results of Widespread Use Analysis ........................................................................... 101 D. Algorithm Analysis Issues ........................................................................................... 103 E. Recommendations ........................................................................................................ 104

VIII. Recommendations.......................................................................................................... .... 104

Appendices A – Brief Summaries of Data B – NESCAUM Widespread Use Study Supporting Documentation C – Widespread Use Results for NESCAUM States

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### v 

## List of Figures

Figure Page

1 General emissions trends expected for re fueling emissions in future calendar years for a hypothetical State, no incompatibility excess emissions (based on API studies). ....... 17



## List of Tables

Table Page

Table 1. List of Stakeholder Commenters ................................................................................... 25 Table 2. Stage II VRS Comment Summary................................................................................. 29 Table 3. On-board Refueling Vapor R ecovery (ORVR) Co mment Summary............................ 32 Table 4. ORVR and Stage II VRS Co mpatibility Comment Summary....................................... 35 Table 5. Widespread Use Calcula tion and Date Comment Summary......................................... 43 Table 6. Phase Out of Stage II Vapor Recovery Systems Co mment Summary .......................... 49 Table 7. Phase Out of Stage II Vapor Recove ry Systems in the OT R Comment Summary ....... 52 Table 8. Stage II State Implementation Pl an (SIP) Credits Comment Summary ........................ 55 Table 9. Enhanced Vapor Recove ry (EVR) Comment Summary ............................................... 59 Table 10. Monitoring/Inspections of Stage II VRS Comment Summary.................................... 61 Table 11. Emissions Factors and Emi ssions Testing Comment Summary.................................. 64 Table 12. Exemptions for Rental Car Facilities Comment Summary ......................................... 66 Table 13. Stage I and II Equipment and Unde rground Storage Tank (UST) Emissions Comment Summary........................................................................................................................ ....... 68 Table 15. Summary of Previous Data Collected by EPA: Test Data for Excess Emissions. ..... 76 Table 16. Pressure Data for Balance St age II VRS Without an UST Add-on APCD ................. 82 Table 17. Pressure Data for ORVR-Compa tible Vacuum Assist Stage II VRS.......................... 83 Table 18. Stage II VA VRS, with and without P/V Valve, with and without add-on APCD...... 85 Table 19. Stage II Balance VRS, with P/V valve, no UST vent add-on APCD.......................... 86 Table 20. Stage II Balance VRS, with P/V valve, no UST vent add-on APCD.......................... 86 Table 21. No Stage II VRS, with a P/V valve, no UST vent add-on APCD ............................... 87 Table 22. Analysis of Frequency Plots for UST Pressure for All Data and Before/After Fixing the Leak....................................................................................................................... .......... 88 Table 23. No Stage II VRS, with a P/V valve, no UST vent add-on APCD ............................... 88 Table 24. Summary of Weekday and Weekend UST Vent Pressures (No Stage II VRS, with P/V valve)......................................................................................................................... ............ 89 Table 25. Stage II VRS Testing and Failure Rates by State ........................................................ 91 Table 26. Initial Pressure Decay Test Results ............................................................................. 93 Table 27. Margin by Which Pres sure Decay Test Failed ............................................................ 93 Table 28. Equipment Problems that Contribut ed to Pressure Decay Test Failure....................... 94 Table 29. Parts Found Leaking During Pressure Decay Tests..................................................... 94 Table 30. A/L Ratio Testing Results........................................................................................... . 95 Table 31. EPA IUVP Test Results............................................................................................... 96 Table 32. Optical Remote Sensing at an RGO with No Stage II VRS and No P/V Valve.......... 97

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### vi Table 33. Data Provided by NESCAUM................................................................................... 100 Table 34. Values for Key Parameters ......................................................................................... 101 Table 35. Summary of Algorithm Analysis............................................................................... 102 Table 36. Difference in Emissions Between ORVR only and ORVR with Stage II VRS plus IEE

............................................................................................................................... .............. 103



## List of Acronyms

A/L – air to liquid ratio API – American Petroleum Institute CARB – California Air Resources Board CE – Control efficiency DIPE – di-isopropyl ether DTC – diagnostic trouble code EF – emission factor EFPAG – Emission Factors Policy Application Group EVR – enhanced vapor recovery FPMA – Florida Petroleum Marketers Association GDF – gasoline dispensing facility GVR – Gilbarco Veeder Root HDGV – heavy duty gasoline vehicle IEE – incompatibility excess emissions ISD – in station diagnostics IUVP –In use verification program MTBE – methyl tertiary butyl ether NACS – National Association of Convenience Stores NESCAUM – Northeastern States fo r Coordinated Air Use management OBD – onboard diagnostics ORVR – onboard refueling vapor recovery P/V – pressure/vacuum RSA –Remote Sensing Air, Inc RVP – Reid vapor pressure SIGMA – Society of Independent Gasoline Marketers of America SII – Stage II TAEE – tert-amyl ethyl ether TAME – tertiary amyl methyl ether TCEQ – Texas Commission on Environmental Quality UST – underground storage tank VA – vacuum assist V/L – vapor returned to liquid dispensed ratio VMT – vehicle miles traveled VRS – vapor recovery system VST – Vapor Systems Technology, Inc. WSPA – Western States Petroleum Association

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### 7 

## I. Executive Summary

In order to determine how better emissions monitoring at gasoline dispensing facilities (GDFs) could provide emissions reductions or state implementation plan (SIP) credits, the Emissions Factors Policy Appli cations Group (EFPAG) within the Emissions, Monitoring, and Analysis Division of the U.S. Environmental Pr otection Agency’s (EPA’s) Office of Air Quality Planning and Standards (OAQPS) reviewed a number of interre lated emissions quantification and policy issues. These issues include:

1. How to determine when “widespread use” of on-board refueling vapor recovery (ORVR) canisters occurs,

2. How to phase out Stage II vapor recove ry systems (VRS) once widespread use
occurs,

3. Whether other emissions points, such as the underground storage tank (UST) vents need to be controlled,

4. Whether there are opportunities to provide St ate Implementation Plan (SIP) credits to states for certain volatile organic compound (VOC)-reduction activities at GDF,

5. Whether potential UST pressure-related emissions exist,

6. What are actual emissions reduc tions achieved by Stage II VRS,

7. What actual emissions reductions are achie ved by ORVR, and the control efficiency of ORVR throughout the vehicle’s life span,

8. How to quantify excess emissions from ORVR and vacuum assist Stage II VRS incompatibility,

9. Whether equity issues for existing GDF should be considered when new GDF are built near the widespread use date,

10. Whether nationwide, as opposed to only nonattainment area-wide, controls are needed,

11. Whether a maximum achievable control t echnology (MACT) or generally available control technology (GACT) is needed to control hazardous air pollutant (HAP) emissions at GDF,

12. Whether in-station diagnostics and/or enha nced vapor recovery are needed, and

13. Whether the emissions factors used to estimate GDF emissions are accurate.

This paper discusses these issues and identifi es options for the Ozone Policy and Strategies Group in OAQPS’s Air Quality Standards and Strate gies Division, as well as for the Waste and Chemical Processes Group in OAQPS’s Emissions Standards Division, to c onsider in addressing these issues.

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### 8 

## II. Introduction
Emissions from GDF are a nationwide problem, a nd gasoline use in vehicles and trucks is increasing annually. Volatile organic compounds (VOC) and HAP are emitted from the refueling of light-duty gasoline vehicles and trucks at GDF and fugitive sources at GDF. VOC emissions from Stage II refueling processes were estimated to be more than 470,000 tons per year (ton/yr) in the 1999 version 2.0 Na tional Emissions Inventory (1999v2 NEI). 1, 2 

### From the 1999v2 NEI, the HAP emissions (pollutants listed in the Clean Air Act Amendments of 1990) from Stage II refueling could be in the ra nge of 22,000 to 83,000 ton/yr, based on use of emissions factors for baseline, re formulated, and oxygenated gasoline. 3



### The emissions points from controlled St age II process operati ons include vehicle refueling emissions at the nozzl e/fillpipe interface, spillage, UST vent breathing and emptying, and pressure-related fugitives. A VRS captures the vehicle refueling vapors normally emitted at the vehicle fill pipe and returns them to the UST. 4 

### A VRS also has an impact on the UST vent emptying emissions as the UST is emptied during refueling. 5



### When an ORVR-equipped vehicle refuels at GDF with Stage II VRS, the amount and composition of the vapor returned to the UST by the Stage II control syst em can be impacted. As ORVR equipment is being phased in for new vehicles, there is some concern regarding the compatibility of ORVR controls and Stage II contro ls. An increase in the amount of air (in lieu of gasoline vapor) returned to the vapor space of the UST will lead to gasoline evaporation, or vapor growth, in the UST and lead to excess emi ssions from the UST vent. A larger amount of air is returned to the UST vapor space for so me Stage II vacuum assist VRS when fueling vehicles with ORVR controls, and therefore, th e excess emissions are greater for some vacuum assist systems. These excess emissions are re ferred to “incompatibility excess emissions.”

Currently, UST vent emissions are estimated to be relatively small compared to the uncontrolled refueling emissions level base d on current emissions factors (ranges from 7.6 pounds of VOC per 1000 gallons of fuel dispensed [lb VOC/1,000 gal] to 11.1 lb VOC/1,000 gal for an uncontrolled refueling emissions factor to 1.0 lb VOC/1000 gal for UST vent and fugitive emissions). 6, 7 

### Several Stage II equipment vendors maintain that a larger

1 Draft 1999 National VOC Inventory for Gasoline Distribution . April 2003. See: http://www.epa.gov/ttn/chief/eiip/techreport/volume03/index.html.

2 The NEI emissions estimates include vehicle refueling losses, spillage losses, UST vent breathing and emptying losses, and fugitive losses.

3 A table of HAP species percentages of VOC emissions can be found at http://www.epa.gov/ttn/chief/eiip/tech report/volume03/iii11_apr2001.pdf.

4 Technical Guidance: Stage II Vapor Recovery Systems for Control of Vehicle Refueling Emissions at Gasoline Dispensing Facilities, Volumes I and II. U.S. Enviro nmental Protection Agency. EPA Publication No. EPA450/3-91-022a and EPA Publication No. EPA-450/3-91-022b. November 1991.

5 Ref. 4, p 3-10

6 CARB. Uncontrolled Vapor Emissions Factor at Gasoline Dispensing Facilities. January 2000.

7 AP-42. Section 5.2, Transportation and Marketing of Petroleum Liquids. January 1995. See http://www.epa.gov/ttn/chief/a p42/ch05/final/c05s02.pdf

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### 9 source of emissions at GDF is related to posi tive pressure build-up in the underground storage tank. When the UST pressure is positive, there is potential for increased fugitive emissions and emissions from the UST vent. In general, if an add on pollution control device is employed to reduce the overall storage tank pressure while at the same time capturi ng and recovering vent emissions, the driving force for fugitive emissi ons and the vent emissions would be greatly reduced.

In reviewing emissions quantification issues associated with Stage II VRS at GDF, we in EFPAG drafted an issues paper and conducted a p ublic meeting for stakeh olders. The purpose of the issues paper and public meeting was to al low stakeholders an opportunity to provide comments and input for EPA’s consideration. In addition, we met separately with a few stakeholders to consider their specific issues, and we met with equipment vendors to consider their concerns and comments. Summaries of th e public meeting, as well as the stakeholder and vendor meetings are presented in Section II and Section III.


## III. Background

After discussions and review within EPA, on August 12, 2004, the EMAD Division provided a copy of the Stage II Vapor Recovery Systems Issue Paper to stakeholders for their review and comment. Purposes of the Stage II Vapor Recovery Systems Issue Paper included:

(1) Providing background informa tion regarding available data, (2) Discussing EPA’s ideas regarding the definition of widespread use, (3) Discussing ancillary issues related to Stage II VRS, and (4) Soliciting comments from stakeholders.

More specifically, EPA sought comments on the following issues discussed in the August 12, 2004 Paper:

# Approach for determining widespread use , including: (1) using MOBILE6 algorithms for computing widespread use and (2) making the definition of widespread use specific to States, regions, or areas;

# Options for granting SIP Credits for certain activities, including: (1) continuing the use of Stage II controls after the determination that widespread use has occurred, (2) opting to require Stage II controls in new areas, and (3) requiring improved monitoring for Stage II control systems to increase rule effectiveness;

# Associated issues , including (1) the significance of UST vent emptying and breathing emissions, (2) the significance of fugitive emissions, and (3) the potential need for new emissions factors for VOC and HAP.

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### 10 A. Description of Stage II Vapor Recovery Systems 6, 8, 9



### The two most common types of Stage II VRS are “vapor balance” and “vacuum assist;” some VRS are referred to as “hybrid” system s that are classified as vacuum assist. 10, 11 

### The Society of Automotive Engineers (SAE) estimates th at 53 percent of VRS in the U. S. are vapor balance systems and 47 percent are vacuum assist systems. California estimates that vacuum assist systems comprise approximately 20 percent of their VRS, while New Jersey estimates they have 10 percent vacuum assist VRS. The Northe ast States for Coordinated Air Use Management (NESCAUM) believes that the perc ent of vacuum assist systems in their region is as high as 70 percent.

The vapor balance VRS is configured with a corrugated boot over the nozzle spout and is designed to capture displaced vapo r from the vehicle fuel tank. 12, 13 

### The vapor balance VRS operates based on the principle of vapor replacement and provides a vapor recovery return line to collect vapors from the vehicle fuel ta nk displaced by the incoming liquid gasoline. 14 

### The vapor balance VRS depends on an adequate seal being established between the vehicle being refueled and the faceplate of the fueling nozzle. 15, 16 

### As gasoline is pumped from the UST, a slight vacuum occurs in the UST which helps pu ll the vapors into the UST vapor space.

A vacuum assist VRS is sometimes “bootless;” a vacuum (by a pump) is used to pull the gases back through a series of holes (perforatio ns) in the nozzle spout during refueling to the headspace of the UST. 17, 18 

### The vacuum assist Stage II VRS design concept is based on the need to recapture vapor from the fill pipe of non-OR VR vehicles in equal volume to the gasoline dispensed during refueling. In most cases, liquid along the wall of the vehicle’s fillpipe allows the dispensing nozzle to form a seal with the fi llpipe. For most vacuum assist VRS, the UST vent is required to be equipped with a pressure /vacuum (P/V) va lve designed to open only if the

8 Refueling Emissions Controls at Retail Gasoline Dispensing Stations in New Jersey. Prepared for API by Tech Environmental, Inc. July 17, 2002.

9 Refueling Emissions Controls at Retail Gasoline Dispen sing Stations in Texas. Prepared for API by Tech Environmental, Inc. July 16, 2002.

10 Ref. 4, p. 4-2

11 Enhanced Vapor Recovery: Initial Statement of R easons for Proposed Amendments to the Vapor Recovery Certification and Test Procedures for Gasoline Load ing and Motor Vehicle Gasoline Refueling at Service Stations, Hearing Notice and Staff Report. California En vironmental Protection Agency, Air Resources Board. February 4, 2000. pp. 7 and 8.

12 Ref. 11, p. 8.

13 Refueling Emissions Controls at Retail Gasoline Dispensing Stations in New Jersey. Prepared for API by Tech Environmental, Inc. July 17, 2002, p. 2-3.

14 Ref. 13, p. 2-3

15 Ref. 4, p. 4-2.

16 Ref. 13, p. 2-3.

17 Ref. 12, p. 8.

18 Ref. 13, p. 2-3.

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### 11 pressure or vacuum inside the tank increases beyond a defined threshold. 19, 20 

### The vacuum assist works well with non-ORVR equipped vehicles, recapturing at least 95 percent of the vapor displaced by the gasoline. However, when refu eling an ORVR vehicle, there are no vapors to recapture in the vehicle’s fill pipe and the system recaptures ambient air in a roughly equal volume, depending on the air to liquid ratio, to the gasoline delivered and returns it to the UST
vapor space.
Stage II VRS is certified to achieve, and can achieve, 95 percent control efficiency. The actual in-use control efficiency achieved, however , is affected by rule effectiveness and rule penetration. The rule effectiven ess is impacted by defects/leak s or malfunctions that occur within the VRS. The rule eff ectiveness and in-use control efficiency can be improved through better monitoring of the VRS and more frequent oversight inspections. With more frequent monitoring, malfunctions and defects /leaks can be repaired more qui ckly and can be expected to reduce excess emissions, i.e., incr ease rule effectiveness. Rule penetration accounts for the number of GDF in an area that are actually subject to the Stage II control requirements (e.g., GDFs that dispense less than 10,000 gallons per mont h are exempt from Stage II controls in an area).

In practice, the range of in-use control effi ciencies for Stage II VRS are 62 to 92 percent depending on the inspection frequency (this range is for no exemptions, i.e., 100 percent rule penetration). 21 

### When rule penetration is accounted for, depending on the exemption level for an area, the in-use control efficien cy ranges from 56 to 90 percent. 22 

### EPA Region 1 indicated that most of their States (Maine, New Hampshire, Vermont, Massachusetts, Connecticut, and Rhode Island) rely on an in-use efficiency of 84 pe rcent for Stage II VRS in their SIP calculations. 23



### B. Description of ORVR

ORVR-equipped vehicles collect the gasoline va por displaced from the vehicle fuel tank during filling; the gasoline vapors are adsorb ed in a canister and, so metime afterwards, are released to the engine. ORVR controls are e xpected to achieve from 95 to 98 percent reduction of the vehicle refueling emissions (59 FR 16273 and 16279-80; April 6, 1994). When refueling a vehicle with ORVR control onl y, the ORVR canister does not a ffect UST vent breathing and emptying losses. 24

19 Ref. 4, p. 4-30.

20 Ref. 13, p. 2-3.

21 Ref. 4, p. 4-50.

22 Ref. 4, p. 4-54.

23 Electronic mail communication from A. Arnold, EPA Region 1, to T. Driscoll, EPA/OAQPS/EMAD. July 29, 2004.

24 Stage II Comparability Study for the Northeast Ozone Transport Region . U.S. Environmental Protection Agency. EPA Publication No. EPA-452/R-94-011. January 1995, p. 15.

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### 12 C. Description of Stage II/ORVR Issues

Section 182(b)(3) of the Clean Air Act (C AA), 42 U.S.C. 7511a(b)(3), requires the Stage II vapor recovery program for moderate, serious, severe, or extreme ozone national ambient air quality standards (NAAQS) nonattainment areas. Section 202(a)(6) of the CAA, 42 U.S.C. 7521(a)(6) requires EPA to develop standa rds for ORVR controls on light-duty vehicles. Section 202(a)(6) of the C AA also states that the section 182(b )(3) Stage II requirement shall not apply in moderate areas after ORVR sta ndards are promulgated. On April 16, 1994, EPA promulgated regulations requiring the phase-in of ORVR controls on new vehicles. In addition, the CAA provides that EPA may revise or wa ive the Stage II control requirements of section 182(b)(3) for “serious” or worse ozone no nattainment areas after EPA determines that ORVR control systems are in “widespread use” throughout the motor vehicle fleet.

As ORVR equipment is being phased in for new vehicles, there is some concern regarding the compatibility of ORVR controls and Stage II cont rols. When an ORVR-equipped vehicle refuels at GDF with Stage II VRS, the amount and composition of the vapor returned to the UST by the Stage II control sy stem can be impacted. An in crease in the amount of air (in lieu of gasoline vapor) returned to the vapor sp ace of the UST will lead to gasoline evaporation, or vapor growth, in the UST and lead to excess emissions from the UST vent. A larger amount of air is returned to the UST vapor space for so me Stage II vacuum assist VRS when refueling vehicles with ORVR controls, and therefore, th e excess emissions are greater for some vacuum assist systems. 25



### While considering how to define and calculate widespread use, EPA was presented with issues related to Stage II VRS, ORVR, and their potential for incompatibility, including: (1) excess vapor growth within the UST system, (2) UST system pressure build up, (3) fugitive emissions, and (4) gas station emissions monitoring. Subsequent sections outline and discuss these issues. Detailed comments from the stakeh olders and options to ad dress these issues are discussed in Section V.

D. Continued Use of Stage II VRS

Section 202(a)(6) provides that EPA may re vise or waive the application of the requirements of section 182(b)(3) of the C AA for serious, severe, or extreme ozone nonattainment areas after EPA determines that ORVR control systems are in “widespread use” in the motor vehicle fleet. If EPA decides to revise or waive these requireme nts, States or areas could decide to repeal requirements for Stage II VRS, following demonstration of widespread use in the area or State. Under this scenari o, there would be many serious, severe, and extreme counties that currently have Stage II controls that would no longer be required to have them after widespread use occurs. The State could also decide that the Stage II requirements will remain in effect. We expect a benefit to retaining Stag e II VRS until all vehicles have ORVR. EPA may consider providing additional SIP credits where States (non-OTR) retain Stage II VRS after widespread use occurs. EPA c ould provide SIP credits from the date widespread use occurs (depending on the definition of widespread use chosen) until the time when combined ORVR and Stage II VRS emissions are no longe r less than ORVR emissions only.

25 Ref. 11, p. 36.

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### 13 E. Underground Storage Tank Emissions

Emissions from an UST vent could result fr om one or more of the following conditions: 26 

### (1) normal emptying and breathing emissions expect ed from the UST vents without any Stage II controls during refueling (uncont rolled); (2) normal emptying and breathing emissions expected from the UST vents when Stage II VRS are us ed during refueling, bot h vapor balance and vacuum assist systems (controlled); or (3) excess emissions from the UST vent related to vapor growth resulting from the incompatibility of co mbined Stage II vacuum assist VRS with ORVRequipped vehicles durin g refueling. (Note : The AP-42 emissions fact or for UST vent emptying and breathing emissions also includes vapor loss between the UST and the gas pump, i.e., fugitive emissions.) 27 

### Lastly and as a sepa rate issue, some studies suggest that there are significant emissions from the UST vents, other than thos e from refueling vehicles. 28



### F. Fugitive Emissions

Fugitive emissions at a GDF could result from one or more of the following: (1) the normal fugitive emissions expected from GDF w ithout any Stage II controls; (2) the normal fugitive emissions expected from GDF when Stage II VRS is used; (3) the excess fugitive emissions from the GDF resulting from the incompa tibility of combined vacuum assist Stage II VRS with ORVR-equipped vehicles during refue ling; and (4) the potential fugitive emissions from the deterioration and aging of gasoline dispensing equipment.

CARB studies suggest that pr essure-related fug itive emissions resulting from leaks at GDF may be significant. Furthermore, some testing by CARB suggests that pressure-related fugitive emissions may increase when vacuum assist Stage II VRS is used in conjunction with ORVR-equipped vehicles. 29 

### CARB test method procedures cal culate pressure-related fugitive emissions based on pressure measurements in the system. A recent API study measured fugitive emissions simulated in a field laboratory se tting and concluded that the CARB calculations overestimate fugitive emissions. 30 

### We are reviewing data pr ovided by vendors and plan to observe and have emissions testing conducted to quantify fugitive emissions under the various uncontrolled and controlled scenarios at GDF.

26 Emissions discussed here include th ose from breathing and emptying and do not include emissions from filling (i.e., related to Stage I).

27 AP-42. Section 5.2, Transportation and Marketing of Petroleum Liquids. January 1995. See http://www.epa.gov/ttn/chief/a p42/ch05/final/c05s02.pdf

28 Membranes, Molecules, and the Science of Permeation. Tedmund Tiberi. Petroleum Equipment & Technology

. April 1999.

29 CARB. Preliminary Draft Test Report, Total Hydrocarbon Emissions from Two Phase II Vacuum Assist Vapor Recovery Systems During Baseline Operation and Simulated Refueling of Onboard Refueling Vapor Recovery (ORVR) Equipped Vehicles. June 1999.

30 API. ORVR Compatibility Study for the Gilbarco Vaporvac VRS . February 2004. Includes Phase 1, Phase 2 - Outside, and Phase 2 - SHED.

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### 14 G. GDF Emissions Monitoring, Inspections, and Maintenance

As discussed previously in th e Background section, the in-use control efficiency of Stage II VRS ranges from 56 to 92 percent, depending on the inspection frequency and the exemption levels. 31 

### After the VRS equipment is installed, associ ated wear and tear, malfunctions, or system problems can result in reduction of certified e fficiency. While Stage II control systems can achieve 95 percent or better control efficienc y, in-use efficiency is demonstrated to drop significantly without proper operation and maintenance. 32 

### Data analyzed during preparation of the EPA’s Technical Guidance Document indicate that conducti ng semi-annual inspections provide in-use efficiencies of 92 percent, annual inspections provi de in-use control efficiencies for Stage II VRS of 86 percent, and minimal or less frequent in spections provide 62 percent inuse efficiencies (these values assume no exemptions). 33 

### The in-use control efficiency for Stage II is directly related to the inspection freq uency and subsequent repa ir of systems. Based on the inspection program conducted by an area, SI P credits may be provid ed above the typical in-use efficiency demonstrated from Stage II VRS operation.

We believe that better (and more frequent) monitoring, coupled with good operation and maintenance programs, results in emissions re ductions. GDF include several potential VOC emissions points other than the refueling interf ace that are monitored infrequently, at best. Several types of improved monitoring are being conducted by States that result in increased control efficiencies of the Stage II VRS e quipment and increased emissions reductions. Improved monitoring may include: (1) oversight inspections and (2) requirements for in-station diagnostics (ISD).

Oversight inspections of the Stage II VRS at GDF are conducted by area inspectors and generally focus on Stage II VRS equipment defects and: (1) visual inspection of the nozzles, boots, faceplates, and hoses for cuts, tears or ot her disrepair (some States require more than visual inspections); (2) checks of the nozzle chec k valves, nozzle latches, etc.; (3) inspection of the air pollution control device (APCD) on the US T, if any (i.e., the processor); (4) on-site paperwork and records; and (5) confirmation that the installed VRS matches the permitted VRS. Some areas have an equipment checklist or an insp ection form that inspectors use at each site, while others do not. The inspection frequency ra nges from once every 5 years to two to three inspections each year. Some areas have priority inspection programs, where GDF with recurrent problems are inspected more frequently and co nscientious GDF are inspected less frequently, perhaps only once per year. 34



### Another closely related option for improve d monitoring might include a maintenance program for dispenser components. A GDF could implement a program of scheduled replacement of components that may leak. Inthis program, each component would be datestamped and replaced on a scheduled basis, regardless of detected leaks or other defects/malfunctions. This maintenance progr am may prevent leaks from occurring.

31 Ref. 4, p. 4-54.

32 Ref. 4, p. 4-53.

33 Ref. 4, p. 4-50.

34 Ref. 4, pp. 6-22 through 32.

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### 15 In-Station Diagnostics (ISD) is a program th at measures operati ng parameters of the Stage II VRS and GDF equipment to ensure it is operating properly. Th e ISD program provides real-time monitoring of critical VRS components and signals when failure modes are detected. The parameters monitored depend upon the type of VRS. For vapor balance VRS, UST pressure, pressure drop across hose, nozzle, etc. (to detect liquid blockage), and vapor returned to liquid dispensed (V/L) ratio 35 

### with a flow meter would be measured. 36 

### For vacuum assist VRS, UST pressure and V/L ratio with a sensor would be measured; if the V/L ratio is out of limits, the vapor pump flow is adjusted to achieve the correct V/L ratio. 37 

### If the assist VRS also has an air pollution control device (APCD) or pr ocessor on the UST, opera ting parameters of the APCD such as hydrocarbon concentration, flow ra te, flame detection, and pressure would be monitored. 38 

### California has indicated that the goal of the ISD program in their State is to bring the in-use control efficiency to the 90 percent currently assu med in the inventory. 39 

### For other States that adopt ISD programs, SIP credits may be provided if it is determined that the in-use control efficiency in their SIP has been exceeded.

H. Widespread Use Determinations

As previously mentioned, when EPA determ ines that ORVR control systems are in widespread use throughout the motor vehicle fleet, States will have the opti on to remove Stage II VRS. This determination has several components, including: (1) defining “widespread use,” (2) predicting when it will occur, a nd (3) how it can be demonstrated and verified. We know the definition and occurrence of widespread use is in tegral for State and local air pollution control agencies, so they can revise thei r control strategies and update thei r SIPs. Some of the ways to interpret and define widespread use include:

a. When “x” percent of the vehicl es in service are ORVR-equipped, b. When “x” percent of the vehicle mile s traveled (VMT) are from ORVR-equipped vehicles,

c. When the total VOC emissions from ORVR-equipped vehicles are equal (or equivalent) to the total VOC emissi ons from Stage II VRS programs, or d. When “x” percent of gasoline sold is dispensed to ORVR-equipped vehicles. Some of the widespread use definitions are simple appr oaches and some are more complex. In each of these definitions, the re quirement for what percentage represents widespread use would be establis hed first (i.e., 95 percent, 90 per cent, 85 percent, etc.). The analysis/computation would then be conducted base d on State-specific data , or region-specific

35 The vapor returned to liquid dispensed (V/L) ratio is an important operating factor of VRS. The V/L ratio is also referred to as the air returned to liquid dispensed, or A/L ratio. The V/L ratio refers to the ratio of the quantity of vapor and air returned to the UST headspace to the quantity of gasoline pumped out of the UST.

36 Ref. 11, p. 66.

37 Ref. 11, p. 67.

38 Ref. 11, p. 67-68.

39 Ref. 11, p. 94.

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### 16 data if a larger or smaller area than a State woul d be analyzed. Each of the possible definitions are discussed below, along with the a dvantages and disadvantages of each.

Definition (a) (percentage of ORVR-equipped vehicles ). Definition (a) is a simple approach for widespread use. In this definition, the analys is would be conducted based on vehicle registration data, projections of that data into the future , and the phase-in schedule for ORVR. While the approach accurate ly represents the vehicle fleet, it is important to note that more vehicle miles are traveled for newer vehicl es, as people tend to drive newer vehicles more often and for longer trips than older vehicles. Definition (a) does not reflect this, and also does not reflect some general differen ces in vehicles such as fuel economy (miles per gallon) and useful life.

Definition (b) (percentage of VMT by ORVR-equipped ve hicles). Definition (b) is also a fairly simple approach. Definition (b) would be based on all of the data inputs for definition (a) plus the VMT data by class of vehicle. Th is approach addresses th e VMT by ORVR vehicles issue mentioned under definition (a); an area or St ate is more likely to reach the criterion in definition (b) before reaching th e criterion in definition (a) (i.e ., widespread use would occur earlier with definition (b)). VM T data are generally available for States and regions. This approach may not address differences in vehicl es such as fuel economy (miles per gallon) and useful life.

Definition (c) (VOC emissions with ORVR controls equal VOC emissions with Stage II VRS only). Definition (c) is a slightly more co mplex approach that would require calculation and comparison of vehicle refueling emissions based on two different refueling control measures. This definition would require the data inputs for definitions (a) and (b) along with data on ambient temperature, Reid vapor pressure, rule effectiveness, rule penetration, and the percentage of GDF with vacuum assist Stag e II VRS (to determine incompatibility excess emissions). The advantage of this approach is that it addresses and comp ares emissions levels directly. A disadvantage w ith this approach is that the in-use control efficiency of the Stage II VRS must be correctly determined (ra nge was provided as 56 to 90 percent). 40



### Definition (d) (gasoline dispensed to ORVR-equipped vehicles). Definition (d) would require data on the volume of gaso line sold in addition to the data inputs needed for definition (b). A disadvantage of this approach is that gasoline quantities dispensed typically are not available on a county or area basis and must be estimated based on either VMT data and fuel economies or county gasoline sales (in dollars). This approach does, however, address differences in vehicles such as fuel economy fo r each vehicle type. Included as part of the Regulatory Impact Analysis (RIA) conducted fo r the ORVR regulations in January 1994, the widespread use analysis was based on ga soline dispensed to ORVR-equipped vehicles. 41

40 Ref. 4, p. 4-54.

41 Final Regulatory Impact Analysis: Refueling Emission Regulations for Light Duty Vehicles and Trucks and Heavy Duty Vehicles. U.S. Enviro nmental Protection Agency, Office of Mobile Sources. January 1994.

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### 17 I. Description of SIP Credit Opportunities

In prior meetings and discussions with stak eholders, several questions arose regarding SIP credits related to the widespread use date and Stage II control requirements. The questions include how SIP credits might be impacted by: (1 ) continuing to use Stage II controls after the widespread use date, (2) requiri ng Stage II controls in new ar eas, and (3) applying improved monitoring to Stage II control systems to decrease emissions and increase rule effectiveness. Figure 1 shows the relative emissions for several cont rol measures and in-use efficiencies. The figure shows the full range of possible in-use effi ciencies and their relation to the ORVR only control scenario (point B versus point B’ de pending on the Stage II cont rol efficiency). The figure also shows that the combined use of OR VR and Stage II VRS controls results in lower VOC emissions than either control measure alone. If a State applie d both control measures in its projected emissions baseline, it could not receive additional SIP credit for those same measures, i.e., to avoid double-counting.

0 2 4 6 8 10 12 14 16 18

2005 2010 2015 2020 2025 2030 2035

Future Calendar Years V O C ( t o n s / s u m m e r d a y ) Stage II Controls Only_90% IUE

Stage II Controls Only_56% IUE

ORVR Only

Stage II Controls (90%IUE) with ORVR and No Incompatibility Excess Emissions Stage II Controls (56% IUE) with ORVR and No Incompatibility Excess Emissions

Point B Point B'



### Figure 1. General emissions trends expected fo r refueling emissions in future calendar years for a hypothetical State, no incompatibility excess emissions (based on API studies).



### 1. SIP Option for States to Include Stage II VRS in Additional Areas. States could require Stage II VRS in areas wh ere they are not curre ntly required and/or located, even knowing that Stage II VRS may not be required after relatively few years. Under the new 8-hr ozone designations : (1) several MSAs were revi sed and additional counties were included in ozone nonattainment areas, (2) several MSAs that were serious or severe under the 1- hour standard are newly classified as moderate under the 8-hour ozone standard, and (3) several

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### 18 areas have been newly classified as ozone nonattainment areas (added to the moderate nonattainment classification). Where MSAs we re revised and counties were added and the MSAs were previously classified as serious or severe, the added counties are not likely to have Stage II controls in place. If th e State decides to reta in Stage II controls in these MSAs after the widespread use date, States could require these ad ded counties to also cont rol Stage II emissions. In the second scenario, a State could require Stag e II in moderate nonattainment areas that have been newly added to the ozone nonattainment areas.

State and local agencies may be reluctant to require Stage II VRS fo r a limited number of years. However, some States may be interest ed in requiring Stage II VRS for GDF that are not currently required to have Stage II controls, if adequate SIP cred its are granted. A few moderate areas (outside of OTR) retained Stage II co ntrols following the Apr il 1994 promulgation of ORVR controls (e.g., counties in Florida). If SIP credits can be granted for requiring Stage II VRS in additional areas, the credit calculation wo uld include the emissions reductions that reflect combined Stage II and ORVR controls. For thes e counties, the emissions from GDF would be affected significantly.

2. Other SIP Credit Options. SIP credit may also be an op tion for States where stations install UST vent controls or other control measures after Stage II VRS re quirements are removed. The other control measures may include a P/V valve or an UST add-on APCD (processor) or possibly other CARB EVR requirements.

Groundwater Contamination from Stage II VRS. 

### Some studies suggest that l eaking USTs, includin g liquid leaks and po ssibly vapor leaks, are contaminating the groundwater with MTBE. MT BE is a component of gasoline and is added to reformulated gasoline, oxygenated fuels, and premium grades of unlead ed gasoline. EPA has not set a national standard for MTBE in drinki ng water, but many States have set their own limits.

EPA-promulgated federal UST regulations have contributed significan tly to the reduction of soil and groundwater contamination (by MTBE and other fuel components). Unfortunately, even with these regulations in place, there are sometimes equipment failures and installation mistakes that result in releases of fuel to the environment; in addition, there are also some concerns that vapor leaks occu r from the UST when the tank becomes pressurized. EPA is currently working with States to improve the compliance rate of the leak detection requirements through compliance assistance programs, UST insp ections, and enforcement actions. As of December 22, 1998, substandard USTs not meeting requirements for spill, overfill, and corrosion were required to be upgraded or closed. 42 34



### – UST Regulations



### New UST . Federal UST regulations specify th at new UST installed after December 22, 1988 must meet four requirements: (1) that the installa tion of the tank and piping be certified to meet industry codes, (2) that the tank be inst alled with leak detecti on, (3) that the tank be

42 See: http://www.epa.gov/swerust1/mtbe/index.htm

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### 19 installed with spill and overfill protection, and (4 ) that the tank be installed with corrosion protection. 43, 44

35, 36 

### All of these requirements are cruc ial in ensuring that the UST does not contaminate groundwater. The leak detection requirements include three components; the leak detection system must:

# Detect a leak from any porti on of the tank or its piping,

# Be calibrated, operated, and maintained as directed by manufacturer’s instructions; and

# Meet performance requirements contained in 40 CFR 280.43 and 280.44. A GDF must conduct monthly monitoring of the UST using the leak detection system and must select at least one of the followi ng methods to determine if leaks exist:

1. Interstitial Monitoring: de termine if there are leaks in the space between the UST and the second barrier.

2. Automatic Tank Gauging Systems: use automation to monitor product level and inventory control.

3. Monitoring for Vapors in the Soil: samp le vapors in the soil surrounding the UST.

4. Monitoring for Liquids in the Groundwater: monitor the groundwater table near the UST for the presence of released free product on the water table.

5. Statistical Inventory Reconc iliation: requires that a trained professional use sophisticated computer software to perf orm a statistical anal ysis of gasoline inventory, delivery, a nd dispensing data.

6. Other Methods Approved by the Regulatory Au thority: a comparable proven method to the above methods.

As an alternative to the monthly monitoring methods, a GDF may combine inventory control with tank tightness testing for the first te n years after the instal lation of a new UST. After ten years have passed, the GDF would then have to use one of the six monthly monitoring methods mentioned above. An inventory control program consists of taking daily measurements of UST contents and recording deliveries and the amount of product pumped from the UST. This information along with daily and monthly calcu lations indicates if th ere is a leak. A tank tightness test must be c onducted every five years.

Leak detection monitoring is also important for UST piping. Pressurized piping must meet one of the following requirements: (1) piping must be installe d with devices that automatically shut off, restrict flow, or sound an alarm; or (2) conduct an annual tightness test or

43 Straight Talk on Tanks: Leak Detection Methods for Petroleum Underground Storage Tanks and Piping. U.S. Environmental Protection Agency. EPA Publication No. EPA 510-B-97-007. September 1997.

44 Musts for USTs: A Summary of Federal Regulation for Underground Storage Tank Systems. U.S. Environmental Protection Agency. EPA Publication No. EPA 510-K-95-002. July 1995.

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### 20 one of the six monthly monitori ng methods noted above for UST. If the UST piping is suction piping, the leak detection requirements are de pendent on the type of suction piping used.

New USTs must also meet spill and overfill re quirements. All new installed UST must be installed with a catchment basin. A catchment basin, also referred to as a spill containment manhole or spill bucket, is a bucket sealed aroun d the UST fillpipe. Most catchment manholes are equipped with pumps or drains to remove li quid spills. New USTs must also have overfill protection upon installation. Three commonly used overfill protection de vices provide either automatic shutoff, overfill alarms, or ball float valves.

Lastly, a new UST must have corrosion protection. The US T and associated components must be comprised of either (1) non-corrodible material such as fiberglass or jacketed in noncorrodible material, (2) made of steel that is coated with a co rrosion-resistant coating and with cathodic protection, or (3) made of steel clad with a thick layer of non-corrodible material (does not apply to piping).

Existing UST . Existing UST that were instal led before December 22, 1988 were required to meet the leak detection require ments by December 1993. Both spill and overfill protection requirements and corrosion protecti on requirements were required to be met by December 22, 1998.

The leak detection requirements for existing US T are similar to the requirements for new UST. Existing UST can use any of the six m onthly monitoring methods as described for new UST. Spill and overfill requirements are the sa me for existing and new UST. Existing UST must also meet the corrosion protection requireme nts. If the existing tank does not currently meet the corrosion requirements specified for new UST, the existing UST must be modified. If the existing UST is made of steel, one of follo wing methods must be chosen to add corrosion protection: (1) add cathodic prot ection, (2) add interior lining to the UST, i.e., non-corrodible material, or (3) combine cathodic protection and inte rior lining. The existing UST piping that is made of steel must also have cathodic protection.

– SIP Credits Associated with Preventing UST Leaks 

### Currently, the federal UST regulation requi res a GDF to pick one of six monthly monitoring methods for identifying UST leaks (des cribed above), or as an alternative to the monthly monitoring methods, a new UST may co mbine inventory control with tank tightness testing for the first ten years after the inst allation of the UST. While these monitoring requirements are mostly in place to detect liq uid leaks from UST, so me of the monitoring methods may also detect vapor le aks, for example, the tank tight ness requirements. In addition, periodic pressure testing of the UST such as st atic pressure tests or pressure decay tests will confirm that there are no vapor leaks from the tank and fittings. We believe that SIP credits may be warranted for areas that re quire GDF to perform a combination of monitoring methods to monitor for UST liquid and vapor leaks. A GDF utilizing more than one monitoring method would have a back-up method in the event one m onitoring method failed to detect a leak. SIP credits may also be warranted for areas that require more frequent monitoring than monthly monitoring.

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### 21 

## IV. Stage II Discussion Meetings with Stakeholders and Vendors
During Stage II data collection, we met one-on-one with HERTZ, Alliance of Automobile Manufacturers ( AAM), ARID Technologies, In c. (ARID), Vapor Systems Technologies, Inc. (VST), Healy Systems, In c. (Healy), EMCO Wheaton, and the American Petroleum Institute (API). The information disc ussed and/or data received from these meetings are summarized below.

A. Hertz Meeting Summary

At the request of Hertz Rent-a-Car (Hertz), we met to discuss a waiver from Stage II VRS requirements for existing and ne w rental car facilities. Hert z currently maintains a vehicle fleet where approximately 97 percen t of the vehicles have ORVR equipment. Hertz believes that because their vehicle fleet is almost entirely comprised of vehicles w ith ORVR equipment and because maintaining Stage II VRS is redundant, rem oval of Stage II VRS at their facilities would not result in an increase in VOC emissions. Although we cannot provide a direct waiver from Stage II VRS requirements to Hertz, we have di scussed providing a memorandum to States and Regions that would support the granting of a waiver of Stage II VRS by a State.

In order to obtain emissions data to s upport development of such a memorandum, we have discussed with Hertz a monitoring sche dule for emissions points at GDF under several scenarios. The objectives for such monitoring ar e to: (1) demonstrate th at VOC emissions would not increase if Stage II VRS are removed at existi ng Hertz airport GDF facilities, (2) demonstrate that VOC emissions would not increase if Stag e II VRS are not installe d at newly constructed Hertz airport GDF facilities, and (3) demonstrat e that VOC emissions reductions from refueling a high percentage of ORVR-equipped vehicles are at least equivalent to emissions reductions obtained from a Stage II VRS.

B. Alliance of Automobile Ma nufacturers (AAM) Meeting Summary

Also, at the request of AAM we met to disc uss a waiver from Stage II VRS requirements at automobile manufacturing facilities. AAM believes that because almost all of the new vehicles being refueled at manufacturing f acilities have ORVR equipment and because maintaining Stage II VRS is redundant, removal of Stage II VRS at their manufacturing facilities would not result in an increase in VOC emissions. Again, we informed them that although we cannot provide a direct waiver from Stage II VR S requirements to automobile manufacturers, we have discussed providing a memorandum to Stat es and Regions that would support the granting of a waiver by a State. Although such a waiver request would be very similar to the rental car agency waiver described above, there are several key differences in the refueling operations for the automobile manufacturers, such as: (1) th ere are no vapors in th e vehicle gasoline tanks before they are fueled for the first time, so ther e are no vapors to be expelled from the vehicle tank (also called the “green tank e ffect”) and (2) the line from th e gasoline dispenser to the UST may be several miles long, which may cause so me additional emissions due to the expansive piping necessary to move the gasoline to the di spensing area. The automobile manufacturers have submitted some emissions test data monitoring these conditions. These data are summarized in Section VI.

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### 22 C. ARID Technologies Meeting Summary

We met with representatives of ARID Technologies, manufac turers of add-on APCD for UST vents. The APCD is a membrane techno logy (called PERMEATOR) that prevents UST venting of gasoline vapors. ARID claims the technology can be used with balance Stage II VRS and vacuum assist VRS. ARID believes the technology allows for improved UST vapor recovery efficiency during UST breathing and emptying; the technology has the potential to recover gasoline product that would otherwise be emitted to the atmosphere as vapor.

ARID believes there is an increase in emissions that results from the combined use of vacuum assist Stage II VRS and ORVR. ARID al so maintains that counting UST emissions as either fugitive or vent emissions is largely academic. The important point is that an excess vapor generation rate is present within the UST syst em. The excess vapor volume will result in an observed pressure increase within the UST. A relatively “tighter” system will yield higher UST vent emissions (ARID includes emptying, breathi ng, and incompatibility excess emissions) and a relatively leaky system will yield higher fugitive em issions. In general, if an UST add-on APCD is employed to reduce the overall storage tank pr essure while at the same time capturing and recovering UST vent emissions, the driving force for fugitive emissions is greatly reduced, and both the fugitive and UST vent emi ssions are significantly reduced.

D. Vapor Systems Technologies, Inc. (VST) Meeting Summary

We met with representatives of VST, ma nufacturers of another add-on APCD for the UST vent. VST’s product, a membrane processo r that reduces fugitive emissions, is undergoing CARB testing to determine if it is compatible with refueling ORVR-equipped vehicles. VST has 3 test sites in California and is working to establ ish additional test sites in other regions in the U.S. VST believes that its monitoring data show : (1) most, if not all, positive tank pressure fugitive emissions to the atmosphere are from l eaking UST systems, (2) the increase in ORVR vehicle penetration is causing increased fugitive emissions when used with vacuum assist Stage II VRS, and (3) VST’s new technologies provid e the ability to use ORVR and Stage II VRS systems simultaneously while reducing UST syst ems pressures and eliminating fugitive vapor emissions.

VST believes the fugitive vapor emissions at GDF are more severe than previously considered. VST believes that th e growing rate of ORVR equipmen t in the vehicle population is contributing to an increase in fugitive vapor emissions. VST believes that UST systems have a high leak rate, resulting in increased fugitiv e emissions, and the UST systems require a high level of maintenance to remain tight.

E. Healy Systems, Inc. (Healy) Meeting Summary

Healy believes that the assumption that ORVR fleet penetration at some point will make Stage II VRS redundant is not accurate. Healy belie ves that 20 percent of gasoline dispensed in the foreseeable future will fuel non-ORVR equippe d vehicles and other motor driven units. If Stage II VRS equipment is removed, then 100 percent of the refueling vapor emissions associated with non-ORVR equipped vehicles and ot her motor driven units will be emitted to the atmosphere. Healy also maintains that the source of emissions at GDF is positive pressure build-

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### 23 up in the ullage space of the UST and that the pr oblem is associated with the design of Stage II vacuum assist VRS. Healy sugge sts that fugitive leaks are in the magnitude of 1 gallon per minute. Healy manufactures an UST add-on APCD , the Clean Air Separator (or bladder tank), that acts as a pressure management system. Any excess vapors from the UST vent due to pressurization are routed to the bladder tank and are contained rather than emitted to the atmosphere. These vapors may be returned/pul led back into the UST from the bladder through the UST vent when the UST pressure drops below -8.0 inches of water column (in. w.c.). The bladder collapses as the contained vapors are returned to the UST.

F. EMCO Wheaton Retail Meeting Summary

EMCO Wheaton manufactures various gas di spensing nozzles, including a dripless nozzle, P/V valves, Stage I fittings for UST, manhole covers, and othe r equipment. EMCO Wheaton believes that nozzles ar e not being replaced frequent ly enough; many nozzles at GDF deteriorate to the point where th e nozzle can no longer shut itsel f off during vehicle refueling. EMCO Wheaton referenced a study conducted in Sout hern California that showed, on average, that nozzles are approximately 18 months old. EMCO Wheaton sells a standard nozzle for approximately $20, while a Stage II VRS nozzl e costs approximately $110. One of EMCO Wheaton’s test sites in California with a balanc e Stage II VRS showed that the P/V valve never opened and that the tank pressure never exceed ed 3 in. w.c. over a one-year period. EMCO Wheaton also stated that new UST are structurally sound and are ex tremely tight, and as a result, vapor leaks are not likely to occu r. Vapor leaks may occur, howev er, around the tank’s fittings. Tank inspections aid in the ability to keep the UST tight and are often performed every 6 months in California. EMCO Wheat on believes underground contamination is caused by residual contamination and not new leaks and that dr ips from GDF may also be contributing to groundwater pollution. In summary, EMCO Wheaton believes that (1) balance Stage II VRS should be retained because these systems are alre ady ORVR compatible, and very little expense is required to convert a vac uum assist VRS to a balance VRS, (2) GDF should be inspected frequently, (3) UST vents need to be teste d, (4) CARB’s EVR program is too stringent and expensive and does not result in corresponding emissions reductions, (5) the widespread use definition should retain Stage II VRS for as long as possible, and (6) in -station diagnostics (ISD) are inexpensive and effective.

G. American Petroleum Institute (API) Meeting Summary

API began the discussions with a general pr esentation of the Stage II VRS, widespread use, and ORVR/Stage II VRS incompatibility issu es. A description of widespread use studies conducted by API followed. API also descri bed a study conducted by the University of Tennessee on the costs associated with opera ting and maintaining Stage VRS. During a discussion of in-use control efficiency claime d by State and local air pollution control programs (States), API indicated that States claim 77 percent, while EPA said that some States claim up to 90 percent. MOBILE6, the EPA model for estima ting emissions from mobile sources, applies a 98 percent control efficiency for the fill-pipe re fueling emissions. A discussion of what CARB is requiring for most California GDF followed. Enhanced Vapor Recovery (EVR) and in-station diagnostics programs were discussed. API said that it would cost each station about $30,000 to comply with the EVR program and that few, in some cases none, equipment vendors had developed equipment to comply with CARB’s EVR requirements.

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### 24 The key discussion concerned the di fferences between CARB’s and API’s incompatibility excess emissions (IEE) that occur when refueling a car. API disagreed with the way CARB conducted the tests and with the way CARB interpreted the results of their testing. Further, API explained how their testing was more realistic and s howed the IEE to be less than half of CARB’s IEE levels. CARB estimated IE E to be 2.5 to 4.5 tons per day for the entire state. Discussions of emissions from USTs fo llowed and API disagreed with the way that CARB estimated the pressure-related fugitive emissions.

API described a collaborative effort by CARB and the Western States Petroleum Association (WSPA) to co llect more information about pressu re-related emissions. The results of this project may be very informative for a ny decisions EPA would make. However, it is our understanding that this project has not been st arted and may have been cancelled. API also described some other IEE, UST, and widespread use testing they have been doing in an Arizona laboratory.

A discussion of the issues paper (see aforementioned references) ensued and EPA indicated that if a definition requires calcu lation of emissions, EPA would probably use MOBILE6. EPA also thought that there may be enough information to quantify IEE. API disagreed and added that CARB does not believe there are enough data to quantify IEE. This discussion led to a discussion of incompatibil ity emissions factors and their validity.

There was some final discussion of the indus try in general and whether “majors” or “independents” owned the gas stations. Independ ents own most of the GDFs. There was also some discussion of potential SIP credit ideas, especi ally where States may add or retain Stage II VRS after the widespread use date.


## V. Public Meeting – September 2004
On September 20, 2004, EPA held a public meet ing to provide stakeholders and other interested parties the opportunity to present da ta or views concerning Stage II VRS, widespread use, or other pertinent Stage II issues. Approximately 30 non-E PA people attended the meeting in Research Triangle Park, along with 10 EPA staff and 12 participants by phone, including 2 EPA regional staff and a representative from the California Air Resources Board. Thirteen representatives of refining trad e associations, marketing trade associations, States, equipment vendors, and gasoline station inspectors made presentations at this meeting. EPA asked clarifying questions during the pres entations but did not respond to specific or direct questions raised during the meeting.

At the conclusion of the meeting, EPA enc ouraged stakeholders to provide their presentations either electronically or in hard copy, as well as to provide any data pertaining to Stage II emissions or other pertinent data. EP A posted papers, presentations, and data on an EPA website accessible to the public ( http://www.epa.gov/ttn/naaqs/ozone/ozonetech/stage2/). EPA also said that it would not respond to indi vidual comments from stakeholders but would respond generally in a rule or policy regarding Stage II.

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### 25 A. Comments from the Public Meeting and on EPA’s Issues Paper

Twenty-two representatives of refining trade associations, marketing trade associations, States, equipment vendors, and gasoline station inspectors submitted comments. A list of the stakeholders who submitted comments and a general overview of the comments are presented below.

Table 1. List of Stakeholder Commenters

Entity Contact(s) Comment Reference NESCAUM Ken Colburn Executive Director, (Lisa Rector) Letter dated September 30, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/nescaum_09-30-04.doc Connecticut Department of Environmental Protection (Connecticut DEP) Chris James, Director, Planning & Standards, (Ariel Garcia, Debbie Tedford) Letter dated September 30, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/state_of_conn_9-30-04.pdf New Jersey Department of Environmental Protection (NJDEP) Judith Rand Letter dated September 29, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/state_of_new_jersey_09-29-04.doc Commonwealth of Virginia (Virginia) James Ponticello Letter dated September 30, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/comonwealth_of_va_9-30-04.pdf
California Air Resources Board (CARB) Cindy Castronovo Letter dated October 4, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/calif_air_resources_board_10-4-04.pdf
Texas Commission on Environmental Quality (TCEQ) David Schanbacher, Chief Engineer, (Kim Herndon, Eddie Mack, Jason Harris) Letter dated September 30, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/state_of_texas_09-30-04.wpd

Wisconsin Department of Natural Resources (Wisconsin DNR) Lloyd Eagan, Director, Bureau of Air Management, (Ralph Patterson) Letter dated September 29, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/state_of_wisconsin_09_30_04.pdf
Ohio Environmental Protection Agency (Ohio EPA) Bill Juris, Compliance and Enforcement Letter received September 30, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/state_of_ohio_9-30-04.doc Missouri Department of Natural Resources (Missouri DNR) Leanne Tippett Mosby, Director (Bud Pratt) Letter dated September 15, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/state_of_missouri_9-15-04.pdf Collier Shannon Scott, Counsel to National Association of Convenience Stores (NACS) and Society of Independent Gasoline Marketers of America (SIGMA) R. Timothy Columbus, Gregory Scott, Joseph Green Letter dated September 30, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/nacs_sigma_09-30-04.pdf

BP US Convenience Operations (BP) James S. White, Regulatory Affairs Letter received September 28, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/bp_us_convenience_operations_09-30- 04.doc

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### 26 Entity Contact(s) Comment Reference Veeder-Root Kent Reid, Director of Strategic Development Letter dated September 14, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/veeder_root_%209-15-04.doc Healy Systems, Inc. (Healy) James Healy, President Letter dated September 15, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/healy_systems_9-15-04.pdf Letter dated September 30, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/healy_systems_9-30-04.pdf
EMCO Wheaton Retail (EMCO) Jim Lawrence, (Ken Turcotte) Letter dated September 29, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/emco_wheaton_09-30-04.doc Letter Attachment 1 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/emco_wheaton_attachment_1_09-30- 04.pdf Letter Attachment 2 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/emco_wheaton_attachment_2_09-30- 04.pdf Vapor Systems Technologies, Inc. (VST) Glenn K. Walker, President, (Scott Brown) Letter dated September 30, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/vapor_systems_technology_09-30-04.pdf
American Petroleum Institute (API), NACS, Petroleum Marketers Association of America (PMAA), SIGMA Prentiss Searles, representing 44 state and regional trade associations, 8000 independent petroleum marketers, 1,700 retail member companies (100,000 stores employing 1.4 million workers), 250 independent fuel marketers, and 28,000 retail outlets employing more than 270,000 workers. Letter dated September 30, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/nacs_sigma_pmaa_api_09-30-04.pdf Attachment (Letter to API from Sonoma Technology , Inc. [STI]) www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/nacs_sigma_pmaa_api_attachment_09-30- 04.pdf

Costco Wholesale, Inc. (Costco) Tim Hurlocker, Director of Gasoline Operations Letter received September 30, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/costco_wholes ale_09-30-04.doc Husky Corporation (Husky) Art Fink, VP Engi neering Letter received September 28, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/husky_09-28-04.doc Letter dated August 31, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/husky_8-31-04.pdf Crompco Corporation (Crompco) Edward Kubinsky Jr. Letter received September 23, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/crompco_09-23-04.doc Frank & Gramling, Counsel to Florida Petroleum Marketers Association (FPMA) Robert Fingar Letter dated September 27, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/fpma_%2009-27-04.doc

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### 27 Entity Contact(s) Comment Reference ARID Technologies, Inc. (ARID) Tedmund Tiberi Letter dated September 28, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/arid_technologies_9-30-04.pdf Remote Sensing Air, Inc. (RSA) Judith Zwicker Letter dated September 10, 2004 www.epa.gov/ttn/naaqs/ozone/ozonetech/stag e2/remote_sensing_air_09-10-04.doc



### B. Stage II Vapor Recovery Systems – Balance vs. Vacuum Assist

As discussed earlier in this paper, the two most common types of Stage II VRS are balance and vacuum assist.

1. Comment Overview

Two stakeholders indicated th at they prefer the balance VRS over the vacuum assist VRS. Other stakeholders indica ted that they have concerns regarding the effectiveness of vacuum assist systems, mainly due to the incomp atibility issues associated with vacuum assist VRS and ORVR, which is discussed further in S ection V.C. One stakeholder commented that they had no choice but to use a vacuum assist VR S due to their operational model design (single direction traffic through the GDF re quires longer hoses to fuel from either side of the vehicle).

The Missouri DNR stated that its Air Polluti on Control Program (APCP) determined that a Stage II vacuum assist VRS does not perform as well as a balance VRS. The APCP was able to make this determination from inspector obs ervations. The APCP specifically observed excess emissions [not related to incompatibility ex cess emissions] from the P/V valves or excess emissions from the nozzle interface for vacuum assist systems. The inspectors also observed problems with vacuum assist VRS vapor pro cessors (i.e., UST vent add-on APCD, or processors) and perpetual maintenance issues. In contrast, the APCP system testing performed on balance VRS indicated that the balance syst em is more reliable and more economical to maintain. Missouri DNR suggested that EPA cl osely consider requir ing the conversion of vacuum assist Stage II VRS to balance Stage II VRS.

A representative from RSA asked the quest ion, “Does it make sense to allow the continued use of Assist VRS with their higher emissions than Balance VRS even without the ORVR incompatibility...” issue? RSA suggested that balance Stage II VRS are less expensive and more efficient than vacuum assist VRS and that Missouri has proven that the conversion of most vacuum assist VRS to balance VRS is easy and relatively inexpensive. RSA also stated that UST vent emptying and breathing emissions are significant for vacuum assist systems and that Missouri DNR and CARB have shown that these emissions are much less significant for balance systems that use the natural pressure ba lance of the system to keep pressures around an average of -0.5 in. w.c. Fugitive emissions ar e also much less significant for a balance VRS because of the system’s relative steady low pressure s. RSA stated that system pressures greater than 2 in.w.c. for any significant amount of time cau ses the release of pressure-related fugitives through nozzle check valves, breakaways, etc.; vacuum assist VRS are more likely to reach these pressures than balance VRS.

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### 28 2. Discussion and Recommendation As mentioned above, there are basically two types of Stage II VRS – balance and vacuum assist. The balance VRS is a relatively benign system that relies on a tight seal between the vehicle being refueled and the faceplate of the no zzle. During refueling, a slight vacuum occurs in the UST that helps pull the vapors into th e UST vapor space. These VRS are relatively inexpensive and easy to maintain. Another feature of the balance Stage II VRS is that the entire system (including the UST) typically does not result in pressurization (and stays at mostly negative pressure), which may prevent fugitiv e leaks. Conversely, vacuum assist VRS dispensing equipment costs up to $40,000 a nd cost approximately $4,100 to maintain. 45 37 

### Vacuum assist Stage II VRS may require an UST pressurization system (i.e., an UST add-on APCD or UST processor) to maintain a negative pressure.

UST pressure data indicates, for the most part, that balance VRS are either not pressurized or less pressurized than the vacuum assist VRS. We believe that low or no pressurization, generally, would result in fewer or no fugitive emissions throughout the system. However, we believe that it would be difficult to defend requiring only balance VRS if: (1) Stage II VRS requirements were retained, or (2) EPA provi ded SIP credits for State or local authorities that choose to retain Stage II VRS. One UST add-on APCD, the ARID Permeator, was tested at a GDF with vacuum assist Stage II VRS to pr ovide information about its efficiency for pressurized systems. This te sting included emissions measurement of the UST emissions and showed greater than 99 percent reduction in UST vent emissions over uncontrolled levels (with a P/V valve and with an add-on APCD). This same add-on APCD is to be tested at a new GDF with no Stage II VRS; this test will provide information about its efficiency for non-pressurized systems (no P/V and with an add-on APCD).

We do not recommend a policy dictating the t ype of Stage II VRS to be used. We do recommend a policy or regulation requiring GDFs to completely dismantle or disable the VRS in a way that will not exacerbate fugitive leaks.

C. On-Board Refueling Vapor Rec overy (ORVR) Control Efficiency

ORVR is a fairly new technology (ORVR installation commenced in model year 1998 vehicles) that collects the gasoline vapor displaced from the vehicle fuel tank during filling; the gasoline vapors are adsorbed in a canister, and so metime afterwards, are re leased to the engine. ORVR controls are expected to achieve from 95 to 98 percent re duction of the vehicle refueling emissions.

45 Letter from P. Searles, API, to L. Rector, NESC AUM. ORVR Widespread Use. March 9, 2005.

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### 29 Table 2. Stage II VRS Comment Summary

Stakeholder Comment Summary Comment Details
Missouri DNR Missour i DNR stated that Stage II vacuum assist VRS are more problematic than balance VRS. Missouri DNR contended that balance systems are more effective and easier to maintain. - Missouri DNR’s APCP has observed from a vacuum assist system excess emissions from P/V valves or excess emissions from the nozzle interface. There are currently no Stage II vacuum assist VRS in Missouri now. - Missouri DNR stated, “It seems surprising that VA systems have been used at all since they are more expensive to purchase, install and maintain than balance systems and have a lower efficiency than balance systems.”
RSA RSA indicated that balance VRS are more effective than vacuum assist VRS. RSA stated that higher UST pressures lead to more emptying and breathing emissions and fugitive emissions. Vacuum assist VRS were more likely to reach higher pressures, which lead to emissions.
Costco Costco stated that they typically do not use balance VRS because their high-volume operational model requires extra-long hoses. Costco stated that Stag e II balance VRS do not work with Costco’s operational model due to the need for extra-long hoses. CARB has only approved a short (9 foot) balance hose.



### 1. Comment Overview Concerns were expressed regarding the cont rol efficiency of ORVR canisters and the long-term control efficiency thes e canisters will continue to achie ve. Eight stakeholders and one equipment vendor expressed concern regarding the effectiveness of ORVR canisters over the life of the vehicle. Another stakeholder suggested th at there was sufficient data to support the longterm use of ORVR.

NESCAUM and the Connecticut DEP stated that before de termining when widespread use occurs, EPA should determine the effectiven ess of ORVR canisters over the life of the vehicle. NESCAUM is concerned about the e ffectiveness of the OBD systems that indicate ORVR malfunctions; these systems should be tested and veri fied by EPA before any decisions are made about widespread use. The Wiscons in DNR, Missouri DNR, and CARB indicated that they are concerned that ORVR control efficien cy will degrade over time. Both NESCAUM and Healy stated that EPA should test high mil eage ORVR-equipped vehicles to determine the ORVR efficiency over time. TCEQ has requested that EPA provide to States technical documentation demonstrating the ORVR actual in-u se efficiency of 98 percent, as well as information detailing how EPA plans to ensure continued compliance of the ORVR control efficiency.

The Wisconsin DNR asked if ORVR compatib le Stage II VRS could be viewed as a backup for those ORVR systems th at fail to operate correctly. The Ohio EPA stated that the effectiveness of ORVR with a nd without vehicle inspection and maintenance programs should be addressed.

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### 30 API suggested that solid testing methodol ogies are used to demonstrate ORVR effectiveness. NACS and SIGMA stated that th ey believe sufficient data already exists to support the long-term use of ORVR.

2. Discussion and Recommendation We believe that ORVR control efficiency can achieve from 95 to 98 percent reduction of the vehicle refueling emissions based on ORVR can ister design. There are currently no data confirming the long-term control efficiency, per se, of ORVR canisters, however, EPA does have data that indicate that ORVR canisters are meet ing their emissions limit of 0.2 grams per gallon (g/gal). These data show some difference in performance for high and lo w mileage vehicles but additional testing is planned. EPA has also been actively testing th e performance of OBD systems, the OBD evaporative emissions monito r, and the ORVR system integrity checks. Vehicles are equipped with an on -board diagnostics (OBD) system that, in addition to a number of other functions, checks the in tegrity of the vehicle’s evapor ative system, stores diagnostic trouble codes (DTC), and alerts the operator/driver with a malf unction indicator light (MIL) on the dashboard of the vehicle th at a repair may be needed. The OBD is designed to identify malfunctioning emissions control components on th e vehicle before emissions standards are exceeded. Studies have shown that OBD systems identify deteriorated or broken components or systems that lead to higher emissions.

One of the OBD functions is to monitor th e ORVR system integrity by periodically checking the evaporative system pressure as well as the ORVR canister purge function. If the OBD detects a problem with the ORVR system, a warning light (a MIL) indicating an engineproblem comes on so that the vehicle operator know s to seek service and repair. ORVR system failures detected by the OBD fall into two categorie s: (1) failure of the purge function, and (2) loss of system integrity. The purge diagnostic ch ecks to see that a controlled volume of air is drawn through the canister. The air desorbs hydrocarbons from the canister carbon and then carries them to the engine to be burned. If th e air purge is not functi oning, the carbon in the ORVR canister becomes saturate d and cannot hold any additional refueling vapors. The OBD also checks to identify any leaks occurring in th e hoses and connections that route the gas vapors to the canister and to the engine, as well as th e mechanical integrity of the tank and fill-neck. The hoses and connections of the ORVR system must be leak proof for the ORVR control system to work. 46 38



### From April 1999 to May 2000, EPA conducted a 30-vehicle study to evaluate the effectiveness of OBD evaporative emissions monito rs in identifying in-use vehicles (model years 1996 through 2000) with excess evap orative emissions. In this study, 22 of 25 OBD evaporative emissions monitors registered DTCs when failu re conditions were induc ed, suggesting that OBD evaporative emissions monitors work satisfactorily. Five vehicles were tested with small leaks; 3 of the 5 vehicles were calibrated to meet the 0.040 in. OBD leak st andard but were tested with a

46 The Long-Term Durability of Onboard Vehicle Vapor Rec overy (ORVR) Control System s, Draft. Prepared for API by Harold Haskew & Asso ciates, Inc. February 2005.

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### 31 smaller 0.020 in leak and illuminated DTCs. This suggests that some OBD systems are quite robust and have leak detection capability well below the minimum federal requirement. 47 39



### Two other major programs concerning OBD performance have been or are being conducted: (1) EPA has conducted a high-m ileage OBD study on model year 1996 through 1999 vehicles with greater than 100,000 miles, a nd (2) EPA has begun to receive data from automobile manufacturers on OBD performan ce in calendar year 2005 on model year 2001 highmileage (50,000+) vehicles and model year 2004 lo w-mileage (10,000+) vehicles as part of the In-Use Verification Program (IUVP). 48

40 

### This program includes approximately 2000 FTP emissions data tests per year and OBD informa tion (MIL illumination and DTC). In conjunction with the manufacturer testing, EPA will also co nduct confirmatory tests on approximately 150 vehicles per year to verify the re sults of the manufactur er in-use testing. Th e data from these two programs should provide sufficient information to evaluate and confirm that OBD systems are working effectively and increase confidence in their use.

Some preliminary data from EPA’s IUVP pr ogram are provided in section VI.B. These data indicate that the majority of OBD system s perform well and that the majority of ORVR canisters are performing at or above the required emissions sta ndard. Of 151 tests on the ORVR canisters, 91 percent reduced refueling emissi ons to 0.2 g/gal or less. There were some differences in low mileage vehicl es versus high mileage vehicles (with a larger percent of the low mileage vehicles passing the emissions limit).

Based on evaporative system testing, of whic h ORVR is one part, the system does appear to remain intact and operate properly, with a low failure rate. The OBD evaporative emissions check has been found to be a suitable replacement for functional evaporative emission I/M tests. Based on testing of ORVR canisters that are in -use on vehicles, these canisters appear to continue controlling refueling em issions after several years of operation. See Section VI.B for additional data. Given the preliminary results fr om these studies, we are comfortable with the long-term functionality of the vehicle evaporativ e system and the ORVR canister controls. EPA is continuing to evaluate these systems and collect the testing data from automobile manufacturers and condu ct testing itself.

An idea was suggested that with retention of Stage II VRS on GDF, even retention of ORVR-compatible VRS, that the Stage II VRS could possibly be viewed as a backup for those ORVR systems that fail. API submitted a paper that indicated that the design of the fillpipe on an ORVR-equipped vehicle has a seal (either liquid or mechanical) that prevents vapors from exiting to the atmosphere. 49

41 

### The seal is designed to ensure th at vapors from the vehicle gasoline tank are routed to the ORVR canister and do not es cape through the fillpipe. With such a design, a Stage II VRS is not likely to control refuel ing emissions from failing ORVR vehicles, even with an “ORVR-compatible” system at the GDF.

47 Effectivness of OBD II Evaporative Emissions Monitors – 30 Vehicle Study. U.S. Environmental Protection Agency. EPA Publication No. EPA420-R-00-018. October 2000.

48 On-Board Diagnostics (OBD) Policy Workgroup: Findings and Recommendations, by the Mobile Source Technical Review Subcommittee, Cl ean Air Act Advisory Committee. November 2002. p. 11 and 16.

49 The Long-Term Durability of Onboar d Vehicle Vapor Recovery (ORVR) Control Systems. Prepared for American Petroleum Institute (API) by H. Haskew , Harold Haskew and Associates. May 27, 2005.

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### 32 Table 3. On-board Refueling Vapor Recovery (ORVR) Comment Summary

Stakeholder Comment Summary Comment Details NESCAUM NESCAUM indicated that they are concerned about the effectiveness of ORVR canisters. NESCAUM suggested that EPA review relevant test data to ensure that a reasonable efficiency factor is attributed to ORVR. NESCAUM suggested the following: 1. A need to provide support and oversight of the

automotive industry so as to ensure failing ORVR systems are pr operly maintained. 2. A need to understand the types of malfunctions

that a vehicle’s OBD can detect. 3. EPA should test high mileage vehicles and those

vehicles that have been in service for a number of years to determine the efficiency of the ORVR system over time. 4. Develop a system to track ORVR system

problems. The system should resemble the procedures used to verify proper operation of Stage II VRS.
Connecticut DEP The Connecticut DEP stated that the phase out of Stage II should not occur until ORVR effectiveness has been determined over the lifespan of the ORVR canister. Connecticut DEP believes the possibility of ORVR system failures exist and if such failures were to occur after Stage II VRS removal, refueling vapor emissions would be too serious of an occurrence to risk. Wisconsin DNR Wisconsin DNR asked, ‘Could ORVR-compatible Stage II systems be viewed as “insurance” or back-up for those ORVR systems that fail to operate correctly or efficiently?’ Wisconsin DNR also stated their need to know what EPA’s expectations are in terms of in-use efficiency of ORVR, aske d whether there will be an ORVR degradation factor, and what is the technical basis for these expectations.

Ohio EPA The Ohio EPA indicated that I/M issues related to ORVR should be addressed. “The effectiveness of ORVR with and without a motor vehicle inspection and maintenance program.”
Missouri DNR Missouri DNR indicated that ORVR carbon canisters eventually break down. Missouri DNR stated that there is not sufficient data to know with any level of confidence that ORVR vehicles will maintain their initial efficiency; older vehicles will eventually most likely need Stage II VRS to control refueling emissions. TCEQ TCEQ stated that the Issues paper did not cite any studies that determines the actual in-use control efficiency of ORVR systems. TCEQ suggested that EP A “...provide the states with technical documentation demonstrating the stated ORVR IUE of 98 percent as well as information detailing how EPA plans to ensure that automobiles continue to comply with this standard. Texas believes that EPA should analyze IUE and provide results of their analysis to the states.” CARB CARB stated that API’s study and the Issues Paper did not consider the possible degradation of the ORVR efficiency of 98 percent. Healy Healy commente d that the in-use control efficiency of ORVR was not addressed in the Issues Paper. Healy recommended that EP A evaluate a selection of 1998 ORVR-equipped vehicles with high mileage using SHED test methods or equivalent test methods to determine in-use control efficiency.

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### 33 Stakeholder Comment Summary Comment Details
API API stated that the effectiveness of ORVR has been demonstrated using solid testing methodologies. API stated, “The effectiveness of ORVR is required to be demonstrated using solid testing methodologies (Sealed Housing for Evaporative Determinations) in new vehicles and has also been confirmed in tests conducted using California testing methodologies on in-use vehicles at actual gasoline dispensing facilities (GDFs), without any need for regulatory agencies to have to hire personnel to inspect the systems on a regular basis.”
NACS and SIGMA NACS and SIGMA referenced inuse evaporative system testing data for ORVR-equipped vehicles submitted by the North Carolina Petroleum Marketers Association to EPA. NACS and SIGMA stated that the evaporative test data confirmed the perfor mance of ORVR as an effective control technology for refueling emissions; these data supported the assumptions that underpin the policy choice by Congress to utilize ORVR for the long-term.



### D. ORVR and Stage II VRS Compatibility Issues

When an ORVR-equipped vehicle refuels at GDF with Stage II VRS, the amount and composition of the vapor returned to the UST by the Stage II VRS controls can be adversely impacted. An increase in the amount of air (in lieu of gasoline vapor) returned to the vapor space of the UST will lead to gasoline evaporatio n, or vapor growth, in the UST and lead to excess emissions from the UST in the form of fug itives and vent emissions. A larger amount of air is returned to the UST vapor space for so me vacuum assist Stage II VRS when refueling vehicles with ORVR controls, and therefore, th e excess emissions are greater for some vacuum assist systems.

1. Comment Overview Eight stakeholders and two equipment vendor s believe that there are incompatibility issues associated with vacuum assist Stage II and ORVR. Two stakehol ders believe there are incompatibility issues bu t these issues become negligible when taking into account that ORVR reduces vehicle fillpipe/nozzle emissions and mi nimizes puff emissions from the removal of a vehicle’s gas cap. Two stakeholders and tw o equipment vendors support the use of balance Stage II VRS because these systems are proven to be compatible with ORVR. One equipment vendor said that they have data that demonstr ates an increase in fugitive emissions as ORVR vehicle fleet penetration increase s due to the incompatibility of vacuum assist Stage II VRS and ORVR.

The Connecticut DEP and NESCAUM requested that EPA completely evaluate and quantify the incompatibility issues associated wi th Stage II VRS and ORVR so that States can make better informed decisions. Connecticut DEP also stated that EPA should consider implementing technology to reduce or eliminate excess emissions from incompatibility as the widespread use date approaches (i.e., UST add-on APCD, CARB’s EVR program, and P/V valves). ARID also requested that EPA conduct testing to accurately quantify IEE.

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### 34 API and STI stated that the incompatibility i ssues associated with vacuum assist Stage II VRS and ORVR are not significant when taking into account that ORVR reduces vehicle fillpipe/nozzle emissions and minimizes puff emissions. STI noted that the magnitude of emissions decrease at the fillpipe (due to ORVR) is greater than the magnitude of the emissions increase due to pressurization of the UST (due to the incompatibility of vacuum assist Stage II VRS and ORVR).

The Missouri DNR, RSA, Husky, and EMCO st ated their support for balance Stage II VRS because these systems are proven to be compatible with ORVR. The Missouri DNR and Husky stated that the combination of balan ce Stage II VRS and ORVR enhances the overall control efficiency of the Stage II VRS.

2. Discussion and Recommendation The incompatibility between the ORVR tec hnology and the Stage II VRS (vacuum assist technology only) is a key issue for the Stage II VRS program. However, some of the stakeholders consider this issue moot because they believe Stage II VRS should be completely removed as it is a redundant control technology. These “red undant” VOC control devices (ORVR and some vacuum assist VRS) cause excess emissions when both are employed. However, when both balance VRS and ORVR are employed, the VOC emissions reductions approach 99 percent according to research by Missouri DNR; t hus Missouri DNR plans to continue requiring balance Stag e II VRS after any widespread us e determination. In addition, CARB will probably be requiring Stage II VRS (both balance and vacuum assist) despite widespread deployment of ORVR and will require gasoline dispensing equipment to be certified through their testing program to ensure th at excess emissions are not caused by the incompatibility of the ORVR and VRS technologie s. Some emissions testing conducted by API indicates that the excess emissions from the in compatibility of ORVR and vacuum assist VRS are not significant, are dependent on which type of vacuum assist VRS is used (i.e., the V/L ratio is an important factor), and that the costs for implementing compatible ORVR and vacuum assist VRS are very expensive.

Despite what some stakeholders believe about the need to eliminate Stage II VRS, we believe that there is merit to the idea to provi de SIP credits for State and Local air pollution control agencies (APCA) that choose to retain Stage II VRS after the widespread use date; many APCAs were in favor of this idea. If so, then it would be desirable for EPA to collect additional data to further characterize the excess emissions from ORVR-Stage II vacuum assist incompatibility.

There are some data from emissions test ing by CARB and API showing there are excess emissions caused by the incompatibility of th e vacuum assist VRS and ORVR (see section VI.A). However, their emissions testing results do not agree and, as a result, we believe it would be desirable to obtain additional emissions monito ring data to better understand this relationship. CARB and the Western States Petroleum Association (WSPA) pl an to conduct some emissions testing to better define these emi ssions, however, when their testi ng will occur is unclear. Hertz is planning to conduct some emissions testing that will include vehicle refueling fillpipe interface and UST vent testing and tank pressure tracking. In addition, Hertz will be conducting testing to demonstrate that withdrawing vacuum assist Stage II VRS will not adversely impact VOC emissions from their GDFs. As part of this te sting, they will be monitoring fillpipe emissions.

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### 35 Because most of their vehicles are ORVR-equipped and the Stage II VRS are vacuum assist, there will likely be excess emissions data from incompatibility. NH DES, University of New Hampshire (UNH), Gilbarco/Veeder Root (GVR ), and EFPAG are planning an emissions monitoring project that will provide more data on the excess emissions from incompatibility. We believe all of the aforementioned testing wi ll enable EPA to better quantify the excess emissions from incompatibility and develop polic y based on the “better” data. These tests are scheduled to be conducted in 2006. See section VI.D for more information.

We recommend that the AQSSD’s Ozone Po licy and Strategies Group (OPSG) wait until the results of these studies ar e finalized before coming to a ny conclusions about the excess emissions from the incompatibility of Stage II VRS (some vacuum assist) and ORVR. We are working closely with the participants in these stud ies to set up monitoring protocols that provide quality data. We have and will observe the testi ng to ensure that the data collected are quality data.

Table 4. ORVR and Stage II VRS Compatibility Comment Summary

Stakeholder Comment Summary Comment Details
Connecticut DEP Connecticut DEP asked EPA to evaluate and quantify the incompatibility issues related to Stage II VRS and ORVR. The Connecticut DEP stated that EPA should consider implementing technology to reduce or eliminate excess emissions from incompatibility as the widespread use date approaches. Costco Costco commented that prior to the installation of a membrane processor, vent episodes were measured, and these measurements showed that the UST vent was venting almost all day long due to the incompatibility of their vacuum assist VRS and ORVR. Costco commented that their policy was to install vacuum assist Stage II VRS at all their GDF, even in areas where it was not required. Their policy has changed due to the incompatibility of vacuum assist VRS and ORVR. Costco also stated, “Perversely and ironically, Stage II VRS increase emissions when used to fuel ORVR vehicles.”

Ohio EPA Ohio EPA stated concern regarding the need for area-specific Stage II VRS data (i.e., whether vacuum assist or balance, and if vacuum assist, what brand or type of system) when addressing incompatibility. The Ohio EPA stated, “If a state chooses to address incompatibility in its SIP, or if USEPA requires SIPs to address incompatibility, shouldn’t there be data on the types and relative numbers of Stage II VRS control systems regarding incompatibility?”Ohio EPA suggested that the data could be areaspecific or use EPA default values. TCEQ The TCEQ stated that their Stage II VRS program is affected by the high percentage of vacuum assist VRS present in Texas. TCEQ commented that the Houston-Galveston nonattainment area has approximately 92 percent vacuum assist VRS compared to a national average of 47 percent. TCEQ also stated that, most current vacuum assist systems ha ve varying degrees of incompatibility with ORVR systems, some of which result in excessive fugitive and vent emissions from GDFs.

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### 36 Stakeholder Comment Summary Comment Details NESCAUM NESCAUM indicated that they are concerned about the number of vacuum assist VRS that are located in their member states; the potential excess emissions that result from ORVR-equipped vehicles refueling at these stations may result in a significant source of new emissions. NESCAUM further stated, “Given the nonattainment status of some of these areas, allowing these emissions to remain unchecked could have significant air quality and public health ramifications.” NESCAUM stated “[s]tates are concerned with the potential public health threat that might result as aconsequence of ORVR incompatibility with vacassist Stage II systems. States urge EPA to immediately undertake a detailed study to quantify and document the potential emissions attributable to ORVR incompatibility. If ORVR incompatibility is determined to be a signif icant source of emissions, NESCAUM recommends that the EPA develop strategies that will not result in a detriment to public health. Such a finding must also not result in any penalty to the program effectiveness of Stage II currently claimed in state ozone SIPs.”

Missouri DNR Misso uri DNR stated that they do not believe that there is a compatibility issue with the Stage II vapor recovery program for balance systems. Missouri DNR indicated those Stage II vacuum assist VRS in their present form are incompatible with ORVR. - Missouri DNR said that the balance system only enhances ORVR and that the two technologies together are capable of ac hieving over 98 percent efficiency. - Missouri DNR maintained that by eliminating vacuum assist VRS, incompatibility excess emissions are also eliminated.

RSA RSA suggested that Stage II VRS requirements should be maintained and only the use of balance VRS should be allowed. RSA asked the question, “Does it make sense to allow the continued use of Assist VRS with their higher emissions than Balance VRS even without the ORVR incompatibility and increasingly higher emissions with the ORVR incompatibility?” CARB CARB stated that they disagree with the Stage II Issues Paper statement that “API data show the miniboot reduces excess emissions” because “CARB tests define excess emissions due to ORVR incompatibility as additional fugitive and vent emissions during fueling of ORVR vehicles.”
API API stated that there are incompatibility issues with vacuum assist Stage II and ORVR.

API further stated that these incompatibility issues become negligible when taking into account that ORVR reduces fill pipe emissions and minimizes puff emissions from the removal of a gas
cap. API commented, “As described in the API ORVR compatibility study and the attached STI technical comments, some vacuum assist systems are less compatible with ORVR than others. Accounting forthese different systems and their relative vaporemission control capabilities would be difficult at best.”

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### 37 Stakeholder Comment Summary Comment Details STI STI indicated concern with respect to issues of clearly defining the terms “ORVR compatibility” and “excess emissions,” and the quantification of emissions. STI suggested that the terms “excess emissions” and “incompatibility emissions” be defined so that the definitions incorporate the total emissions due to refueling. STI discussed testing conducted by CARB and API, specifically that CARB testing did not take into account the reduc tion of fillpipe emissions from ORVR, which was quantified in the API testing. STI also suggested that ORVR may reduce emissions from the initial puff that is emitted from the removal of a vehicle’s gas cap. STI stated, “If the magnitude of the emissions decrease at the fillpipe is greater than the magnitude of the increase in emissions due to pressurization, the net effect of ORVR sy stems is beneficial, i.e., they are reducing total refueling emissions. However, it appears that EPA’s issue paper (p. 10) defines the terms “excess emissions” and “incompatibility excess emissions” based solely on the change in pressurization-related emissions. This definition can easily be misconstrued, since the terms “excess emissions” and “incompatibility” often result in a perception that emissions from a VRS are increased by ORVR.” - STI commented that an API-sponsored study found that in seven out of eight tests, puff emissions were lower for ORVR-equipped vehicles than those from non-ORVR vehicles by 3-5 grams per refueling event.

Hertz Hertz stated that there are incompatibility issues with current Stage II systems and ORVR, which results in IEE. Husky Husky stated that the Issues Paper does not take into account that required ORVR compatible Stage II systems are more efficient. Husky indicated that an ORVR-compatible Stage II VRS is at least 95 percent efficient verses 85 percent efficiency before ORVR. Husky further commented that ORVR compatible balance Stage II VRS achieves an efficiency of almost 99 percent because ORVR-equipped vehicles cause the VRS to operate at a negative pressure. Husky also stated that ORVR compatible vacuum assist Stage II VRS are also more efficient because the systems maintain a negative pressure. EMCO EMCO noted that balance systems have been proven to be compatible with ORVR by CARB and that converting a VRS to a balance is not expensive. VST VST stated that they have data that indicate that the increase of ORVR vehicle penetration is increasing fugitive emissions when used in conjunction with vacuum assist Stage II VRS. VST indicated that a growing trend of ORVRequipped vehicles in California is contributing to an increase in fugitive emissions. VST test data indicated the following increase in ORVR fleet penetration:

Test Date 8/02 2/04 7/04 ORVR Penetration 26% 38% 44%

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### 38 Stakeholder Comment Summary Comment Details ARID ARID suggested that EPA conduct testing to accurately quantify the incompatibility excess emissions (IEE). ARID stated that their m easured and modeled data show a remarkable increase in the incompatibility excess emissions generated in the UST as a result of the fundamental incompatibility of Stage II vacuum assist and ORVR technologies. ARID provided IEE data from two test sites.



### E. Widespread Use Calculation and Date

As discussed earlier in this paper, EPA ha s defined four possible ways to interpret widespread use.

1. Comment Overview Five stakeholders commented that they suppor t definition (c), or a similar definition, for widespread use (VOC emissions from ORVR controls equal VOC emissions from Stage II VRS only). Five stakeholders commented that they support definitions (a), (b), or (d) primarily due to the simplistic nature of these definitions. A coupl e of stakeholders stated that definition (c) is much too complex and not consistent with what Congress intended. One stakeholder indicated that the widespread use date may not affect them because they expect to maintain Stage II VRS after the widespread use date. A couple of st akeholders suggested alte rnative definitions for defining widespread use. One equipment vendor stated that they do not support the idea that Stage II VRS will become a redundant technology wh en ORVR becomes prevalent in the vehicle fleet, given that 20 percent of gasoline dispensed cu rrently and in the foreseeable future will be to non-ORVR vehicles.

NESCAUM urged EPA to adopt a policy th at defines widespread use based on demonstrating that ORVR achieves emissions re ductions equal to thos e reductions claimed by States in their SIPS; the widespr ead use definition should factor in the effect of vehicles in the fleet that will never have ORVR. The Conn ecticut DEP stated that they agree with NESCAUM’s suggestions for determining widespread use.

Virginia stated that they pr efer definition (c) because it is the most appropriate way to determine widespread use. Vi rginia suggested that EPA use locality-specific inputs in their algorithms to compute IEE and emptying and br eathing losses of UST. NJDEP noted their preference for definition (c), but pointed out two concerns that th ey have with this definition. NJDEP stated that they do not believe that 100 percent rule effectiv eness for ORVR is an accurate assumption and that the MOBILE6 model can not run all of the scenarios presented in the Issues paper.

From a modeling standpoint, TCEQ preferred definition (b). Wisconsin DNR suggested using either definition (a) or (b ), which are simple approaches. If definition (c) is chosen by EPA, both TCEQ and Wisconsin DNR requested th at EPA provide guideli nes on how States can use readily available data to determine in -use efficiency of their Stage II VRS.

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### 39 CARB commented that widespread use may not apply to California because they expect to show an emissions benefit by continuing the use of Stage II VRS even after ORVR-equipped vehicles are in widespread use.

The Ohio EPA suggested that EPA consid er a simple and direct comparison for determining widespread use; the simplest co mparison is determining when the amount of gasoline dispensed to ORVR-equipped vehicles is equal to the amount of gasoline dispensed by means of Stage II VRS. Missouri DNR stated that removing Stage II VRS would be premature because there will always be a si gnificant number of vehicles in the fleet that will not be equipped with ORVR. Missouri DNR recommended th at widespread use be defined at the point where emissions from ORVR crosses the emissions from balance Stage II VRS, which yields a widespread use date near 2030.

API encouraged EPA to determine a wide spread use definition that follows Congressional intent; API supported definitions (b ) or (d) because these definitions reflect a common sense interpretation of the term widesp read use. API suggested that under these definitions, EPA examine when the percentage of ORVR systems installed is equivalent to the Stage II VRS in-use efficiency that is in a gi ven SIP. NACS and SIGMA also recommended that EPA use a common sense approach in determining wi despread use; they st ated that definitions (a), (b), or (d) reflect a reasonable interpre tation and follow a common sense approach. NACS and SIGMA suggested that EPA cons ider using the median Stage II VRS in-use efficiency value from State SIPs.

Hertz stated that the most c onservative definition of widespread use should be when the vehicle fleet is comprised of 95 percent ORVR-equipped vehicles.

2. Discussion and Recommendation As noted from the comments above, the stakeholders are very concerned about determining a widespread use date and the method used to determine the widespread use. The Clean Air Act Amendments of 1990 give little background to the intent of Congress for widespread use and the language in the Act give little guidance on how to determine widespread use. Mike Thrift of EPA’s Office of General Counsel, opined, “...statutory language gives us substantial discretion to define “widespread” and “thr oughout,” and even “the” with respect to “m.v. fleet.” Of course, the le gislative history may shed some light on how Congress thought we ought to interpret the lan guage, but under the Chevron doctrine, courts have not generally ruled that contrary legislative hist ory, on its own, removes an agency ’s discretion to interpret ambiguous statutory language. As long as we define these words and phrases reasonably through a notice and comment process (e.g., a ru lemaking to waive Stage II VRS in serious, severe, and extreme areas), the courts will give us deference in interpreting the Act, even if they think that a different interpretati on is better. Under Chevron, we only have to be reasonable, not “best” in the court’s view, unle ss the court rules that the langua ge leaves us no discretion and that our interpretation is plainly contrary to its one clear meaning.” 50

42 

### We interpret his statement to mean that we can choose an approach (inter pretation) for widespread use as long as we can defend it.

50 Personal communication (email) from Mike Thrift to Tom Driscoll, February 22, 2005.

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### 40 Generally, the comments are divided between those, industry and some states, wanting a simple and direct determination of widespread use [supported definitions (a), (b), or (d)] and those, most of the states, wanting the more comp licated approach to determining widespread use [supported definition (c)]. Industry believes wide spread use should be based on when most of the cars have ORVR canisters installed, when most of the gasoline pumped into ORVR-equipped vehicles, or when most of the VMT are miles traveled by ORVR-equipped vehicles. For a more thorough discussion of the definitions, see the St age II VRS Issues Paper, pages 18-20. There are a couple of other issues associated with the wi despread use date including: (1) if definitions (a), (b), or (d) are chosen, then what percentage of the vehicles , gas pumped, etc. makes sense to use as achieving widespread use; i.e., 85, 90, or 95 percent? and, (2) can the Ozone Transport Region (OTR) States determine a regional widespread use date?

API stated in their comments that defin itions (b) and (d) represent a common sense approach and the data to make th e decision are easy to obtain. So me States noted that some of the data required for definition (c) may be difficult to obtain. Easy to obt ain data is one of the primary benefits to choosing defi nitions (a), (b), or (d). Ho wever, determining a percentage, which is needed for definitions (a), (b), and (d), as having achieved widespread use would be somewhat arbitrary and difficult to defend. For example, is 50 percent ORVR-equipped vehicles considered widespread use, or is 95 per cent gasoline pumped to ORVR-equipped vehicles considered widespread use? In their commen ts, API discussed the merits for using some percentages as opposed to others.

In a follow-up letter from API, they suggested a new definition (c2) that is based on the date when emissions with ORVR-only controls ar e less than the emissions with combined Stage II VRS and ORVR controls, including incompatibility emissions. 51

43 

### This definition would clearly identify the date at wh ich there would be no emissions in crease as a result of removing Stage II VRS. We subsequently adde d a new definition (c2) to our list:

Definition (c2) (VOC emissions with ORVR contro ls equal the VOC emissions with combined Stage II VRS and ORVR controls, with incompatibility excess emissions). Definition (c2) is similar in complexity to definition (c). One advantage with this approach is that there would be no possible increase in emissions from the decommissioning of Stage II VRS controls, as there might be with definition (c). One disadv antage with this approach, in addition to the inuse control efficiency for Stage II VRS mentioned for definition (c), is that the incompatibility excess emissions (IEE) factor must also be corr ectly determined. There is some disagreement over the quantity of these emissions.

In comparison to definitions (a), (b), and (d ), definitions (c) and (c2) are more tied to actual air quality impacts. These approaches make sense for what EPA is trying to achieve. In other words, we don’t want to remove Stage II VRS until we are sure that ORVR will achieve and continue to achieve the equivalent VOC em issions reductions. Using definition (c) makes more sense if EPA provides SIP credits. The negativ e side to selecting defi nitions (c) or (c2) is that it requires knowing the control efficiency for Stage II VRS programs in each State, the

51 Memorandum from T. Tamura, STI, to P. Searles, API. Onboard Refueling Vapor Recovery (ORVR) Systems – Proposed Definitions of Widespread Use. March 3, 2005.

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### 41 control efficiency for ORVR, and the quantity of I EE. States will be looking to EPA to answer these issues.

There are some other elements that need to be factored into this discussion. Some vehicles (such as motorcycles, lawn mowers, and some large vehicles) will never have ORVR. It will be difficult to quantify the VOC emissions from refueling these types of vehicles. Missouri DNR suggested that up to 20 percent of vehicles will never have ORVR. We are not sure that 20 percent is correct, but we know only definitions (c) and (c2) account for this factor. In a streamlined estimate of the percentage of gasolin e vehicles never to have ORVR (based on all gasoline vehicles), based on 1996 nati onal fleet data, 94 percent of all gasoline vehicles will eventually have ORVR controls. 52

44 

### The 1996 national fleet data were used as the basis to develop the MOBILE6 defaults. This analysis used conservative assumptions, namely an assumption that no HDGV class 2B vehicles will ever be ORVR, even though some vehicles in this class will be covered (complete vehicles).

An analysis of the gasoline dispensed to ORVR-equipped vehicles has not been conducted. It is true that larg er, never-to-be-covered non-ORVR ve hicles would likely fuel large amounts of gasoline per vehicle, but they represent a small porti on of the fleet (approximately 3.6 percent of the gasoline fleet). While fueling of motorcycle s (approximately 2.3 percent of the gasoline fleet) and other motor-driven equipmen t may represent a large number of fuelings, the individual gasoline volume dispensed for eac h event is small and may not represent a large portion, either. Vacuum assist Stage II VRS do r ecover the refueling emissions from motorcycle refueling and filling of other motor-driven equipment, however, balance VRS do not control these refueling emissions. Some states (Calif ornia and Missouri, for example) may choose to continue Stage II VRS, despite any widespread us e determination. We need to ensure any policy or regulation we develop will not undermine their decisions/efforts.

The algorithm needed to determine widespread use depends on the de finition chosen. For definitions (a), (b), and (d), relatively strai ghtforward calculations requiring specific information such as the gallons of gasoline pumped and the vehicle registration and age distribution will be needed. We have thought in the past that the mo re simple definitions, for example definition (a), may be easier for States to use, however, some States have had difficulties in assembling vehicle registration data. The definitions we have termed as “easier-to-use” or “State-friendly” may be just as problematic for some States as the more complicated definitions are for other States. Definitions (c) and (c2) require more inform ation and many specific pieces of information. Algorithms from the MOBILE6 model (with some minor modifications), which most every State uses, can be used to compute widespread use for definitions (c) and (c2). With definition (c2), it will be desirable for EPA to better characterize th e IEE. EPA likely will have to determine the IEE for multiple types of vacuum assist system s (GVR, WayneVac, etc.) as the IEE depends on the V/L ratio. In addition, States, if they have not already done so, will have to determine what the Stage II VRS in-use control efficiency is in their State based on I/M programs conducted and any throughput cutoffs for applicability, and EPA will need to make a determination on the longterm in-use control efficiency for ORVR controls . As mentioned previously, the initial data on

52 Memorandum from K. Schaffner, RTI, to T. Drisco ll, EPA/OAQPS/EMAD. Streamlined Estimate of Gasoline Vehicles Never to Have ORVR. September 30, 2005.

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### 42 ORVR seems to confirm that ORVR continues to work long-term, and EPA is tracking this issue with continued testing programs.

Because the OTR States have separate requi rements for ozone than other States, they have asked for the ability to ma ke a widespread use determinati on for the entire region. Section 184(b)(2) requires: (1) EPA to conduct a study to identify emissions reductions control measures comparable to Stage II controls (called comparable measures), and (2) OTR States to revise their SIPs to require Stage II or comparable measur es. For more specific information regarding OTR requirements, see the EPA Stage II Issues Paper on pages 3 and 4. There were no stakeholders that opposed the proposal to allow separate considerations for the OTR States, and we recommend that the OTR be allowed to proceed in their determination on a re gional basis, if that is their preference.

Again, we believe that the planned emissions monitoring described in section VI.D will give us more qualitative information on the IEE to make a better decisi on regarding widespread use. Nevertheless, based on the information and comment responses we have, we believe definitions (c) and (c2) as the best option for determining widespread use. We believe either of these definitions is defendable. Definition (c 2) would not allow increases in VOC emissions when transitioning from the combined ORVR/Sta ge II VRS to ORVR systems only. Definition (c) would also allow the widespread use date to be determined based on emissions, and SIP credits could be offered for those States w ho continue requiring Stage II VRS beyond the widespread use date.

As mentioned previously in the Issues Paper, the definitions may be inter-related and may provide similar results, so we have conducted an an alysis of the definitions for 3 States to test this hypothesis. We collected data from 3 States and estimated the widespread use date for all five definitions for each State. A preliminary summa ry is provided in section VII. This analysis allowed us to see the range of values and determin e if the definitions are the same or if one is truly different. The results for these States show that definitions (b), (c2), and (d) are fairly similar. For these States, definition (c) would result in the earliest widespread use date; both definitions (c) and (c2) are affected by the in-use control efficiency for Stage II VRS and definition (c2) is affected by the magnitude of th e IEE. Initial data from Vermont indicate that definition (a) would provide the la test widespread use date. For these States, a percentage of approximately 85 percent for VMT for ORVR vehicles (b) and for gasoline throughput for ORVR vehicles (d) falls somewhere betw een the (c) and (c2) definitions.

In conjunction with recommending definitions (c) or (c2), we also recommend that algorithms to determine widespread use be ba sed on the MOBILE6 model. EPA is addressing the issues with respect to these definition choices , namely we have emissions testing planned to quantify the IEE and the EPA Office of Mobile Sources (OMS) is investigating control efficiency for ORVR. Some additional work may have to be done to help States with in-use control efficiencies for Stage II VRS. Finally, we recommend that the OTR States be allowed to have a region-wide determination and we s hould start the process to allow region-wide determination (by amending the comparab ility study or other acceptable method).

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### 43 Table 5. Widespread Use Calculat ion and Date Comment Summary

Stakeholder Comment Summary Comment Details NESCAUM NESCAUM preferred a widespread use definition similar to definition (c). NESCAUM urged EPA to adopt a policy that defines widespread use based on demonstrating that ORVR systems achieve VOC emissions reductions equal to those reductions claimed by States in their SIPs. - NESCAUM asked EPA to issue guidance for States to make a determination. NESCAUM stated, “[i]f EPA decides to use to choose an alternative method (e.g., defining widespread use to the percentage of ORVR vehicles in the fleet or gasoline dispensed to ORVR vehicles) the Agency should still tie these numbers to a technical basis, including air quality modeling, in order to assure that removal of the Stage II program does not degrade air quality.” - NESCUAM further suggested that EPA perform a modeling exercise on several “pilot” states to determine if a correlation exists between the one-for-one equivalency and percent of ORVR vehicles in the fleet; if the exercise indicated a statistically significant correlation, NESCAUM would then support that method for determining widespread use. - NESCAUM suggested that EPA factor in the effect of vehicles in the fleet that will never have ORVR when determining widespread use. - NESCAUM also made suggestio ns for those areas where the Stage II program is not implem ented statewide; EPA should calculate emissions in these areas based on gasoline dispensed to ORVR vehicles in those counties where Stage II controls exist.
Connecticut DEP Connecticut DEP suggested that EPA adopt a definition that preserves the effectiveness of existing Stage II programs. Connecticut DEP stated that they agree with NESCAUM’s procedure for determining the definition of widespread use. Connecticut DEP stated that: (1) Before States are allowed to drop Stage II VRS programs after the applicable widespread use date occurs, EPA needs to complete a study to confirm that ORVR systems will properly operate over the useful life of a vehicle; and (2) EPA should consider implem enting technology to reduce or eliminate excess emissions from incompatibility as the widespread use date is reached. Virginia Virginia preferred definition (c). – Virginia stated that definition (c) is the most appropriate way to determine “widespread use.” Virginia also supports an uniform nationwide widespread use definition. – Virginia stated that in the development of a widespread use algorithm, EPA should develop an algorithm to compute themagnitude of “incompatibility excess emissions,” using localityspecific inputs. - Virginia also stated that an algorithm should be developed for determining emptying and breathing emissions; algorithm should incorporate locality-specific data.
CARB CARB maintained that widespread use may not apply to California since CARB expects to show an emissions benefit by continuing the use of Stage II VRS even after ORVR-equipped vehicles are in widespread use. CARB also commented that the Stage II Issues Paper should probably be revised to say that CARB will retain Stage II VRS after the widespread use date, “if there is an emissions benefit.”

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### 44 Stakeholder Comment Summary Comment Details NJDEP NJDEP preferred definition (c). The NJDEP had the following two issues with definition (c): (1) does not believe that 100 percent rule effectiveness for ORVR is accurate, and (2) NJDEP cannot run the MOBILE6 model using all the scenarios presented in the Issues Paper. NJDEP added that if the MOBILE6 model is not revised to allow state-specific emissions calculations, then definition (b) may be more appropriate. TCEQ TCEQ stated that definition (b) from a modeling standpoint would be the easiest and most realistic way to determine widespread use. - TCEQ stated that the method of determining widespread use would have a significant impact on their program since promulgating ORVR compatible requirements. “It is possible that widespread use, depending on the definition chosen by the EPA, could occur relatively soon after the TCEQ’s ORVR compatibility deadline for existing Stage II systems which is April 1, 2007.” – TCEQ requested that if definition (c) is used, then EPA should provide guidelines on how States can use readily available data to determine in-use efficiency for existing Stage II VRS. – TCEQ stated that any widespread use definition requiring data on the percentage of gasoline dispensed would require additional reporting because Texas GDFs ar e not currently required to report gasoline throughput information.
Wisconsin DNR Wisconsin DNR suggested using either definition (a) or (b). – Wisconsin DNR commented, “[i]ncorporating either of the simple approaches with the development of an algorithm may be sufficiently accurate for projec ting the approximate time when widespread use occurs.” – Wisconsin DNR said that they agree with EPA’s suggested approach to use one widespread use definition for all States and having state-specific inputs to make the widespread use date applicable to that state. – Wisconsin DNR also stated that they agree that when Stage II VRS are removed that the continued use of Pressure/Vacuum (P/V) valves should be required. – Wisconsin DNR stated that if EPA chooses option (c), EPA needs to provide states with in formation on how states can use readily available data to determine in-use control efficiency of Stage II VRS. Ohio EPA Ohio EPA suggested that EPA consider a simple and direct comparison for determining widespread use. Ohio EPA stated that the simplest comparison for widespread use is determining when the amount of gasoline dispensed to ORVR-equipped vehicles is equal to the amount of gasoline dispensed by means of Stage II VRS. Ohio EPA commented, “The issues of incompatibility, ruleeffectiveness for Stage II, and spillage for ORVR vs. Stage II would not be considered due to the complexities and relative inaccuracies associated with eval uating such issues. Also, the nominal control efficiencies fo r Stage II and ORVR would not be considered significantly different. In the event USEPA considers the nominal control effi ciencies to be significantly different (e.g., 95 percent for pre-EVR Stage II and 98 percent for ORVR), the comparison ofgasoline dispensed to ORVRequipped vehicles and dispensed by means of Stage II could include an adjustment factor for nominal control efficiencies.”

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### 45 Stakeholder Comment Summary Comment Details
Missouri DNR Missouri DNR stated that they believe that ending Stage II VRS would be premature; balance systems complement ORVR, yielding a control efficiency greater than 98 percent. - Missouri DNR provided data that indicates there will always be a significant number of vehicles that will never have ORVR; they strongly suggest that Stage II balance VRS not be discontinued. - Missouri DNR suggested another possible definition for widespread use that is derived from Figure 6 from the Issues Paper; widespread use could be defined as the point where ORVR only crosses or joins balance Stage II VRS only, which yields a date sometime near 2030. API API stated that they support definitions (d) or (b) because they reflect a common sense interpretation of the term “widespread use.” Conversely, the API maintained that definition (c) is too complex and not consistent with what Congress intended. For definition (d), API suggested that quantities of gasoline dispensed on a countywide basis could becalculated from countyspecific VMT data by using fuel economy data incorporated into the MOBILE6 model.

API indicated that they support a widespread use definitionthat is applied on an area-byarea and/or regional basis.

API also offered to work with EPA on how to determine an alternative baseline for the OTR so that OTR States can take credit for ORVR. – API stated that “[t]he consum er is already paying for ORVR systems on their vehicles and should not have to pay again for the maintenance of redundant vapor controls at the gasoline dispensing facility. State environmental agencies should not be asked to implement Stage II VRS programs after widespread use is determined since ORVR and Stage II are duplicative technologies.” API also comme nted that it is expensive for states to administer an effective Stage II VRS program and that states should be allowed to focus their air quality improvement efforts on programs other than Stage II VRS. – API added that “[u]nder Definitions (b) and (d), to identify the appropriate percentage that equa tes to ORVR widespread use, EPA should examine when the percentage of ORVR systems installed is equivalent to the Stage II in-use efficiency that is in a given SIP.” API provided the following example: If a state has an 85 percent efficiency for th e Stage II VRS, then once 87 percent of vehicles have ORVR, the state would have achieved widespread use. To calculate 87 percent, use the MOBILE6 value of 98 percent efficiency for ORVR technology and then divide the in-use efficiency (in th is example, 85 percent) by 98 percent. – API also mentioned the spreadsheet they developed to calculate the percent of gasoline dispensed to ORVR-equipped vehicles based on VMT data and other MOBILE6 input data. API suggested that their spreadsheet could be updated with information with automobile manufacturers regarding when ORVR was actually implemented on the vehicles. – API stated that definition (c) would require data that is extremely difficult to ascertain. - API encouraged EPA to determine a definition of widespread use that follows Congressional intent.
FPMA FPMA noted that definitions (a) and (b) meet the intent of Section 182(b)(3), and option (d) may meet the intent, while definition (c) goes far beyond whether ORVR is in widespread use and would be the most difficult calculation to make.

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### 46 Stakeholder Comment Summary Comment Details Healy Healy indicated that they do not agree with the Issues Paper assumption that the ORVR fleet penetration will at some point make Stage II VRS redundant. - Healy commented that a review conducted by CARB concluded that 20 percent of gasoline dispensed currently and in the foreseeable future will be n on-ORVR vehicles; if Stage II VRS is removed, then 100 percent of non-ORVR refueling emissions will be emitted to the atmosphere. Healy used an equation to conclude that the vapor recovery efficiency after the widespread use date and dismantle of Stage II VRS would be 76 percent. - Healy suggested that the widespread use calculation take into account the actual in-use control efficiency of ORVR. EMCO EMCO suggested setting the widespread use definition at a vehicle population percentage of 98 percent ORVR. EMCO commented, “Ostensibly both Stage II systems and ORVR vehicles run at 95 percen t efficiency. Consequently if Stage II controls were removed from dispensing facilities when the vehicle population is 95 pe rcent ORVR, the net effect on emissions would be zero. The 95 percent ORVR vehicle trigger would then be a logical starting point. However, allowing the 5 percent non ORVR vehicles to begin refueling with no vapor recovery increases their emission rate by a factor of 20. This flies in the face of common sense. Surely any environmental protection advocate worth his weight in VOC’s would cringe at the prospect of abandoning the use of effective, proven methods of reducing refueling emissions.”
RSA RSA indicated that definition (c) appears to be the most reasonable since it deals with real emissions and reduction of emissions. RSA stated that definition (c) re quires an accurate determination of annual emissions for VRS and for ORVR under the following scenarios: 1) For VRS emissions with no ORVR. Under this scenario RSA pointed out the following issues/questions: a. Will average annual emissions factors for VRS be used with average annual gasoline sales? b. Will the emissions factors be determined for the VRS in place or as an assumed efficiency multiplied by an uncontrolled emissions factor? c. Will the emissions factors include things such as the nozzle/fillport, spillage/pseudospillage, breathing, and vent emptying? 2) For ORVR emissions. Under this scenario RSA pointed out the following issues/questions? a. Will hybrid vehicles be included along with the percentage of fuel used? b. How will data be broken down for a vehicle type (i.e., model year, make, or combination) c. Will SHED test data be used? 3) For VRS and ORVR. Under this scenario RSA made the following comments: a. For a balance VRS, the nozzle /fillport efficiency increases to greater than 99 percent. b. A vacuum assist VRS may reduce the effectiveness of ORVR.

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### 47 Stakeholder Comment Summary Comment Details NACS, SIGMA NACS and SIGMA indicated that they are “particularly concerned” about EPA’s preference for definition (c); they stated that definition (c) would contradict the “clear policy choice of Congress in identifying ORVR as a superior technology.” NACS and SIGMA stated that definitions (a), (b), and (d) reflect a reasonable interpretation of what widespread use means and these choices reflect a more common sense approach. NACS and SIGMA stated that they would like EPA to give more consideration to definitions (b) and (d). - These groups stated, “NACS and SIGMA members have spent hundreds of thousands of dollars installing and maintaining Stage II systems over the last decade. These burdens were assumed as part of the compromise reflected in section 202(a)(6) of the Clean Air Act and subsequent promulgation of ORVR requirements: service station owners would install Stage II systems in certain nonattainment areas over the interim period until ORVR was in place in a majo rity of the vehicle fleet to control these same refueling emissions. The timeframe for achieving widespread use was envisioned as approximately 10- 15 years after promulgation of ORVR requirements. We are now approaching, or possibly in some areas at, the point of widespread use of ORVR. NACS and SIGMA members have done their part in controlling refueling emissions. Consistent with what Congress intended, it is now time to phase out Stage II requirements and recognize an d promote ORVR as the more equitable and effective approach to controlling refueling emissions.” - NACS and SIGMA commented that definition (c) misses the mark in defining widespread use and is an exercise in futility; definition (c) identifies “widespread effect” and not widespread use of ORVR. - NACS and SIGMA suggested th at EPA consider using the median Stage II in-use efficien cy value from St ate SIPs, given the difficulty in pinpointing a preci se estimate of Stage II in-use efficiency, to identify the percen tage that would define ORVR widespread use under Options (a), (b), or (d).
Hertz Hertz stated that the most conservative definition of widespread use is 95 percent of the vehicle fleet being comprised of ORVR-equipped vehicles.
ARID ARID noted that the extreme magnitude of incompatibility excess emissions should strongly influence the thought processes for the definition and supporting algorithms related to widespread use.



### F. Phase Out of Stage II Vapor Recovery Systems

After the widespread use date is determined, EPA may decide to allow Stats or areas to repeal requirements for Stage II VRS

1. Comment Summary Five stakeholders and one equipment vendor expressed concern regarding the phase out of Stage II VRS. One stakeholder stated that they would like to s ee the continued use of Stage II VRS because it would remain a critical element of an ozone attainment strategy. Two

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### 48 stakeholders stated that Stage II VRS should not be adopted by new areas because there would only be marginal benefit at significant costs. One stakeholder commented that they would like to see the requirement for Stage II VRS at new GDF revoked in Southeast Florida. Lastly, one stakeholder suggested that Stage II VRS nozzles are costly, complex and difficult to use and believes that sooner rather than later replacement of Stage II VRS with ORVR will allow for nozzles to be built for durability, reliability, and safety instead of specifically for Stage II VRS.

The Ohio EPA requested that an impact st udy be conducted before discontinuing Stage II VRS in nonattainment areas to determine the impacts of dismantlement. The Wisconsin DNR also indicated that they would like assurances that the disconnection of Stage II VRS would be monitored. TCEQ stated that faulty vacuum a ssist systems have the ca pacity to cause more fugitive and vent emissions than a GDF without St age II VRS, and simply ceasing to investigate GDFs with Stage II VRS would harm air quality as numerous vacuum assist VRS would remain in service without maintenance or oversight.

NESCAUM suggested that EPA ta ke measures to ensure that States do not remove Stage II VRS if the removal would resu lt in an increase in VOC emissions. NESCAUM also stated that new stations should not be re quired to install Stage II VRS if the widespread use date is near (i.e., within a year or two years) but instead us e alternative measures. The CT DEP stated that Stage II VRS is an effective and efficient mean s of reducing ozone precursor emissions and as such, Stage II should not be phased out. CT DEP believes that continued use of Stage II VRS is necessary because only light-duty ve hicles are required to have OR VR. The CT DEP also stated that the phase out of Stage II s hould not occur until ORVR effe ctiveness has been determined over the lifespan of the ORVR canister.

The FPMA commented that there are two dates to consider related to the phase out of Stage II VRS: (1) the date after which St age II VRS will no longer be required for new construction; and (2) the date after which Stage II VRS will not be required to be maintained at existing facilities. FPMA further stated that thei r primary concern is to obtain an immediate end to requiring Stage II VRS at ne w GDFs in Southeast Florida.

Both API, NACS, and SIGMA stressed that Stage II VRS should not be adopted by new areas; the costs associated with this adoption w ould be excessive and are not justified by the diminishing marginal benefit of emissions reductions.

2. Discussion and Recommendations

There are two issues associated with these comm ents: (1) after the widespread use date is achieved, ensuring existing Stage II VRS are rem oved in a manner that does not increase VOC emissions from the GDF, and (2) should we allow GDFs built near, but before, the widespread use date to be granted an exemption from installing Stage II VRS? If so, then how long before the widespread use date can a station be built without Stage II VRS and what in-kind measures can we require to compensate for the subsequent VOC emissions from these GDFs? This is an equity issue; some believe it is not fair to existing GDFs with Stage II VRS requirements to allow an exemption to installing Stage II VRS fo r new GDFs. We agree. NESCAUM suggested that a cost-benefit analys is be conducted by EPA to determine wh at is the period of time, prior to the widespread use date, that newly built GDFs would not have to install Stage II VRS.

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### 49 There is a concern that if Stage II VRS are not properly removed from GDF, then there will be resultant leaks as the system deterior ates or as replacement non-VRS equipment are installed. There is potential for fugitive VOC l eaks if Stage II VRS remain in place and are not maintained and not sufficiently capped. There is also a potential for leaks if new equipment, such as nozzles, that are not Stage II VRS co mpliant, replace worn out Stage II VRS compliant equipment. Given the track record for GDF mainte nance, we believe this issue is important to address. EPA should strongly c onsider providing guidance on mi nimal standards for removal of Stage II VRS equipment. OAQPS should work clos ely with the Office of Underground Storage Tanks (OUST) on removal requirements.

All the stakeholders that responded were gene rally in agreement with allowing a waiver or exemption to new GDF built near the widespread use date. There were few comments on what control measures to implement in place of Stage II VRS. NESCAUM mentioned stricter Stage I requirements. Other measures that could be adopted would be more frequent inspections, monitoring of the system pressure, in-station di agnostics, requiring an add-on control device to the UST, etc.

We recommend that EPA develop a policy, guid ance, or rule requiring GDF to remove or decommission Stage II VRS equipment in a way that will minimize leaks. Another recommendation is that EPA allow States to gran t waivers to GDF that are being built near the widespread use date. We recommend that EPA conduct a cost analysis to determine when new GDF would no longer be require d to install Stage II VRS. In addition to waivers granted to these newly built GDF, we recommend th at they be required to implement other VOC emissions reductions measures, such as dripless nozzles, US T add-on APCD, in-station diagnostics, or have the State increase inspections of the GDFs. We believe the State should have the latitude to choose the alternative emissions reductions m easures, increase inspec tions, or some other equivalent measures as long as the State can show th at the alternative VOC emissions reductions measure (in combination with ORVR emissions re ductions) is equivalent to the VOC emissions reductions achieved by Stage II VRS. We r ecommend that EPA develop additional guidance on control measure options and the control effici encies that can be achieved. Finally, we recommend that EPA develop guidance for allowi ng SIP credits for source owners or operators who retain Stage II VRS.

Table 6. Phase Out of Stage II Vapo r Recovery Systems Comment Summary

Stakeholder Comment Summary Comment Detail
NESCAUM NESCAUM stated that EPA should take measures to ensure that a State can not eliminate Stage II VRS if removal of these systems would result in an actual emissions increase in VOC. NESCAUM proposed that new GDF not be required to install Stage II VRS and, instead, impl ement alternative measures (such as improvements to the control efficiency of the GDF Stage I system) so as not to gain an economic advantage over GDFs that previously had to install Stage II VRS. NESCAUM recommended that EPA conduct a cost-benefit analysis to determine when this “interim” period should start. TCEQ TCEQ has concerns that VOC emissions will increase if oversight of VRS ceases/stops once widespread use is achieved. TCEQ stated, “Because faulty vacuum assist systems have the capacity to cause more fugitive and vent emissions than a GDF without a Stage II VRS, simply ceasing to investigate GDFs with Stage II VRS would harm air quality as numerous vacuum assist VRS would remain in service without maintenance or oversight.”

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### 50 Stakeholder Comment Summary Comment Detail
Connecticut DEP Connecticut DEP commented that they want to see continued use of Stage II VRS and requested that EPA require implementation of Stage II in ozone nonattainment areas as required by the CAA. Connecticut DEP stated, “Continued use of Stage II systems is necessary because only light duty vehicles are required to have ORVR canisters available. Connecticut DEP believes that Stage II systems will remain a critical element of an attainment strategy into the foreseeable future.”

Ohio EPA Ohio EPA noted that an impact study should be conducted before discontinuing Stage II VRS in nonattainment areas to determine the impact of the discontinuance, while taking into account SIP projections. Ohio EPA stated, “The US EPA should identify all areas outside of the OTR that implemented Stage II, identify the basis for the implementation (e.g., to meet the 15 percent reduction requirement for 1996, to meet other reasonable further progress requirements, etc.), and identify the years for any emissions projections. This may uncover issues not considered by USEPA or may help resolve issues already considered by USEPA. Those non-OTR areas should be allowed to use either the above-suggested comparison for discontinuance of Stage II or a more complicated comparisonof emissions that may include incompatibility, ruleeffectiveness, etc. pursuant to USEPA policy that results from this issues paper.”
Wisconsin DNR Wisconsin DNR stated that they have concerns about disconnecting Stage II VRS. Wisconsin DNR indicated that they want assurances that the disconnection of Stage II VRS be properly monitored. Wisconsin DNR requested that EPA address this issue in the case that Stage II system s are no longer needed.

FPMA FPMA stated that Stage II is a redundant technology and the VRS equipment has a limited useful life. FPMA noted that their primary concern is to obtain an immediate end to requiring Stage II VRS at new GDFs in Southeast Florida. - FPMA commented that there are two regulatory considerations to consider fo r phasing out Stage II VRS: (1) the date after which Stage II VRS will no longer be required for new construction; and (2) the date after which Stage II will not be required to be ma intained at existing facilities. - FPMA stated “Our concern is that if EPA does not distinguish between areas former ly designated as “moderate” nonattainment and areas that ar e “serious” nonattainment or worse, regulators responsible for the previously “moderate” areas will apply the same “wid espread use” criteria as EPA will apply to the “serious” or wo rse areas. It is our position that Stage II regulations in areas where Stage II was not required under the Clean Air Act ought to be repealed before Stage II is revised or waiv ed in “serious” or worse nonattainment areas.” Healy Healy stated that additional steps, such as quantifying thegasoline dispensed to nonORVR vehicles, need to be taken before dismantling Stage II systems. Healy recommended that current data from the US Department of Transportation and other sources be used todetermine the actual distribution of gasoline to ORVRequipped vehicles and to non-ORVR equipped vehicles in order to better calculate the impact of dismantling Stage II VRS.

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### 51 Stakeholder Comment Summary Comment Detail
Costco Costco stated that they would like to see Stage II replaced with ORVR; replacement of Stage II VRS would allow manufacturers to build nozzles that are built for durability and reliability instead of specifically designed for VRS, which are costly, complex, and difficult to use. API API stated that they do not support the adoption of Stage II VRS in new areas. API commented, “The cost per ton VOC reduced by Stage II is rapidly growing as the ORVR is implemented in the vehicle fleet.” NACS, SIGMA NACS, SIGMA stated that EPA should not permit the expansion of Stage II VRS in

new areas. These groups maintained that the costs associated with installing new or enhanced Stage II VRS are not justified by the diminishing marginal benefits that may be achieved before the widespread use date arrives.



### G. Phase Out of Stage II Vapo r Recovery Systems in the OTR

1. Comment Summary

Two stakeholders indicated th at they would like to see a mechanism developed that would allow OTR states the ability to phase out thei r Stage II VRS.

NESCAUM recommended that EPA determin e a regional phase-out date that is consistent with the latest date that an OTR st ate would achieve widespr ead use. NESCAUM also requested that EPA provide an early opt-out met hod for those OTR States that demonstrate that removal of Stage II VRS would not degrade air qua lity. Virginia also agreed that EPA should provide an additional mechanism for OTR States to phase out of the Section 184(b)(2) Stage II VRS, or comparable measure, requirement; requ irement would be similar to the mechanism for moderate or worse nonattainment areas under Sec tion 184(b)(3) to allow the removal of Stage II VRS once ORVR controls are determined to be in widespread use. Both NESCAUM and Virginia recommended updating the “Stage II Comparability Study.”

2. Discussion and Recommendations

The discussion and recommendations for this sec tion are similar to those in Section V.F. Again, the recommendation is for EPA to allow OT R States to grant waivers to GDFs that are being built prior to the widespread use date, a nd we recommend that the GDFs that are granted waivers be required to implement other VOC emi ssions reductions measures, such as in-station diagnostics, or have the State increase inspections of the GDFs. We believe each OTR State should have the latitude to choose the altern ative emissions reductions measures, increase inspections, or some other equivalent measures as long as the State ca n demonstrate that the alternative VOC emissions reductions measur e (in conjunction with ORVR controls) is equivalent to the VOC emissions reductions achieved by Stage II VRS. As with the phase out for the rest of the country, the same guidan ce document on the decommissioning of Stage II VRS may be necessary. Because the “Stage II Comparability Study” must be updated or otherwise

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### 52 amended to allow removal of Stage II VRS, we recommend that this process begin soon, with input from OTR States.

Table 7. Phase Out of Stage II Vapor Rec overy Systems in the OTR Comment Summary

Stakeholder Comment Summary Comment Detail NESCAUM NESCAUM indicated that they would like to see a pathway developed that would allow OTR states to phase-out their Stage II VRS programs. NESCAUM suggested that EPA determine a regional phase-out date that is consistent with the latest date that an OTR state reaches widespread

use. - NESCAUM stated, “Under current EPA policy, the only pathway for phasing out Stage II in OTR states is the implementation of comparable measures equivalent to Stage II reductions achieved in 1999. Given this scenario, redundant vapor recovery programs (ORVR and Stage II) will run side-by-side in perpetuity unless a policy change is made at EPA. Therefore, the NESCAUM states support a revision of the Comparability Study to develop a pathway that would allow OTR states to phase-out their Stage II programs at the point where this does not result in increased emissions.” - NESCAUM would also like to see EPA provide an early opt-out method for those OTR states that are able to demonstrate that the removal of Stage II VRS would not increase VOC emissions nor degrade air quality. Virginia VA stated that EPA should provide an additional mechanism for OTR states to be able to phase out of the section 184 (b)(2) Stage II VRS or comparable measure requirement. VA suggested updating the “Stage II Comparability Study” with a baseline that co incides with the year that ORVR is determined to be in widespread use.



### H. Stage II State Implemen tation Plan (SIP) Credits

As previously discussed in this paper, SIP cr edits could possibly be granted to States for maintaining Stage II VRS after the widespre ad use date, implementing Stage II VRS in additional areas, and implementing improved monitoring and/or control measures.

1. Comment Summary

Five stakeholders stated that they support granting SIP credits for maintaining Stage II VRS after the widespread use date. One stakehol der suggested that SIP credits be granted to States for adopting controls that minimize ORVR incompatibility emissions. One stakeholder stated that SIP credits should be granted for continuing to require pre-EVR standards or for requiring any part of CARB’s EVR program. Fo ur stakeholders and one equipment vendor stated that EPA should grant SIP credits for States that require equipment such as P/V valves or add-on APCD. Three stakeholders indicated that they support granting SIP credits for improved monitoring of Stage II VRS. Tw o stakeholders suggested that SIP credits be granted for implementing Stage II VRS in new areas. One stak eholder contended that SIP credits should be granted to States for additional te sting of Stage I equipment. Tw o stakeholders maintained that SIP credits should not be granted for the conti nuance of Stage II VRS after the widespread use date and for adopting Stage II VRS in new areas.

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### 53 NESCAUM stated that they support SIP cred its for maintaining Stage II VRS after the widespread use date but only if the emissions reductions achieved are greater than those emissions reductions achieved from ORVR. NE SCAUM also stated support for granting SIP credits for improved monitoring and inspections of GDF, and the adoption of controls to minimize ORVR incompatibility emissions. NESC AUM further offered to assist the EPA with developing methods to enhance test ing and inspection programs.

The Connecticut DEP commented that EPA s hould grant SIP credits for States that require P/V valves and technology that reduces IEE, and for implementing Stage II VRS in new areas or moderate ozone attainment areas.

The NJDEP suggested that EPA grant SIP cred its for improved monitoring of Stage II VRS and for requiring P/V valves and mini-boots on vacuum assist VRS. NJDEP also indicated that SIP credits be granted for maintaining Stag e II VRS after the widespread use date, but only if widespread use occurs before 100 percen t fleet turnover of ORVR-equipped vehicles.

The TCEQ maintained that EPA should manda te ORVR compatibility for States that choose to continue their Stage II VRS programs in order to be granted additional SIP credits.

The Wisconsin DNR suggested th at SIP credits be granted for maintaining Stage II VRS after the widespread use date, for conducting additional testing of St age I equipment, the installation of a new technology that reduces emissions, and for requiring P/V valves. The Wisconsin DNR also recommended that SIP credits be granted to States for continuing to use pre-EVR standards or for using a ny part of CARB’s EVR program.

Both API, NACS, and SIGMA stated that they do not support the gr anting of SIP credits for maintaining Stage II VRS after the widespr ead use date and for implementing Stage II VRS in new areas. These groups also stated that they do, however, support SIP credits for emissions reductions due solely to ORVR. API further no ted that SIP credits should not be granted for implementing CARB’s EVR program, the installati on of an ISD, or the installation of unihose equipment.

2. Discussion and Recommendations Despite what some stakeholders believe about the need to eliminate Stage II VRS, we believe that there is merit to the idea to provi ding SIP credits for State and Local APCA that choose to retain Stage II VRS after the widespread use date. SIP credits related to continued use of Stage II VRS would depend on which definition EP A selects. For definition (c2), it is not clear what additional SIP credits would be available for continued use of Stage II VRS; for definition (c), additional SIP cred its may be available for the diffe rence in emissions levels with ORVR only and emissions levels with combined Stage II VRS and ORVR plus the incompatibility excess emissions. SIP credits co uld be provided for continued use of Stage II VRS and ORVR-compatible Stage II VRS for any of the definitions prior to the date associated with definition (c2). For Stat es that use MOBILE6, the State emissions inventory may already account for ORVR emissions reductions.

We believe that there is merit in granting SIP credits to State and Local APCA that choose to install other control measures after Stage II requirements are removed, such as UST

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### 54 add-on APCD, P/V valves at GDF, improved para metric monitoring or ISD systems, dripless nozzles, operating training, and in creased inspections. Additiona l control measures could be used at new facilities waived from requirements to install Stage II VRS, for GDF that remove Stage II VRS, or at other large-emitting GDF. We recommend, as stated previously, that EPA develop a guidance document, such as a CTG, di scussing the control measures, efficiencies, and costs associated with each measure. Some cont rol measures could be used in conjunction with continued Stage II VRS or could be used by GDF that remove the VRS systems. Preliminary monitoring shows that there may be additional fugitive emissions from the UST if the UST is not vapor tight. A P/V valve control measure s hould be accompanied by periodic UST pressure testing to confirm that fugitive emissions are not increasing due to pressurization of the UST and leaks. For balance systems and uncontrolled GDF (i.e., no Stage II VRS), the UST are more likely to remain at negative pressures for longer periods of time and pressurization of the UST may be less of an issue. UST with vacuum assist Stage II VRS will likely be at positive pressure for the majority of the time (generating additional fugitives when the UST is pressurized at 0 to 3 in. w.c.), and these GDF could benefit from a ddition of a control measure to alleviate positive
pressures.
As there are some concerns regarding vapor leaks from UST due to pressurization and contamination of groundwater and soil (discussed la ter in this section), those additional control measures that alleviate pressurization of the US T should be given close consideration by States in the interim period before the widespread use date , especially for vacuum assist Stage II VRS.

While we have not yet collected data on or tested the UST vent emissions for an uncontrolled GDF, these emissions levels should be quantified and the potential emissions reductions determined for UST control devices. We plan to conduct testing at an uncontrolled GDF that will include measurement of UST emissions (see section VI.D).

We do not recommend requiring Stage II VRS in additional areas. It does not seem prudent to require a system that may be removed in a few years. Again, the cost analysis study to assess when new GDF would not be required to install Stage II VRS relative to the widespread use date may also address this issue.

Additional control measures with respect to Stage I operations will be addressed in an area source standard for GDF. The Stage I so urce category will not be addressed here.

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### 55 Table 8. Stage II State Implementation Plan (SIP) Credits Comment Summary

Stakeholder Comment Summary Comment Detail NESCAUM NESCAUM stated that they support the use of SIP credits to encourage States to maintain stringent vapor recovery programs to control both VOC and air toxics emissions.

NESCAUM suggested that SIP credits only be granted when Stage II VRS achieves greater emissions reductions than those achieved by ORVR alone following the widespread use date. - NESAUM stated, “Once the use of Stage II controls does not garner any actual emission reductions, SIP credits should no longer be granted.” - NESCAUM also indicated th at SIP credits should be granted for improved monitoring and inspections of GDF’s continuing to use Stage II VRS. - NESCAUM stated that States should be granted SIP credits for enhanced en forcement and compliance assistance efforts (such as enhanced monitoring and/or inspection programs) that will improve VRS efficiencies. - NESCAUM stated that EPA should investigate other means for maintaining progra m effectiveness, such as requirements to implement an equipment change-out schedule; - NESCAUM provided a copy of a report from Vermont’s Air Pollution Control Board that was used as a basis for such a program. - NESCAUM offered to work with EPA to develop methods to enhance testing and inspection programs and to quantify the benefits of these activities. - NESCAUM indicated that if ORVR incompatibility proves to be significant then incompatibility emissions should be considered new and not as the result of shortcomings of Stage II VRS design or the Stage II regulations adopted by a stat e’s SIP; states that adopt controls to minimize ORVR compatibility emissions should be given full SIP credit for those incremental reductions achieved.
Connecticut DEP Connecticut DEP commented that EPA should allow SIP credits for States that require P/V valves and technology to reduce incompatibility excess emissions, and for States that choose to require Stage II VRS in new areas or moderate ozone nonattainment areas. Virginia VA supported SIP credits for areas that maintain Stage II VRS after widespread use has been achieved.
NJDEP NJDEP stated that SIP credits should be granted for improved monitoring of Stage II VRS and other improvements such asrequiring P/V valve and miniboots on vacuum assist VRS. - NJDEP stated that they have upgraded their Stage II VRS regulations to require annual testing of both Stage I and II systems and installation of P/V valves and mini-boots on nozzles (effective June 2, 2003). - NJDEP also believes that SIP credits should be granted if a state continues to requ ire Stage II VRS after the widespread use date, if widespread use does not occur at 100 percent fleet turnover.

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### 56 Stakeholder Comment Summary Comment Detail TCEQ TCEQ stated that ORVR compatibility should be mandated for those states choosing to maintain their Stage II VRS in exchange for SIP credits.
Wisconsin DNR Wisconsin DNR recommends that EPA allow States to claim SIP credits for Stage II VRS that remain in operation after the widespread use date is reached. Wisconsin DNR also suggests that EPA provide additional SIP credits for additional testing of Stage I equipment. – The Wisconsin DNR, despite the language in Sections 202(a) (6) and 182(b) (3), plans to retain Stage II VRS in nonattainment areas after the widespread use date is achieved. – Wisconsin DNR recommends that States that require Stage II VRS after the widespread use date is achieved, continue to require periodic testing and emissions monitoring. – Wisconsin DNR recommends that States be granted SIP credits for continuing to require pre-EVR standards and for requiring any part of the CARB Enhanced Vapor Recovery controls, such as ORVR compatibility. – Wisconsin DNR recommends that SIP credits be granted for any new technology insta lled at a GDF that produces verifiable emissions reductions, even if it is not part of the CARB EVR program. – Wisconsin DNR also recommends that SIP credits be granted for those States that require a P/V valve, if P/V valves prove to be beneficial.
API API stated that after a state identifies the appropriate percentage of ORVR systems installed is equivalent to the Stage II in-use efficiency that is in a given SIP, SIP credits would then be appropriate for emissions reductions due solely to ORVR.

API indicated that they do not support SIP credits for the continued use of Stage II VRS after the widespread use date, or implementing Stage II VRS in new areas.

API stated that CARB’s program requiring a retrofit to existing GDFs to meet the new EVR is not necessary and as such, SIP credits should not be granted. – API cited a Tech Environmental Study 53

47 done in Tennessee that indicated the cost per ton of VOC emissions reductions increases from $10,000/ton in 2007 to $26,000/ton in 2015. API added that when the cost of the State’s administration of th e program is included that these costs rise to $11,000/ton and $29,000/ton, respectively. 54

48 – API also cited the Tennessee proposal to implement Stage II VRS requirements in new counties. Tennessee decided against such requirements because Stage II was not a significant strategy and would become even less significant as more and more vehicles have ORVR control and larger activated carbon canisters. Also, Tennessee was not aware of any EAC [Early Action Compact] areas that actually used Stage II as a proposed strategy in the final analysis. 55 45 – API stated that SIP credits should not be given for retrofitting existing equipment to accommodate CARB’s EVR program; both pre-EVR and EVR systems when properly maintained are certified to recover 95 percent of the refueling emissions. – API also indicated that SIP credits should not be granted for ISD installation or for requiring the installation of unihose equipment at GDFs.

53 Cost Benefit Analysis for Stage II VRS Control in the Knoxville EAC Area. Tech Environmental (prepared for API). April 2004.

54 Stage II Vapor Recovery System Operations & Systems Installations Costs. API Publication 1645. August 2002.

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### 57 Stakeholder Comment Summary Comment Detail RSA RSA stated that they believe it is appropriate to provide additional SIP credits related to the use of VRS. RSA stated that they support SIP credits for the following actions: 1) Maintaining Stage II controls after the widespread use date as long as the VRS is a balance system or a vacuum assist VRS that has pass ed CARB’s strict [EVR] requirements. 2) Stage II VRS (balance or CARB approved vacuum assist VRS) in new areas in or der to reduce the transport of emissions to non-attainment areas or to provide additional health protection. 3) Emissions reductions associated with improved monitoring. All States should be required to have an inspection and maintenance program in place. 4) The installation of P/V valves. EPA should require P/V valves on all stations whether VRS equipped or not. 5) VRS should be equipped with unihose dispensers in order to reduce the number of possible emissions points. 6) Stage I testing should continue after widespread use and Stage II testing should continue for as long as the VRS are in operation.
NACS and SIGMA NACS and SIGMA stated that they do not believe that SIP credits should be granted for continuing Stage II VRS after the widespread use date and for implementing Stage II in new areas. They did recommend that SIP credits be granted for emissions reductions attributed to ORVR. NACS and SIGMA commented, “Granting SIP credits after the widespread use date for enhancing or maintaining Stage II in existing areas or, ce rtainly, for extending Stage II into new areas would be inconsistent with this Congressional policy choice. In fact, it would be illogical to grant SIP credits for Stage II controls that address the very same emissions for which credit is granted due to the use of ORVR. Of course, States should receive SIP credit for the emission reductions attributable to ORVR as Stage II is phased out.”

NACS and SIGMA further noted that the substantial cost associated with installing new or enhanced Stage II are not justified by the diminishing marginal benefits that may be achieved by Stage II before the widespread use date arrives.
ARID ARID indicated that SIP credits should be granted for installation of APCD systems and for integrated monitoring and local inspection and maintenance programs. ARID suggested that SIP credits could be given for the designation of BACT, MACT, or RACT for the use of APCD technology and/or inspection and maintenance
programs.

55 Email communication , Wayne Davis, PhD, University of Tenness ee and Prentiss Searles, American Petroleum Institute, March 31, 2004.

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### 58 I. Enhanced Vapor Recovery (EVR)

1. Comment Summary Two stakeholders expressed concern that CARB would no longer support or archive preEVR Stage II VRS. One stakeholder suggested that those vacuum assist Stage II VRS that pass CARB EVR approval would be much more complex and more expensive to install and maintain. One equipment vendor commented that CARB’s EVR program has cer tified several new Stage I VRS; full implementation of these new systems w ill result in decreased hydrocarbon emissions. One equipment vendor stated th at a portion of CARB’s EVR progr am will result in decreased emissions, while some EVR requirements may actually increase fugitive emissions. One stakeholder recommended that States be granted SIP credits for continui ng to require pre-EVR standards and for requiring any part of the CARB EVR, su ch as ORVR compatibility.

The TCEQ indicated that they have relied on CARB to test and verify Stage II VRS but are now in the process of continuing to mainta in pre-EVR standards w ithout the assistance of CARB. API also indicated that they are conc erned that CARB will no longer support or archive pre-EVR Stage II VRS and as such, areas wit hout archived pre-EVR requirements could, by default, adopt EVR. API recommended that EP A archive the pre-EVR certifications and test procedures.

Missouri DNR suggested that vacuum-a ssist Stage II VRS meeting CARB EVR requirements would be more complex and expensive to install and maintain.

2. Discussion and Recommendations OPSG should consider adopting certain com ponents of CARB’s EVR program, such as those that make the Stage II VRS controls compatib le with ORVR as well as the ISD monitoring. All areas where Stage II VRS is required will con tinue with these controls until widespread use is achieved; some areas of the U.S. will no long er require Stage II VRS once widespread use is achieved and other areas will continue with Stage II VRS after the widespread use date. OPSG’s options include: (1) requiring no additional cha nges for Stage II VRS compatibility with ORVR through the widespread use date and phasing out Stage II VRS requirements once widespread use occurs, or (2) requiring that Stage II VRS be ORVR compatible prior to and following the widespread use date for areas that have a nd/or will retain Stage II VRS requirements.

Whether or not to require ORVR compatible Stage II VRS will depend on which widespread use definition is sel ected and how early the date occurs. An early definition, such as definition (c) would not likely warrant additional conversion of vacuum assist Stage II VRS equipment, however, definition (a) would come later and the emissions benefits for ORVR compatible VRS may be worth the effort. The cost s associated with this issue could be included as a component of the suggested cost analysis study for new GDF waivers.

The MTBE issue is another considerati on in deciding whether to require ORVR compatibility for Stage II VRS, and possibly ha s an effect in decidi ng on which definition. While some States have suggested that a later widespread use de finition is better from their perspective, an earlier defin ition may help alleviate any MTBE issues associated with incompatibility of vacuum assist VRS with ORVR.

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### 59 Another issue related to retaining the exis ting Stage II VRS requirements is that CARB has changed its program to require EVR compliant systems. Because other States often refer to CARB-certified equipment in their regulations and SIPs, once CARB removes the non-EVR certifications, this will be an issue for those States to deal with.

Table 9. Enhanced Vapor Recovery (EVR) Comment Summary

Stakeholder Comment Summary Comment Detail TCEQ TCEQ indicated that they had previously relied on CARB to test and verify Stage II VRS equipment and that they are nowattempting to continue preEVR standards without the assistance of CARB. - TCEQ stated that TCEQ and other States have relied on CARB to test and certify new Stage II VRS and peripheral equipment; however, since the implementation of EVR, CARB has decided not to certify or provide support for the previous VRS standard of 95 percent. - TCEQ stated that they are attempting to continue the preEVR standards while incorporating a requirement for ORVR compatibility. Wisconsin DNR Wisconsin DNR supported granting SIP credits for any implementation of EVR. Wisconsin DNR recommended th at States be granted SIP credits for continuing to require pre-EVR standards and for requiring any part of the California Air Resources Board (CARB) Enhanced Vapor Recovery controls such as ORVR compatibility. The WDNR also recommends that EPA allow SIP credit for any new technology installed at GDFs that results in verifiable VOC emissions reductions, even if it is not part of the CARB EVR program.
Missouri DNR Missouri DNR stated that their pressure data was the basis for CARB’s decision to limit UST pressures to no greater than + 0.25”wc as a CARB-EVR requirement. Missouri DNR stated that vac uum assist Stage II VRS that pass CARB EVR requirements will be significantly more complex and much more expensive to install and maintain.

API API stated their concern that CARB will no longer support or archive pre-EVR Stage II VRS systems and equipment. API stated, “Meanwhile, most jurisdictions outside of California have specifically referenced and require CARB certified systems, equipment and testing procedures for their Stage I and/or Stage II regulations without qualification. If these individual jurisdictions fail to archive the pre-EVR references to the CARB certification program, these jurisdictions could, by default, adopt the CARB EVR program. Several states have recognized this dilemma and have archived the pre-EVR certifications and test procedures while allowing the voluntary installation of EVR systems. Another possible alternative to this dilemma is for the EPA to archive the pre-EVR certificati ons and test procedures.”
VST VST stated that their newest hanging hardware, including the ENVIRO-LOC vapor recovery nozzles, exceeds CARB’s EVR front-end emissions standards by 90 percent.

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### 60 Stakeholder Comment Summary Comment Detail Healy Healy commented that CARB’s EVR program has resulted in the certification of several new Stage I VRS and when fully implemented will reduce hydrocarbon emissions by 25 tons/day statewide. Healy indicated that they are th e first to pass EVR Stage II testing and that EVR approved Stage I VRS have improved the ability to maintain leak tightness over long periods of time.

EMCO Wheaton EMCO stated that some of the requirements of the CARB EVR program are “straightforward and will result in decreased emissions.” EMCO also noted that some of the EVR requirements may actually increase fugitive emissions. – EMCO suggested that the following EVR requirements will decrease emissions: dripless nozzles, liquid retention requirements, balance system component pressure drops, and leak tight connectors and fittings. – EMCO stated, “The pressure limit requirement of +0.25 inches w.c. daily average, a nd +1.5 inches w.c. maximum requirement seeks to minimize pressure related fugitive emissions. These emissions may not actually exist in a properly constructed and tested system. These are the same emissions that are addressed by the phase I EVR requirements. The net result is a requirement th at, in effect, chases potential fugitive emissions.”



### J. Monitoring/Inspections of GDF and Stage II VRS

As discussed previously in this paper, the ex pected in-use control efficiency of Stage II VRS ranges from 56 to 90 percent, depending on the inspection frequency and the exemption levels. While Stage II control systems can achieve 95 percent or better co ntrol efficiency, in-use efficiency is shown to drop significantly without proper operation and maintenance.

1. Comment Summary

A few stakeholders commented that conducti ng more frequent inspections acts as a mechanism to improve Stage II VRS efficiency. One stakeholder indicate d that they would like to work with EPA in developing methods to enhance testing and insp ection programs. One equipment vendor commented that incentives should be developed to encourage and assist GDF owners and operators to insta ll monitoring equipment that can help ensure that the VRS is operating properly. One stakeholder commented th at ISD systems do not assure compliance, but instead identify failures at GDF that cause excess emissions.

The Wisconsin DNR indicated that fugitive emi ssions are related to the deterioration and aging of GDF equipment and periodic testing/ monitoring would help identify problems, which would lead to an improvement to in-use control efficiency.

NESCAUM stated that they would like to wo rk with the EPA in developing methods to enhance testing and inspection programs and sugg ested that EPA investigate other means for maintaining program effectiveness. NESCAUM en closed a report that summarizes the results of a test program conducted by the Vermont Air Pollu tion Control Program; this test program was the basis for Vermont’s enhanced monitoring and inspection program (see section VI.B).

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### 61 RSA recommended that a nationwide inspection program be developed to inspect Stage I VRS with P/V valves; this program would provi de significant reductions in VOC and HAP at a low cost.

Crompco, a provider of Stage II VRS compliance testing, indicated that there is a strong need to require more periodic testing on a basis more frequent than every 5 years. Crompco suggested an annual test. Crompco contends that as the testing frequency goes up, failure rates and emissions rates go down because problems are being identified and fixed; a well-maintained VRS helps control fugitive emissions from the system.

Veeder Root suggested that most Stage II VR S failures are difficult to detect and may go uncorrected until the next inspection; however, an ISD can assist a GDF by alerting the GDF of potential problems. Veeder Root strongly r ecommended that incentives be made to GDF to encourage installation of ORVR compatible St age II VRS and monitoring equipment to ensure proper operation.

ARID stated that good housekeeping practices have not been present for GDF. ARID maintained that the use of an UST add-on APCD will give the GDF an incentive to ensure that the hardware is properly maintained. ARID fu rther noted that conti nuous monitoring of UST pressure can alert GDF of potential problems.

2. Discussion and Recommendations We believe that improved (and more freque nt) monitoring, coupled with good operation and maintenance programs, results in emissi ons reductions. Use of ISD is a practical, inexpensive approach to better operation of GDF and VRS. EFPAG is currently collecting information regarding costs and that information will be forwarded to OPSG accordingly. We recommend that ISD be included as a control measure option fo r reducing emissions from GDF not only until the widespread use date is implem ented but also continuing for GDF that do not or no longer have Stage II VRS. Control measur es such as increased inspections, improved parametric monitoring, ISD, and operating training should be includ ed in the control measures guidance for the States. These systems could be applied to continued us e of Stage II VRS, new GDF that are waived of the requirements for Stage II VRS, or at uncontrolled GDF.

Additional control measures with respect to Stage I operations will be addressed in the area source standard for GDF. The Stage I so urce category will not be addressed here.

Table 10. Monitoring/Inspections of Stage II VRS Comment Summary

Stakeholder Comment Summary Comment Detail Crompco Crompco indicated that GDF should periodically survey the effectiveness of their VRS on a basis more frequently than every five years to reduce fugitive emissions. Crompco, a GDF inspection company, indicated that Stage II VRS is a very important component in controlling fugitive emissions from GDFs. Crompco provided data on GDF inspec tions (pressure decay tests) that showed: (1) inspections were important for ensuring that the Stage II VRS operate correctly, and (2) the more often inspections were conducted, the less frequently VRS equipment failures were found.

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### 62 Stakeholder Comment Summary Comment Detail
CARB CARB stated that the ISD monitoring identifies failures that cause excess emissions but do not assure compliance. - CARB indicated that EPA mis-characterized ISD because ISD systems do not assure compliance, but instead identify failures at GDF that cause excess emissions. - CARB also stated that EPA implied that the ISD system automatically adjusts the V/L ratio; this is incorrect. The statement was taken from the February 4, 2000 staff report that discusses a specific sensor and not an ISD requirement.
Wisconsin DNR Wisconsin DNR stated that periodic testing/monitoring provides an opportunity to improve the in-use efficiency of Stage II VRS. Wisconsin DNR commented, “The potential fugitive emissions are also related to deterioration and aging of the gasoline dispensing equipment and periodic testing/monitoring would help to identify problem components.” NESCAUM NESCAUM indicated that they would like to work with the EPA to develop methods to enhance testing and inspection programs and in quantifying the added benefits of such actions. NESCAUM submitted a report from the Vermont Air Pollution Control Program that was used as the basis for Vermont’s enhanced monitoring and inspection program. This report stated that testing was conducted at thirty two GDF to determine how well in-use GDF systems maintain compliance with performance standards and the level of effort required to bring GDF back into compliance. API API stated that EPA guidance indicates that in-use effectiveness is a function of the frequency of agency inspections.
RSA RSA recommended that there be a nationwide inspection program of Stage I VRS with P/V valves. RSA stated, “We feel that implementation of certified and inspected Stage I VRS with PV valves nationwide would provide significant reductions in VOC and HAP emissions for the relatively low cost of these systems. They have the additional benefit of having overfill protection to reduce the emissions of liquid gasoline into the soil and waterways near stations as well as the pollution of soil and water from the deposition of vapors.”
Veeder-Root Veeder-Roo t stated that most failures of VRS result in excess emissions, are difficult to detect, and typically go uncorrected until the next inspection takes place, which in most regions is only required annually. Veeder-Root suggested that ISD equipment can assist a GDF owner and/or operator in keeping their VRS in proper repair and operation. - Veeder-Root stated, “As components on the vapor recovery system wear out, dr ift out of calibration or fail, the ability of the system to capture and control vapor loss into the atmosphere is adversely affected and the collection efficiency at the vehicle may be reduced. For example, a station operating at 60% efficiency instead of the required 90% has the potential to emit an additional 450 gallons of liquid gasoline per year into the environment.” - Veeder-Root has developed ISD equipment to meet CARB requirements. - Veeder-Root recommends that incentives be developed, “to encourage and assist GDF owners and operators to install ORVR-compatible Stage II VRS and Vapor Recovery Monitoring Equipment that can help insure that the Stage II VRS are operating at or above the levels they were originally designed to meet.”

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### 63 Stakeholder Comment Summary Comment Detail EMCO EMCO stated that oversight inspections have improved Stage II efficiency. EMCO commented, “However, oversight inspections are very different animals than planned obsolescence programs. The [equipment component replacement] proposal sketched out in paragraph 1 page 25 of the Issues Paper is simply not realistic. Date stamping and replacing components on a regular basis regardless of any known problem is unduly burdensome to the gas station operators.”
ARID ARID noted that incentives for performing good housekeeping practices have not been present for GDF. ARID maintained that the use of an APCD and recovered product will give the GDF the proper incentive to ensure hardware is properly maintained and the vapor carrying components remain vapor tight. – ARID stated, “[t]he wise station owner will diligently maintain their APCD equipment with the confidence that their efforts and investment will be rewarded with saved product.” – ARID noted that continuous monitoring of UST pressure can alert a GDF of situations that warrant further investigation; a GDF can pinpoint the anomaly by examining typical leak source s, arranging a leak decay test, or arranging a detailed hardware inspection. – ARID suggested that useful monitoring information can be obtained with “macro” variables such as combined UST pressures and APCD run times; this type of monitoring is simple, elegant, robust, and cost-effective.



### K. Emissions Factors and Emissions Testing

As discussed in the Issues Paper, the current average AP-42 emissions factor information is almost 20 years old and does not always account for more recent changes in gasoline composition.

1. Comment Summary Three stakeholders and one equipment vendor commented on the need for new emissions factors. One stakeholder stated that they do not necessarily agree with API emissions factors and that they are working in conj unction with another partner on a test program to collect more information.

TCEQ agreed with EPA that there needs to be new emissions factor s for Stage I and II VRS. Wisconsin DNR and RSA noted a poten tial need for new VOC and HAP emissions factors for GDF. Wisconsin further suggested that EPA study and quantify fugitive emissions under various controlled and uncont rolled scenarios. RSA also commented that the emissions factor used to determine the spillage contribu tions for Figure 5 in the Issues Paper (Stage II VRS-only emissions levels) did not seem reas onable from CARB documents and Missouri DNR studies.

ARID suggested that more testing be done to determine emissions factors for IEE from combined use of vacuum-assist Stage II VRS and ORVR, UST vent breathing and emptying emissions without Stage II VRS and with and wi thout P/V valves, and fugitive emissions from Stage II VRS.

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### 64 CARB stated that they do not necessarily agree with the emissions factors determined from API testing. CARB noted that they are work ing together in conjunction with API and the Western States Petroleum Associ ation (WSPA) on a test program to collect more information. See section VI.C.

2. Discussion and Recommendations

Some of the variables known to affect em issions factors for GDFs include: ambient temperature, seasonal variation in gasoline Re id Vapor Pressure, ga soline throughput, vapor tightness of the GDF and VRS, and percentage of ORVR-equipped vehicles. We recommend updating the emissions factors based on all the data collected from stakeholders and additional emissions testing to be conducted by EPA and st akeholders. Only three emissions measurement tests were submitted by the stakeholders for traditional GDF, EPA is planning to conduct testing at two GDF, and Hertz is planni ng to conduct testing at their on -site GDF. These data include multiple emissions points in controlled and uncontr olled scenarios, and may be used to develop updated emissions factors. Based on continued disc ussions with stakeholde rs, it is clear that there is additional data that could be collected and included in these analyses.

Table 11. Emissions Factors and Emissions Testing Comment Summary

Stakeholder Comment Summary Comment Detail
CARB CARB stated that their staff does not necessarily agree with API emissions factors. CARB indicated that CARB and API are working together in conjunction with the WSPA on a test program to collect more information to help address differences in emissions data collected to date. TCEQ TCEQ indicated that they agree with the EPA regarding the need for new emissions factors for Stages I and II. TCEQ noted that allowing local inputs, such as liquid temperature and Reid Vapor Pressure, would be beneficial.

Wisconsin DNR Wisconsin DNR noted the need for new VOC and HAP emissions factors for GDFs. Wisconsin DNR suggested that EPA study and quantify fugitive emissions under various controlled and uncontrolled scenarios.

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### 65 Stakeholder Comment Summary Comment Detail RSA RSA stated that there is a potential need for new emissions factors for VOC and HAPs. RSA also commented that the use of 0.5 of the AP-42 values for spillage emissions for the ORVR vehicles and 1.0 of the AP-42 value for Stage II VRS seems unreasonable. Accurate values for the spillage must be used. RSA commented, “The HAPs emission factors should be related to the VOC emission factors relative to the composition of the gasoline and the temperature of the gasoline. CARB has done a number of studies analyzing SUMMA® canisters collected from various points in the vapor recovery systems to determine the relative concentrations of various components. MDNR has some similar data. The problem is that there is great variability of composition of gasoline, even the more strictly related RFG fuels. A good survey of data available should be made first to determine exactly what is appropriate for use for the systems and fuels being used in the areas of interest at the present and likely to be used in the next 10 years or so. It is also important to determine the actual emissions of the older ORVR vehicles upon fueling. It probably would be useful to do so me specific VOC and HAPs measurements for these since it may be that the distribution of HAPs in relation to total VOC will be different for the ORVR than the VRS (i.e., the adsorption profile may well be different from the vaporization profile).”
ARID ARID stated th at they support the need for field testing to accurately quantify refueling–related emissions. ARID indicated there needs to be more testing to determine emissions factors for incompatibility excess emissions from vacuum assist Stage II and ORVR, UST vent breathing and emptying emissions from the UST without Stage II VRS and with and without P/V valves, and fugitive emissions from Stage II VRS.



### L. Exemptions for Rental Car Facilities

1. Comment Summary One stakeholder requested a waiver from Stage II VRS requirements for rental car facilities whose vehicle fleet is comprised mostly of ORVR-equipped vehicles. Another stakeholder requested timely guidance from EP A on exemptions for rental car facilities dispensing 100 percent of their fuel to ORVR-equipped vehicles.

TCEQ suggested that EPA provide timely guida nce on exemptions for facilities, such as rental car facilities and car dealerships, disp ensing 100 percent of their fuel to ORVR-equipped vehicles.

Hertz requested a waiver from Stage II VRS. Hertz indicated that their current vehicle fleet is comprised of 99.3 per cent ORVR-equipped vehicles and that this percentage would approach 100 percent by July 2006.

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### 66 2. Discussion and Recommendations EPA is considering drafting and releasing a waiver guidance memorandum for rental car facilities for those facilities that can demonstrat e that a significant portion of their vehicles are ORVR-equipped, that a significan t portion of gasoline throughput is dispensed to ORVR vehicles, or that the emissions reductions achie ved with ORVR controls are equivalent to the emissions reductions achieved with Stage II VRS. Because the majority of vehicles fueled are new vehicles with ORVR controls, the refue ling emissions will be controlled by the ORVR canister. A similar waiver is also being considered for auto mobile manufacturing facilities.

Table 12. Exemptions for Rental Car Facilities Comment Summary

Stakeholder Comment Summary Comment Detail TCEQ TCEQ requested that EPA provide guidance on exemptions from rental car facilities. TCEQ recommended that EPA provide timely guidance on exemptions for rental car facilities and car dealerships that dispen se 100 percent of their fuel to ORVR-equipped vehicles. Hertz Hertz requested exclusion from Stage II VRS requirements because their vehicle fleet islargely comprised of ORVRequipped vehicles. Hertz stated that the widespread use definition should be applied to them . Hertz indicated that their vehicle fleet is co mprised of 99.3 percent ORVR-equipped vehicles and that this percentage will approach 100 percent by July 2006.



### M. Stage I and II Equipment and UST Emissions

1. Comment Summary

One stakeholder commented that active tank management with membrane processors is the proper way to address excess emissions from the UST. Two equipment vendors commented that controlling the pressure of the UST will prevent fugitive VOC emissions from the Stage II VRS system. Other stakeholders maintained that processors utilized by vacuum assist Stage II VRS actually increase emissions of some polluta nts (referring to incinerator controls). Two stakeholders suggested that CARB’s approach to estimating fugitive emissions actually penalizes a VRS that is vapor tight. One equipment vendor stated that required ORVR compatible Stage II VRS were more efficient and that its compatib le equipment reduces emissions and maintains UST pressure. Another stakeholder suggested that P/V valves should be placed on all UST
vents.

The Missouri DNR suggested that a vacuum assist Stage II VRS that utilizes a combustion processor or incine rator actually increases emissi ons of polycyclic aromatic hydrocarbons (PAHs), as well as greenhouse gases, and nitrogen oxides; these pollutants would not have been emitted without the addition of an incinerator. RSA agreed with the Missouri DNR regarding an increase in emissions from utilizing a processor. RSA stated, “It does not make sense to create a problem when trying to so lve another especially wh en there are other less polluting means available.” Missouri DNR also s uggested that P/V valves be installed at all permitted Stage I GDF.

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### 67 Costco Wholesale stated that prior to instal ling a membrane processor, their UST vented almost all day due to the incompatibility of ORVR and their vacuum assist VRS; after the membrane processor was activated, the vent ep isodes ceased. Costco also contends that membrane processors work with all UST systems (controlled and uncontrolled) and regardless of VRS type.

API commented that vapor processors are e xpensive. Both API and STI stated that CARB’s method to calcul ate fugitive emissions has changed and now penalizes an UST system for being vapor tight. STI indicated that CARB and WSPA have drafted a testing protocol to help resolve this issue bu t as of yet, the protocol has not been finalized.

Healy stated that ORVR compatible Stage II VRS are more efficient. Healy indicated that their compatible nozzles reduce emissions a nd that their Clean Air Separator (and UST addon APCD) acts as a pressurization system.

VST suggested that by keeping the pressure of the UST below positive pressure, fugitive emissions from the UST would be minimized. VS T further stated that they have several UST control systems, such as a membrane processor, that will control the pressure of the UST and recover gasoline vapor.

EMCO maintained that P/V valves should be placed on all UST vents and that many vacuum assist Stage II VRS require an UST add-on APCD to deal with ORVR incompatibility.

ARID contended that an APCD is the key f actor in reducing the overall pressure of the UST. ARID also stated that a tight VRS system resulted in higher UST vent emissions, while a leaky VRS system resulted in higher fugitive emissions.

2. Discussion and Recommendations

We believe that VOC emissions from UST vents and leaks from USTs may be a major emission point at GDF, and as ORVR-equipped ve hicles become more common, the emissions from UST at GDF with vacuum assist Stage II VR S are likely increasing. However, many of the stakeholders have not identified UST vents as a large source of VOC emissions. There have been some recent studies that indicate there are vapor leaks from USTs with resultant MTBE groundwater contamination. Some of the UST st aff in the States (and at EPA’s Office of Underground Storage Tanks) believe that Stage II VRS, especially the vacuum assist systems, may be responsible for the vapor leaks. OUST has a current project unde rway to determine the causes and develop prevention meas ures for these vapor leaks.

There are few data showing VOC emissions from USTs. Many certification tests have been conducted in California, yet there are lit tle emissions measurement data for UST vents (CARB’s test procedure calculated UST fugitive emissions based on pressure data). Because CARB’s EVR program has requirements to contro l both tank pressures and UST vent emissions, the current CARB certification testing may not indicate any US T emissions problems. API’s comments seem to indicate that any UST emissi ons would be insignific ant; however there are some data that have been supplied from vendors that show positive tank pressures lead to VOC UST emissions. Several vendors have suggested that GDF are emitting significant quantities of gasoline vapors and could save up to $2,000 per month by collecting these vapors.

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### 68 We have observed one emissions measuremen t test in Florida in December 2004 where the tank pressure was greater than 3 in. w.c. for th e entire test period. When the pressure reached 3 in. w.c., the P/V valve popped open and vented em issions to the atmosphere. The P/V valves are required by Stage I (gasoline tank refilling) provisions in ozone nonattai nment areas. If tank pressures are positive, then there will be fugi tive leaks either thr ough small cracks, improper fittings, etc. or through the UST vent.

As mentioned above, staff that work with US Ts regularly think th at pressurized tanks lead to vapor leaks. Gary Lynn of the New Hamp shire DEP said that he thinks all USTs leak. 58 46



### We recommend the use of P/V valves on UST vents nationwide for additional HAP control.

Table 13. Stage I and II Equipment and Underground Storage Tank (UST) Emissions Comment Summary

Stakeholder Comment Summary Comment Detail
Missouri DNR Missouri DNR stated that vacuum assist Stage II VRS that use a combustion processor (incinerator) increase emissions. Missouri DNR also suggested that the EPA require permitted Stage I GDF to install P/V valves. – Missouri DNR suggested that combustion processors increase emissions of PAHs as well as green house gases, and nitrogen oxides that would not otherwise be emitted. – Missouri DNR stated that Stage I is inexpensive to install and maintain, and would significantly reduce the VOC, HAPs, HC and MTBE issues.

Costco Costco indicated that they believe membrane technology virtually eliminates vent and fugitive emissions from GDF and is the right way to manage UST pressure. – Costco stated, “[W]e believe that membrane processors work with all US T systems, whether Stage II is balance, vac assist, or ab sent. Allowing tank systems to ‘breathe’ to atmosphere (as all do without tank pressure management, especially at night) is to face the uncomfortable decision of how much pollution is OK. We prefer no pollution at all if the technology is available to prevent it. With membranes, virtually all vent and fugitive emissions are eliminated.” – Costco commented, “We do not believe there is any long-term future for Stage II vapor recovery, but we feel that all stations should be built to actively manage their tank pressures to prevent venting.” API API stated that vapor processors are expensive. API also stated that the approach CARB uses to calculate fugitive emissions has changed significantly and now penalizes an UST system for being vapor tight. API criticized CARB’s EVR cost data for vapor processors. API stated that th is data is unrealistically low.

58 Teleconference with EPA, February 2005.

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### 69 Stakeholder Comment Summary Comment Detail
STI STI stated that CARB’s methodology for estimating fugitive emissions penalizes Stage II VRS that are more vapor tight. STI indicated that CARB and the WSPA have drafted a testing protocol to help resolve this issue and that the protocol has not yet been finalized.

Healy Healy indicated that required ORVR compatible Stage II systems are more efficient. – Healy stated that their Stage II VRS nozzles reduce emissions through reduced spillage, fewer drips, no “spitting”, clean fills at 10 gallons per minute; the nozzles also reduce “topping off” spills and potential for fires. – Healy provided data to de monstrate that their Clean Air Separator prevents the ullage space pressure from exceeding CARB’s maximum av erage positive pressure of 0.25 in. w.c.
VST VST maintained that controlling the pressure of the tank (and keeping it below positive pressure) will prevent fugitive emissions of VOCs from the system. – VST commented on UST emissions and how they result from the pressure of the tank and fuel delivery system. – VST has several systems that will control the pressure in the tanks and recover the VOC emissions such as a membrane processor. VST st ated that new technologies will provide the ability to utilize ORVR systems and Stage II systems simultaneously.
RSA RSA maintained that vacuum assist Stage II VRS equipped with processors do not solve the pollution problem because the processor causes emissions of other pollutants that would not have been emitted without the processor. RSA stated, “It does not make sense to create a problem when trying to solve anothe r especially when there are other less polluting means available.”

EMCO EMCO stated that P/V valves should be placed on all UST vents. EMCO also noted that vacuum assist Stage II VRS often require add-on control devices to deal with the incompatibility emissions problem. EMCO referenced a processor cost of $30,000.

ARID ARID stated that an APCD is key to reducing the overall UST tank pressure. – ARID commented that an excess vapor generation rate is present in the UST and that excess vapor within the UST will result in a pressure increase; a tight system will yield higher vent emissions, while a leaky system will yield higher fugitive emissions. ARID notes that an air pollution control device reduces the overall storage tank pressure while at the same time capturing and recovering vent emissions. – ARID stated that testing performed at one of their test sites demonstrated that their PERMEATOR significantly reduced fugitive emissions; the UST vent without the PERMEATOR on resulted in fugitive emissions by more than 200 times.

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### 70 N. MTBE Groundwater Contamination from UST

1. Comment Summary One stakeholder provided documentation that contends the UST leaks are from vapors that are released through the innate pressuriza tion of the USTs by the vacuum assist Stage II VRS. Two stakeholders commented that with the removal of Stage II VRS, contamination of groundwater caused by fugitive emissions from the pressurized VRS at GDF would cease. One stakeholder suggested that the MTBE issue is a good example of what can go wrong while fixing one problem but not paying attention to the eff ects of the proposed solution. One equipment vendor stated that EPA should address the MTBE problem by requiring the use of CARB certified ORVR compatible Stage II VRS.

The Missouri DNR stated that New Hamp shire is experiencing MTBE groundwater contamination. Missouri DNR submitt ed an article that maintained that the leaks are caused by vapors that are released through the innate pre ssurization of the UST by vacuum assist Stage II VRS.

Both API and BP stated that the removal of Stage II VRS in favor of ORVR would help minimize groundwater contamination. API further st ated that they have a group of experts that are examining the groundwater contamination issue. API and BP recommended that more research be done to identify the significance and associated circumstances of groundwater contamination before any widespre ad regulatory actions are taken.

Healy stated that New Hampshire has been monitoring a large percentage of Stage IIequipped GDF to examine the extent of gr oundwater pollution. He indicated that New Hampshire’s findings indicate that 129 out of 300 GDF show unacceptable levels of MTBE. Healy suggested that th e contamination was caused from vacuum assist Stage II VRS due to ORVR incompatibility. Healy r ecommended that EPA make every e ffort to address this issue by requiring GDF to use CARB-certified ORVR compatible Stage II VRS.

2. Discussion and Recommendations UST fugitive emissions are caused by pressuri zation of USTs. While fugitive emissions may occur when pressurization occurs for either balance or vacuum assist, balance systems seem to minimize the amount of time the UST is at positive pressure and therefore may minimize fugitive emissions. Vacuum assist systems, however, may cause pressurization of the UST during operating hours in addition to off hours. Measures that can be taken to reduce the pressurization of UST vacuum assist systems should be studied and considered. These may include some components of the EVR program that make vacuum assist Stage II VRS compatible with ORVR vehicles. The use of MT BE as an oxygenate in gasoline has resulted in detections of MTBE in drinking wa ter. In the past, it was frequen tly leaking USTs or spills that caused the contamination of soil and water at and near the GDF site. However, with implementation of stricter UST regulations, the c ontamination of soil and water is thought to be caused by vapor leaks from the UST. The CAA requires that RFG contain 2 percent oxygen by weight, and over 85 percent of RFG contains MTBE and approxi mately 8 percent contains

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### 71 ethanol. 56

47 

### Some States have banned MTBE use in gasoline, and MTBE may be replaced in favor of other oxygenates such as ETBE , TAME, TAEE, DIPE, ethanol, and TBA. 57

48 

### The changes in the gasoline composition may eliminat e the MTBE in gasoline, however, because the other oxygenates have similar but not identical ch emical characteristics, they may simply result in a shift in the contaminant compound found in soil and groundwater near GDF. 56 

### The effect of the other oxygenates may not yet be known but f ugitive emissions certainly should be minimized as a precaution regardless of the next gene ration of oxygenates. In any case, EPA could implement requirements to minimize fugitive emi ssions, such as increased testing of vapor tightness and reducing pressurization of tanks, es pecially from vacuum assist Stage II VRS.

Table 14. MTBE Groundwater Contamin ation from UST Comment Summary

Stakeholder Comment Summary Comment Detail
Missouri DNR Missouri DNR indicated that New Hampshire is experiencing MTBE ground water contamination. Missouri DNR provided an article that contends that the leaks are caused by vapors that are released through the innate pressurization of the UST by the vacuum assist VRS. API API stated that discontinuing Stage II VRS in favor of ORVR will help eliminate groundwater contamination issues. API further stated that they have a group of experts working on the groundwater contamination issue and believe more needs to be done to identify the significance and circumstances related to groundwater contamination before any widespread regulatory actions are taken. API commented that there have been some isolated incidents of groundwater contamination allegedly from UST system vapor leaks. API stated that some recent papers have preliminary data to bolster such allegations; however these papers also acknowledged the need for further research on this
matter.

BP BP stated that with the removal of Stage II VRS in favor of ORVR, contamination of groundwater caused by fugitive emissions from the pressurized VRS at GDF would cease. BP also acknowledged the need for further research on the groundwater contamination issue. BP commented that API an d member companies are concerned about the allegation that GDFs are causing MTBE contaminatio n of groundwater; they are currently working on th is issue. BP also cautioned, “... given that this forum includes regulators and rule makers, more needs to be done before taking any widespread regulatory actions.”

RSA RSA stated that the MTBE issue is a good example of what can go wrong when not addressing all the potential pollution problems while trying to solve another problem. RSA commented, “It does not make sense to create a problem when trying to solve another especially when there are other less polluting means available.”

56 Achieving Clean Air and Clean Water: The Report of the Blue Ribbon Panel on Oxygenates in Gasoline. EPA Publication No. EPA420-R-99-021. September 15, 1999.

57 Predicted Ground Water, Soil and Soil Gas Impacts from U.S. Gasolines, 2004 First Analysis of the Autumnal Data. EPA Publication No. EPA 600/R-05/032. February 2005.

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### 72 Stakeholder Comment Summary Comment Detail Healy Healy shared information from New Hampshire that indicated that some GDF are showing levels of MTBE that are unacceptable. Healy suggested that a vacuum assist Stage II VRS will most likely be polluting the soil and ground water due to ORVR vehicle refueling. Healy stated that EPA should apply every effort to address groundwater contamination by requiring the use of CARB certified ORVR compatible Stage II VRS. - Healy stated that New Hampshire has been monitoring a large percentage of Stage II equipped GDF to determine the ex tent of groundwater pollution. New Hampshire’s findings showed that 129 out of 300 GDF showed unacceptable levels of MTBE. - Healy further stated that almost all the GDFs with unacceptable MTBE levels were vacuum assist Stage II VRS and no ORVR compatible systems were on the list. - Healy also indicated that studies performed by the University of California, Davis confirmed that MTBE vapor releases are strongly associated with vacuum assist Stage II VRS. - Healy maintained that the source of this pollution is a build-up of positive pressure in the ullage space of the UST.



## VI. Emissions Monitoring and Testing Data
A. Previous Data Collected by EPA

Prior to the public meeting in September 2004, EPA collected and analyzed data from several studies conducted to evaluate excess em issions from the refueling of ORVR-equipped vehicles at GDF with Stage II VR S. Each data source and the te sts conducted are discussed, the key results and conclusions presented in the da ta sources are summarized, and a large summary table of all the data is presen ted. The table is organized to identify the actual measurements conducted and results reported in the study.

Emissions may occur (and may be measured or calculated) at numerous points within the system. CARB’s Stage II VRS certificat ion test method, TP-201.2, addresses making measurements or calculating emissions from se veral points in the system. The measurement points include:

1. Emissions at nozzle/vehicle interface (“fillpipe” emissions),

2. VOC’s returned through the vapor passage of the hose,

3. Emissions from the UST P/V valve,

4. Emissions from the assist processor ( not applicable in these studies), and

5. Calculated pressure-related fugitives based on UST pressure measurements.

(EPA defines refueling emissions as the ev aporative loss emissions during refueling, as well as emissions from spillage. For the purposes of the discussions below, spillage emissions are not addressed and any reference to “refue ling emissions” does not include spillage. The emissions data generally are reported as lb VOC/ 1,000 gallons dispensed. In the actual reports,

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### 73 both lb /1,000 gallons dispensed and grams of VO C per gallon (g/gal) dispensed were used; this often got confusing as the author s switched back and forth. The data in the summary table are presented in lb/1,000 gallons.)

1. CARB’s Preliminary Test Report, June 1999 (GDF) These tests were conducted in August/Septemb er 1998 at two GDF with vacuum assist Stage II VRS to quantify excess emissions from va por growth; each GDF had a different type of vacuum assist system. At the ti me of the tests, these two types of systems represented 80 percent of VA systems in CA and dispensed 55 percent of the gasoline purchased. The emissions from the Stage II VRS were determined from dir ect measurement of P/V valve emissions and calculation of fugitive emissions based on UST pr essure readings. CARB did not measure or attempt to quantify the emissions at the nozzle/fill pipe interface (“fillpipe emissions”) during the study. The testing consisted of two phases: (1 ) “baseline” normal operations, and (2) simulated ORVR. Because ORVR vehicles we re not prevalent when the tests were done, the refueling of ORVR was simulated by modifying the dispensers to ingest ambient air; an ORVR population of approximately 40 to 45 percent was simulated.

Negligible emissions were emitted from the P/V valve, and UST fugitive emissions occurred due to leaks. Excess emissions, wh ich are based on pressure-related fugitive calculations, also occurred when refueling wi th the simulated ORVR scenario. Table 15 includes a detailed summary of the data for each emissions point. CARB used these data to establish excess emissions factors for refueling of ORVR-equipped vehicles in combination with vacuum assist Stage II VRS of 0.86 lb/1000 gal fo r the Gilbarco system and 0.06 lb/1000 gal for the Dresser Wayne system with the P/V valve in place. Operation without the P/V valve was considered atypical and these data were not used in CARB’s final analyses.

2. Phase 1 of API’s ORVR Compatibility Study (GDF)

These tests were conducted at a GDF in Califor nia with a vacuum a ssist (Gilbarco) Stage II VRS to determine the amount of excess emissi ons from refueling ORVR-equipped vehicles. The tests were conducted using summertime RFG (RVP 7.0 psi) and two types of nozzles. In Test 1, refueling was conducted w ith standard vacuum assist nozzl es for a 100-car matrix. Test 2 also included a 100-car matrix, how ever, nozzles with “miniboots” were used to limit the influx of ambient air during refueling. The testi ng was conducted using CA RB’s certification test procedure TP201.2. These data are summarized in Table 15.

The overall pressure-related emissions for Test 1 (with the standard vacuum assist nozzle) were 1.38 lb/1,000 gal and for Test 2 (with the miniboot nozzles) were 0.494 lb/1,000 gal. Therefore, the miniboot showed a reduc tion in pressure-related emissions of 0.886 lb/1000 gal (or a 64 percent reduction) . The effects of ORVR vers us non-ORVR vehicles on UST pressures and UST vent emissions due to interfer ences from vehicles simultaneously refueling at other pumps connected to tanks could not be differentiated (i.e., quantified).

The emissions from the vehicle fillpipe/nozzle interface were measured, and the test results showed that ORVR controls reduced em issions from the interface by 0.31 lb/1,000 gal. Therefore, it was concluded that the value CARB determined for the excess emission factor due

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### 74 to vapor growth in the UST (0.86 lb/1,000 gal, see above) should be offset accordingly; i.e., total excess emissions should be 0.86 lb/1,000 gal - 0.31 lb/1,000 gal, or 0.55 lb/1,000 gal.

3. Phase 2 of API’s ORVR Compatibility Study (Outside)

These tests were outdoor tests conducted at a research facility using a 3,000 gal UST that contained 1,000 gal of gasoline. The gasoline was a summer grade oxygenated fuel with a RVP of 7.8 psi. Six refueling tests were conducted on 3 vehicles (two with ORVR and one without ORVR). The UST emissions from the P/V valv e and the pressure-related fugitives were measured; the system was demonstrated to be leak free prior to testing, and a fugitive leak rate was simulated, and controlled, using a calibrated n eedle valve. The fugitive emissions measured while refueling ORVR and non-ORVR vehicles were compared to determine the incompatibility excess emissions. In addition, the pressure-relat ed fugitives were measured and compared to those predicted by the CARB calculations.

For the standard nozzle tests, the pressure-rel ated excess emissions were calculated to be 0.72 lb/1000 gal. The fillpipe emissions fo r ORVR-equipped vehicles were 0.39 lb/1,000 gal less than for non-ORVR vehicles (represents a 91 percent reduction). The adjusted (“net”) ORVR excess emissions were 0.33 lb/1,000 gal (i.e ., pressure-related excess emissions minus the savings at the fill pipe, equal to 0.72-0.39). If these corrections are used on the data generated from MOBILE6, the correct excess emission fact or to use would be 0.42 lb/1,000 gal (not 0.33 lb/1,000 gal) because MOBILE6 already accounts fo r some of the fillpipe reductions achieved by ORVR-equipped vehicles by using a 98 percent cont rol efficiency for ORVR rather than the 95 percent efficiency used for Stage II VRS.

For the miniboot nozzle tests, the pressure-relat ed excess emissions were calculated to be zero (-0.008 lb/1000 gal). It was shown that the fillpipe emissions for ORVR-equipped vehicles were less than for non-ORVR vehi cles. The adjusted (“net”) OR VR excess emissions were -0.39 lb/1000 gal; i.e., a decrease in emissions [zero pressure-rela ted excess emissions minus the savings at the fill pipe is equal to a reduction of 0.39 lb/1000 gal].

4. Phase 2 of API’s ORVR Compatibility Study (SHED) The emissions testing was conducted in S ealed Housing for Evaporative Emissions (SHED). A total of 36 refueling tests using procedures similar to the federal ORVR certification test were conducted for three vehicles (two with ORVR and one non-ORVR). During these tests, the impacts of the RVP, temperature, the A/L ratio, and the type of ORVR equipment were determined.

First, the ORVR performance was checked (val idated) with a baseline certification. The tests were conducted to investigate the impact of several factors, including:

(1) RVP: The tests were conducted with an RVP of 7.1 and 7.8 psi;

(2) Temperature difference: Three summertime temperature scenarios were used: one vapor growth and two vapor shrinkage scenar ios. The scenarios included varying the temperature of the fuel dispensed and th e temperature of the vehicle gasoline tank.

(3) A/L ratios: standard no zzle and the miniboot.

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### 75 (4) Type of ORVR equipment: recirculation or not.

The fillpipe emissions for ORVR and non-ORVR vehicles fall w ithin the range of values measured in the Phase 1 and Phase 2 (outdoor te sts). The fillpipe emissions for ORVR-equipped vehicles were 0.46 lb/1000 gal less than for the non-ORVR vehicles. For ORVR-equipped vehicles, fillpipe emissions were not sensitive to changes in the RVP, the temperature differences between the vehicle tank and the dispensed gasoline, and the A/L ratio. There was, however, a positive correlation between the fillpipe emissi ons and the vehicle tank temperature.

For non-ORVR vehicles, there was a positive co rrelation of the fillpipe emissions with the RVP, a negative correlation of the fillpip e emissions with A/L ratio, and a negative correlation of the fillpipe emissions with delta T, as assumed in MOBILE 6. The fill-pipe emissions for the miniboot (A/L ratio of 0.95) were greater than (approximately double) the fillpipe emissions with the standa rd nozzle (A/L ratio of 1.15). Th e emissions are greater for the vapor growth scenario (temperature of the fuel in the vehicle gasoline tank is less than the temperature of the fuel being dispensed). Fo r the ORVR-equipped vehicles, the puff emissions (the puff of emissions when the gas cap is remo ved) are the same order of magnitude as the fillpipe emissions; the same is true to non-ORVR vehicles.

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### 76Table 15. Summary of Previous Data Collectedby EPA: Test Data for Excess Emissions.Data sourceUnit type/test conditionsFillpipeemissions(a) (b)P/V Valveemissions(c)Calculatedpressure -relatedfugitives(leaks)(d)Totalpressure -relatedemissions(e = c+d)Totalrefuelingemissions(f =b+c+d)Excessemissiondue toORVRincomp. (g)ORVRemissionreduction atfill pipe(h)Adjustedexcessemissiondue toORVRincomp.(i)VRSreturn line,HC conc,%(j)NotesGilbarco VABaseline:0.396CARB [1]Scenario 1Gilbarco VAORVR:Not measured Negligible0.7820.386Notmeasured(p)Dresser WayneBaseline:0.028CARB [1]Scenario 2Dresser WayneORVR:Not measuredNegligible.0.05240.0244Notmeasured(p)Dresser Wayne(withoutP/V valve)Baseline:0.026 0.026CARB [1]Scenario 3Dresser Wayne(withoutP/V valve)ORVR:Not measured Negligible0.289 0.2890.263Notmeasured(p)CARB Gilbarco VADresser Wayne0.860.06CalculatedfromScenarios1 & 2 (p)Gilbarco VAStandard nozzle(OPW 11VA1);non-ORVR0.4232 %API [2]Test 1Gilbarco VAStandard nozzle(OPW 11VA1);ORVR vehicles0.110.8230.5571.38Not measured0.31(73% lessthan nonORVR)11%Gilbarco VAWith “miniboot”(OPW 12VW);non-ORVR0.42 approx40%API [2]Test 2Gilbarco VAWith “miniboot”(OPW 12VW);ORVR vehicles0.110.0080.4840.494Not measured 0.31(73% lessthan nonORVR)approx 17%Minibootreducespressurerelatedfugitives0.886lb/1000gal (64%reduction)

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### 77Data sourceUnit type/test conditionsFillpipeemissions(a) (b)P/V Valveemissions(c)Calculatedpressure -relatedfugitives(leaks)(d)Totalpressure -relatedemissions(e = c+d)Totalrefuelingemissions(f =b+c+d)Excessemissiondue toORVRincomp. (g)ORVRemissionreduction atfill pipe(h)Adjustedexcessemissiondue toORVRincomp.(i)VRSreturn line,HC conc,%(j)NotesOutdoor test 5;Standard nozzlenon-ORVR1.53(check)0 (Measured)0.022(Measured)0.022NA 33.2 check runnumbertable 6-4Outdoor test 1;Standard nozzleORVR vehiclewith recirc.0.024 0 (Measured)0.918(Measured)0.9180.896 3.0 CARB:0.86Outdoor test 3;Standard nozzleORVR vehiclewithout recirc.0.026(check)0 (Measured)0.229(Measured)0.2290.207 0.6 check runnumbertable 6-4API[3]Standard nozzleORVR vehicle,wgt. average(calculated)0.025 0.745 (k) 0.72 (k) 0.39 (m)(91% lessthan nonORVR)0.33 2.4(RTI)Note: fillpipereductionscalculatedfor thesetests= 1.505API[3] Outdoor test 6;Miniboot;non-ORVR2.11 0 (Measured)0.011(Measured)0.011NA 38.8Outdoor test 2;Miniboot;ORVR vehiclewith recirc.0.002 0 (Measured)0.004(Measured)0.004- 0.007 5.4Outdoor test 4;Miniboot;ORVR vehiclewithout recirc.not available 0 (Measured)0.002(Measured)0.002- 0.009 7.6Miniboot;ORVR vehicle, wgtaverage(calculated)0.003 (k) -0.008 (k) 0.39 (m)(91% lessthan nonORVR)-0.39i.e., zero6.0(RTI)Note: fillpipereductionscalculatedfor thesetests= 2.1

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### 78Data sourceUnit type/test conditionsFillpipeemissions(a) (b)P/V Valveemissions(c)Calculatedpressure -relatedfugitives(leaks)(d)Totalpressure -relatedemissions(e = c+d)Totalrefuelingemissions(f =b+c+d)Excessemissiondue toORVRincomp. (g)ORVRemissionreduction atfill pipe(h)Adjustedexcessemissiondue toORVRincomp.(i)VRSreturn line,HC conc,%(j)NotesSHEDStandard nozzleNon - ORVR0.32SHEDStandard nozzleORVRwith recirc.0.057SHEDStandard nozzleORVRwithout recirc0.007API[4]SHEDStandard nozzleORVR Vehiclewgt avg. (calc)0.045 0.275API[4] SHEDMini-bootNon - ORVR0.69SHEDMini-bootORVRwith recirc0.054SHEDMini-bootORVRwithout recirc0.007SHEDMini-bootORVR VehicleWgt Avg. (calc)0.041 0.649AverageforStandard&miniboot= 0.46(91% lessthan nonORVR)

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### 79Data sourceUnit type/test conditionsFillpipeemissions(a) (b)P/V Valveemissions(c)Calculatedpressure -relatedfugitives(leaks)(d)Totalpressure -relatedemissions(e = c+d)Totalrefuelingemissions(f =b+c+d)Excessemissiondue toORVRincomp. (g)ORVRemissionreduction atfill pipe(h)Adjustedexcessemissiondue toORVRincomp.(i)VRSreturn line,HC conc,%(j)NotesSHEDVehicle 3Non - ORVRPUFF (n)0.321SHEDVehicle 1ORVRwith recircPUFF (n)0.030API [4]SHEDVehicle 2ORVRwithout recircPUFF (n)0..007API [4] Vehicle 1: ORVRCertification0.017[0.008]API[4] Vehicle 2: ORVRCertification0.002[0.001]EPA Standard forORVR0.44[0.20](Includesspillage)

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### 80Data sourceUnit type/test conditionsFillpipeemissions(a) (b)P/V Valveemissions(c)Calculatedpressure -relatedfugitives(leaks)(d)Totalpressure -relatedemissions(e = c+d)Totalrefuelingemissions(f =b+c+d)Excessemissiondue toORVRincomp. (g)ORVRemissionreduction atfill pipe(h)Adjustedexcessemissiondue toORVRincomp.(i)VRSreturn line,HC conc,%(j)NotesNOTESa Refueling emissions = fill pipe displacement + spillageper EPA definition; spillage not addressed in these datab Fill pipe emissions = fill pipe displacement emissionsc P/V vent emissions = emissions from UST vent pressure/vacuum valved Calculated pressure related (PR) fugitive emissions from VRS leaks per CARB calculation methode Total pressure related emissions = P/V vent emissions + PR fugitivesf Total refueling emissions = total refueling emissions by CARB test method = Fill pipe displacement + P/V vent emissions + calculated PR fugitives (spillageestimated separately or byperformance standard of nozzle?)g Excess emissions due to ORVR incompatibility= total pressure related emissions forORVR - total pressure related emissionsfor non-ORVR vehicles. Note: the API report refers to excessemissions of pressure-related fugitives separately from P/V emissionsh ORVR emission reductions at fill pipe = measured fill pipe displacement emissions for non-ORVR vehicles - measured fill pipedisplacement emissions for ORVR vehiclesi Total adjusted excess emissions= pressure related excess emissions due to ORVR incompatibility - ORVR emissions reductionsachieved at fill pipeNote: the API report refers to thisas “total incompatibility emissions”j Average hydrocarbon concentration in the VRS return line.k Weighted average of ORVR with and without recirculation; assumes 75% of ORVR vehicles have recirculation.m Average of Phase 1 (in-field) tests and SHED testsn PUFF = puff of emissions that occur when gas cap is removed; measured quantity normalized to gallons dispensedp Measured values are from test simulation of 40 to 45% ORVRvehicles; calculated emissions factors are extrapolated; dividemeasured Gilbarco value by 0.45;divide measured Dresser Waynevalue by 0.39 [CARB Enhanced Vapor recoveryISOR, February 2000, Appendix D; CARB Enhanced Vapor Recovery Technology Review, October 2002]NA = Not ApplicableAll emission units are lb/1000 gals dispensed or [g/gal] unless otherwise noted.

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### 81 B. Data Provided by Stakeholders

Several stakeholders provided monitoring and te sting data to assist us in understanding: (1) the sources of emissions at GDF, and (2) th e impact UST pressure has on emissions at GDF. We received data from multiple States, GDF operators, and equipment vendors. We also received data for vehicle fueli ng operations at automobile manufact uring facilities. These data included:

# Balance Stage II VRS, with a P/V valve, with no UST add-on APCD;

# Balance Stage II VRS, without a P/V valve, with no UST add-on APCD;

# Vacuum assist Stage II VRS with and without an UST add-on APCD;

# Vacuum assist Stage II VRS with and without an P/V valve; and

# No Stage II VRS, with a P/V valve, and no UST add-on APCD (i.e., Stage I scenario).

We did not receive data for a scenario with:

# No Stage II VRS and no P/V valve; or

# For no Stage II VRS, with a P/V valve, and with an UST add-on APCD. The data received are summarized below, includ ing the testing scenarios, the test data, and related conclusions. Some data consisted primar ily of parameter operating data and some data included emissions testing data as well. Each set of data provided information on one or more of the various emissions points from Stage II operati ons. Additional informa tion is provided in Appendix A for each data set.

1. California GDF Testing, Site 1

The test was conducted to conclude whet her an UST vent add-on APCD (i.e., a processor) would be necessary on a balance Stage II system to be compliant with the EVR UST pressure requirements (CP-201). The operating conditions of the GDF were monitored over a 36-day test period during February and March in California, and fuels with different RVP were in use over the time period. The February winter fuel had a RVP of 13 psi and the March fuel had a RVP of 9 psi. No emissions measurement testing was conducted. The GDF shuts down every night for 6 hours. The gasoline throughpu t was 41 percent to ORVR-equipped vehicles, and the percentage of ORVR-equi pped vehicles was 42 percent.

Stage II balance VRS, with P/V valve, no UST vent add-on APCD

. The system was at negative pressure for the majority of the test period and remains at negative pressure for long periods. The system passed weekly pressure decay tests, indicating the system was vapor tight. There are few to no periods at 0 in. w.c. (significant time at 0 in. w.c. would indicate leaks). Some positive pressure periods were seen during the testing but the frequency, magnitude, and duration were low. Du ring the 36-day testing period, the CARB daily average pressure limit and the daily hourly ma ximum pressure were exceeded on a few days; however, the 30-day rolling averag e pressure met the CARB limits. The data are summarized in Table 16. The test demonstrates that the balance system meets th e pressure profile requirements

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### 82 of CARB’s EVR CP-201, without the use of an US T add-on APCD (i.e., processor). In addition to meeting the CARB EVR pressure requirements, the UST pressure never exceeded 3 in. w.c. during the testing period, so the UST vent never opened. The V/L ratios for each fueling point over the 36-day period ranged from 0.71 to 1.0.

Additional analysis was conducted to compare the UST pressures for the two RVP. The analysis was conducted on a subset of data, specifically for those shut down hours when no fueling is being conducted at the GDF. For th e shutdown periods only, th e 30-day rolling daily average was 0.35 in. w.c. for RVP of 13 psi and was 0.055 in. w.c. for RVP of 9 psi. The 30-day rolling average hourly maximum pressure was 2. 4 in. w.c. for RVP of 13 psi and was 0.51 in. w.c. for RVP of 9 psi.

Table 16. Pressure Data for Balance Stage II VRS Without an UST Add-on APCD

Based on RVP

Parameter Test period over February 1 through

March 21, 2005 Exceeded, days CARB limit High RVP (13 psi) Low RVP (9 psi)
All Data a CARB daily average P, in. w.c. +0.04 3 +0.25 in. w.c. NA NA

30-day rolling average hourly maximum P, in. w.c. +0.32 2 +1.5 in. w.c. NA NA

Average V/L Ranged from 0.71 to 1.0
Calculated UST emissions from positive P periods 7 lb HC during testing period; extrapolated annually to 48 lb/yr.

Subset of data
For GDF shutdown periods only, daily average P, in. w.c. NA NA NA +0.35 +0.055

For GDF shutdown periods only, 30-day rolling average hourly maximum P NA NA NA +2.4 +0.51

a Minus data from 13 days (February 16-28) prior to failed leak decay test.



### 2. California GDF Testing, Site 2

This test was conducted to determine whethe r the ORVR-compatible vacuum assist Stage II VRS and an UST add-on APCD are EVR co mpliant. The UST add-on APCD is an expandable bladder that accepts vapor from th e UST during positive pressure periods. The operating conditions of the GDF were monitore d in January and August 2004. No emissions testing was conducted. The GDF sh uts down each night. The percen tage of ORVR vehicles is not known, although it should not matter for an OR VR-compatible system. The daily average V/L ratio at the two pumps for the January ti me period ranged from 0.95 to 1.1 over the test period. A summary of the operating data and po ssible emissions implications is shown in Table 17.

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### 83 ORVR-compatible vacuum assist Stage II VRS, with P/V valve, without UST add-on APCD. 

### Without the add-on APCD (August 11-17 data), the UST pressures ranged from approximately -9 in. w.c. to +3 in. w.c. Du ring operating hours when the GDF was dispensing fuel from the UST, the significant negative UST pressures were maintained. During nighttime hours when the GDF was closed and not operatin g, there was consistent pressure increase, indicating vapor growth. The pressures during o ff-hours were often above 0 in. w.c., indicating pressurization of the tank and possible fugitive emissions. The pressures rose to +3 in. w.c. on some nights, indicating P/V valve venting and UST vent emissions and UST fugitive emissions as well.

ORVR-compatible vacuum assist Stage II VRS, with P/V valve, with UST add-on APCD, and with a simulated fugitive leak. 

### With the add-on APCD and a simulated fugitive leak, pressures ranged from -8 in. w.c. to approximately 0 in. w.c. There were a few momentary spikes in pressure (as high as +4.5 in. w.c.) with return to 0 in. w.c. During overnight hours, there was consis tent pressure increase, indicating vapor growth. There are minimal episode s above 0 in. w.c. because the UST is vented to the flexible bladder at +0.15 in. w.c. (If th e Clean Air Separator was not in place, significant positive pressures could not be maintained due to the leak that was simulated during this testing scenario.) During operating hours , the UST pressures decreased to negative pressures, however, with the simulated leak, not as much vacuum was pulled on the UST (i.e ., the pressures did not appear to be as negative as show n in the “tight” UST data above).

ORVR-compatible vacuum assist Stage II VRS, with P/V valve, and with UST add-on APCD. 

### With the UST add-on APCD, the pressure ranged from approximately -9 in. w.c. to just above 0 in. w.c. During operating hours when th e GDF was dispensing fuel from the UST, the UST pressures decrease and significant negative pressures are maintained. During nighttime hours when the GDF would be closed and not oper ating, there was consistent pressure increase, indicating vapor growth. However, there were minimal episodes above 0 in. w.c. because the UST vents to the flexible bladder at +0.15 in. w.c.

Table 17. Pressure Data for ORVR-Compatible Vacuum Assist Stage II VRS

Parameter Without add-on APCD With add-on APCD and a simulated leak With add-on APCD Range -9 to +3 in. w.c. -8 to 0 in. w.c. -9 to 0 in. w.c. During operating/ fueling hours Significant negative P Negative P Significant negative P

Overnight Positive P overnight, sometimes > +3 in. w.c. No positive P because vented to APCD at +0.15 in. w.c. (If the APCD were not in place, significant positive P would not occur due to the fugitive leak; emissions would occur from fugitive leaks rather than at the UST vent.) No positive P because vented to APCD at +0.15 in. w.c.

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### 84 Parameter Without add-on APCD With add-on APCD and a simulated leak With add-on APCD UST emissions Significant fugitives, Significant vent emissions No fugitives, No vent emissions (If the APCD were not in place, significant fugitives would occur, however, no vent emissions would be likely.) No fugitives, No vent emissions



### 3. California GDF Testing, Site 3 This testing was conducted on a GDF in Calif ornia with a balance Stage II VRS. The operating conditions of the GDF were monitored dur ing a 7-day period in December. A total of 486 vehicle fuelings occurred and a total of 2,816 gal were dispensed during the test period. The vehicles fueled during the test period were 100 percent ORVR, and the GDF closes for 8 hours each day. The UST pressures ranged from approximately -2.6 in. w.c. to +0.15 in. w.c. over the 7-day period. The UST pressures seemed consis tent with typical UST pressures for refueling, with higher pressures during nigh ttime hours when the GDF was closed (i.e., not dispensing fuel) and with negative pressures during operating hours (dispensing fuel). The UST pressures were less than or equal to 0 in. w.c. for 95 percent of the operating pe riod, and were greater than 0 in. w.c. for 5 percent of the operating time.

The pressure data indicate that the balance Stage II VRS used to fuel ORVR vehicles is not likely to generate excess emissions from the UST due to ORVR refuelings (from incompatibility). Because the UST pressures are negative for the majority of the time, fugitive emissions and UST vent emissions may be minimized.

4. Florida GDF Testing, Site 1 The Florida Department of Environmental Pr otection (DEP) and we observed testing at a GDF with a vacuum assist Stage II VRS that ha d an installed add-on APCD on the UST vent. The UST add-on APCD is a membrane system th at accepts gasoline va pors during periods of positive UST pressure and recovers and returns the gasoline vapors to the UST. These data are for Florida in February, UST temp erature of 74°F, ambient T of 71°F, RVP of fuel of 11.1 psia, V/L ratio of 0.97, and a fueling rate of approximately 8 gal/min; the percentage of ORVR vehicles fueled is not known. The UST ve nt emissions testing was conducted for an approximately 24-hr period for each testing s cenario including both daytime operating hours (i.e., refueling) and during nighttime hours when no refueling operations occurred (i.e., the GDF was closed). The emissions data fo r all scenarios are shown in Table 18.

Stage II VA VRS, no P/V valve, no UST add-on APCD. 

### The emissions rate from the UST vent is 3.48 lb/1,000 gal and 2.78 lb/hr.

Stage II VA VRS, with a P/V valve, no UST add-on APCD.


### The emissions rate from the UST vent is 1.20 lb/1,000 gal and 0.95 lb/hr. UST pressures during this testing were at +3 in. w.c., so f ugitive emissions were likely occurring. The UST system passed the leak decay test; a portable HC analyzer, however, showed that drain valve

### DRAFT 02-07-06



### 85 bucket leaks became prominent at a pressure of +2.7 in. w.c. These emissions data likely represent low values in that fugitive leaks were occurring with the P/V valve in place. An emissions reduction of 59.8 percent from uncontro lled UST vent levels could be calculated, however, addition of the fugitive emissions (not qu antified for the testing) that are occurring to this vent emissions value would likely show li ttle to no decrease in em issions rate over the uncontrolled levels shown above (no P/V valve, no UST add-on APCD).

Stage II VA VRS, with a P/V valve, with UST add-on APCD. 

### The emissions rate from the UST vent is 0.014 lb/1,000 gal and 0.0113 lb/hr. The UST vents to the add-on APCD when the UST pressure reaches +0.5 in. w.c.; at these pressures, there should be little to no fugitive emissions occurrin g. These data represent an emissions reduction of 99.3 percent from uncontrolled UST vent rates.

Table 18. Stage II VA VRS, with and without P/ V Valve, with and without add-on APCD

Source Uncontrolled System, a lbs/1,000 gal Controlled System, b lbs/1,000 gal Controlled System, c lbs/1,000 gal
UST vent emissions 3.48 1.20 0.014

a Uncontrolled scenario means: w ith Stage II VA VRS, no P/V valve, no UST add-on APCD (ORVR

unknown).
b Controlled scenario means: with Stage II VA VRS, with P/V valve, no UST add-on APCD (ORVR unknown).

This emissions data point does not include fugitive emissions that are occurring due to leaks in the UST system.

c Controlled scenario means: with Stage II VA VR S, with P/V valve, with UST add-on APCD (ORVR

unknown).



### 5. Missouri GDF Testing, Site 1 The emissions levels from the vehicle refueling fillpipe/nozzle interface, the spillage emissions, and the UST vent breathing and f ugitives are shown in Table 19. Uncontrolled emissions levels were determined from AP-42 em issions factors. These data are for ambient T of 75°F and RVP of 11.3 psi. The emissions we re determined for two types of nozzles. The emissions testing was conducted in October in Missouri and the benc h testing was conducted from June through March. (The fueling rates in gal/min are not available.) During the vehicle refueling testing, 77 vehicles were refueled at pump 9 and 76 vehicles were refueled at pump 10. Vehicle matrix data on the model year vehicle and the make are available. The number of ORVR vehicles is not known.

### DRAFT 02-07-06



### 86 Table 19. Stage II Balance VRS, with P/V valve, no UST vent add-on APCD

Efficiency Relative to Uncontrolled System

Source Uncontrolled System (without VRS),

lbs/1,000 gal Controlled Pump 9 Husky 5010 (V Short), lbs/1,000 gal Controlled Pump 10 Husky 5210

(V Long), lbs/1,000 gal Pump 9 Husky 5010

(V Short) Pump 10 Husky 5210

(V Long) Vehicle Fueling 14.6 [AP-42 EF equation] 0.64 a [emissions measurement] 0.63 a [emissions measurement] 95.6% 95.7%

Spillage/PseudoSpillage 0.46 0.083 [measured] 0.10 [measured] 82.0% 78.3%

Breathing (Pressure Related Fugitives from components such as P/V valves and nozzles) 1.00 [AP-42 EF] 0.16 [calculated] 0.16 [calculated] 84.0% 84.0%

a A portion of this value was due to evaporation of liqui d droplets on the nozzle afte r completion of each fueling

event and really belongs in the spillage/pseudospillage category.



### 6. Missouri GDF Testing, Site 2

The emissions levels from the vehicle/nozzl e interface, the spillage emissions, and the UST vent breathing and fugitive emissions are shown in Table 20. The uncontrolled emissions levels were determined from AP-42 emissions fact ors. These data are for ambient T of 75°F and RVP of 12.76 psi. The emissions testing was co nducted in October and the bench testing was conducted from May through December. During th e vehicle refueling testing, a total of 205 vehicles were refueled. Approximately 5 of th ese were ORVR vehicles (which reflected the actual ORVR percentage of the ve hicle fleet at that time, 2.4 pe rcent). The fueling rate in gal/min is not available. Vehicle matrix da ta on the model year vehicle and the make are available.

Table 20. Stage II Balance VRS, with P/V valve, no UST vent add-on APCD

Source Uncontrolled System (without VRS), Lbs/1,000 gal Balance VRS, lbs/1,000 gal Efficiency Relative to Uncontrolled System Vehicle Fueling 14.6 [AP-42 EF equation] 0.79 [emissions measurement] 95.2%

Spillage/Pseudo-Spillage 0.46 0.02 [measured] 97.8%

Breathing (Pressure Related Fugitives from components such as P/V valves and nozzles) 1.00 [AP-42 EF] 0.06 [calculated] 94.0%

### DRAFT 02-07-06



### 87 7. Missouri Automobile Manufac turer GDF Testing, Site 3

The emissions levels from the vehicle fue ling fillpipe/nozzle in terface, the spillage emissions, and the UST vent breathing and fugiti ves are shown in Table 21. Emissions testing was conducted to measure the uncontrolled emissions levels for vehicle fueling; the testing was conducted in March with ambient T of 72 o F and filling rate of 6 to 9 gal/min (assumed RVP of 11.99 psi). The uncontrolled spillage and brea thing losses were determined from AP-42 emissions factors and CARB EFs. The controlled emissions levels for vehicle fueling were determined by emissions testing in March with chilled gasoline at 50 o F and a filling rate of 6 gal/min (assumed RVP of 11.99 psi). The testin g for continuous pressure and temperature was conducted from September through December, and th e bench testing was conducted in February, September, and December. All of the vehicles were ORVR, with a si ngle canister design. (Some data are also available for dual canister ORVR at this site bu t are not shown here.)

In addition to the emissions testing, T and P operating data for the UST are available for a 103-day period and a summary of the data is sh own in Table 22. Typical weekday pressures show increasing pressures, indicat ing vapor growth, for overnight periods and negative pressures during daytime fueling operations. Typical week end day pressures showed positive pressures for day and night periods. The UST pressures were great er than 0 in. w.c. for 29.6 percent of the test period (pressure-related fugitives are likely occurr ing) and were greater than +3.0 in. w.c. for 4.2 percent of the testing period (UST vent emissions are likely occu rring). A leak was fixed on day 72 of the test. Another analysis of the pressure data was conducted for the time period before and after the leak. The tank maintains negative pressures for longer periods after the leak is fixed (48 percent of the time) than before (19 percent). In addition to maintaining negative pressures, the UST will also “better” maintain pos itive pressures after the leak is fixed; UST vent emissions are more likely to occur in a tight system, in place of UST fugitive emissions that occur in leaking systems. Because the UST at automobile manufacturing facilities have longer vapor growth periods, the UST emissions from these operations may be higher than would typically be seen at a traditional GDF.

Table 21. No Stage II VRS, with a P/ V valve, no UST vent add-on APCD

Source Uncontrolled System a [in MY2001/2002 mockup tanks] lbs/1,000 gal Controlled b MY2003 - mockup, lbs/1,000 gal Efficiency Relative to Uncontrolled System Vehicle Fueling 17.6 [emissions measurement] 0.0779 [emissions measurement] 99.6%

Spillage/Pseudo-Spillage 0.75 [CARB EF] 0.48 [measured] 36.0%

Breathing (Pressure Related Fugitives) - UST emissions - fugitives 1.0 [modified AP-42 equation] 0.24 [calculated based on P, T, time] 76.0%

a Uncontrolled scenario means: No chilling, no ORVR, no Stage II VRS, w/ P/V valve [some vapor return from a s

fueling area balance nozzle, but this has a small impact becau se small gasoline throughput].
b Controlled scenario means: with Chilling, with ORVR single, and No Stage II VRS.

### DRAFT 02-07-06



### 88 Table 22. Analysis of Frequency Plots for UST Pressure for All Data and Before/After Fixing the Leak

All data Before leak is fixed After leak is fixed Pressure ranges, in. w.c. minutes % minutes % minutes % < -8.0 40,809 27.9% 19,680 19.2% 21,129 48.3% -8.0 < P < 0.0 62,137 42.5% 50,166 48.9% 11,971 27.4% <0.0 102,946 70.4% 69,846 68.1% 33,100 75.7% >0.0 43,265 29.6% 32,651 31.9% 10,614 24.3% >3.5 6,249 4.27% 4,184 4.08% 2,065 4.72%



### 8. Missouri Automobile Manufacturing GDF, Site 4

The emissions levels from the vehicle fue ling fillpipe/nozzle in terface, the spillage emissions, and the UST vent breathing and fugiti ves are shown in Table 23. Emissions testing was conducted to measure the uncontrolled emissions levels for vehicle fueling; the testing was conducted in March with ambient T of 72 o F and filling rate of 8 ga l/min (assumed RVP of 11.99 psi). The uncontrolled spillage and breathing lo sses were determined from AP-42 emissions factors and CARB EFs. The cont rolled emissions levels for vehi cle fueling were determined by emissions testing in March w ith chilled gasoline at 43 o F and with a filling rate of 8 gal/min (assumed RVP of 11.99 psi). The testing for continuous pressure and temperature was conducted in October and November, and th e bench testing was conducted in August, September, and December. All of the (controlled ) assembly line vehicles and the uncontrolled mockup tanks were ORVR (dual), and the controlled mockups for the MY2004 were ORVR (single).

Table 23. No Stage II VRS, with a P/ V valve, no UST vent add-on APCD

Source Uncontrolled System a MY2003 mockup tanks lbs/1,000 gal Controlled MY2003 b assembly line, dual canister, lbs/1,000 gal Efficiency Relative to Uncontrolled System Controlled MY2004 b

mockup tanks, single

canister, lbs/1,000 gal Efficiency Relative to Uncontrolled System Vehicle Fueling 13.5 [emissions measurement] 0.0118 [emissions measurement] 99.9% 0.0033 [emissions measurement] greater than 99.9%

Spillage/PseudoSpillage 0.75 [CARB EF] 0.063 [measured] 91.6% same same

Breathing (Pressure Related Fugitives) - UST emissions - fugitives 2.09 [modified AP-42 EF] 0.267 [calculation based on P, T, time] 87.2% same Same

a Uncontrolled scenario means: No chilling of gasoline, no ORVR, no Stage II VRS, and with P/V valve.
b Controlled scenario means: With chilling of gasoline, with ORVR, No Stage II VRS, with P/V valve, and with

purge puff nozzle.

### DRAFT 02-07-06



### 89 UST Operating Data for No Stage II VRS and with P/V valve. 

### Some typical UST operating pressure data ar e shown in Table 24. The pressure data show a pattern of high vacuum during production operations on weekdays (i.e., fueling) and higher pressures close to or at th e cracking pressure of the P/V va lves during off times (overnight and weekends). Because the UST at automob ile manufacturing facili ties have longer vapor growth period, the UST emissions from these oper ations may be higher than would typically be seen at a traditional GDF.

Table 24. Summary of Weekday and Weeken d UST Vent Pressures (No Stage II VRS, with P/V valve)

Friday, 11/08 Saturday, 11/09 Sunday, 11/10 Monday, 11/11 Tuesday, 11/12 Wednesday, 11/13 Thursday, 11/14 Pressure, psi N S N S N S N S N S N S N S
Minimum -9.29 -10.62 -9.12 -10.48 1.26 1.19 -9.16 -10.72 -9.25 -10.65 -9.23 -10.58 NA NA
Maximum 3.37 3.30 3.40 3.35 3.32 3.22 3.36 3.34 3.39 3.38 3.63 3.58 3.59 3.51 Average -6.10 -6.87 1.80 1.62 2.58 2.49 -5.27 -5.90 -6.59 -7.33 -5.81 -6.43 -15.44 -11.17 Friday, 11/15 Saturday, 11/16 Sunday, 11/17 Monday, 11/18 Pressure, psi N S N S N S N S
Minimum -9.06 -10.47 1.60 1.52 2.27 2.26 -9.29 -10.77
Maximum 3.38 3.35 3.12 3.06 3.04 3.03 3.06 3.03 Average 1.58 1.44 2.64 2.59 2.79 2.76 -5.08 -5.77 Note: Data are provided for pressure gauges at both the north and south ends of the UST.



### 9. New Hampshire GDF Data The NH DES monitored approximately 300 GDF in New Hampshire to determine the extent of groundwater pollution with MTBE. The GDF that were monitored included a number of different control types, in cluding balance and vacuum assi st Stage II VRS, and some GDF without Stage II VRS controls. The groundwater monitoring data show that a number of the GDF have detectable levels of MTBE and a num ber have exceeded the groundwater limit. With the MTBE limit for groundwater at 13 ppb, approximately 88 GDF exceeded the limit. Of these 88 GDF, 51 are confirmed to be vacuum assist St age II VRS that are not ORVR compatible. The last MTBE concentration readings for those GDF that exceeded the limit ranged from 18 to 1,110,000 ppb.

10. Multi-State GDF Data Testing for multiple GDF with Stage II VRS cont rols was conducted in 17 States over a 15-month period. Testing included pressure deca y tests (static pressure performance test), dynamic backpressure tests, and A/L ratio testing. A total of 7,514 pressure decay tests were conducted over this time period in the 17 States. Of these pressu re decay tests, approximately 19 percent failed, and the failure rate from State to State ranged from 0 percent (only 2 GDF were tested) to 29 percent. These failures occurred despite retesting following maintenance attempts by the test technician to repair tank fittings, di spenser fittings, and hangi ng hardware while onsite when a GDF failed an initial try.

### DRAFT 02-07-06



### 90 A number of dynamic backpressure tests we re conducted, with 3,974 tests on the gasoline (wet) side and 3,916 on the vapor (dry) side. These tests check for any blockage in the gasoline or vapor piping or hoses. Overa ll, approximately 6.5 percent of th e wet backpressure tests were failures (ranging from 0 to 33 percent from State to State) and 3.4 percent of the dry backpressure tests were failures (ranges from 0 to 25 percent).

There were 4,313 A/L ratio tests summarized in the data. Approximately 27 percent of the tests were failures; these tests are considered to be failures if even one fueling point at the GDF fails and cannot be repaired by the technician or if a fueling point is out of order when the test is conducted. All fue ling points must be working properly to pass the test.

A summary of the testing and the failure ra tes by States is pr ovided in Table 25. Information on the frequency requirements for speci fic tests is also prov ided. There is much variability in the failure rate from State to State and also from test type within a single State.

### DRAFT 02-07-06



### 91Table 25. Stage II VRS Testing and Failure Rates by StatePressure decay testsBackpressure testsBackpressure testsA/L ratio testsStatePD TestPressure,in. w.c.TestsFailsaFail,%WetBTestsWetBFailsbFail ,%DryBTestsDryBFailsbFail ,%TestsFailscFail ,%Test FrequencyCT 10180 34 19 143 5 4 143 3 2 54 22 41 Every 3 years (changed from every 5 yearson 7/26/04, A/L not required before thisdate)DC 260 6 10 46 1 2 46 – – 70 30 43 Annual (Vac-assist), 5 years balanceDE 10115 14 12 50 4 8 49 – – 106 33 31 Annual all testsFL 292 8 9 60 2 3 60 2 3 51 2 4 PD & A/L Annual, blockage every 2 yearsin Miami-Dade and every 5 years inBrowardMA 101,268 115 9 678 18 3 680 9 1 1,029 248 24 PD & A/L annual for all systems, wet/dryblockage every 3 years for all systemsMD 2723 142 20 71 8 11 71 5 7 621 211 34 PD & A/L annual for all systems, dryblockage annual for balance, wet blockageevery 5 years for all systemsME 1028 5 18 3 1 33 3 – – 24 7 29 PD & A/L Annual for vac-assist, blockageevery 5 years, PD and Blockage every 5years for balanceNC 102 – – 2 – – 2 – – – – – PD & Blockage every 5 yearsNH 1067 8 12 56 1 2 56 1 2 44 15 34 Every 3 years all testsNJ 22,496 672 27 1,533 113 7 1,532 52 3 606 153 25 PD & A/L annual for all systems, wet/dryblockage every 3 years for all systems (PDchanged from every 5 years to annual lastyear)NY 10914 223 24 731 64 9 732 35 5 279 93 33 PD & B Every 5 years (No A/Lrequirement)OH 2131 8 6 64 – – 4 1 25 157 27 17 PD & A/L annual for all systems, wet/dryblockage every 5 years for all systemsPA 21,039 128 12 378 29 8 379 20 5 1,019 251 25 PD & A/L Annual for vac-assist, blockageevery 5 years, PD and Blockage every 5years for balanceRI 10155 16 10 76 5 7 76 1 1 157 51 33 PD & A/L annual for all systems, wetblockage every 3 years for all systemsSC2 – – – – – – – – – – – No requirementsVA 2231 67 29 82 8 10 82 6 7 95 33 35 PD & Blockage every 5 years for allsystems (A/L at discretion of agency)

### DRAFT 02-07-06



### 92Pressure decay testsBackpressure testsBackpressure testsA/L ratio testsStatePD TestPressure,in. w.c.TestsFailsaFail,%WetBTestsWetBFailsbFail ,%DryBTestsDryBFailsbFail ,%TestsFailscFail ,%Test FrequencyVT 1011 – – 1 – – 1 – – 1 – – PD & A/L every 5 years for all systems,wet/dry blockage for every 5 years forbalance onlyTotal7,514 1,446 19.2% 3,974 259 6.52% 3,916 135 3.45% 4,313 1,176 27.3%Avg Avg Avg AvgaPressure decay failures are considered failures after all attempts have been made by the technician to repair.bBlockage failures are underground blockage failures.cA/L failures are considered failures if evenone fueling point at the site fails and cannotbe repaired.The only time A/L is considered a pass is when all fueling points areworking properly at the time of the test.

### DRAFT 02-07-06



### 93 11. Vermont GDF Data Testing was conducted at 32 GDF to determin e how well in-use GDF systems maintain compliance with performance standa rds and the level of effort requ ired to bring GDF back into compliance. Nineteen percent of GDF were ba lance and 81 percent were various types of VA VRS. No recent maintenance had been conducted at these facilities. Testing included (1) pressure decay tests, (2) A/L ra tio test for VA VRS, and (3) vacuum line integrity test for GDF with a central vacuum pump. Testing was c onducted on an “as is” basis, i.e., without any maintenance being conducted prior to testing. Th e technicians also tracked the amount of effort to bring each GDF into compliance. The conclu sions from these data are that a significant number of GDF will fail pressure decay tes ting without ongoing maintenance. Another conclusion is that the majority of GD F do meet the A/L ratio requirements.

Pressure decay tests. 

### A total of 90 USTs, 128 gasoline dispensers , and 360 gasoline nozzles were included in the testing. Fill caps and Stage I poppet valves were the equipment components involved in failure of the pressure decay test; the balance no zzles contributed to the failure at all of the balance VRS GDF. Twelve percent of the fill caps, 27 percent of Stage I poppet valves, and 23 percent of balance nozzles were found to be le aking. Data on the pres sure decay tests is provided in Tables 26 through 29.

Table 26. Initial Pressure Decay Test Results

Subset of

GDF No. of GDF (percentage) No. Pass (percentage) No. Fail (percentage) All stations 31 (100%) 10 (32%) 21 (68%)
VA 25 (81%) 10 (40%) 15 (60%)
Balance 6 (19%) 0 (0%) 6 (100%)



### Table 27. Margin by Which Pressure Decay Test Failed

Pass/Fail description Percent of total stations
Pass – Within Allowed Leak Rate 32 Fail – Up to 10% Above Allowed Leak Rate 26
Fail – Between 10% and 50% Above Allowed Leak Rate 13
Fail – Greater than 50% Above Allowed Leak Rate 29

### DRAFT 02-07-06



### 94 Table 28. Equipment Problems that Cont ributed to Pressure Decay Test Failure

Part Percent of Failing Stations Where Component Was a Factor a Fill Cap 41 Stage I Poppet Valves 41 Fill Adaptor 32 Spill Bucket Drain Valve 27
Nozzle b 27 Breakaway 14
In-Tank Monitor 5 Submersible Pump 5

a At most GDF, more than one component contributed to failure, therefore,

percentages do not add to 100 percent.
b Nozzles were a contributing f actor only at balance stations.



### Table 29. Parts Found Leaking During Pressure Decay Tests

Part Number Leaking % Leaking, Out of Total Number Tested Fill Cap 11 12 Stage I Poppet Valve 15 27 Fill Adaptor 9 10 Spill Bucket Drain Valve 12 not determined Balance System Nozzle 13 23 Breakaway 3 <1
In-Tank Monitor 3 not determined Submersible Pump 1 1



### Vacuum Line Integrity Test. 

### Vacuum line integrity testing was performed at two GDF with VA VRS that had a central vacuum source. Both GDF passed this test on the initial attempt.

A/L Ratios. 

### A/L ratio tests were performed at 26 VA VR S GDF and involved testing of 298 nozzles. The majority of nozzles passed the A/L ratio testing. Most nozzles that failed did so with a small margin. Information on the A/L ratio testing is provided in Table 30.

### DRAFT 02-07-06



### 95 Table 30. A/L Ratio Testing Results

Percent of Nozzles

Status WayneVac Gilbarco Vapor Vac Healy Franklin Intellivac Within Allowable Range 85 94 92 100 Fail– Within 10% of Allowable Range 11 4 4 0 Fail– Between 10% and 50% of Allowable Range 2 2 4 0 Fail– Greater than 50% of Allowable Range 2 0 0 0 Number of GDF Tested: WayneVac = 15 (186 nozzles); Gilbarco VaporVac = 8 (48 nozzles); Healy = 2 (56 nozzles); Franklin = 1 (8 nozzles).



### Required Effort to Attain Compliance. 

### Following test failures, the testing technician conducted repairs, adjusted equipment, and replaced broken or worn components. For mo re than 50 percent of the components, minor maintenance such as tightening was sufficient to st op leaks. At 6 of 21 GDF, tightening of parts or other adjustments was sufficient to pass the pressure decay test; at 15 of 21 GDF, replacement of one or more parts was required.

For the A/L ratio failures, adjustment of th e vacuum motor or replacement of nozzles resolved most problems.

Overall, replacement parts at 19 GDF cost $6,315 ($332/GDF).

12. EPA’s Initial In-Use Evaporat ive Testing of ORVR Vehicles Two-day evaporative testing was conducted on a total of 32 ORVR ve hicles of various ages. The odometer readings ranged from 6,800 to 190,000 miles, with an average of 45,000 miles per vehicle. Of the 32 vehicles testing, 28 passed the evaporative testing, indicating an 88 percent pass rate. While these evaporative system tests do not provide information specifically on the control efficiency of ORVR canisters, th ese tests do provide data indicating that most ORVR systems are operating correctly.

13. EPA’s IUVP

The latest EPA data from the IUVP incl udes testing on a tota l of 151 ORVR-equipped vehicles, using FTPs for the outlet of the ORVRcanister. Overall, 9.3 percent of the ORVRequipped vehicles (14 out of 151) had canister em issions greater than the 0.2 g/gal limit. An analysis of the data with respect to high m ileage versus low mileage vehicles was also conducted. Of the high-mileage vehicles, 13 percent (6 out of 47) had emissions greater than the 0.2 g/gal limit. Of the low-mil eage vehicles, 7.7 percent (8 out of 104) had emissions greater than the 0.2 g/gal limit. These resu lts are presented in Table 31.

### DRAFT 02-07-06



### 96 Table 31. EPA IUVP Test Results

Overall Low Mileage High Mileage Test Result Number Percentage Number Percentage Number Percentage < 0.2 g/gal 137 91% 96 92% 41 87% > 0.2 g/gal 14 9.3% 8 7.7% 6 13%
Total 151 100% 104 100% 47 100



### B. Other Data Found within Literature

1. WSPA – UST vent emissions This study measured VOC emissions from the UST vent and determined the effect of tank capacity and P/V valves on emissions levels . Conclusions drawn (by the authors of the study) from this testing indicated that the UST ve nt emissions are not directly correlated to the UST capacity, the product throughput, or the ambient T and P. It was also concluded from these emissions data that working losses compared to breathing losses are a sm all part of total UST vent emissions.

Stage II balance VRS, without a P/V valve, no UST vent add-on APCD.


### The emissions level from the UST vent is 0.08 3 lb/1,000 gal. The ambient T, RVP of the fuel, and the fueling rate are not known. Ther e were no ORVR vehicles refueled during the testing (conducted prior to ORVR implementation).

Stage II balance VRS, with P/V valve, no UST vent add-on APCD.


### The emissions level from the UST vent is 0.024 lb/1,000 gal. (Same scenario discussed in the previous paragraph.)

2. ORS Pilot Study This pilot study was conducted to evaluate optical remote sensing (ORS) technology for determining emissions factors. The study was co nducted over a 3-day period at a retail gasoline outlet (RGO) with no Stage II VRS and without P/ V valves. Both open-path Fourier transform infrared (OP-FTIR) and open-path ultraviolet (OP- UV) systems were used to determine gasoline vapors, benzene, and toluene and these values were compared to the AP-42 emissions factors. A vehicle refueling emissions factor and a total emissions factor (including fugitive and vehicle refueling emissions from ground level and vent pipe s from elevated releases) were measured and calculated and are shown in Table 32.

The study showed that both OP-FTIR and OP-UV systems detected emissions from vehicle fueling, UST vents, and fugitive emissions . In comparing the emissions to the AP-42 emissions factors, the OP-FTIR determined vehicl e refueling emissions fact ors were higher. The study suggested that the results ma y be site-specific and conclusi ons may not be applicable to other RGO facilities.

### DRAFT 02-07-06



### 97 Table 32. Optical Remote Sensing at an R GO with No Stage II VRS and No P/V Valve

Source Measured Emissions Factor Emissions Factor Based on AP-42 Equation Vehicle Fueling, no Stage II VRS, OP-FTIR (F1) 0.16% + 0.05%, mass percent a 0.11% (using generic T and RVP) 0.12% ± 0.02% (using UST T for dispensed fuel T and using ambient T for vehicle tank fuel) Vehicle Fueling, no Stage II VRS, OP-FTIR (F2) 0.15% + 0.03%, mass percent a 0.11% (using generic T and RVP) 0.12% ± 0.02% (using UST T for dispensed fuel T and using ambient T for vehicle tank fuel) Average Total Emissions Factor, OP-FTIR (F1) 0.32% a –

Average Total Emissions Factor, OP-FTIR (F2) 0.35% a –

a Compares average mass of vapors emitted (kg emitted ) to the average mass of gasoline dispensed (kg

dispensed).



### C. Planned Testing

1. Florida GDF Testing, Site 2 The Florida Department of Environmental Prot ection (Florida DEP) is planning testing at a station with no Stage II VRS. The Florida DEP c ontact indicates that this testing is to occur in the Fall of 2005. The station has installed ARID’s Permeator system in lieu of Stage II VRS and has requested a variance for 24 months or until Stage II VRS is no longer required, whichever is earlier. EPA may observe some of the testing and obtain additional data to address some of the Stage II VRS issues.

2. Hertz Testing, Rental Car Facilities

Hertz believes that because their vehicle flee t is almost entirely comprised of vehicles with ORVR equipment and because maintaining Stage II VRS is redundant, removal of Stage II VRS at their facilities would not result in an in crease in VOC emissions. To demonstrate this,Hertz is considering testing of emissions from the fillpipe and UST vent using the CARB TP201.2 test protocol. During the testing, Hertz will also collect data on UST system leak tightness and/or tank pressure. Hertz is considering testing at a vacu um assist Stage II VRS station without an UST add-on APCD, at a vapor balance Stage II VRS station without an UST add-on APCD, and at a station with no Stage II VRS. Da ta from these tests would address some of the current data gaps.

3. New Hampshire GDF Testing [ Editorial note – the New Hampshire testing de scribed in this section has been canceled due to scheduling and funding issues. ]

The NH DES, the UNH, GVR, and EPA plan to conduct testing at a GDF in New Hampshire beginning in January and continui ng through April 2006. The GDF has a vacuum assist Stage II VRS in place and will have an IS D system installed at the site. There are 3 gasoline UST and one diesel UST at the facility. Testing will be conducted for two scenarios.

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### 98 The first (baseline) will be testing of the Stage II VRS currently in place, and the second scenario (follow-up) will involve conversion to an OR VR-compatible Stage II VRS by installing the Healy EVR Phase II system. Th e GDF site is subject to th e NH DES Groundwater Management Permit (GMP) program to monitor pe troleum discharges that are beli eved to have occurred at the site. The facility is required to monitor thr ee times per year for a num ber of specific VOCs and static water elevations at eight on-site and two off-site monitoring wells. MTBE and TAME have been the major contaminants at the site. ORS systems will be used to measure emissions from vehicle refueling, UST vents, and fugitiv es. The objectives of the emissions testing include:

# Obtaining OP-FTIR measurements for al iphatic compounds, such as methanol, ethanol, MTBE, and other HAP;

# Obtaining UV-DOAS measurements for ben zene, toluene, ethylene, and xylenes (BTEX) compounds;

# Calculating emissions fluxes dow nwind from major hot spots;

# Identifying major hot spots by generating surface concentration maps in the horizontal plane; and

# Obtaining more sensitive measurements of aromatic HC across identified hot spots.

4. Arizona GDF Testing

In collaboration with the Salt River Pima Maricopa Indian Community, we conducted ORS testing at two GDF in Arizona in Oct ober 2005 to measure emissions from vehicle refueling, UST vents, and fugitives.. One GDF has no Stage II VRS and the other has a vacuum assist Stage II VRS. The objectiv es of these emissions tests are the same as those mentioned above for the New Hampshire testin g. Results are being summarized.


## VII. NESCAUM Widespread Use Study
As previously discussed in this paper, there are four possible definitions being considered for defining widespread use of ORVR. Definition (a) (percentage of ORVR-equipped vehicles) is based on vehicle registration da ta, projections of that data in to the future, and the phase-in schedule for ORVR. Definition (b) (percentage of VMT by ORVR-e quipped vehicles) is based on all of the data inputs for definition (a) plus the VMT data by class of vehicle. Definition (c) (VOC emissions with ORVR controls equal VOC emissions with Stage II VRS only) requires comparison of calculated vehicle refueling emissi ons based on two different refueling control measures. This definition requires the data input s for definitions (a) and (b) along with data on ambient temperature, RVP, rule effectiveness, ru le penetration, and the pe rcentage of GDF with vacuum assist Stage II VRS (to determine inco mpatibility excess emissions). Definition (d) (gasoline dispensed to ORVR-equipped vehicles) re quires data on the volume of gasoline sold in addition to the data inputs needed for definition (b).

The EPA used data provided by NESCAUM from three states (Massachusetts, New Hampshire, and Vermont) to calculate widesp read use for each potential definition. The algorithms are based on MOBILE6 data/equations. This section summarizes the calculation results for determining the widespread use date for each potential widespread use definition.

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### 99 A. Methodology for Determining Widespread Use

Algorithms used for calculating widespread use are based on MOBILE6 equations, with the addition of an IEE factor for ORVR-equippe d vehicles refueling at GDF equipped with vacuum assist Stage II VRS. 59

49 

### An IEE factor of 0.86 lb/1,000 gal (based on CARB’s findings) was used for calculation purposes. The algorith ms calculated VOC emissions for a summer day in a given calendar year (CY) for all gasoline vehicle type s under the following control scenarios:

1. Emissions from Stage II VRS only, without ORVR, 2. Emissions from ORVR only, without Stage II VRS, 3. Emissions from compatible Stage II VRS and ORVR, and 4. Emissions from incompatible Stage II VRS and ORVR.

Equations based on MOBILE6 were also used to calculate the per centage of VMT from ORVR-equipped vehicles in a given CY and to calcu late the percentage of gasoline dispensed to ORVR-equipped vehicles in a given CY.

MOBILE6 refueling emissions factors have tw o components. The first component is for vapor displacement and the second is for spill age. The uncontrolled vapor displacement emissions factor and spillage emissions factor for vehicle refueling are used in all calculation scenarios. The uncontrolled vapor displacement emi ssions factor is area-specific in the sense it accounts for ambient temperature and gasoline volat ility or Reid Vapor Pressure (RVP), which are inputs to the MOBILE6 model. An uncontro lled spillage emissions factor of 0.31 grams per gallon is used in all calculations [MOBILE6 ap plies a 50 percent contro l level to spillage for ORVR]; this value is consistent with the valu e presented in AP-42 (Chapter 5.2 Transportation and Marketing of Petroleum Liquids). Algorit hm equations are presented in Appendix B - NESCAUM Widespread Use Study Supporting Documentation, along w ith a description of each equation. Appendix B also contains the calculation spreadsheets.

B. NESCAUM Provided Data

NESCAUM provided EPA with data from three states to aid in analysis and comparison of the widespread use dates determined fo r each potential widesp read use definition. NESCAUM was asked to supply the following data for each state:

# Stage II VRS In-use Control Efficiency (CE);

# Ambient Temperature Data (used to calculate refueling emissions);

# In-use RVP of the gasoline used during the summer ozone season, and whether the gasoline was RFG;

# Total gasoline usage, gallons/yr for the mo st recent available CYs and for those years that the states have projected data;

59 API commissioned Tech Environmental to develop a sp readsheet to reproduce data from the MOBILE6 that includes IEE from ORVR-equipped vehicles and vacuum assist Stage II VRS.

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### 100 # Percentage of GDFs equippe d with balance Stage II VRS, and percentage of GDFs equipped with vacuum assist Stage II VRS, and percentage of GDFs equipped with balance Stage II VRS and Stage I (indicate the percentage of Stage I GDFs not equipped with P/V valves);

# Percentage of GDFs equipped with Stage I, but not equi pped with Stage II, and the percentage of Stage I GDFs not equipped with P/V valves;

# Expected percentages of balance and vacuum assist for new VRS installations (i.e., x percent of new VRS installations will be balance systems; y percent of new VRS installations will be vacuum assist);

# Vehicle distribution data by vehicle type and age;

# Vehicle mileage accumulation data;

# Vehicle miles traveled (VMT) data;

# Diesel sales fraction data;

# Vehicle fuel economy data;

# Alternatively-Fueled Vehicle (AFV) penetration data; and

# Anti-Tampering Program data.

If the state was unable to provide area specif ic data, EPA used MOBILE6 default values, which are based on national averages. Table 33 summarizes the data collected from each state and indicates which MOBILE6 default values we re used in the algorithms for determining widespread use.

Table 33. Data Provided by NESCAUM

Provided Data Or MOBILE6 Defaults Used Requested Data Massachusetts New Hampshire Vermont Stage II VRS CE 9 9 9 Ambient Temperature Data 9 9 9 In-use RVP of the gasoline used during the summer ozone season, and indicate if the gasoline is RFG 9 9 9

Total gasoline usage, gallons/yr for the most recent available CYs and for those years that the states have projected data 9 9 9

Percentage of GDFs equipped with balance Stage II VRS 9 9 9

Percentage of GDFs equipped with vacuum assist Stage II VRS 9 9 9

Percentage of GDFs not equipped with Stage II VRS, but equipped with Stage I. Also indicate the percentage of Stage I GDFs not equipped with P/V valves 9 9 9

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### 101 Provided Data Or MOBILE6 Defaults Used Requested Data Massachusetts New Hampshire Vermont Percentage of GDFs equipped with balance Stage II VRS and Stage I. Also indicated the percentage of Stage I GDFs not equipped with P/V valves 9 9 9

Vehicle distribution data by vehicle type and age 9 9 Defaults Vehicle mileage accumulation data Defaults Defaults Defaults Vehicle miles traveled (VMT) for the most recent calendar year and any years where projected data are available 9 9 9

VMT fractional mix (represents the fraction of total highway VMT accumulated by each vehicle type) Defaults 9 Defaults

Diesel sales fraction data 9 Defaults Defaults Vehicle fuel economy data Defaults Defaults Defaults Anti-Tampering Program data 9 9 9

9 Denotes that data provided by the State was used in the analysis.



### C. Results of Widespread Use Analysis

A widespread use date for definitions (a), (b), (c), and (d) were determined for each state. A variation of definition (c) was also considered in the analysis of widespread use dates. API suggested that definition (c) need ed to be modified to clearly identify the date at which there would be no emissions increase as a result of removing Stage II VRS. 60

50 

### Specifically, the modified definition (c), referred to as definition (c2), is when the total VOC emissions from ORVR-equipped vehicles are equal to or less th an the total VOC emissions from Stage II VRS and ORVR, including IEE. The input values fo r key parameters (except vehicle mix) provided by the three states and used for the an alysis are summarized in Table 34.

Table 34. Values for Key Parameters

Parameter MA NH VT Stage II VRS in-use Control Efficiency, % 84 68.6 62.4 Minimum Ambient Temperature, °F 60.9 a 62 b 59.9 a Maximum Ambient Temperature, °F 79.4 a 92 b 81.2 a RVP, psi 6.8 (RFG) 6.8 (RFG) 8.5 Percent of VRS that are Balance, % 41 20.4 10 Percent of VRS that are Vacuum Assist, % 59 79.6 90

a Average summer day.
b Probably minimum, maximum (not average).

60 Memorandum from T. Tamura, STI, to P. Searles, API. March 3, 2005. Onboard refueling vapor recovery (ORVR) systems – proposed definitions of “widespread use.”

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### 102 Table 35 summarizes the results of the anal ysis. Based on the assumptions for this analysis and applying the emissions-based calcula tions [definitions (c) and (c2)], widespread use occurs within the 7-yr window of 2008 to 2015. Us ing the definitions based on the percentage of VMT by ORVR-equipped vehicles and the percen tage of fuel dispensed to ORVR-equipped vehicles [definitions (b) and (d)] and the criterion of 85 to 90 pe rcent, widespread use occurs within the 5-year window of 2011 to 2016.

Table 35. Summary of Algorithm Analysis

Definition Description MA WSU Date NH WSU Date VT WSU Date
85% of fleet with ORVR 2015
90% of fleet with ORVR 2017 (a)
95% of fleet with ORVR 2023 85% of VMT from ORVR-equipped vehicles 2011 2012 2013

90% of VMT from ORVR-equipped vehicles 2012 2013 2015 (b)

95% of VMT from ORVR-equipped vehicles 2015 2016 2019

(c) Emissions from ORVR only are equal to emissions from Stage II only 2010 2008 2008

(c2) Emissions from ORVR-equipped vehicles are equal to or less than the total emissions from Stage II VRS and ORVR, including IEE 2013 2013 2015

85% of gasoline dispensed to ORVRequipped vehicles 2011 2012 2013

90% of gasoline dispensed to ORVRequipped vehicles 2013 2014 2016 (d)

95% of gasoline dispensed to ORVRequipped vehicles 2016 2018 2021



### As previously mentioned, if Stage II VRS is removed when the ORVR only emissions are equivalent to the Stage II VRS emissions [def inition (c)], an increase in emissions from the level achieved with both ORVR and Stage II VRS controls will occur. The results from this analysis indicate that for the year widespr ead use is achieved th is increase would be:

State Year Increase, tpsd

MA 2010 2.0 NH 2008 1.0 VT 2008 0.6

As the penetration of ORVR-equipped vehicles increases, this difference in emissions between ORVR only and ORVR with Stage II and I EE decreases rapidly with each ensuing year, as indicated in Table 36.

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### 103 Table 36. Difference in Emissions Between ORVR only and ORVR with Stage II VRS plus IEE

Emissions, (tons per summer day)
Year MA NH VT
2008 0.97 a 0.64 a

2009 0.72 0.49
2010 1.96 a 0.47 0.36
2011 1.00 0.25 0.25
2012 0.24 0.10 0.15
2013 -0.38 b -0.06 b 0.08
2014 0.01
2015 - -0.05 b

a Def (c): ORVR = SII
b Def (c2): ORVR = SII+ORVR+IEE



### D. Algorithm Analysis Issues

The in-use CE used in determining widespr ead use for definition (c) has an impact on how soon widespread use is reached. A higher in-u se CE will result in a later widespread use date, while a lower in-use CE results in an earlie r widespread use date. Th e impact of the in-use CE is understandable because a low in-use CE repr esents a Stage II VRS that is not operating as efficiently and effectively as the systems desi gned CE; therefore, as ORVR-equipped vehicles become more prominent in the vehicle fleet, it takes less time for ORVR technology to be more effective at reducing emissions. A high in-use CE for Stage II VRS delays the widespread use date because ORVR technology only becomes more effective at reducing emissions when the vehicle fleet is mostly comprised of ORVR-equipped vehicles.

The IEE factor used in determining a widespr ead use date for definition (c2) impacts how soon the widespread use date occurs. The larger the IEE factor, the sooner the widespread use date will approach. Definition (c2) takes into ac count that there is an additional level of control achieved by Stage II VRS beyond the control level defined by definition (c) (i.e., when the ORVR control level is equivalent to the Stage II VRS control level), but this additional level of control is offset by IEE. As ORVR-equipped vehi cles become more prominent in the fleet, the IEE increases; eventually the emissions from ORVR only are less than the emissions from combined Stage II VRS and ORVR, including IEE. For these analyses an IEE factor of 0.86 lb/1000 gal was used (based on CARB data for a VA system with a certified A/L ratio of 1.0 to 1.2). This emissions factor was used for all VA systems in these analyses and no attempt was made to adjust the factor for systems with lowe r A/L ratios nor for volatility of the fuel (Reid vapor pressure). Using a smaller IEE factor w ould result in a later date for widespread use defined by (c2). Because applying a smaller IEE f actor would result in less IEE, the difference in total emissions between ORVR only and ORVR with stage II VRS plus IEE would increase (i.e., the emissions summarized in Table 36 woul d increase). IEE factors lower than the 0.86 lb/1000 gal value used in these analyses have been reported fo r systems with lower A/L ratios

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### 104 [specifically: by CARB (for Dresser Wayne VA system) and by API ( for Miniboot); See Section VI]

E. Recommendations

As discussed previously, EPA stated support for definition (c), however after examining the results from determining widespread use for definitions (c) and (c2), we recommend definition (c2). Definition (c) is less ideal than definition (c2) because it does not take into account the short-term increase in emissions from the removal of Stage II VRS. As ORVRequipped vehicles become more prominent in th e fleet, the emissions increase from Stage II removal decreases and eventually the emissions from ORVR only are less than the emissions from combined Stage II VRS and ORVR, including IEE. Definition (c2) is complicated and is largely impacted by the IEE factor used in al gorithm analysis. EPA believes that additional emissions monitoring needs to be conducted to be tter understand IEE. As discussed in Section V.D., CARB and the WSPA plan to conduct some emissions testing to better define IEE; however, when their testing will occur is unclear . Hertz is planning to conduct some emissions testing that will include UST vent emissions and ta nk pressure tracking. In addition, Hertz will be conducting testing to demonstrate that wit hdrawing Stage II vacuum assist VRS will not adversely impact VOC emissions from their GDFs. Because most of thei r vehicles are ORVRequipped and the Stage II VRS are vacuum assist , their test data will provide IEE data. NH DES, University of New Hampshire (UNH), Gilbarco/Veeder Root (GVR), and EFPAG are conducting an emissions monitoring project that w ill also provide more IEE data. We believe that these emissions tests will enable EPA to bett er quantify the IEE and indicate what IEE factor to use in determining widespread use.

EPA recommends that States use the same me thodologies as presented in this section to calculate a widespread use date. States are ad vised to wait until EPA has had time to examine the IEE data collected from upcoming testing befo re calculating widespread use dates. Once EPA has examined the IEE data, EPA will provi de guidance on what IEE factor to use in widespread use calculations.



## VIII. Recommendations
A summary of our recommendations from th e previous sections are as follows:

 OPSG not dictate a policy on vacuum-assi st versus balance for Stage II VRS.

 OPSG continue to urge OMS to produce da ta for ORVR in-use long-term control efficiency.

 We continue to conduct testing to determin e the IEE and forward the data results to OPSG.

 OPSG consider definition (c2) as the best option for determining widespread use.

 Regarding phase out of Stage II VRS, OPSG: (1) develop guidance on the decommissioning of Stage II VRS; (2) allow waivers for new GDF and conduct a cost study to determine when new GDF are not requ ired to install Stage II VRS; and (3) develop guidance on other control measur es, control efficiencies, and costs.

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### 105  OPSG recommend P/V valves for all UST vent s nationwide for additional HAP control.

 Regarding phase out in the OTR: (1) same recommendations as above for Stage II VRS in other States; (2) OPSG provide the mechanism to pha se out section 184(b)(2) requirements for Stage II VRS by updating or amending the Stage II Comparability Study, or other acceptable means.

 OPSG develop guidance for awarding SIP cred its to GDF owners/operators who provide additional control for the thre e categories includi ng, (1) new GDF; (2) GDF that remove Stage II VRS; and (3) other large-emitting GDF.

 OPSG consider adopting some components of CARB’s EVR.

 OPSG recommend use of ISD and increased inspections.

 Provided adequate funding is available, we update emissions factors based on emissions measurement data.

 OPSG draft and release memorandum indicat ing our acceptance of waivers for Rental Car Facilities and Automobile Manufacturers.

 OPSG consider additional control measures that focus on alleviating UST pressurization and thus reducing MTBE groundwater contamination.

 We continue to conduct testing to determine the magnitude of UST emissions (both vent and fugitive) and provide the data results to OPSG.

# Appendix A

Brief Summaries of Data Provided by Stakeholders

### Previo us Da ta Col lected by EPA

SUMMARY OF EXCESS EM ISSION DATA This summa ry

present s the key data and conclusi ons from s everal studies c onducted to evalua te

excess em issions cr eated f rom the re fueling of Onboa rd Refue ling Va por Reco very (ORVR) equipped cars at Gasoline Dispensing Fa cilities (GDF) using vapor recove ry sy stems (VRS). For each data source: (1) the tests conducte d are described, (2) key results and conclusions presented in the dat a source s are sum marized, a nd (3) a t able of t he data i s presen ted. The table is organized to identify the actual measurements conducted and re sults reported in the study.

GENERAL NOTES

EPA defines refueling emissions as the evapora tive loss emissions during refueling, as well as emissions from spillage. For the purposes of this summary , spillage emissions are not addressed and referenc e to “refueling emissions” does not include spillage.

Emissions may occur (a nd may be mea sured or calculated) at numerous points within the system. CARB’s VRS certifica tion test method, TP-201.2, addresses making measurements or calculating emissions from several points in the sy stem. The measurement points are: 1. Emissions at nozzle/vehicle interface (“fill pipe” emissions) 2. VOC’s r eturned through the vapor passag e of the h ose 3. Emissions from the UST P/V valve 4. Emissions from the assist processor (not applicable in these studies), and 5. Calcula ted pres sure-r elated f ugitive s based on UST tank pr essure m easure ments

The emissions data generally are reported as lb VOC/1000 gallons dispensed. Note tha t in the actual reports both lb VOC/1000 gallons dispensed and g VOC/g al dispensed were used; this often got confusing as the authors switched bac k and forth. The figures from the re ports that
are pre sented a long with this summar y ty pically use g VO C /gallon s dispense d, where as the da ta in the summary table is prese nted in lb/1000 gallons. 1 lb/1000 gallons = 0.454 g/gallon (roughly , there are 2 lb/1000 gallon per g /gallon).

SOURCES

[1] CAR B: P rel im in ary Dr aft Tes t R epo rt, “To tal Hydr oca rbo n Em is si ons fro m Tw o P has e II Vacuum Assist Vapor Recovery Systems During B aseline Operation and Simulated Refueling of Onboard Refueling V apor Recovery (ORVR) Equipped Vehicles”, June 1999

• Tests conducted in August/September 1998 at two facilities with Vacuum Assist(VA ) VRS. to qua ntify “excess e missions” f rom vapor growth

• At time of t ests, the se two ty pes of sy stems represente d 80% of V A sy stems in CA, and dispense 55% of gasoline purchased

• VRS emissions were determined from direct measurement of UST pre ssure/ vacuum (P/V) valve emissions and calculation of fugitive emissions based on UST pr essur e readi ngs

### • CARB did not measure or attempt to quantify the emissions at the nozzle/fill pipe interface (“fillpipe emissions”) during the study

• Testing had two phases: 1) “baseline” normal ope rations and 2) simulated ORVR (mix of 4 0% ORVR vehi cles)

. Because ORVR vehicles were not prevalent when tests were done, the ref ueling of ORVR was simulated by modifying the dispense rs to ingest ambient air.

Key Results :

• Negligible emissions emitted from the P/V valve when P/V valve in opera tion; fugitiv es were from othe r unknown location s (e.g. leaks)

• Excess emissions did occur (calculated pressure related f ugitives) when refueling with the si mulated O RVR scena rio. See t able 1 fo r details

. Ultimate ly, CARB used these data to develop an averag e excess emissions factor of 0.86 lb/1000gal when refueling ORVR equipped vehicles with VA VRS.

[2] API: ORVR Compatibility Study for the Gilbarco Vaporvac VRS, Febr uary 2004; Phase 1

• ORVR compatibility study at a GDF in California.

• The fuel was summertime reformulated feder al gasoline (RVP 7.0)

• The vapor recovery system was vacuum a ssisted (Gilbarco).

• Used CARB Stage 2 certification test proce dure TP201.2. Figure 2-1 identifies the measurement points. The measurement points are: 1) Emissions at nozzle/vehicle interface (“fill pipe” emissions); 2) VOC’s returned through the vapor pa ssage of the hose; 3) Emissions from the UST P/V valve; 4) Emissions from the assist processor (not applicable in these studies), and 5) Calculated pressure related fug itives based on UST tank pressure

measure ments.

• Test 1: 100 car matrix, standard VA nozzles

• Test 2: 100 car matr ix, nozzles with “miniboots ,” to limit in flux of ambi ent air

Key Results :

• Overall pressur e relate d emissions :

• Test 1 (st andard n ozzle): 1.38 lb/1,000 g al

• Test 2 (min iboot): 0. 494 lb/1,00 0 gal.

• Therefore, Miniboot reduces pressure r elated emissions by 0.886 lb/1000 gal (64 percen t)

• Could not differentiate (quantify ) the effects of ORVR vs non-ORVR vehicles on UST pressures and UST vent emissions due to interferences fr om vehicles simultaneously refueling at other pumps connected to tanks

• Emissions from the fill pipe were measured. ORVR vehicles reduce emissions from the nozzle/fillpipe interface by 0.31 lb/1,000 g al. Therefore, it is concluded that the CARB “ORVR excess emission factor” due to vapor grow th (0.86 lb/1,000 gal) should be offset according ly; i.e., total excess emissions are 0.86

### lb/1,000 g al - 0.31 l b/1,000 g al or 0.55 lb/1,000 g al.

[3] API: ORVR Compatibility Study for the Gilbarco Vaporvac VRS, Febr uary 2004, Phase 2 – Outside

• Outdoor tests using 3000 gallon UST containing 1000 ga llons in a laboratory setting

• RVP: 7.8 summer grade oxyg enated

• Six refueli ng tests on 3 vehic les (two w ith ORVR an d one with out ORVR)

• Measured UST fugitives from P/V vent & pressure related fugitives (the system was first demonstrated to be leak free; then a f ugitive leak rate was controlled using a calibrated needle valve)

• Compared fugitiv es measu red while refuel ing ORVR & non-ORVR v ehicles to determine incompatibility excess emissions

• Compared pressure related fug itives actually measure d to those predicted by CARB cal culation s

Key Results : For standard nozzle:

• Pressure related excess em issions we re calc ulated to be 0.72 lb /1000 ga l.

• Fill pipe emissions for ORVR equipped vehicles were 0.39 lb/1000 gal less than for non-ORVR vehicles (91% reduction)

• Adjusted (“net”) ORVR excess emissions were 0.33 lb/1000 gal. [i.e., pressure rela ted e xcess emiss ions m inus t he sa ving s at th e fil l pipe = 0.7 2-0. 39]

• If us ing thes e corre ctions on d ata ge nerate d from MOB IL E6, the c orrect excess emi ss io n fa cto r to use is 0.4 2 l b/ 100 0 ga l (n ot 0.3 3 l b/ 100 0 ga l) b eca use MOB ILE 6 already accounts for some of the fill pipe reductions achieved by ORVR equipped vehicles by using a 98% control efficiency for ORVR rather than the 95% eff iciency for VRS. For minib oot:

• Pressure related excess em issions we re calc ulated to be zero ( -0.008) l b/1000 g al.

• Fill pipe emissions for ORVR equipped vehicles were less than for non-ORVR vehicle s

• Adjusted ( “net”) ORVR exces s emissions were -0 .39 lb/1000 gal; i.e ., a dec rease in emission s [zero pre ssure re lated exc ess emissi ons minus th e saving s at the fi ll pipe = a re duct ion of 0.39 l b/100 0 ga l].

[4] API: ORVR Compatibility Study for the Gilbarco Vaporvac VRS, Febr uary 2004, Phase 2 – SHED

• Conducted in Sealed Housing for Evaporative Emissions (SHED)

• Thirty-six refueling te sts using procedures similar to the federal ORVR certifi cation te st;

• Three v ehicles (two ORVR, one non- ORVR)

• First checked (validated) ORVR perfor mance (i.e., baseline certification)

• Inve stigate d impact o f:

• RVP 7.1 & 7.8;

### • Temperature: three summertime temperature scenarios (one vapor growth and two vapor shrinkage scenarios) by varying the temperature of the fuel dispensed and vehicle tank)

• A/L r atios (sta ndard no zzle & minib oot);

• Typ e of ORVR e quipment ( recirc ulation or not)

Key Results :

• Fill pipe emissions for ORVR and non-ORVR vehicles fall within the range of values me asured i n the Phase 1 and Phas e 2 - outdo or tests.

• Fill pipe emissions for ORVR equipped vehicles were 0.46 lb/1000 gal less than for non- ORVR vehic les

• For ORVR equipped vehicle s, fill pipe emissions a re insen sitive to c hange s in RVP, delta T, and A/L ratio; there is a positive corr elation of fill-pipe emissions with vehicle tank temperature

• For non- ORVR vehic les, ther e is a posi tive cor relation of fill-p ipe emissi ons with RVP, a negative correlation of fill-pipe emissions with A/L ratio, and a negative correlation of fill-pipe emissions with delta T, as assumed in MOBI LE 6

• fill-pipe emissions for the miniboot (A/L =0.95) were g reater than (about double) the fill pipe emissions with the standard nozzle (A/L =1.15)

• the emissions are greater for the vapor growth scenario (temper ature of fuel in vehicle tank is less than temperature of fuel being dispensed)

• “Puff” l osses (th e puff of emissions w hen the g as cap is removed ) are th e same order of magnitude as fill-pipe emissions for both ORVR and non-ORVR equipped vehicles

### SUMMARY OF EXCESS EM ISSION DATA

All emi ssi on unit s are l b/1000 gals di spensed or [ g/gal ] unle ss oth erwis e noted

Data Source Unit Type/ Test conditions Fill Pipe Emissions (a) (b) P/V Vent Emiss ion (c) Calculated Pressure Related Fugitives (leaks) (d) Total Pressure Related emissions (e = c+d) Total Refueling emissions (f =b+c+d) Excess Emiss ion due to ORVR Incomp. (g) ORVR Emiss ion reduct ion at fill pipe (h) Adjusted Excess Emiss ion due to ORVR Incomp. (i) VRS Return line, HC Conc. % (j)

CARB [1] Scenario 1 Gilbarco VA Baseline: Not measured Negligible 0.396 Not measured Gilbarco VA ORVR: 0.782 0.386

CARB [1] Scenario 2 Dres ser W ayne Baselin e: Not measured Negligib le. 0.028

Dres ser W ayne ORVR: 0.0524 0.0244 Not measured

CARB [1] Scenario 3 Dresser Wayne (with out P/V valve) Baselin e: Not measured Negligible 0.026 0.026

Dresser Wayne (with out P/V valve) ORVR: 0.289 0.289 0.263 Not measured

CARB 0.86 Note

Calcu lated from Scenarios 1 thru 3Data Source Unit Type/ Test conditions Fill Pipe Emissions (a) (b) P/V Vent Emiss ion (c) Calculated Pressure Related Fugitives (leaks) (d) Total Pressure Related emissions (e = c+d) Total Refueling emissions (f =b+c+d) Excess Emiss ion due to ORVR Incomp. (g) ORVR Emiss ion reduct ion at fill pipe (h) Adjusted Excess Emiss ion due to ORVR Incomp. (i) VRS Return line, HC Conc. % (j) Note

API [2] Test 1 Gilbarco VA Standard n ozzle (OPW 11VA1); non-ORVR 0.42 0.823 0.557 1.38 32 %

Gilbarco VA Standard n ozzle (OPW 11VA1); ORVR veh icles 0.11 Not measured 0.31 (73% lessthan nonORVR) 11%

API [2] Test 2 Gilbarco VA With “ miniboo t” (OPW 12VW); non-ORVR 0.42 0.008 0.484 0.494 approx 40% Miniboo t reduces
pressure related fugitives 0.886 lb/10 00 gal (64% reduction) Gilbarco VA With “ miniboo t” (OPW 12VW); ORVR veh icles 0.11 Not measured 0.31 (73% lessthan nonORVR) approx 17%Data Source Unit Type/ Test conditions Fill Pipe Emissions (a) (b) P/V Vent Emiss ion (c) Calculated Pressure Related Fugitives (leaks) (d) Total Pressure Related emissions (e = c+d) Total Refueling emissions (f =b+c+d) Excess Emiss ion due to ORVR Incomp. (g) ORVR Emiss ion reduct ion at fill pipe (h) Adjusted Excess Emiss ion due to ORVR Incomp. (i) VRS Return line, HC Conc. % (j) Note

API [3] Outdoo r test 5; Standard n ozzle non-OR VR 1.53 (check ) 0 (Meas ured) 0.022 (Meas ured) 0.022 NA 33.2 check r un number table 6-4

Outdoo r test 1; Standard n ozzle ORVR veh icle with recirc. 0.024 0 (Meas ured) 0.918 (Meas ured) 0.918 0.896 3.0 CARB: 0.86

Outdoo r test 3; Standard n ozzle ORVR veh icle without recir c. 0.026 (check ) 0 (Meas ured) 0.229 (Meas ured) 0.229 0.207 0.6 check r un number table 6-4

Standard n ozzle ORVR veh icle, wgt. (calc ulate d) 0.025 0.745 (k) 0.7 2 (k) 0.39 (m) (91% lessthan nonORVR) 0.33 2.4 (R TI) Note: fill-pipe reductions calculat ed for these tests = 1.505

API [3] Outdoo r test 6; Miniboot ; non-OR VR 2.11 0 (Meas ured) 0.011 (Meas ured) 0.011 NA 38.8

Outdoo r test 2; Miniboot ; ORVR vehicle with recirc. 0.002 0 (Meas ured) 0.004 (Meas ured) 0.004 - 0.007 5.4

Outdoo r test 4; Miniboot ; ORVR vehicle without recir c. not available 0 (Meas ured) 0.002 (Meas ured) 0.002 - 0.009 7.6

Miniboot ; ORVR vehicle, wgt
average (calc ulate d) 0.003 (k) -0. 00 8 (k) 0.3 9 (m) (91% lessthan nonORVR) -0.39 i.e., zero 6.0 (R TI) Note: fill-pipe reductions calculat ed for these tests = 2.1 averageData Source Unit Type/ Test conditions Fill Pipe Emissions (a) (b) P/V Vent Emiss ion (c) Calculated Pressure Related Fugitives (leaks) (d) Total Pressure Related emissions (e = c+d) Total Refueling emissions (f =b+c+d) Excess Emiss ion due to ORVR Incomp. (g) ORVR Emiss ion reduct ion at fill pipe (h) Adjusted Excess Emiss ion due to ORVR Incomp. (i) VRS Return line, HC Conc. % (j) Note

API [4] SHED Standard n ozzle Non - ORVR 0.32

SHED Standard n ozzle ORVR with recirc. 0.057

SHED Standard n ozzle ORVR without recirc 0.007

SHED Standard n ozzle ORVR Vehicle Wgt Av g. (calc.) 0.045 0.275

API [4] SHED Mini-boot Non - ORVR 0.69

SHED Mini-boot ORVR with recirc 0.054

SHED Mini-boot ORVR without 0.007

SHED Mini-boot ORVR Vehicle Wgt Av g. (calc) 0.041 0.649 Average for Standard & miniboot

= 0.46 (91% lessthan nonORVR) recircData Source Unit Type/ Test conditions Fill Pipe Emissions (a) (b) P/V Vent Emiss ion (c) Calculated Pressure Related Fugitives (leaks) (d) Total Pressure Related emissions (e = c+d) Total Refueling emissions (f =b+c+d) Excess Emiss ion due to ORVR Incomp. (g) ORVR Emiss ion reduct ion at fill pipe (h) Adjusted Excess Emiss ion due to ORVR Incomp. (i) VRS Return line, HC Conc. % (j)

API [4] SHED Vehicle 3 Non - ORVR PUFF (n) 0.321

SHED Vehicle 1 ORVR with recirc PUFF (n) 0.030

SHED Vehicle 2 ORVR without recirc PUFF (n) 0..007

API [4] Vehicle 1: ORVR Certification 0.017 [0.008]

API [4] Vehicle 2: Certification 0.002 [0.001]

EPA Standard for ORVR 0.44 [0.20] (Includes spillage)

ARI D [5] Non-O RVR and ORVR autos [0.0458] for nonORVR;

[0.0092] for ORVR Not Reported (?) Not Reported (?) Not Reported (?)

Or 0.04 2?, based on what Roy did for the API [2] results? Not Reported (?) 0.042 (Roy put this parameter in the “Pressure Releated Fugitives” colum n, when deali ng with API [2] 0.0805 [0.0366] -0.03 85(?) (May b e

wro ng, if the “0.042" belo ngs in the “Pressure related fugitives” column 35.40% for nonORVR; 5.65% for ORVR ORVR Note= me asur ed fi ll pipe di spla cement emis sion s f or non- ORVR vehicl es - measu red f il l pi pe dis place ment emis sion s f or 

### ( a) Re fueling em issions = fill pipe d isplace men t + spillag e per EP A de finition; spillag e not a ddr essed in these d ata (b) Fill pipe emiss ions = fil l pipe displacement emissi ons (c) P/V vent emissions = emissi ons from UST vent pressure /vacuum valve (d) Cal cula ted pr essu re re lat ed (PR) f ugi ti ve emi ssi ons f rom VRS leak s per CARB calcul ati on met hod (e) Total pr essure relat ed emissi ons = P/V vent emi ssi ons + PR fugit ives (f) Total ref ueli ng emiss ions = t otal r efuel ing emi ssi ons by CARB test met hod = Fill pipe dis placement + P/V vent emis sions + calcul ated PR fugi tiv es (sp il lag e es ti mat ed s epar ate ly or by perf orman ce s tan dard of n ozzl e?) (g) Exce ss emissions due to OR VR incomp atibility = total pressure related emissions for O RV R - total pressure related emissions for non -ORV R vehicles ;
No te: the API rep ort refers to excess em issions of pressure-related fugitives sepa rately from P/V emissions

- ORVR emissi ons r educt ions achi eved at fi ll pipe Note: th e API report re fers to th is as “tot al i ncompatibi lit y emis sions ” (j) Avera ge hydrocar bon concentra tion i n the VRS retu rn li ne. (k) Weighted average of OR VR with and without recirculat ion; assumes 75% of OR VR vehicles have recirculati on. (m) A verag e of P hase 1 (in-field) tests a nd S HE D tes ts (n) PUFF = puff of emi ssi ons t hat occur when g as ca p is remove d; meas ured qu anti ty normal ized to ga ll ons di spens ed
NA = N ot Ap plicab le (i) Total adjus ted e xces s emi ssi ons = pr essu re re lat ed exce ss e miss ions due t o ORVR incompati bil it y (h) ORVR emissi on redu cti ons at fi ll pipe
OR VR vehicles NOTES

### Source Company/Org anization (include Title and date): Phase II Balance Sys tem Te st Repor t, Lincoln Te st Site. Hu sky Corpor ation, F ranklin Fueling Systems. June 2005. (Data from F ebruary 1 to March 21, 2005)

. [Submitted by Husky Corporation]

Test Scenario (Describe): The GDF tested is a balance Stage I I VRS. The test w as condu cted to c onclude w hether a n UST vent add-on APCD (i.e., a processor) would be nec essary on the ba lance system to be c ompliant with the EVR UST pressure requirements (CP-201). The test studied the effe cts of the GDF that shut down each night for 6 hours while operating with high RVP winter fuel and with lower RVP fuel. A to tal of 121 ,000 ga l was dispe nsed ove r the test ing time p eriod. A n ISD s yst em was in place. Redun dant m onit oring w as in p lace. T he ISD col lecte d data on system press ure, u llage data, and the nozzle fuel and vapor (V/L ratio), and CARB collected data on sy stem pressure, baromet ric pre ssure, RV P, Static pr essure d ecay test, Dy namic ba ck press ure test, liquid extraction functionality by hose drainage, and ORVR penetration per centage.

Based on tracking ORVR activity over a 13-hour period, 41 percent of g asoline throughput went to ORVR vehicles (1,540 gal/3,745 gal). So, the balance VRS collected vapors for 59 percent of the fuel dispensed, and ORVR controlled the vehicle refue ling vapors for 41 percent of the fue l. For comparison purposes, the percentag e of ORVR vehicles was 42 percent (149/354).

Emissions Testing: None.

Operating Data: Testing was conducted from Febr uary 1 throug h March 21, 2005. Winter fuel (high RVP) was used during the time period February 1 through 28; lower RVP fuel was used during Marc h 1 through 21.

Results and Conclusions Reported : Pressure decay tests were conducted weekly

. The system passed these tests, however, on February 22 the pressure decay test failed; without modification or maintenance, the tank then passed the pressure decay test on February 28. The data from February 16 through February 28
was suspe ct and wa s excluded from the t est and a naly sis.

Pressures and temperatures were monitored c ontinuously. These data indicate both (1) that the system is leak free and (2) the amount of emissions that would be sent to a processor if one wer e in place (i.e., a ny p ositive pr essure g reater than 0 in. w .c.). [No te that no vapor wa s actual ly vented from the UST because the P/V valve was in place and would not open unless pressure reached 3 in. w.c.; it did not over the 36-day period.] The system remains at sig nificant negative
pressur e for lon g perio ds (excee ding 8 ho urs) and this would a lso indica te the sy stem is tig ht (in addition to the pressure decay tests above). There were 3 day s when the pressure flat-lined or remained at 0 in. w.c. for a length of time, indica ting a possible leak. Each of these events wa s explained and/or corrected. The amount of emissions that would be sent to a proce ssor was calculated from the total time when UST pressures were above 0 in. w.c. The UST fugitive and

### vent emissions were calculated to be 7.7 lb of HC and this was extrapolated to an annua l basis of 48 lb/yr that would be controlled by a processor (if one were in place ).

During the 36-day testing period, the CARB daily average pressure w as exceeded on 3 day s and the 30-da y a verag e pressu re was 0 .04 in. w.c . (compa red to the allowed 0 .25 in. w.c .) The da ily hourly maximum pressure was exceede d on 2 days, and the 30- day ave rage hourly maximum pressure was 0.32 in. w.c. (compared to 1.5 in. w.c.)

. The test demonstrates that the balance system meets the pressure profile requirements of CARB’s EVR CP-201, without the use of a
processor.

A comparison of the pressures resulting from the hig h and low RVP fuels was also conducted. For sh utdo wn peri ods (e arly morn ing ho urs wh en pres sures will be high est), the da ily average pressure dropped from -0.04 in. w.c. to -0.45 in. w.c. with the lower RVP fuel. Additional analysis was conduc ted to compare the UST pressures for the two RVP. The analy sis was conducted on a subset of data, specifically for those shut down hours when no fueling is being conducted at the GDF. For the shutdown periods only , the 30-day r olling daily ave rage was 0.35 in. w. c. for R VP of 1 3 psi and was 0.055 in. w. c for R VP of 9 psi. The 30 -day roll ing ave rage hourly maximum pressure was 2.4 in. w.c. for RVP of 13 psi and was 0.51 in. w.c. for RVP of 9 psi. A summary table for e ach RVP is provided.

The V/L ratios were a lso measured for each of the 12 fueling points. The daily avera ges ranged from 0.34 to1.66 across the fueling points (the sensors at 2 of the fue ling points failed and are not included). The average V /L ratios over the 36-day period for each fueling point rang ed from 0.71 to 1.0.

Comm ents: The pressures experienced by the balance sy stem are generally low and the system does not experience vapor releases. These sy stems appear to be vapor tight because sig nificant negative, and occasional positive, pressures are maintained in the tank ove r long periods (several hours and longer) and few to no periods are shown at 0 in. w.c. (if there were, this would indicate leaks)

. For the majority of time, the UST tank is at negative pressure. The neg ative pressures reduce the potential for UST fugitives emissions and UST venting emissions. Positive pressure periods were seen during the study but the frequency , magnitude, and duration are low. Emissions from the positive pressure periods were estimated to be 48 lb/y r.

### Daily Summary of Pressure Data for F riday, March 11, 2005

### Daily Summary of Pressure Data for Saturday, Marc h 12, 2005

### Daily Average Nighttime (2300 to 0500) System Pressures with High RVP Fuel (~13 psi).

### Daily Average Nighttime (2300 – 0500) System Pressures with Low RVP Fuel (~9 psi).

### Source Company/Org anization (include Title and date): UST pressure monitoring data at a GDF in Sacram ento, CA. January and August 2004. [Submitted by Healy , Inc.]

Test Scenario (Describe) : The GDF has a Healy vacuum assist Enhanced Vapor Recovery (EVR) Stage II VRS and a Clean Air Separat or on the U ST; this sy stem is ORV R compatib le. An I SD sy stem is als o installed.

Emissions Testing: None.

Operating Data: UST pressure measurements were shown with and without the Clean Air Separator operating. Pressure data are shown for:

(1) su mmer f uel in August (Augus t 11-1 7) wit hout the Cl ean Ai r Sepa rator operat ing, (2) for summer fuel in August (August 25-31) with the Clean Air Separator operating with a simulated fugitive leak, and (3) for winter fuel in January (December 31-January 20) with the Clean Air Separator operat ing.

The Clea n Air Sepa rator is a tank with a n expanda ble bladd er that a ccepts v apor fr om the UST and reduces UST vent emissions and UST fugitive emissions that result from positive pressures. When UST pressures exceed +0.15 in. w.c., the UST vents to the flexible bladder where the vapor is c ontained

. The con version o f a vacu um assist Sta ge I I VRS to an ORVR co mpatible Stage II VRS includes replacing the vacuum source (pump), hose assembly, and the nozzle.

Results an d Conclusions Reporte d: Without the UST Clean Air Separator in place (August 11-17 data), the pr essures range from approximately -9 in. w.c. to +3 in. w.c. D uring operating hours when the GD F was dispensing fuel from the UST, the UST pressures decrease d and significant negative pressur es were maintained. During nighttime hours when the GDF w ould be closed and not operating, there was consistent pressure increase, indicating va por growth. The pressures during off-hours were often above 0 in. w.c., indicating pressurization of the tank and possible fug itive emissions. The pressures rose to +3 in. w.c. on some nights, indicating P/V valve ve nting and UST vent emissions a nd UST fug itive emis sions as we ll.

The August 25-31 pressure data g raphs with the UST Clean Air Separator and with a simulated fugitive leak show pressures rang e from -8 in. w.c. to approximately 0 in. w.c

. There were a few momentary spikes in pressure (as high as +4.5 in. w.c.) with return to 0 in. w.c. Duringoffhours, there was consistent pressure increase , indicating vapor growth. There are minimal epi sod es a bov e 0 i n. w .c. bec aus e th e US T is ven ted to th e fl ex ib le b lad der at + 0.1 5 i n. w .c. (If the Clean Air Separator was not in place, significa nt positive pressures would not be maintained due to the leak tha t was simula ted durin g this te sting sc enario. ) During operati ng hour s, the UST

### pressures decrease to significa nt negative pressures, however, w ith the simulated leak, not as much vacuum is pulled on the UST (i.e., the pressures do not appear to be a s negative as shown in the “tight” UST data above).

With the UST add-on APCD in place (January data ), the pressure ranges fr om approximately -9 in. w.c. to just above 0 in. w.c. During operating hour s when the GDF was dispensing fuel from the UST, the UST pressures decrease and sig nificant negative pressures are maintained. During nighttime hours when the GDF would be closed and not oper ating, there was consistent pressure increa se, indic ating va por gro wth. Howe ver, the re are minimal ep isodes ab ove 0 in. w .c. bec ause the UST ve nts to the f lexible bla dder at + 0.15 in. w. c. Ther e are a few mome ntary spikes in pressure with immediate return to 0 in. w.c. The daily average V/L ratio at the two pumps for the January time period rang ed from 0.95 to 1.1 over this time period.

Comm ents: Based o n these da ta, the He aly EVR sy stem with th e Clean A ir Separ ator on th e UST doe s limit positive pressure periods in the UST, reducing the potential for f ugitive emissions and reducing UST venting periods that occur when the pressure rises to +3 in. w.c. or greater. Sig nificant negati ve press ures ar e maintai ned durin g oper ating ( i.e., disp ensing) hours.

### Source Co mpany/Or ganizatio n: Summary of th e Eval uati on fo r Phase II Ba lanc e Typ e Vapo r Recov ery Sy stems Interac ting with On-Bo ard Refuel ing Vapor R ecover y (ORVR) Equipped Vehic les. Data collecte d in Dece mber 2002

. [Submitted b y EM CO Wheaton Retail]

Test Scenario: The GDF has a balance Stag e II VRS. Pressure measurements of the UST were taken fr om December 4-10 in California. The vehicles re fueled at the facility were 100 percent ORVR. The GD F c lo se s f or 8 h ou rs pe r d ay.

Results and Conclusions Reported : The pressures in the UST ranged fr om -2.6 iwc to +0.15 iwc over a 7-day period. A total of 486 vehicle fuelings were conducte d and a total of 2,816 gal were dispensed. The pressures seemed consistent with typical UST pressures f or refueling with higher pre ssure during nighttime hours when the GDF was closed and not dispensing fu e l and with negative pressures during op e rating hours whe n the GDF is dispens ing fue l (althoug h the date s and times were no t specifi cally delineated on the graph). The UST pre ssures were less than or equal to 0 iwc for 95 per cent of the operating time and was gr e ater than 0 iwc and less than +0.25 for 5 per c ent of the operating time.

The pressure data indicate that the balance S tage II VRS used to fuel ORVR vehicles will not generate excess emissions from the UST due to ORVR refuelin g s. Because the UST pressures are negative most of the time with a small amount of time at positive pressures, fu g itive emissions and UST vent emissions are minimized.

Com m ents: None.

### Source Co mpany/Or ganizatio n: Test Report for the Arid Technologies Vapor Recovery Unit Installed at the Costco Gasoline Station, Lantana, Florida. Testing conducted in February 2005. The dra ft repor t is undated (appears to be circa Mar ch 2005).

Test Scenario: Emissions testing was conducted at the Costco retail gasoline station to demonstrate the c apture efficiency of an UST add-on APCD on the UST and to compare the UST vent stack emissions when the add-on A PCD is oper ating ( on) and n ot opera ting (of f). The G DF has a vacuum a ssist Stage II VRS. The add-on APCD is Arid Technologies I nc. vapor control unit called the PERMEATOR. ® 

### This device is used to control VOC emissions from the UST vent during gasoline dispensing operations. The PERMEATOR® is a membrane sy stem that allows gasoline vapors to pass through and back to the UST; air is prevented f rom permeating the membrane and is vented to the atmosphere.

The test period was continuous and lasted approximately 72 hours. Sampling was conducted at the outlet vent of the USTs when the add-on APCD was not operating. Sampling w as conducted at three locations on the add-on APCD while it was operating. Te sting was conducted with and without the P/V valves in place; these conditions are referre d to in the test report as “Vent Off” and “Vent On,” respectively

. The number of ORVR vehicles fueled at the fac ility during the testing periods is not known.

Operating Data: A grap h of UST pr essure d ata for periods w ith and wit hout the a dd-on APCD (and with the P/V in place) is provided. While the add-on APCD was operating, the UST pre ssure is maintained at approximately 0.5 in. w.c with the majority of measurements ranging f rom 0.3 to 0.9 in. w.c. Venting to the add-on APCD occurs when pressure s within the tank reach approximately 0.5 in.

w.c. While the add-on APCD is operating, the P/V valve never opens be cause the UST does not reach sufficient pressure, so there are no UST vent emissions. In addition, because pressurization above approximately +0.5 in. w.c . does not occur, UST fugitive emissions may also decrease. When the add-on APCD is not operating, the pressures are ty pically at approximately 3.3 in. w.c. The UST pr essure w ill incre ase to ap proximatel y 3 i n. w.c. a nd then the P/V valve will open t o releas e the pre ssure an d gasoli ne vapor s to the atm osphere

. UST vent e missions ar e occur ring in addition to UST fug itive emis sions.

Results an d Conclusions Reporte d: Test results were as shown in the table below.APC D off with P/V val ve APCD on with P/V val ve 

### Emissions Testing Results for UST Vent Add-on A PCD.

Test C ondition s

Te st Da te

Gasoline Loaded, gal

Av er ag e I nl et Co nc en t ra t i on , % C 3

Av er ag e O ut l et Co nc en t ra t i on , % C 3
Average Hydrocarbon Emi ssi on, lbs /1000 gal

Hydrocarbon Emissi on Rate, lb/24hr

Hyd roca rbo n Re mov al Efficien cy, % (m ass basis)

Amb ient T, °F

UST tempera ture, °F

RV P, p sia

V/L ratio **

Fuelin g rate, ga l/min

Per cent O RV R ve hicles fue led, % APC D off without P/ V valve

Februa ry 14- 15, 2005

19,186

NA

39.79

3.48

66.84

NA

71°F

74°F

11.1

0.97

8 Februa ry 16- 17, 2005

18,908

NA

41.58

1.20 *

22.75 *

65

. 5% *

71°F

74°F

11.1

0.97

8 Februa ry 15- 16, 2005

19,121

38.52

0.72

0.014

0.27

99.3%

71°F

74°F

11.1

0.97

8

Not known Not known Not known * Due to a leak, fugi tive emissi ons were released to the atmosphere during UST pressurization periods; the amount of fu git ive emi ssi ons (i .e., gasoli ne vapors) releas ed are not qua nti fiabl e. ** Th e V /L ratio w as calc ulated base d on an ave rage fo r regula r gaso line on ly, at fueling p oints 7 throug h 12 while the GDF was closed a nd on fuel ing poin ts 1 t hrough 6 whi le t he GDF was open. The majorit y of ga soli ne pumped durin g the test w as regu lar fuel.



### Comments: The testing demonstrates that the P/V valve may reduce UST vent emissions. When P/V valves

were no t in place , emissions were 3. 48 lbs/1,00 0 gal (6 6.84 lb/24h r). When t he P/V val ve was in place, emissions were reduced to 1.20 lbs/1,000 gal (22.75 lb/24hr) ; while the UST vent emissions may have bee n reduced, there were fug itive emissions occurring due to UST sy stem leaks during this test due to vapor growth and pre ssurization of the tank. The amount of fugitive emissions, (i.e., gasoline vapor leaks) were not qua ntified but would likely show similar emissions levels to the uncontrolled scenario for the UST vent emissions (no P/V valve, with no add-on APCD).

The testi ng demo nstrates that the U ST add-on APCD, the PE RMEATOR® m embrane sys tem, was effective in separating g asoline vapor from air and returning the va por to the UST, thereby reducing UST vent emissions to the atmosphere. With the add-on APCD operating, UST vent emissions were reduced to 0.014 lb/1,000 gal (0.27 lb/24hr); the ca lculated control efficiency (mass basis) was 99.3 percent. The Permeator sy stem also limits positive pressures in the UST,

### reducing the potential for fugitive e missions and reducing UST venting periods that occur whe n pressure rises to +3 in. w.c. or grea ter.

### Source Company/Org anization (include Title and date): Husky MO/PETP Testing Final Report, Citgo Express Mart, Fe stus, Missouri. July 1997 through March 1998. Prepared by Environmental Solutions, Inc., for the Missouri Department of Natural Resources (MD NR). [Submitted by RSA]

Test Scenario (Describe): The Citgo Express Mart uses a balance Stage I I VRS with P/V valves on the UST vents. There are 3 USTs manifolded together. During the test period, two Husky nozzles were teste d. Husky nozzle model 5210, V long was tested with an 109-vehicle matrix, while Husky nozzle model 5010, V shor t was teste d with an 10 7-ve hicle matr ix.

Emissions Testing Data: The following MO/PETP tests were conducted:

• Bench T esting ( MO/TP-201 .2B) - r equires bench te sting of nozzles, P/V v alves, drain valves for transition flow, and leak rates

• Dynamic Pressure (Back Pressure) Testing ( MO/TP-201.4)

• Static Pressure (Leak De cay) T esting (MO/TP-201.3)

• Liquid Removal Test (MO/TP-201.6)

• Stage I Eff iciency Te st (MO/TP-201.1)

• Stage II Efficiency Test (MO/TP-201.2)

• Spillage and Pseud o-Spillag e (MO/TP- 201.2C)

The liquid removal test had not been previously performed in Missouri. This test proved to be difficult and questions regarding the va lidity and applicability of some of the test procedures came to li ght. The State ag ency felt that the test pr oblems we re not sig nifican t to the ove rall test program, and the age ncy dec ided to rewrite the test method.

Operating Data: Continuous T and P data were taken for a 180-day period as part of the testing; these data include T and P of the UST, ambient temperatures, barometric pressur e but were not provided as part of the repo rt.

Results an d Conclusions Reporte d: Test res ults are s ummarized in the tab le below. The bala nce Stag e II VRS at the Ci tgo Expre ss Mart passed the overall efficiency at 97 percent (the overall efficienc y for Missouri is based on the Stage I, vehic le refueling, spillage, and UST emissions). Both Husky nozzles were

recomme nded for approva l to be use d with othe r approv ed balan ce VRS.

### Table 1 - Summary of Stage I and Stage II Te st Results

Efficiency Relative to Uncontrolled System

Source

Loading (Stage I) 13.6 [AP-42 E F equation] 0.0 [meas ured] 0.0 [meas ured] 100% 100%

Vehicle Fueling 14.6 [AP-42 E F equation) 0.64 a [emissions

mea surem ent] 0.63 a [emissions

mea surem ent] 95.6% 95.7%

Spil lage /Pseu doSpillage 0.46 0.083 [meas ured] 0.10 [meas ured] 82.0% 78.3%

Breathing (Pressure Related Fugi tiv es from com pon ents such as P/V valves and no zzles) 1.00 [AP-42 EF] 0.16 [cal cula ted] 0.16 [cal cula ted] 84.0% 84.0%

TOTAL 29.7 0.88 0.89 97.0% 97.0% Uncontrolled System (without VRS)

lbs /1, 000 gal Pump 9 Husky 5010 (V Sho rt),
lbs /1, 000 gal Pump 10 Husky 5210

(V Lon g),
lbs /1, 000 gal Pump 9 Husky 5010,

(V Sho rt) Pump 10 Husky 5210,

(V Long)

a A portion of this val ue was due to evaporation of liquid droplets on t he nozzle after completion of each f ueling event and really be longs in the spillag e/pse udo spillage catego ry.



### Comment: The summary did not specify if any of the ve hicles tested were ORVR-equipped. RSA indicated that there we re possib ly 3 or 4 ORVR- equipped vehicle s tested d uring th e test pro gram.

Notes on Specific Emissions Factors : The vehi cle fue ling EF may be ty pical of other GD F with ba lance Sta ge I I VRS, with simila r RVP, (percent ORVR is not known). The UST vent and fugitive EF may be typical of other GDFs with balance Stage I I VRS, with P/V valve, with similar RVP (percent ORVR is not known). The spilla ge EF m ay be ty pical of other GD F with simi lar nozzles

.

### Source Company/Org anization: OPW MO/PETP Testing Final Report, Mobil Mart, St. Louis, Missouri, May 1998 through December 1998. Prepar ed by Environ mental Solutions, Inc ., for the M issouri De partme nt of Natural Resources (MDNR). [Submitted by RSA]

Test Scenario: The Mobil Mart uses a balance Stage I I VRS with P/V valves on the UST vents. There are 4 USTS all manifolded together. A total of 205 vehicles were te sted; 5 of these were ORVR vehicles, and this percentage is repr esentative of the actual fleet (2.4%).

Emission Testing: The following MO/PETP tests were conducted:

• Bench T esting ( MO/TP-201 .2B) - r equires bench te sting of nozzles, P/V v alves, drain valves for transition flow, and leak rates

• Dynamic Pressure (Back Pressure) Testing ( MO/TP-201.4)

• Static Pressure (Leak De cay) T esting (MO/TP-201.3)

• Stage I Eff iciency Te st (MO/TP-201.1)

• Stage II Efficiency Test (MO/TP-201.2)

• Spillage and Pseud o-Spillag e (MO/TP- 201.2C)

Operating Data: Continuous T and P data were taken for a 180-day period as part of the testing; these data include T and P of the UST, ambient temperatures, barometric pressur e but were not provided as part of the repo rt.

Results an d Conclusions Reporte d: Test results are shown in the table below:

### Summary of Stage I and Stage II Test Results

Source Uncontrolled System (without VRS)

lbs /1, 000 gal Bal anc e VRS
lbs /1, 000 gal Effi cienc y Relati ve to Uncontrolled System

Loading (Stage I) 16.5 [AP-42 E F equation] 0.0 [meas ured] 100%

Vehicle Fueling 14.6 [AP-42 E F equation] 0.79 [emissions

mea surem ent] 94.6%

Spillage/Pseudo-Spillage 0.46 0.02 [meas ured] 97.8%

Breathing (Pressure Relat ed Fugi ti ves f rom

com pon ents suc h as P /V valves and no zzles) 1.00 [CARB EF] 0.06 [meas ured] 94.0%

TOTAL 32.6 0.87 97.3%



### Comm ents: Notes on Specific Emissions Factors : The vehicle fueling EF may be typical of other GDF with balance Stage I I VRS, with similar RVP, perc ent ORVR. The UST ve nt and fug itive EF m ay be ty pical of other GD Fs with ba lance Sta ge I I VRS, with P/V valve , with simila r RVP, per cent ORV R. The spilla ge EF m ay be ty pical of other GD F with simi lar nozzles

. As an additional analysis, RSA went bac k to the original test data and considered the impact of ORVR on Stage II balance sy stems. RSA noticed a reduction in the average emissions factor when both ORVR and Stage II balance sy stems were used at the same time. I t is not clear wheth er the e miss ions factor given i s for v ehicl e refue ling o nly or rep resent s an ov erall average emissions factor. The table below shows the data.

1998 1998 

### Impact of ORVR on a Stage I

M odel Year 

### e VRS I Balanc

1999

ORV R-equipped No Yes Yes

Number of ORVR -equipped Vehic les 11 5 6

Average Emiss ions Fact or, l b/1,000 gal 0.302 0.050 0.042

Std Devi ati on of Emi ssi ons Fac tor 0.621 0.045 0.046

Ave rage V apo r Rec ove ry Efficien cy, % 98.1 99.7 99.7

Std D eviatio n of V apo r Rec ove ry Efficien cy, % 3.99 0.29 0.29

### Source Company/Org anization (include Title and date): DaimlerChrysler Corporation St. Louis Assembly Plant - South, MOP ETP Testing Final Report, January 2001 through February 2002. Remot e Sensing Ai r, Inc . for Missouri Department of Natural Resources. May 28, 2004

. [Sent by RSA]

MO/PETP Testing Report for DaimlerChrysler Corporation St. Louis Assembly Plant - South, Final Report. URS Corporation for Daimler Chrysler Corporation. January 30, 2003. [Sent by AAM]

Addendum t o the MO/P ETP Test ing Report for Daim lerChry sler Cor poration St . Louis Assembly Plant - South, Final Report, for the Single Canister On-Board Refueling Vapor Recovery System MO-P ETP Testing Conducted on February 8, 2003. URS Corporation for Daimler Chrysler Corporation. October 16, 2003. [Sent by AAM]

Approval Letter 2004-03 for DaimlerChrysler St. Louis South Assembly Plant. F rom R. Randolph, MDNR, to T. Tecklenburg, DaimlerChrysler Corporation. [Sent by AAM]

Test Scenario (Describe): All vehicles from the production area are O RVR, i.e., fuel 100 percent ORVR vehicles. The GDF has a different config uration than traditional. There are two fueling areas, with no return of vapors f rom the a ssembly line fue ling ar ea to the UST, i.e., no Stage II VRS, and a satellite fueling area, with a balance vapor recovery nozzle that returns vapors to the UST. Fueling at the satellite fueling area is restricted to ORVR vehicles a nd fueling on weekends is to be limited. The satellite fueling area has a thr oughput of approximately 1.4 pe rcent, i.e., minimal impact. There are three 20,000 g al USTs located in a tank farm. Gasoline is chilled prior to fueling. The three vent pipes from the USTs are [vapor] manifolded to one vent with a P/V valve. For fueling emissions testing, emissions were collected using a sleeve a round the nozzle interface to collect emissions e scaping from this a rea; the emissions f rom the OR VR canist er vent w ere col lected in a second sleeve. (The plant had a Ha sstech processor/incinerator as the main vapor re covery control p rior to pr oduction o f all ORVR v ehicles but MDNR ha s since a llowed the facility to remove it; the Hasstech incinerator controlled vehicle f ueling emissions.) The State agency allowed the facility to r emove Stage II VRS for MY2001, i.e., in 2000. Some emissions informat ion is base d on calc ulations.

Emissions Testing Data: The following MO/PETP tests were conducted:

• Bench T esting ( Modified MO/TP-201 .2B) - r equires bench te sting of nozzles, P/V valves, drain valves for transition flow, and leak rates

• Static Pressure (Leak De cay) T esting (MO/TP-201.3)

• Stage I Eff iciency Te st (MO/TP-201.1)

• Continuous monitoring of storage tanks

• Stage II Efficiency Test (Modified MO/TP-201.2), both dual and single canister ORVR testing

• Spillage and Pseud o-Spillag e (MO/TP- 201.2C)

### Operating Data: Continuous T and P data of the USTs are available for September 9 throug h December 20, 2001, for a tota l of 103 da ys. Data ar e availa ble for 1 46,302 minu tes out of 148,320 po ssible minu tes, or 98.6 percent of the time period. The data ava ilable for all 103 day s are shown in an attached table along with the daily average pressures a nd the minimum and maximum 1-min P value for each day

. Pressures for a ty pical weekday are shown in an attached gra ph for Wednesday October 17; pressures for a ty pical weekend day , when the facility is c losed for 2 days, a re shown in an attached graph for Sunday October 21. The weekday graph shows increasing pre ssures (due to vapor growth) overnig ht and negative pressures during the day while fue ling operations are occurring. The a verage P for the weekda y was -3.09 in. w.c . (minimum 1-min P of -7.69 and maximum 1-min P of +1.67 in. w.c.)

. The wee kend day graph shows con tinued va por gro wth and positive pressure for the entire day ; the average P for the day was +2.45 in. w.c. (minimum 1-min P of +1.68 and maximum 1-min P of +2.99 in. w.c.).

Freque ncy plot of all P data

. A gra ph showing the fre quency of press ure for the 103 da y pe riod is also provided. The pressure is greate r than 0 in. w.c. for 43,265 minutes, or 29.6 percent of the time; pressure related fugitive emissions are likely to be occurring during these time pe riods. The pre ssure is g reater than 3 in. w .c for 6, 249 minute s, or 4.2 p ercent of the time period; U ST vent emissions are likely occ urring during these period when the P/V valve opens. Because the facility fixed a leak on Nove mber 19, the frequency plots are shown for the time period before and after the leak.

Frequency plot for P data before and after a lea k is fixed

. September 9 through November 19. A freque ncy plot f or the time perio d befo re the l eak was fixe d, fro m Sep tembe r 9 thr ough November 19, is provided. A frequency plot for the period after the leak was fixed, November 20 throug h Decem ber 20, is also prov ided. The “befor e” time pe riods show that the U ST remains at the most negative pressures for a pproximately half of that following the leak fix (19
per cen t v s. 4 8 pe rce nt ), i .e. , wi th th e le ak f ix , t he t ank can mai nt ain neg ati ve p res sur es b ett er. In addition, the UST in g eneral will mainta in positive pressur es for lo nger p eriods ( 4.72 per cent) than before the leak fix (4.08 percent); UST vent and fug itive emissions occur during positive
pressur e period s. For a vapor tig ht UST, the positive p ressure s are ma intained and UST emissions occur from the UST vent. For a leaking U ST, positive pressures are not maintained as long b ecause fugiti ve leak s are oc curri ng.

The total pressure related fugitive and U ST vent emissions were calculated to be 281.3 lb over the 103 da y tim e period ; with a fu el throug hput of 885 ,450 ga l, the emis sions fac tor for U ST fugitives and vent emissions is 0.32 lb/1,000 gal. [This value is slightly hig her than the value reported by the facility in the test repor t, however, no explanation as to why is given.]

### Analysis of F requency Plots for UST Pre ssure for A ll Data and Be fore and Afte r the F ixing Leak

Pressure
ranges, in.

w.c. All data Before leak is fixed After leak i s fi xed

minutes % minutes % minutes %

< -8.0 40,809 27.9% 19,680 19.2% 21,129 48.3%

-8.0 < P < 0.0 62,137 42.5% 50,166 48.9% 11,971 27.4%

<0 .0 102,946 70.4% 69,846 68.1% 33,100 75.7%

>0 .0 43,265 29.6% 32,651 31.9% 10,614 24.3%

>3 .5 6,249 4.27% 4,184 4.08% 2, 065 4.72%



### Results an d Conclusions Reporte d:

Summary of Emissions Factors a nd Efficiency Determinations for both St age I and St age II ( single canister ORVR). [This is the type or canister currently used; single canister is used on MY2003 and later.]

Source Uncontrolled System [in MY2001/2002 mock up tank s] lbs/1,0 00 gal

Loading (Stage I) 13.5 [AP-42 E F eqn]

Vehicle Fueling 17.56 [emiss ions m easur eme nt]

Spillage/Pseudo-Spillage 0.75 [ CARB EF ]

Breathing (Pressure Related F ugitives) - UST em - f

ugit ives 1.0 [modif ied AP- 42 EF]

TOTAL 32.87 Contro lled MY2003 ­ mockup, lbs/1,0 00 gal Efficien cy Relat ive to Uncontrolled System

0.13 [meas ured]

0.0779 [emissions

mea surem ent]

0.48 [meas ured]

0.24 [cal cula ted ba sed on P, T, ti me]

0.93 99.0%

99.6%

36.0%

76.0%

97.2%
Uncontrolled: No chilling, no OR VR, no Stage II VR S, w/ P/V valve [some vapor return f rom satell ite f ueling balance nozzle, but small i mpact because less gasoline t hroughput]. Cont rol led : w / Ch il li ng, w/ ORVR single , No Stage II VRS, w/ P/V valve. [The controlled breathing emissions es timated from the data are 0.32 lb/1, 000 gal, which does the value shown here

as pro vided by the fac ility in the test rep ort. 

### ]

### Summary of Emissions Factors a nd Efficiency Determinations for Stage II alone ( single canister ORVR).

Source

Vehicle Fueling

Spillage/Pseudo-Spillage

Breathin g (Pressu re Relat ed Fugitives) - UST em - f

ugit ives

TOTAL Uncontrolled System [in MY2001/2002 mock up tank s] lbs/1,0 00 gal

17.56 [emiss ions m easur eme nt]

0.75 [CARB EF]

1.0 [modif ied AP- 42 EF]

19.31 Contro lled MY2003 - mockup, lbs/1,0 00 gal

0.0779 [emissions

mea surem ent]

0.48 [meas ured]

0.24 [calcu late d based

on P, T, ti me]

0.7979
Uncontrolled: No chilling, no OR VR, no Stage II VR S, w/ P/V valve [some vapor return f rom satell ite f ueling balance nozzle, but small i mpact because less gasoline t hroughput]. Contr oll ed: w / Chi ll ing , w/ ORVR singl e, No St age I I VRS. [The controlled breathing emissions es timated from the data are 0.32 lb/1, 000 gal, which does the value shown here

as pro vided by the fac ility in the test rep ort. 

### ]

Summary of Emissions Factors a nd Efficiency Determinations for both St age I and St age II ( dual Efficien cy Relat ive to Uncontrolled System

99.6%

36.0%

76.0%

95.87%



### canister ORVR). [Dual canisters are no longer in use after MY2002.]

Source

Loading (Stage I)

Vehicle Fueling

Spillage/Pseudo-Spillage

Breathin g (Pressu re Relat ed Fugitives) - UST em - f

ugit ives

TOTAL Uncontrolled System [MY2001/200 2 mock up tank s] lbs/1,0 00 gal

13.5 [AP-42 eqn 3-1]

17.56 [emiss ions m easur eme nt]

0.75 [CARB EF]

1.0 [modified AP-42 eqn]

32.87 Controlled MY2001/2002,

lbs/1,0 00 gal

0.13

0.014 [emissions

mea surem ent]

0.48 [meas ured]

0.24 [ calc ba se d o n P
, T, time]

0.86 Efficien cy Relat ive to Uncontrolled System

99.0%

99.9%

36.0%

76.0%

97.4%
Uncontrolled: No chilling, no OR VR, no Stage II VR S, w/ P/V valve [some vapor return f rom satell ite f ueling balance nozzle, but small i mpact because less gasoline t hroughput]. Co ntrolled : w/ Chilling, N o Sta ge II V RS , w/OR VR dual. [The controlled breathing emissions es timated from the data are 0.32 lb/1, 000 gal, which does the value shown here

as pro vided by the fac ility in the test rep ort. 

### ]

### Summary of Emissions Factors a nd Efficiency Determinations for Stage II alone ( dual canister ORVR).

Source Uncontrolled System [in MY2001/2002 mock up tank s] lbs/1,0 00 gal Controlled MY2001/2002,

lbs/1,0 00 gal Efficien cy Relat ive to Uncontrolled System

Vehicle Fueling 17.56 [emiss ions m easur eme nt] 0.014 [emissions

mea surem ent] 99.9%

Spillage/Pseudo-Spillage 0.75 [CARB EF] 0.48 [meas ured] 36.0%

Breathin g (Pressu re Relat ed Fugitives) - UST em - f

ugit ives 1.0 [ modified AP-42 eq n] 0.24 [ calc bas ed on P, T, time] 76.0%

TOTAL 19.31 0.734 96.2%
Uncontrolled: No chilling, no OR VR, no Stage II VR S, w/ P/V valve [some vapor return from satell ite f ueling balance nozzle, but small i mpact because low gasoline throughput]. Co ntrolled : w/ Chilling, N o Sta ge II V RS , w/OR VR dual.



### Comments : Because the leak deca y test is conducted during off-production hours when there is continual pressurizing of the tank with vapor growth, the g rowth may mask a le ak greater than the allowed
amount. MO DNER recommended that it might be more productive to require continuous monitoring for one month ever y 5 y ears ra ther tha n the lea k decay test.

The operating data for the UST pre ssures show that the system is at positive pressure (i.e., greater than 0.0 in . w.c.) f or 720 hou rs out of th e 103 day period, o r 29 perc ent of the time. Be cause gasolin e dispens ing stops for long er peri ods over w eekend s in additio n to overn ight per iods, these UST s likely operate at positive pressur e for a h igher p ercent age of time than w ould likely be seen at traditional uncontrolled GDF. These per iods at pressures greater than 0.0 in. w.c . are when UST fugitive and vent emissions occur.

Chilling of the gasoline suppresses vaporization and therefor e emissions, so vehicle fueling emissions a re lower than they would be o therwise at ambien t condition s. Chilling of gaso line is a unique operating condition that is used at several, but not all, fac ilities nationwide; chilling may not be representative of automobile manufacture rs nationwide.

The gr een tank effec t, i.e., no gasolin e vapors present prior to f ueling, may affec t the vehi cle fueling emissions, likely af fects the refueling emissions levels. AAM has indicated tha t refueling emissions would be lower with the green tank effe ct, however, one State agency indicated that the emissions may be highe r, particularly for the immediate splash into the vehicle tank, then the emissions would be similar to re fueling emissions for the remainder of the fue ling event. At any rate, these da ta may not be represent ative of trad itional re fueling at GDF.

### The emissions levels from the UST tank are essentially similar to an uncontrolled UST (i.e, no Stage I I VRS)with a P/V v alve and may be repr esentat ive of tra ditional r efuelin g at GDF , with one noted differe nce. One differe nce in the UST emissio ns would be that the f acility typ ically fuels on Monday throug h Friday a nd shut downs over the weekend (i.e., no fueling ope rations for a 2-day pe riod), causing an extended vapor gr owth period and more UST fugitive and vent emissions. A traditional GDF would be open 7 day s per week without an extended shut down or
vapor g rowth pe riod. The emissions l evels fo r UST emiss ions shown in this rep ort may actually be higher than U ST emissi ons from a tr aditional GDF.

Notes on Specific Emissions Factors : Uncontr olled veh icle fue ling EF s with ambi ent T fue l may be affe cted by the gre en tank e ffect. Vehicle fueling EFs with ORVR-control with ambient tempera ture fuel may be affected by the
green tank eff ect. Vehicle fueling EFs with ORVR-control and with chilled g asoline may be lowe r because of the lower va por pres sure of t he gas oline and may be affe cted by the gre en tank e ffect. Vehicle fueling EFs with chilled ga soline may be lower because of the lower vapor pressur e of the gas oline and may be affe cted by the gre en tank e ffect. Uncontrolled UST vent and fugitives EF with P/V valve may be similar to other uncontrolled tanks (i.e., non-Stage I I VRS) with one noted differenc e, increased UST emissions related to the lo ng er sh ut do wn pe ri od s o f t he fa ci li ty.

### Daily Average Tank Pressures from September 9 to December 20, 2001

Date CountOfTP_"WC Percent Complete AvgOfTP_"WC MinOfTP_"WC MaxOfTP_"WC 9/9/2001 1439 99.93% 1.21 0.033 3.046 9/10/2001 1440 100.00% -6.42 -9.62 0.375 9/11/2001 1440 100.00% -2.62 -9.59 3.296 9/12/2001 1440 100.00% -5.37 -9.69 3.025 9/13/2001 1440 100.00% -5.91 -9.81 3.785 9/14/2001 316 21.94% -2.06 -7.69 2.69 9/15/2001 1440 100.00% -5.03 -8.98 3.506 9/16/2001 1440 100.00% 1.09 -7.01 3.104 9/17/2001 1440 100.00% -4.10 -9.49 3.171 9/18/2001 1440 100.00% -5.34 -9.44 3.83 9/19/2001 1440 100.00% -6.66 -9.25 1.19 9/20/2001 1440 100.00% -6.59 -9.65 0.939 9/21/2001 1440 100.00% -4.60 -9.2 0.874 9/22/2001 1440 100.00% -3.02 -9.26 2.909 9/23/2001 1440 100.00% 2.27 0.428 3.199 9/24/2001 1440 100.00% -5.08 -9.59 0.424 9/25/2001 1440 100.00% -5.75 -9.57 3.7 9/26/2001 1440 100.00% -5.33 -9.91 4.451 9/27/2001 1440 100.00% -4.58 -9.59 2.578 9/28/2001 1440 100.00% -5.79 -9.52 0.968 9/29/2001 1440 100.00% 1.44 -6.571 3.115 9/30/2001 1440 100.00% -0.57 -9.77 2.98 10/1/2001 1440 100.00% -4.10 -8.67 0.727 10/2/2001 1439 99.93% -5.91 -9.43 0.229 10/3/2001 1440 100.00% -3.75 -9.42 1.61 10/4/2001 1440 100.00% -4.00 -8.97 0.433 10/5/2001 1440 100.00% -4.03 -9.05 1.44 10/6/2001 1440 100.00% 1.95 -5.371 3.29 10/7/2001 1440 100.00% 2.83 2.491 3.141 10/8/2001 1440 100.00% -0.43 -8.77 2.813 10/9/2001 1440 100.00% -3.09 -8.03 1.205 10/10/2001 1440 100.00% -2.72 -6.986 2.324 10/11/2001 1440 100.00% -2.55 -7.23 1.681 10/12/2001 1440 100.00% -1.99 -4.023 1.561 10/13/2001 1440 100.00% -5.24 -9.19 2.985 10/14/2001 1440 100.00% -0.26 -8.83 1.772 10/15/2001 1440 100.00% -4.23 -9.21 0.497 10/16/2001 1440 100.00% -3.39 -7.67 2.471 10/17/2001 1440 100.00% -3.09 -7.69 1.669 10/18/2001 1440 100.00% -4.03 -9.19 0.453 10/19/2001 1440 100.00% -4.76 -9.79 3.46 10/20/2001 1440 100.00% 1.92 -4.306 3.106 10/21/2001 1440 100.00% 2.45 1.679 2.993 10/22/2001 1440 100.00% -4.64 -9.65 2.851 10/23/2001 1440 100.00% -5.02 -9.03 2.332 10/24/2001 1440 100.00% -4.76 -9.8 1.642 10/25/2001 1440 100.00% -5.54 -9.99 1.795 10/26/2001 1440 100.00% -4.35 -9.91 4.733 10/27/2001 1440 100.00% -1.45 -6.871 3.198 10/28/2001 1439 99.93% 1.38 -2.688 3.123 10/29/2001 1440 100.00% -3.62 -9.83 2.911 10/30/2001 1440 100.00% -4.48 -9.8 3.434 10/31/2001 1440 100.00% -4.52 -9.66 3.557

11/1/2001 1440 100.00% -6.30 -10.05 2.944 11/2/2001 1440 100.00% -7.69 -9.89 0.008 11/3/2001 1440 100.00% -3.53 -9.48 2.109Date CountOfTP_"WC Percent Complete AvgOfTP_"WC MinOfTP_"WC MaxOfTP_"WC 11/4/2001 1440 100.00% 1.89 -2.764 4.815 11/5/2001 1440 100.00% -4.49 -9.76 3.041 11/6/2001 1440 100.00% -6.42 -9.78 2.735 11/7/2001 1440 100.00% -6.50 -9.84 1.469 11/8/2001 1440 100.00% -7.19 -9.91 1.726 11/9/2001 1440 100.00% -5.96 -9.68 3.789 11/10/2001 1440 100.00% 1.00 -8.75 4.117 11/11/2001 1440 100.00% 2.42 0.864 3.269 11/12/2001 1440 100.00% -4.27 -9.7 3.091 11/13/2001 1440 100.00% -6.56 -9.88 4.457 11/14/2001 1440 100.00% -7.07 -10.06 0.809 11/15/2001 1440 100.00% -6.75 -10.03 0.649 11/16/2001 1440 100.00% 0.83 -9.59 3.387 11/17/2001 1440 100.00% 2.64 2.155 2.918 11/18/2001 1438 99.86% 2.50 -9.7 3.037 11/19/2001 1440 100.00% -5.06 -9.84 2.845 11/20/2001 1440 100.00% -6.43 -9.9 3.504 11/21/2001 1440 100.00% -5.73 -9.91 18.52 11/22/2001 1440 100.00% 0.71 -9.94 3.416 11/23/2001 1440 100.00% 2.74 2.013 3.069 11/24/2001 1440 100.00% 1.99 0.175 5.802 11/25/2001 1440 100.00% -1.58 -3.004 0.174 11/26/2001 1440 100.00% -6.03 -9.81 0.644 11/27/2001 1440 100.00% -7.62 -9.87 5.501 11/28/2001 1440 100.00% -7.55 -9.88 3.706 11/29/2001 1440 100.00% -7.55 -9.85 12.81 11/30/2001 1440 100.00% -7.95 -9.87 0.979

12/1/2001 1440 100.00% -7.98 -9.95 4.411 12/2/2001 1440 100.00% 0.79 -9.79 3.359 12/3/2001 1440 100.00% -5.61 -9.9 3.033 12/4/2001 1440 100.00% -7.86 -10.01 -0.486 12/5/2001 1440 100.00% -7.91 -10 0.007 12/6/2001 1440 100.00% -7.89 -9.94 1.46 12/7/2001 1440 100.00% -8.17 -9.97 -0.538 12/8/2001 1440 100.00% -6.65 -9.9 1.207 12/9/2001 1440 100.00% -1.27 -9.37 3.225 12/10/2001 1440 100.00% -5.59 -9.95 3.033 12/11/2001 1440 100.00% -7.82 -9.99 0.071 12/12/2001 1440 100.00% -8.45 -9.98 -2.843 12/13/2001 1440 100.00% -8.30 -9.96 -3.341 12/14/2001 551 38.26% -7.29 -9.96 1.042 12/15/2001 1440 100.00% 1.27 -9.85 3.268 12/16/2001 1440 100.00% 2.92 1.843 3.099 12/17/2001 1440 100.00% -5.53 -9.93 3.097 12/18/2001 1440 100.00% -8.14 -9.96 -2.528 12/19/2001 1440 100.00% -8.01 -9.99 -0.316 12/20/2001 1440 100.00% -6.71 -10.01 3.989

103 days total during time period

148,320 146,302 minutes available data 98.64%
total minutes during time period 2,472 2,438 hours available data 98.64% total hours during the time periodWednesday October 17, 2001-10-8-6-4-20240:001:002:003:004:005:006:007:008:009:0010:0011:0012:0013:0014:0015:0016:0017:0018:0019:0020:0021:0022:0023:00Time (CST)

P R E SSURE MINUT E AVG. (IN_H2O)3035404550556065 T E MP E RAT URE MINUT E AVG. (DE G F )TP_"WCTT_degFDaimler Chrysler MOPETPSunday October 21, 2001-10.0-8.0-6.0-4.0-2.00.02.04.00:001:002:003:004:005:006:007:008:009:0010:0011:0012:0013:0014:0015:0016:0017:0018:0019:0020:0021:0022:0023:00Time (CST)

PRES S URE MINUTE AVG. (IN_ H2 O)303540455055606570 TEMPERATURE MINUTE AVG. (DEG F)TP_"WCTT_degFDaimler Chrysler MOPETPFrequency of 1-Minute P readingsSeptember 9 through December 20, 2001 (103 days)010002000300040005000600070008000

- 1 0. 00 - 9 . 0 0 - 8 . 0 0 - 7 . 0 0 - 6 . 0 0 - 5 . 0 0 - 4 . 0 0 - 3 . 0 0 - 2 . 0 0 - 1 . 0 0 0 . 0 0 1 . 0 0 2 . 0 0 3 . 0 0 4 . 0 0 5 . 0 0Minute P readings, in. w.c.

Frequencyminute P readings freqThese data are for an uncontrolled UST with no vapor returned to the tank; there is a P/V valve on the UST vent.A total of 10 minutes with pressure greater than +5.5 in. w.c. occurred over the 103 day period and are not shown in this graph.Sunday October 21, 2001-10.0-8.0-6.0-4.0-2.00.02.04.00:001:002:003:004:005:006:007:008:009:0010:0011:0012:0013:0014:0015:0016:0017:0018:0019:0020:0021:0022:0023:00Time (CST)

PRES S URE MINUTE AVG. (IN_ H2 O)303540455055606570 TEMPERATURE MINUTE AVG. (DEG F)TP_"WCTT_degFDaimler Chrysler MOPETPFrequency of 1-Minute P readingsSeptember 9 through December 20, 2001 (103 days)010002000300040005000600070008000

- 1 0. 00 - 9 . 0 0 - 8 . 0 0 - 7 . 0 0 - 6 . 0 0 - 5 . 0 0 - 4 . 0 0 - 3 . 0 0 - 2 . 0 0 - 1 . 0 0 0 . 0 0 1 . 0 0 2 . 0 0 3 . 0 0 4 . 0 0 5 . 0 0Minute P readings, in. w.c.

Frequencyminute P readings freqThese data are for an uncontrolled UST with no vapor returned to the tank; there is a P/V valve on the UST vent.A total of 10 minutes with pressure greater than +5.5 in. w.c. occurred over the 103 day period and are not shown in this graph.Frequency of 1-Minute P readingsSeptember 9 through November 19, 2001 (72 days)05001000150020002500300035004000

- 1 0. 00 - 9 . 0 0 - 8 . 0 0 - 7 . 0 0 - 6 . 0 0 - 5 . 0 0 - 4 . 0 0 - 3 . 0 0 - 2 . 0 0 - 1 . 0 0 0 . 0 0 1 . 0 0 2 . 0 0 3 . 0 0 4 . 0 0 5 . 0 0Minute P readings, in. w.c.

Frequencyminute P readings freqThese data are for an uncontrolled UST with no vapor returned to the tank; there is a P/V valve on the UST vent.There was leak occurring during this time period.Frequency of 1-Minute P readingsSeptember 9 through November 19, 2001 (72 days)05001000150020002500300035004000

- 1 0. 00 - 9 . 0 0 - 8 . 0 0 - 7 . 0 0 - 6 . 0 0 - 5 . 0 0 - 4 . 0 0 - 3 . 0 0 - 2 . 0 0 - 1 . 0 0 0 . 0 0 1 . 0 0 2 . 0 0 3 . 0 0 4 . 0 0 5 . 0 0Minute P readings, in. w.c.

Frequencyminute P readings freqThese data are for an uncontrolled UST with no vapor returned to the tank; there is a P/V valve on the UST vent.There was leak occurring during this time period.Frequency of 1-Minute P readingsNovember 20 through December 20, 2001 (31 days)05001000150020002500300035004000

- 1 0. 00 - 9 . 0 0 - 8 . 0 0 - 7 . 0 0 - 6 . 0 0 - 5 . 0 0 - 4 . 0 0 - 3 . 0 0 - 2 . 0 0 - 1 . 0 0 0 . 0 0 1 . 0 0 2 . 0 0 3 . 0 0 4 . 0 0 5 . 0 0Minute P readings, in. w.c.

Frequencyminute P readings freqThese data are for an uncontrolled UST with no vapor returned to the tank; there is a P/V valve on the UST vent.These data are for after a leak was fixed.A total of 10 minutes with P > +5.5 in. w.c. occurred over the 31 day period and are not shown.

### Calculation of Pressure-Related Fugitives for September 9 through December 20, 2001

SumOfLBS H C S umOfGallons Droppe d Expr1 281.26 885,450 0.3176 lb/1,000 ga l TP1 TP2 S umOfMinute s A vgOfLPM VolL LBS HC

0.25 0.75 5,087 0.02 76.31 0.27 0.75 1.25 2,395 0.04 95.80 0.34 1.25 1.75 2,574 0.06 144.79 0.52 1.75 2.25 2,835 0.15 418.95 1.51 2.25 2.75 7,639 0.40 3,074.70 11.06 2.75 3.25 18,675 2.00 37,277.38 134.06 3.25 3.75 273 4.35 1,186.71 4.27 3.75 4.25 47 44.45 2,089.09 7.51 4.25 4.75 26 64.33 1,672.49 6.01 4.75 5.25 5 104.08 520.41 1.87 5.25 5.75 4 143.84 575.36 2.07 5.75 6.25 1 183.60 183.60 0.66 6.25 6.75 2 223.35 446.70 1.61 6.75 7.25 1 263.11 263.11 0.95 7.25 7.75 1 302.86 302.86 1.09 7.75 8.25 1 342.62 342.62 1.23 8.25 8.75 1 382.38 382.38 1.38 8.75 9.25 1 422.13 422.13 1.52 9.25 9.75 0 461.89 0.00 0.00 9.75 10.25 3 501.64 1,504.93 5.41 10.25 10.75 0 541.40 0.00 0.00 10.75 11.25 0 581.16 0.00 0.00 11.25 11.75 0 620.91 0.00 0.00 11.75 12.25 2 660.67 1,321.34 4.75 12.25 12.75 2 700.43 1,400.85 5.04 12.75 13.25 1 740.18 740.18 2.66 13.25 13.75 2 779.94 1,559.88 5.61 13.75 14.25 1 819.69 819.69 2.95 14.25 14.75 0 859.45 0.00 0.00 14.75 15.25 4 899.21 3,596.83 12.93 15.25 15.75 2 938.96 1,877.93 6.75 15.75 16.25 3 978.72 2,936.16 10.56 16.25 16.75 5 1018.48 5,092.38 18.31 16.75 17.25 2 1058.23 2,116.46 7.61 17.25 17.75 1 1097.99 1,097.99 3.95 17.75 18.25 1 1137.74 1,137.74 4.09 18.25 18.75 3 1177.50 3,532.50 12.70 18.75 19.25 0 1217.26 0.00 0.00 19.25 19.75 0 1257.01 0.00 0.00 19.75 20.25 0 1296.77 0.00 0.00 20.25 20.75 0 1336.52 0.00 0.00 20.75 21.25 0 1376.28 0.00 0.00 21.25 21.75 0 1416.04 0.00 0.00 21.75 22.25 0 1455.79 0.00 0.00 22.25 22.75 0 1495.55 0.00 0.00

>0.25 in. w.c. 39,600 minutes 281.26 lbs HC 27.50 days p-related fug em and UST 660 hours

>3 in. w.c. 19,070 minutes 13.24 days

318 hours UST vent P/V valve em

### Data Source Company /Organization (include Title and date): MO/PETP Testing Report for F ord Moto r Compa ny St. Louis A ssembly Plant, Ha zelwood, Missouri. URS Corporation. August 27, 2003. [Sent by AAM]

Approval Letter 2004-01 for Ford Motor Assem bly Plant. From L. Mosby, MDNR, to M. Szafranski, Ford Motor Company. [Sent by AAM]

Ford Haz elwood MOP ETP Test ing Final R eport, F ord Moto r Compa ny, St. Louis Assembly Plant (SLAP), Hazelwood, Missouri. July 2002 through March 2003. Remote Sensing Air, Inc., for Missouri Department of Natural Resources (DNR). [Sent by RSA]

Test Scenario (Describe): All vehicles fueled at the facility are 100 percent ORVR vehicles. No Stage II controls (no return of vapors to the UST) are used. No UST vent control devices a re used (i.e., no vapor processor). There is one 30,00 0-gal U ST tank, wi th 2 UST ven ts; one of these UST vents wa s perman ently capped off, and the other UST vent ha s a P/V valv e. All mode ls have th e same f uel tank, fill port, and ORVR cani ster con figura tion for a given mo del y ear. MY 2003 vehi cles wer e in production at the time of the test, and all were dual canister sy stems for ORVR. [In MY2004 and later model yea rs, a single canister was used.] Both ty pes of canisters were tested: MY2003 as fully produced ve hicles and MY2004 as mockups. Emissions were collected with a sleeve around the nozzle interface. Emissions at the outlet of the ORVR canister were route d to the area of the nozzle fillport, so both sources of emissions are measured. The only vehicle fueling emissions are at the nozzle/fillport interface. Prior to testing, MDNR had approved disconne ction of th e Stage II vapor re covery control s yst em beca use all ve hicles a re ORVR.

Gasoline is chilled to approximately 43°F prior to fue ling. A special nozzle prevents spillage by via purg e-puff

. For MY2 003, unch illed ga soline fu eling w as perf ormed wit hout ORVR; t hese emissions will match up to the MY2004 emissions tests as well because the vehicle fuel tanks are identica l. Some emis sions info rmation is based on calcula tions.

Emissions Testing Data: The following MO/PETP tests were conducted:

• Bench T esting ( Modified MO/TP-201 .2B) - r equires bench te sting of nozzles, P/V valves, drain valves for transition flow, and leak rates

• Static Pr essure (Leak Decay) Testing (Modi fied MO/TP -201.3B)

• Stage I Eff iciency Te st (MO/TP-201.1)

• Stage II Efficiency Test (Modified MO/TP-201.2)

• Spillage and Pseud o-Spillag e (MO/TP- 201.2C)

• Final V/L Testing

Operating Data: Some typical operating data are available in the final test report. Continuous T and P data for 5 months were recorded as part of the sy stem testing; the facility pr ovided example data for 11 of these days, Nove mber 8 through November 18, 2002. The data a vailable for all 11 day s are

### shown in th e table b elow with the daily averag e pressu re and th e minimum a nd maximum 1- min P value fo r each d ay ; data ar e provide d for both the north end and th e south en d of the U ST (pressure is monitored at two locations within the tank). I n general, the pressure patter n shows high vacuum during production operations on wee kdays (i.e., during fueling) and high pressures at the cracking P of the P/V valves during of f times, i.e., overnight and over weekends. The weekday graphs show increasing pre ssures (due to vapor growth) overnig ht and negative pressures during the day while fueling operations are occur ring. On Friday November 8, the average pressure f or the day f or the north end of the UST was -6.10 in. w.c. (minimum 1-min P of -9.29 in. w.c. and maximum 1-min P of +3.38 in. w.c.). The weekend day graphs show continued vapor growth and positive pressure for the entire day

. On Sunday November 10, the average pressure f or the day a t the north end of the UST was 2.58 in. w.c. (minimum 1-min P of 1.26 in. w.c. and maximum 1-min P of +3.32 in. w.c.)

There a re seve ral wee kday s with pre ssure spi kes in mid- aftern oon when o stensibly the fac ility would be operating and fueling ve hicles; it is not clear what event these pressure spikes
repres ent. [Thes e data pl ots were provided in hardc opy and not in c olor; it wa s difficu lt to decipher which line represented which da ta. We made assumptions regarding which lines we re tank P.]

Summary of Weekday and Weekend UST Vent Pressures

Pressure, in. w.c. Friday, 11/08 Saturday, 11/09 Sunday, 11/10 M onday, 11/11 Tuesday, 11/12 Wednesday, 11/13 Thursday, 11/14

N S N S N S N S N S N S N S

Minimum -9.29 -10.62 -9.12 -10.48 1.26 1.19 -9.16 -10.72 -9.25 -10.65 -9.23 -10.58 NA NA

Maximum 3.37 3.30 3.40 3.35 3.32 3.22 3.36 3.34 3.39 3.38 3.63 3.58 3.59 3.51

Average -6.10 -6.87 1.80 1.62 2.58 2.49 -5.27 -5.90 -6.59 -7.33 -5.81 -6.43 -15.44 -11.17

Pressure, psi Friday, 11/15 Saturday, 11/16 Sunday, 11/17 M onday, 11/18

N S N S N S N S

Minimum -9.06 -10.47 1.60 1.52 2.27 2.26 -9.29 -10.77

Maximum 3.38 3.35 3.12 3.06 3.04 3.03 3.06 3.03

Average 1.58 1.44 2.64 2.59 2.79 2.76 -5.08 -5.77

Not e: Dat a a re pr ov i de d f or pr es su re ga ug es at bo t h t he no rt h ( N) an d s ou t h ( S) en ds of t he UST.

### Results an d Conclusions Reporte d:

Summary of Emissions Factors and Efficiency Determ inations for both Stage I and

Efficiency Relativ e to Uncontrolled System MY2004 mock up tank s, single canister,

lb/1,00 0 gal Efficiency Relativ e to Uncontrolled System

100% same same

99.9% 0.0033 [emissions

mea surem ent] greate r than 99.9%

91.6% same same

87.2% same same

98.8% 0.333 98.9%
Uncontroll ed: No chil li n g of gas oline, no ORV R, no Stage II V RS, and wit h P/V valve. 

### Stage II.

Source

Loading (Stage I)

Vehicle Fueling

Spil lage /Pseu doSpillage

Breathing (Pressure Related F ugitives) - UST em - f

ugit ives

TOTAL Uncontrolled System MY200 3 mockup tanks, du al canister lb/1,00 0 gal

13.5 [AP-42 E F eqn]

13.5 [emissions

mea surem ent]

0.75 [CARB EF]

2.09 [modif ied AP- 42 EF]

29.9 MY 2003 assemb ly line, dual canister lb/1,00 0 gal

0.0 [meas ured]

0.0118 [emissions

mea surem ent]

0.063 [meas ured]

0.267 [cal cula ti on ba se d o n P
, T, time]

0.342

Controll ed: Chil lin g of gas oline, with ORV R, no Stage II VRS, wit h P/Vvalve, and wit h purge puf f nozzl e.


### Summary of Emissions Factors a nd Efficiency Determinations for Stage II alone

.
Source

Vehicle Fueling

Spil lage /Pseu doSpillage

Breathing (Pressure Related F ugitives) - UST em - f

ugit ives

TOTAL Uncontrolled System MY200 3 mockup tanks, du al canister, lb/1,00 0 gal

13.5 [emissions

mea surem ent]

0.75 [CARB EF]

2.09 [modif ied AP- 42 EF]

16.3 MY 2003 assemb ly line, dual canister, lb/1,00 0 gal

0.0118 [emissions

mea surem ent]

0.063 [meas ured]

0.267 [cal cula ti on ba se d o n P
, T, time]

0.342 Efficiency MY2004 Relativ e to in mockup Uncontrolled tank s, single System canister, lb/1,00 0 gal

99.9% 0.0033 [emissions

mea surem ent] greate r than 99.9%

91.6% same same

87.2% same same

97.9% Efficiency Relativ e to Uncontrolled System

0.333 98.0%
Uncontroll ed: No chil li n g of gas oline, no ORV R, no Stage II VRS, w/ P/V val ve

. Controll ed: Chil lin g of gas oline, with ORV R, no Stage II VRS, wit h P/V valve, and wit h purge puf f nozzl e.

### In addition to the testing shown in the tables above, a n additional analysis of the mockup testing for MY20 03 showed controlle d vehicle fueling emissions l evels of 0.1965 lb/1 000 gal , which is a control efficiency of 98.5 percent. These data are r epresentative of ambient temperature fue l, no Stage I I VRS, and dual c anister O RVR.

Comments: Breath ing emis sions fro m the UST ve nt are un related to throug hput.

At automobile manufacturing facilities, the ga soline dispensing stops for longer periods over weekends in addition to overnight periods. The UST at automobile manufac turing facilities likely operate at positive pressur e for a h igher p ercent age of time than w ould be lik ely at a tradition al uncont rolled GD F. These periods a t pressur es gre ater tha n 0.0 in. w. c. are w hen UST fugitive and vent emissions occur.

Chilling of gasoline suppresses vaporization and therefore emissions, so vehicle fueling emissions a re lower than they would be o therwise at ambien t condition s. Chilling of gaso line is a unique operating condition that is used at several, but not all, fac ilities nationwide; chilling may not be representative of automobile manufacture rs nationwide.

The gr een tank effec t, i.e., no gasolin e vapors present prior to f ueling, may affec t the vehi cle fueling emissions. AAM has indicated that refueling e missions would be lower with the green tank effect because no vapors a re present to be displaced, however, one State a gency has indicate d that the emissions m ay be high er, par ticularl y f or the imme diate spla sh into the vehicle tanks, then the emissions would be similar to refueling emissions for the remainder of the fueling
event. A t any rate, th e gree n tank ef fect is a universa l condition for all a utomobile manufacturers , and these da ta may not be represent ative of trad itional re fueling at GDF.

The emissions levels from the UST tank are essentially similar to an uncontrolled UST (i.e, no Stage I I VRS)with a P/V v alve and may be repr esentat ive of tra ditional r efuelin g at GDF , with one noted differe nce. One differe nce in the UST emissio ns would be that the f acility typ ically fuels on Monday throug h Friday a nd shut downs over the weekend (i.e., no fueling ope rations for a 2-day pe riod), causing an extended vapor gr owth period and more UST fugitive and vent emissions. A traditional GDF would be open 7 day s per week without an extended shut down or vapor growth period. The levels for UST e missions shown in this report may actually be higher than UST em issions from a tradit ional GDF.

Notes on Specific Emissions Factors : Uncontr olled veh icle fue ling EF s with ambi ent T fue l may affec ted by the gre en tank e ffect. Vehicle fueling EFs with ORVR-control with ambient tempera ture fuel may be affected by the
green tank eff ect. Vehicle fueling EFs with ORVR-control and with chilled g asoline may be lowe r because of the lower va por pres sure of t he gas oline and may be affe cted by the gre en tank e ffect. Vehicle fueling EFs with chilled ga soline may be lower because of the lower vapor pressur e of the gas oline and may be affe cted by the gre en tank e ffect. Uncontrolled UST vent and fugitives EF with P/V valve may be similar to other uncontrolled

### tanks (i.e., non-Stage I I VRS) with one noted differenc e, increased UST emissions related to the lo ng er sh ut do wn pe ri od s o f t he fa ci li ty. Spillage EF is for a purge puf f nozzle.

### Source Company/Org anization: New Hampshire DES Report on MTBE Levels in Groundwater Near GDF. September 30, 2004. [Submitted by Healy , Inc.]

Test Sce nario : NH DES monitored approximately 300 GDF in Ne w Hampshire to determine the extent of groundwater pollution with MTBE. The GDF monitored include d a number of different control types, including ba lance, vacuum assist, an d some GDF wit hout Stage II VRS contro ls. MTBE is an oxygenate a dditive to gasoline that is used to reduce CO emissions from automobiles and improve a ttainment with the N AAQS.

Operating Data: None.

Results an d Conclusions Reporte d: The groundwater monitoring data show tha t a number of the 300 GDF have detecta ble levels of MTBE an d a number have exce eded the ground water li mit. The sta ndard fo r MTBE in groundwater is 13 ppb. Approximately 88 GDF exceed the limit, and 51 of these are confirmed vacuum assist VRS that are not ORVR-compatible. The table below summarizes the data for the GDF.

Comments : None.Site Histori cal Recent Last MTB E Type of Site No. MTBE range reading, control No. high, ppb MTBE, ppb ppb

1 5,800 44-5,800 480 Exemp t

2 11,000 2,270-4,300 4,300 Gilbarco Retro fit

3 150,000 3,580-7,460 6,250 Balance

4 NA NA NA Way ne Vapor Vac

5 108,000 55-20,300 55 Balance

6 NA NA NA Exemp t, Mani folded

7 150,000 17,000- 46,000 46,000 2 pt. Way ne Vapor Vac

8 22,000 Old Da ta 8,400 2 pt. Way ne Vapor Vac

9 20,000 20-20,000 20 Manifol ded, Way ne Vapor Vac

10 122,000 165-40,800 40,800 Manifol ded, Unk nown

11 120,000 27-64,000 64,000 2 pt. Way ne Vapor Vac

12 17,000 2-4,200 2,350 2 pt. Way ne Vapor Vac

13 26,000 44-18,000 57 Way ne Vapor Vac

14 1,040 20.4 to 1,040 1,040 2 pt. Balance

15 NA NA NA Exemp t

16 18,000 2,000- 18,000 2,900 Manifol ded, Unk nown

17 17,000 180-17,000 2,300 Manifol ded, Balance

18 492 ND-492 492 Way ne Vapor Vac

19 50,000 480-50,000 50,000 2 pt. Gilbarco

20 110,000 260-110,000 33,000 2 pt. Way ne Vapor Vac

21 239,000 53,500- 239,000 239,000 2 pt. Gilbarco 22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42 

### Su in New Hampshire

.
Histori cal MTBE high, ppb Recent
range MTBE, ppb Last MTB E reading, ppb Type of control

NA NA NA Exem pt

NA NA NA Coaxial, Exemp t

16,000 272 to 16,000 16,000 Gilbarco Retro fit

NA NA NA 2 pt. Gilbarco

6,500 2,200-6,500 2,200 Manifol ded, Unk nown

190,000 20,000- 190,000 33,000 2 pt. Gilbarco

NA NA NA Exemp t

5,500 2 to 5,500 5,500 Manifol ded, Gilbarco

16,000 460 to 16,000 16,000 Manifol ded, Exemp t

NA NA NA Exemp t

27,000 BDL t o 550 550 Way ne

NA NA NA Exemp t

23,500 76 to 3,300 640 Wayne Vapor Vac

67,000 1,800 to 67,000 67,000 Manifol ded, Gilbarco

1,420 BD to 56 56 Coaxial, Exemp t

NA NA NA 2 pt. Gilbarco

17,000 BDL t o 1,300 BDL Wayne Vapor Vac

5,830 60.9 to 173 60.9 Coaxial, Exemp t

41,000 130 to 41,000 3,210 2 pt. Gilbarco

59,800 444 to 59,800 444 2 pt. Way ne Vapor Vac

14,700 660 to 9,080 660 Manifol ded, Wayne Vapor Vac 

### mmary of MTBE Concentration Data in Groundwater at GDFSite No. Histori cal high, ppb

43 101,000

44 10,000

45 605

46 39,500

47 1,110,000

48 9,500

49 NA

50 25,000

51 NA

52 7,520

53 LNAP L

54 149,000

55 NA

56 NA

57 NA

58 5,000

59 11,000

60 18

61 NA

62 18,000

63 88,100

64 High MT BE in I ndoor Air Recent range, ppb Last reading, ppb Type of control

12,200 to 101,000 12,200 Manifol ded, Gilbarco Retro fit

BDL t o 5,200 5,200 2 pt. Way ne Vapor Retro fit

192 to 605 192 Manifol ded, Gilbarco Retro fit

815 to 39,500 39,500 2 pt. To kheim

574,000 to 1,110,000 1,110,000 Manifol ded, Way ne Ret rofit

32 to 3,270 442 2 pt. Balance

NA NA 2 pt. Gilbarco

35 to 638 442 2 pt. Balance

Mani folded Gilbarco

17 to 6,750 325 2 pt. Exe mpt

LNAP L LNAP L 2 pt. Way ne Vapor Retro fit

2,400 to 35,900 16,400 Mani folded Gilbarco

NA NA Mani folded Gilbarco

NA NA 2 pt. Gilbarco

NA NA 2 pt. Way ne Vapor Vac

980 to 3,820 1,100 Gilbarco Retro fit

1,500 to 4,300 2,300 2 pt. Way ne Vapor Vac

18 Gilbarco

NA NA Exemp t

3,900 to 18,000 18,000 Manifol ded, Wayne Vapor Vac

2,080 to 88,100 18,200 Manifol ded, Unk nown Site No.

65

66

67

68

69

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85 Histori cal high, ppb Recent range, ppb Last reading, ppb Type of control

34,600 356 to 34,60 0 1,090 2 pt. Way ne Vapor Vac

NA NA NA Exemp t

NA NA NA Balance

2,510 3 to 2,510 53 2 pt. Healy 400

81,500 51,000 to 81,500 81,500 Exemp t

33,100 809 to 9,360 9,360 Gilbarco

6,000 264 to 6,000 264 Exemp t

39,000 130 to 4,500 4,500 Way ne Vapor Vac

2,180 129 to 2,180 129 Coaxial, Balance

NA NA NA 2 pt. Unk nown

NA NA NA 2 pt. Gilbarco

130,000 5,600 to 130,000 5,600 2 pt. Way ne Vapor Vac

23,200 23,200 23,200 2 pt. Way ne Vapor Vac

NA NA NA Coaxial, Balance

NA NA NA 2 pt. Tokhe im

113,000 3,200 to 55,000 55,000 2 pt. Healy 600

NA NA NA 2 pt. Balance

24,000 79 to 24,000 24,000 Way ne

8,190 946 to 8,190 946 Balance

NA NA NA Exemp t

NA NA NA Manifol ded, Unk nown

86 2 pt. Way ne Vapor Vac 2,600 350 to 2,600 440 Way ne Vapor Vac 18Last reading, ppb Type of control Site No. Histori cal high, ppb Recent
range, ppb

87 NA NA

88 NA NA

89 5,500 2,500 to 5,500

90 168,000 50,400 to 103,000

91 NA NA

92 NA NA

93 NA NA

94 NA NA

95 120,000 880 to 120,000

96 50,000 BD to 50,000

97 13,000 1,960 to 13,000

98 47,200 BDL t o 8,200

99 24,000 6,800 to 24,000

100 24,100 35 to 24,100

101 76,900 24,000 to 76,900

102 NA NA

103 58,900 336 to 20,400

104 8,380 BDL t o 2,600

105 NA NA NA 2 pt. Gilbarco

NA Manifol ded, Gilbarco

5,500 2 pt. Gilbarco

50,400 Gilbarco

4,470
near ta nks Exemp t

NA Exemp t ?

NA Exemp t

NA 2 pt. Gilbarco

880 2 pt. Way ne Vapor Vac

50,000 Gilbarco Retro fit

13,000 Gilbarco

2,900 Wayne Vapor Vac

6,800 2 pt. Way ne Vapor Vac

24,100 Coaxial, Exemp t

35,000 Manifol ded, Balan ced

NA Manifol ded, Wayne Vapor Vac

20,400 Manifol ded, Wayne Vapor Vac

398 2 pt. To kheim

NA Mani folded Healy Slap Lock Site No.

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124 Histori cal high, ppb Recent range, ppb

13,000 3,100 to 13,000

NA NA

140,000 420 to 140,000

190,000 970 to 190,000

68,000 15,000

NA NA

6,400 740 to 2,000

50,000 3,400 to 44,000

166,000 230 to 166,000

5,890 531 to 2,790

29,000 22,000 to 29,000

121,000 8,760 to 121,000

3,100 3,100

409,000 18,000 to 140,000

NA NA

32,000 9 to 32,000

2,200 93 to 2,200

7,900 250 to 7,900

30,400 2,620 to 30,400 2,610 Coaxial, Exemp t Last reading, ppb Type of control

3,400 Way ne Vapor Vac

NA Exemp t

420 2 pt. Gilbarco

190,000 2 pt. Way ne Vapor Vac

5,000 Way ne

NA 2 pt. Way ne Vapor Vac

740 Way ne

44,000 2 pt. Way ne Vapor Vac

230 Manifol ded, Gilbarco Retro fit

2,000 Gilbarco Retro fit

22,000 Gilbarco Retro fit

10,500 Manifol ded, Gilbarco

3,100 Manifol ded, Gilbarco Retro fit

18,000 Manifol ded, Gilbarco Retro fit

NA 2 pt. Unk nown

17,000 Way ne

93 2 pt. Unk nown

7,900 Balance

### Source Company/Organization : Data Table on Failur e Rates for Pre ssure De cay Test ing, Dynam ic Backpre ssure Tes ts, and Air-to-Liquid Ratio Tests for 17 States, for June 30, 2003 through September 17, 2004. [Submitted by Crompco Corporation]

Test Sce nario : Testing for GDF with Stage I I VRS controls was conducted in multiple States (17). Testing included pressure decay tests (static pressure performance test), dy namic backpressure tests, and A/L ratio testing. I nformation on the testing frequency in each State is also provided.

Results an d Conclusions : A summary of the te st informa tion is prov ided in the table. A t otal of 7, 514 press ure dec ay tests were conducted over this time period in 17 States. Of the pressure decay tests, approximately 19 percent failed. The failure ra te from State to State ranged from 0 perce nt (only 2 GDF we re tested) t o 29 perc ent. The se failur es includ ed mainte nance a ttempts by the test te chnicia n to repair tank fittings, dispenser fittings, and hanging hardware while onsite when a GD F failed an initial try and then retesting

.

A number of dy namic ba ckpress ure tests were c onducted , with 3,97 4 tests on th e gaso line (we t) side and 3,916 on the vapor (dry ) side. These tests check for any blockage in the gasoline or vapor piping or hoses. Overall, approximately 6.5 percent of the wet backpressure tests were failures (ranging fr om 0 to 33 percent from State to State) and 3.4 percent of the dry backpressure tests were failures (range s from 0 to 25 percent).

There w ere 4,31 3 A/L r atio tests summarize d in the da ta. Appr oximately 27 perce nt of the te sts were failures; these tests are consider ed to be failures if even one fueling point fa ils and cannot be repa ired by the tech nician or if a fue ling poin t is out of or der whe n the test i s conduc ted. All fueling points must be working properly to pass the test.

Comm ents: None.

### Source Co mpany/Or ganizatio n: Stage II Vapor Recovery Pilot Testing Pr oject. Prepared by the Ver mont Department of Environmental Conservation. April 26, 2000. [Submitted by NESCAUM.]

Test Scenario: In 1996, Vermont adopted a re gulation requiring Stage I I VRS on all GDF that pump more than 400,000 gallons of gasoline per y ear. The implementation period ranged f rom December 31, 1997 (for stations pumping more than 1,200,000 gallons per y ear) to December 31, 2000 (for stations pumping more than 400,000 gallons per y ear).

A total of 32 stations with Stage II VRS were tested by the State of Vermont, after they had been operati ng for a t least 1 y ear and for most, i t had bee n at leas t 12 months s ince the y w ere las t tested. (However, 3 GDF had bee n tested just 4 months before this testing.) The stations were heavily weig hted toward bootless vacuum-assist stage I I sy stems, with only 6 of the stations tested be ing equ ipped with balance sys tems.

Tes ts con duc ted in clu ded : (1 ) th e pr ess ure dec ay te st at a ll st ati ons , (2 ) th e ai r-t o-l iq ui d (A /L) ratio test at all stations equipped with bootless vacuum-assist systems, and ( 3) the vacuum line integrity test a t two stations using the Healy Sy stems, Inc. VRS with a central vacuum pump. Testing was per formed o n an “as i s” condit ion (i.e. , without f irst doing any maintena nce to facilitate passing the test, such as tightening loose tank top fitting or replacing worn or broke n parts).

The testi ng inclu ded bala nce sy stems and four var ieties of vacuum- assist sy stems as sh own in Table 1:

Number Tested 

### Table 1. s of Stage II VRS

Type of System 

### Type Tested

Percent age of Total Stations Test ed

Balance 6 19

Frankli n Inte lli vac 1 3

Gilbarco Vapor Vac 8 25

He aly System s with M ode l 600 No zzle 2 6

W ayne Vac 15 47

Total 32 100



### Emissions Testing: None.

Operating Data: None.

### Results an d Conclusions Reporte d: The pre ssure de cay results a re in Tab les 2 thro ugh 5. Th e total nu mber of s yst em compon ents tested included 90 USTs, 128 gasoline dispensers, and 360 ga soline nozzles. As shown in Tables 2 and 3, th e results do not prov ide defi nitive ev idence f or how ma ny months a GD F is likely to maintain compliance with the pressure integrity standard but note that the 3 GDF that had been tested within the last 4 months all passed the pressure decay test. At most GDF that failed, more than one l eaking componen t contribu ted to the test fail ure. The two compo nents most f requent ly observed to be leaking were f ill caps (41 percent of all test failures had fill caps found to be leaking) and Stage I poppet valves, dry br eaks (41 percent of all test failures had Stag e I poppet valves f ound to be leaking ) (totals add to mor e than 100 percen t becaus e multiple componen ts contributed to test failure).

Vacuum Lin e Integr ity Test : Vacuum line integrity testing was performed at the two stations equipped with the Healy Systems I nc. system and using a central vacuum source. Both stations passed th is test on th e initial a ttempt.

Air-to-Liq uid Ratio Te st : The A/L ratio test was perfor med at 26 stations and involved testing of 298 nozzles. Test results are presented in Table 6. The values in Table 5 ar e read from Figure 3 of the report; therefore, the numbers may be slightly off.

The Vermont Agency of Natural Resources concluded that “it is appare nt that a significant number of gasoline stations cannot pass a pressure de cay test without ong oing maintenance. The pressure integrity of Stage II systems degr ades over time and it is evident that most gasoline stations would not pass a pressure decay test by the time their five y ear retesting requirement comes due.”

The Vermont Agency of Natural Resources also concluded that the A/L testing results indicate a high compliance rate with the A/L ratio performance standard.

Table 2.

Numb er of Stati ons Percentage of Total Stations

All Stati ons 31 100

Pass 10 32

Fail 21 68

Vacuum A ssist Stations 25

Pass 10 40

Fail 15 60

Balance Stations 6

Pass 0 0 

### Initial Pressure Decay Test Results

Fail 6 100

### Table 3. ressure Decay Te st Result s – All Stat ions

Percent of Total Stations

Pas s – W ithin Allo wed Leak Rate 32

Fail – U p to 1 0% Abo ve A llowed Leak Rate 26

Fail – B etwee n 10 % a nd 5 0% Abo ve A llowed Leak Rate 13

Fail – G reater than 5 0% Abo ve A llowed Leak Rate 29 

### P

Table 4. Equ ipment Problems that Contributed to a Pressure Deca y Test Failure

Percent of Failing St ations Where Component Was a Fact or

Fill Cap 41

Stage I Poppet Valv es 41

Fil l Adapt or 32

Spill Bucket Drain Valve 27

Nozzle* 27

Breakaway 14

In- Tank Monit or 5

Subme rsi ble Pump 5

* Note: N ozzles were a contributing factor o nly at balance stations.



### Table 5.

Part Numb er Leaking % Leaking, Out of Total Number Tested

Fill Cap 11 12

Fil l Adapt or 9 10

Spill Bucket Drain Valve 12 not deter mined

Stage I Poppet V alve 15 27

In- Tank Monit or 3 not deter mined

Subme rsi ble Pump 1 1

Ba lance System No zzle 13 23

Breakaway 3 <1 

### Parts Found Leaking During Pressure Decay Tests

### Table 6. Air-to-Liquid T esting Results for Each Type of System

Percent of Nozzles Status

W ithin Allowable Range

Fa i l – Wi t hi n 1 0% of Allowable Range

Fail – Betwee n 10% and 50% of Allowable Range W ayneVac Gilbarco Vapor Vac He aly Fran klin Intel liv ac

85 94 92 100

11 4 4 0

2 2 4 0

Fail – Great er t han 50% of Allowable Range 2 0 0 0

Numb er of Systems Tested: WayneVac = 15 (186 no zzles); Gilbarco VaporV ac = 8 (48 noz zles); Healy = 2 (56 noz zles); Frankl in = 1 (8 nozzles).



### Comments: This testing did not include emission measurements, however, the testing does indicate that, at least for the pressure decay test, the systems fail the test without ongoing routine maintenance. The A/L test results were more favorable regarding compliance.

### Source Company/Organization : EPA In-Use Evaporative Testing, Ann Arbor, Michigan

. April 15, 2003. [Submitted by NC Petroleum Marketers Association]

Test Sce nario : Two-day e vaporative system testing was conducted on ORVR vehicles of various age s. After the two-day eva porative test, the vehicles were refue led to a full tank of gasoline and any refueling problems or fuel spitback was noted. The odometer rea dings ranged from 6,800 to 190,000 miles, with an average mileage of 45,000 miles. While the evaporative system testing does not provide data on the control efficiency of ORVR canisters, it does provide data indicating that the OR VR sys te m i s o pe ra ti ng co rr ec tl y.

Results an d Conclusions : A tot al of 3 2 ORVR vehic les we re tes ted. O f thes e vehi cles, 28 pas sed th e evapo rativ e test ing, which represents a 12 percent fa ilure rate.

Comm ents: None.FAIL-2nd veh passed--no followup actionKinked canister supply hose (after dealerperformed Kia ORVR valve recall).Retest, Failed 2.5 Gram StandardFailed 2.5 Gram StandardCommentsShed N/APASSPASSPASSPASSPASSPASSPASSPASSPASSPASSPASSPASSPASSPassPassPassPassPassPassPassPassPassPassPassPassPassPassCount Pass28Yes/NoYesNONONONONONONONONONONONONoNoNoNoNoNoNoNoNoNoNoNoNoNoNoNoNoNoNOTotal EvapGramsGrams0.510.600.780.630.752.390.710.403.694.380.530.640.930.790.771.443.090.770.530.950.550.840.990.990.591.010.95N/ANA1.20.91.2Hot SoakGrams0.060.040.070.080.040.320.180.050.160.170.050.090.070.040.070.210.190.090.040.060.110.040.070.130.090.110.050.070.120.11N/ANADiurnal0.450.560.720.550.712.070.530.353.534.210.480.550.870.750.701.231.110.730.470.840.770.850.890.791.150.520.890.84N/ANA2.90.5EPA In-Use Evaporative TestingAnn Arbor, MichiganXDWXR0095AOLWVWXR0110234YNSXR0110RCCXCRXR0101GBFWTKXR0125BFAYHNXR0099AADXFMXR0115BAEXHNXR0130AAAXFMXR0080BAEYHNXR0160AAZXKMXR0100A02XKMXR0100A02XVWXR0110234XJCXR0121M2XXJCXR0121M2XXGMXR0124919XBMXR0136E46XGMXR0080902XGMXR0080902YVWXR0110234YGMXR0124919XTKXR0125BFAYTKXR0125BFBYTYXR0135AK1YVVXR0133X48YVVXR0133X48YVVXR0133X48XFJXR01251BBXFJXR01251BBXFJXR01251BBEvap Family*XTYXR0135AKIYGMXR013910Eng Fam/ Test GrpXDWXV02.2DO1XCRXV03.5VBOWTKXV02.0VBAWVWXV02.0226XFMXV03.0VBBXFMXV02.0VBAXBMXV02.8LEVYHNXV01.6CA3XHNXV02.3PA3XKMXV01.8A02XKMXV01.8A02XVWXV02.0222XTYXV03.0BBAXTKXV02.0VBAXGMXV03.0061XGMXV01.9001XGMXV01.9001YTKXV01.8VBBYNSXV03.0A6AYTYXV02.2XBAYVWXV01.8228YVVXV2.78EN3YVVXV2.78EN3YGMXV04.6065YGMXV04.6065XFJXV02.5CACXFJXV02.5CACXFJXV02.5CACXJCXV04.0BN4XJCXV04.0BN41VVXT2.43L5TYHNV03.5YA317,91742,53835,63938,13634,94716,19516,37419,62434,51139,19739,19742,6187,162187,066125,79949,63213,80153,93374,64253,39657,22717,61552,00243,34526,81426,70137,3316,82274,48324,49966,68555,3076,822OdometerLiters187,06644,724MilesDisplmaxminavg3.53.01.81.82.03.04.04.02.22.52.52.02.02.32.02.53.02.81.92.01.91.83.02.21.82.82.82.41.64.62.43.5Cadillac CateraLegacy OutackLegacy OutackMercury SableModelVanden PlasAcura 3.5RLSaturn SL1Saturn SL1PROTÉGÉ* R as the fifth letter in the Evaporative Family code is ORVR.ConcordeESCORTMAXIMALeganzaBEETLECivic LXCavalierS 80 T6S 80 T6V70 XCLegacySephiaSephiaAccordDevilleCamrySolara626LXBeetleBeetle328iXJ8626ChryslerNISSANDaewooMAZDASubaruSubaruSubaruMfrToyotaJaguarJaguarToyotaMazdaMazdaHondaHondaHondaFORDVolvoVolvoVolvoBMWFordVWVWGMGMGMVWGMGMKiaKiaClass- Veh IDF100--0022G115-0023G108-0325G121-0049G135-0100D124-0061D126-0053E104-0018E104-0021E106-0005E108-0006E114-0305E114-0309E118-0023E120-0027E120-0027E121-0044F102-0019F112-0025F117-0003F110-0077F123-0085F127-0002F133-0008F127-0027F142-0019F145-0046F146-0011F150-0016F154-0020F154-0114F160-0024ModelYear1999199919991999199919991999199919991999199919981999199919991999199919991999199919992000200020002000200020002001200020002000200010/30/200111/15/200105-22-0105-18-0105-25-0107-17-0107-25-0109-07-0108-15-0112-04-0101-09-0212-19-0001-05-0101-18-0201-30-0201-30-0202-02-0203-01-0203-12-02Test Date04-10-0205-01-0205-08-0205-15-0206-10-0206-21-0207-19-0207-26-0208-04-0212-20-0212-11-0201-21-0303-19-03

### Source Company/Organization : EPA In-Use Verification Program (IUVP), Ann Arbor, Michigan

. No date given, but likely 2004 and later.

Test Sce nario : Beginning in 2004, EPA has instituted an in-use testing prog ram called the In-U se Verification Program (IU VP). The IUVP requires ma nufacturers to test customer-owned and -oper ated vehicle s, includi ng 1-y ear old a nd 5-y ear old v ehicles (minimum 50 ,000 miles ) are te sted. EPA began receiving test da ta in calendar y ear 2005 on high mileage (50,000+) model year s 2001 vehicles and low-mileage (10,000+) mode l year 2004 ve hicles. EPA also conducts confirmatory in-use tests on approximately 150 vehicles per year to ve rify the re sults of the manufacturer in- use testin g. Thes e are EP A’s prel iminary testing data fr om this prog ram.

Results an d Conclusions : Testing on the ORVR canister’s outlet HC concentration by FTP method 24 was conducted on a total of 151 ORVR-equipped vehicles. Overall, 9.3 percent of the vehicles (14 out of 151) had emissions greater than the 0.2 g/g al limit. Of the high-mileage vehicles, 12.8 perc ent (6 out of 47) had emissions greater than the 0.2 g /gal limit. Of the low-mileage vehicles, 7.7 perc ent (8 out of 104) had emiss ions gre ater tha n the 0.2 g /gal limi t.

Comm ents: None.

Test Sum mary for Outlet Co ncentra tions on In-U se ORVR C anisters

. Test Resu lt Overall Low Mil eage High Mi leage

Number Percen tage Number Percen tage Number Percen tage
< 0.2 g/gal 137 90.7 96 92.3 41 87.2
> 0.2 g/gal 14 9.3 8 7.7 6 12.8

Total 151 100 104 100 47 100

# Appendix B
NESCAUM Widespread Use Study Supporting Documentation

## I. Purpose

The purpose of Appendix B is to document and explain the equations used in the algorithm analysis for determining widespread use.



## II. MOBILE6 Calculations

A. Definition (a)

The following equations were used to determine a widespread use date for definition (a) [Note: the equations for definiti on (a) are not exact, because the equation is calculating the percentage of ORVR-equipped vehi cles in a specific vehicle group, not the entire fleet] :

Equation (1):

WT n

i PI PER FLEET VEH ORVR ORVR * 25

1 _ 

### ∑ =

= =



### Where: ORVR FLEET_PER 

### = Percentage of vehicle fleet eq uipped with ORVR in a given year. i = Vehicle age. The vehicle age for a specific vehicle type ranges from one to twenty-five years, with vehicles twenty-five years and older grouped together. ORVR PI 

### = ORVR phase-in rate, based on estimated MY (MY E 

### ) of vehicle. VEHWT = Weighted fractional average of the number of VMT/day in a given CY for a specific vehicle type of a given age in relation to the total VMT/day in a given CY fo r all vehicle types of all ages. See Equation (5).

Equation (2): 1 +

− = i

CY MY E



### Where: MY E 

### = Estimated MY of vehicle. CY = Calendar year. i = Vehicle age. The vehicle age for a specific vehicle type ranges from one to twenty-five years, with vehicles twenty-five years and older grouped together.

Equation (2) is used to estimat e the MY of the vehicle by s ubtracting the CY in question by the vehicle’s age then adding one. For ex ample, if the CY of interest is 2005 and vehicles of age one are being considere d, then the calculation yields a MY 2005.

### Intuitively, one would expect the result to be MY 2004 for a car of age one in the year 2005, however, ages are based on whole numbers and as such, a car of age one could possibly be a brand new car (i.e., MY 2005).

Equation (3):
∑ =

= = 25 n

1 i SVT SVT SVT SVT WT ) VMT * (VAD / VMT * VAD VEH



### Where: VEH WT 

### = Weighted fractional average of the number of VMT/day in a given CY for a specific vehicle type of a given age in relation to the total VMT/day in a given CY fo r all vehicle types of all ages. VAD SVT 

### = Vehicle age distribution (fraction) in a model year for a specific vehicle type. VMT SVT 

### = VMT per day in a given CY for a specific vehicle type, mile/day. i = Vehicle age. The vehicle age for a specific vehicle type ranges from one to twenty-five years, with vehicles twenty-five years and older grouped together.

Equation (3) is used to calculate the weight ed fractional average of VMT per day in a given CY for a specific vehicle type of a given age in relati on to the VMT per day in the same CY for all vehicle types of all ages. The following methodology was used to calculate the weighted fractional average:



## 1. The vehicle age distribution (fractional value) of a specific vehicle type in a given MY is multiplied by the numbe r of VMT per day in a given CY for a specific vehicle type. 

## 2. For ages one through twenty-five for the specific vehicle type in a given CY, multiply the vehicle age distribution of the specific vehicle type in a given MY by the number of VMT per day in a given CY for the specific vehicle type (i.e., twenty-five separa te calculations). The total VMT per day for a specific vehicle type in a gi ven CY is the sum of the individual twenty-five calculations. . 

## 3. Divide the result from step one by the result from step 2.

Equation (4):
365 / AMAR VMT SVT =



### Where: VMT SVT 

### = VMT per day in a given CY for a specific vehicle type, mile/day. AMAR = Annual mileage accumulation ra te for a specific vehicle type of a given age, miles/yr.

### Equation (4) is used to determine VMT per su mmer day for a specific vehicle type of a given age in miles per day. This value is determined by dividing the annual mileage accumulation rate for a specific vehicle type of a given age by the number of days per year (i.e., 365 days per CY).



## B. Definition (b)

The following equations in conjunction with the equations used for determining a widespread use date for definition (a) were us ed to determine a widespread use date for definition (b):

Equation (5):

∑ ∑

= = =

e vehicletyp j MIX VMT MIX VMT PER FLEET GAS GAS ORVR

_ type vehicle j ]

_ _ ORVR_PER / * [ VMT



### Where: VMT ORVR_PER 

### = Percentage of VMT by ORVR-e quipped vehicles in a given CY. ORVR FLEET_PER 

### = Percentage of vehicle fleet eq uipped with ORVR in a given CY. See Equation (1). GAS VMT_MIX 

### = Gasoline component of the VMT fractional mix.

Equation (6):

M F WT n

i MIX VMT VMT DS VEH GAS * ) * 1 ( 25

1 _ 

### ∑ =

= − =



### Where: GAS VMT_MIX 

### = Gasoline component of the VMT fractional mix. i = Vehicle age. The vehicle age for a specific vehicle type ranges from one to twenty-five years, with vehicles twenty-five years and older grouped together. VEH WT 

### = Weighted fractional average of the number of VMT/day in a given CY for a specific vehicle type of a given age in relation to the total VMT/day in a given CY fo r all vehicle types of all ages. See Equation (3). DS F 

### = Diesel sales fraction for a specific vehicle type, based on MY E 

### of vehicle. VMT M 

### = VMT fractional mix (fuel inde pendent) in a given CY for a specific vehicle type.

## C. Definition (c)

The following equations in conjunction with Equations (2), (3), and (4) were used to determine a widespread use date for definition (c):

Equation (7): ∑

= = type vehicle j T R S2 ] GU / * AFE * [VEH E GU



### Where: E S2 

### = Stage II VRS emissions (without ORVR) on a summer day in a given CY for all vehicl e types, grams/gal. VEH R 

### = Vehicle refueling and spillage emissions in a given CY for a specific vehicle type utilizi ng Stage II VRS, grams/mile. AFE = Average fuel economy for a sp ecific vehicle type in a given CY, miles/gal. GU = Gasoline usage in a given CY for a specific vehicle type, gal/day. GU T 

### = Total gasoline usage for a given CY for all vehicle types, gal/day.

Equation (7) was used to calculate Stage II VRS emissions in grams per gal, without ORVR, in a given CY for each vehicle type (based on summertime data). The following methodology was used to calculate emissions:

1. For a specific CY, calculate the Stage II VRS emissions associated with each individual vehicle type. This ca lculation is done by multiplying the calculated vehicle refueling and spillage emissions in grams per mile for the specific vehicle type in question by the average fuel economy (AFE) in miles per gal of the vehicle type, then by the percentage of gasoline used in the CY by the specific vehicle type (i.e., ratio of the gasoline usage of the specific vehicle type in gal per day to total gasoline usage for all vehicle types in gal per day in a given CY). 2. Total Stage II VRS emissions in a given CY equals the sum of the emissions calculated for each individual vehicle type.

Equation (8):
∑ =

= + = 25

n

1 i WT IU R R ] EH * FE)) / (SP 100)) / (CE

- (1 * FE / [(E VEH V



### Where: VEH R 

### = Vehicle refueling and spillage emissions in a given CY for a specific vehicle type utilizi ng Stage II VRS, grams/mile. i = Vehicle age. The vehicle age for a specific vehicle type ranges from one to twenty-five years, with vehicles twenty-five years and older grouped together. E R 

### = Uncontrolled displacemen t losses from vehicle refueling, grams/gal. FE = Fuel economy of vehicle, based on MY E 

### of vehicle, miles/gal.

### CE IU 

### = In-use control efficiency of Stage II VRS. SP = Spillage emissions factor, grams/gal. VEH WT 

### = Weighted fractional average of the number of VMT/day in a given CY for a specific vehicle type of a given age in relation to the total VMT/day in a given CY fo r all vehicle types of all ages. See Equation (3).

Equation (8) was used to calcula te vehicle refueling and spilla ge emissions in a given CY for a specific vehicle type in grams per mile. The following methodology was used to calculate emissions:



## 1. Emissions were calculated for a speci fic vehicle type from ages one to twenty-five (vehicles tw enty-five years and olde r are grouped together), resulting in twenty-five calculations per individual vehicle type. Each calculation consisted of dividing the calculated uncontrolled displacement emissions from vehicle refueling in grams per gal by the fuel economy (FE) of the vehicle in miles per gal. The FE is based on the estimated model year (MY) of the vehi cle type at a given age. 

## 2. The result from step 1 is multiplied by the percentage of emissions not controlled by the Stage II VRS (i .e., one minus the in-use control efficiency). 

## 3. The result from step 3 is added to th e emissions attributed to spillage. Spillage emissions are calculated by di viding the spillage emissions factor in grams per gal by the FE of the vehicle in miles per gal. 

## 4. The result from step 3 is multiplied by the weighted fractional average of the number of vehicle miles traveled (VMT) per day in the given CY for the specific vehicle type of a given age in relation to the total VMT per day in the same CY for all vehicle types of all ages. 

## 5. Total vehicle refueling and spillage em issions in a given CY equals the sum of emissions calculated from ag es one to twenty-five for a specific vehicle type.

Equation (9): ) ∗ ( 0.485 + ) + ∆ = RVP D R T * (0.0884 T) * (0.0949

- (-5.909) E



### Where: E R 

### = Uncontrolled displacement loss es from vehicle refueling (AP-42 equation 6), grams/gal. ∆ T = Difference between temperature of fuel in vehicle tank and temperature of dispensed fuel, °F. T D 

### = Temperature of dispensed fuel, °F. RVP = Reid vapor pressure, psia.

Equation (9) is taken from AP-42 (Chapt er 5.2 Transportation and Marketing of Petroleum Liquids, Equation 6) to calcul ate uncontrolled displacement losses from

### vehicle refueling in grams per gal. This e quation uses constants and takes into account the temperature difference between the fuel in the vehicle fuel tank and the temperature of the dispensed fuel, as we ll as the RVP of the fuel.

Equation (10):
∑ =

= = 25

1 ) * / 1 ( / 1 n

i WT VEH FE AFE



### Where: AFE = Average fuel economy for a specific vehicle type in a given CY, miles/gal. i = Vehicle age. The vehicle age for a specific vehicle type ranges from one to twenty-five years, with vehicles twenty-five years and older grouped together. FE = Fuel economy of vehicle, based on MY E 

### of vehicle, miles/gal. VEH WT 

### = Weighted fractional average of the number of VMT/day in a given CY for a specific vehicle type of a given age in relation to the total VMT/day in a given CY fo r all vehicle types of all ages. See Equation (3).

Equation (10) calculates the AFE for a specific vehicle type in a given CY in miles per gal. The following methodology was used to calculate the av erage fuel economy:



## 1. Divide the weighted fractional averag e of the number of VMT/day in a given CY for a specific vehicle type of a given age by the vehicle type’s fuel economy at the given age. 

## 2. Perform step 1 for all ages one to twenty-five. 

## 3. Sum each result from step 2 to get a total sum. 

## 4. Take the inverse of the total sum.

### Equation (11):

AFE VMT VMT DS VEH GU T M F n

i WT / * * )] * ( 1 [( 25

1 

### ∑ =

= − =



### Where: GU = Gasoline usage in a given CY for a specific vehicle type, gal/day. i = Vehicle age. The vehicle age for a specific vehicle type ranges from one to twenty-five years, with vehicles twenty-five years and older grouped together. VEH WT 

### = Weighted fractional average of the number of VMT/day in a given CY for a specific vehicle type of a given age in relation to the total VMT/day in a given CY fo r all vehicle types of all ages. See Equation (3). DS F 

### = Diesel sales fraction for a specific vehicle type, based on MY E 

### of vehicle. VMT M 

### = VMT fractional mix (fuel inde pendent) in a given CY for a specific vehicle type. VMT T 

### = Total number of VMT per day in a given CY for all vehicle types.

Equation (11) calculates the gasoline usage fo r a summer day in a given CY for a specific vehicle type in gallons per day. The following methodology was used to calculate gasoline usage:



## 1. Multiply the weighted fractional average of the number of VMT per day in a given CY for a specific vehicle type of a given age by the diesel sales fraction of the specific vehicle type, which is based on the estimated MY of the vehicle type. 

## 2. Perform step 1 for ages one to twenty-five. 

## 3. Sum each result from step 2 to get a total sum. 

## 4. Subtract one from the result obtaine d in step 3 (i.e., only account for gasoline fueled vehicles). 

## 5. Multiply result from step 4 by the VMT fractional mix value then by the total number of VMT per summer day in a given CY for all vehicle types. 

## 6. Divide the result from step 5 by the AF E for the specific vehicle type in a given CY.

Equation (12): ∑

= =

e vehicletyp j T GU GU



### Where: GU T 

### = Total gasoline usage for a given CY for all vehicle types, gal/day. GU = Gasoline usage in a given CY for a specific vehicle type, gal/day.

### Equation (12) is used to determine total ve hicle gasoline usage in a given CY for all vehicle types in gallons per day. This valu e is calculated by summing the gasoline usage for each specific vehicle type in gallons per day.

Equation (13): ∑

= =

e vehicletyp j T ORVR ORVR GU GU AFE VEH E ) / * * (



### Where: E ORVR 

### = ORVR emissions (without Stage II) on a summer day in a given CY for all vehicle types, grams/gal. VEH ORVR 

### = Vehicle refueling and spillage emissions in a given CY for a specific vehicle type utilizing ORVR canisters, grams/mile. AFE = Average fuel economy for a spec ific vehicle type in a given CY, miles/gal. GU = Gasoline usage for a given CY for a specific vehicle type, gal/day. GU T 

### = Total gasoline usage for a given CY for all vehicle types, gal/day.

Equation (13) is used to cal culate ORVR emissions (without Stage II VRS) on a summer day in a given CY for all vehicle types in grams per gal. The following methodology was used to calculate ORVR emissions:

1. Multiply vehicle refueling and spilla ge emissions in a given CY for a specific vehicle type utilizing ORVR in grams per gal by the AFE for the specific vehicle type in a given CY in miles per gal. 2. Multiply the result in step 1 by the ratio of gasoline usage in a given CY for the specific vehicle type in gall ons per day to the total gasoline usage in a given CY for all vehicl e types in gallons per day. 3. Repeat steps 1 and 2 for each vehicle types. 4. Sum each result from step 2 to ge t a total sum of ORVR emissions.

### Equation (14):
∑ =

= +

− + = 25

1 ] * ) )) 1 ( ( * / [( n

i WT ADJ PI VAR R ORVR VEH SP ORVR ORVR FE E VEH



### Where: VEH ORVR 

### = Vehicle refueling and spillage emissions in a given CY for a specific vehicle type utilizing ORVR canisters, grams/mile. i = Vehicle age. The vehicle age for a specific vehicle type ranges from one to twenty-five years, with vehicles twenty-five years and older grouped together. E R 

### = Uncontrolled displacement losses from vehicle refueling, grams/gal. FE = Fuel economy of vehicle, based on MY E 

### of vehicle, miles/gal. ORVR VAR 

### = ORVR emission rate adjustme nt for tampering and phase-in rate for model year. ORVR PI 

### = ORVR phase-in rate, based on MY E 

### of vehicle. SP ADJ 

### = Adjusted spillage emissions, grams/mile. VEH WT 

### = Weighted fractional average of the number of VMT/day in a given CY for a specific vehicle type of a given age in relation to the total VMT/day in a given CY fo r all vehicle types of all ages. See Equation (3).

Equation (15):

) * ( * ) 1 ( * ) 1 ( PI R PI R CE VAR ORVR TP ORVR TP ORVR ORVR +

− − =



### Where: ORVR VAR 

### = ORVR emission rate adjustment for tampering and phase-in rate for model year. ORVR CE 

### = Control efficiency of ORVR technology. TP R 

### = Tampering rate for ORVR canisters. ORVR PI 

### = ORVR phase-in rate, based on MY E 

### of vehicle.

Equation (16):

) 1 ) 1 ( * ( * / PI ORVR PI ADJ ORVR SP ORVR FE SP SP

− +

− =



### Where: SP ADJ 

### = Adjusted spillage emissions, grams/mile. SP = Spillage emissions factor, grams/gal. FE = Fuel economy of vehicle, based on MY E 

### of vehicle, miles/gal. ORVR PI 

### = ORVR phase-in rate, based on MY E 

### of vehicle. SP ORVR 

### = ORVR control efficiency for spillage.

Equation (16) is used to estimate the spill age emissions associated with ORVR-equipped vehicles in grams/gal. The following met hodology was used to cal culate ORVR spillage emissions:

### 1. Divide the spillage emissions factor in grams per gallon by the FE of the specific vehicle type of a sp ecific MY in miles per gallon.


## D. Definition (c2)

The following equations in conjunction with Equations (2), (3), (4), (9), (10), (11), (12), (13), (14), (15), a nd (16) were used to determin e a widespread use date for definition (c2):

### Equation (17): ∑

= + + =

e vehicletyp j T ADJ INC COM INC GU GU AFE VEH VEH VEH E ] / * * ) [(



### Where: E INC 

### = Emissions from incompatible Stage II and ORVR technologies on a summer day in a given CY for all vehicle types, grams/gal. VEH COM 

### = Vehicle refueling and spillage emissions in a given CY for a specific vehicle type utilizi ng both Stage II VRS and ORVR canisters (compatible technologies), grams/mile. VEH INC 

### = Vehicle refueling and spillage emissions in a given CY for a specific vehicle type utilizi ng both Stage II VRS and ORVR canisters (incompatible technologies), grams/mile. VEH ADJ 

### = Vehicle refueling and spillage emissions in a given CY for a specific vehicle type utilizing OR VR canisters at an adjusted control efficiency, grams/mile. AFE = Average fuel economy for a spec ific vehicle type in a given CY, miles/gal. See Equation (10). GU = Gasoline usage for a given CY for a specific vehicle type, gal/day. See Equation (11). GU T 

### = Total gasoline usage for a given CY for all vehicle types, gal/day. See Equation (12).

Equation (18):

∑ =

= +

− − +

− = 25

1 ] * ) )) 100 / 1 ( * ) 1 ( ) 100 / 1 ( * ( * / [( n

i WT ADJ IU PI IU VAR R COM VEH SP CE ORVR CE ORVR FE E VEH



### Where: VEH COM 

### = Vehicle refueling and spillage emissions in a given CY for a specific vehicle type utilizi ng both Stage II VRS and ORVR canisters (compatible technologies), grams/mile. i = Vehicle age. The vehicle age for a specific vehicle type ranges from one to twenty-five years, with vehicles twenty-five years and older grouped together. E R 

### = Uncontrolled displacement losses from vehicle refueling, grams/gal. See Equation (9) FE = Fuel economy of vehicle, based on MY E 

### of vehicle, miles/gal. ORVR VAR 

### = See Equation (15). CE IU 

### = In-use control efficiency of Stage II VRS. ORVR PI 

### = ORVR phase-in rate, based on MY E 

### of vehicle. SP ADJ 

### = Adjusted spillage emissions , gram/gal. See Equation (16). VEH WT 

### = Weighted fractional average of the number of VMT/day in a given CY for a specific vehicle type of a given age in relation to the total VMT/day in a given CY fo r all vehicle types of all ages. See Equation (3).

### Equation (19):
∑ =

= − = 25

1 ] * * ) 1 ( * / [ n

i WT PI R E INC VEH ORVR TP FE INC VEH



### Where: VEH INC 

### = Vehicle refueling and spillage emissions in a given CY for a specific vehicle type utilizing incompatible Stage II VRS and ORVR canisters, grams/mile. i = Vehicle age. The vehicle age for a specific vehicle type ranges from one to twenty-five years, with vehicles twenty-five years and older grouped together. INC E 

### = Incompatible emissions from Stage II and ORVR technologies, grams/gal. FE = Fuel economy of vehicle, based on MY E 

### of vehicle, miles/gal. TP R 

### = Tampering rate for ORVR canisters. ORVR PI 

### = ORVR phase-in rate, based on MY E 

### of vehicle. VEH WT 

### = Weighted fractional average of the number of VMT/day in a given CY for a specific vehicle type of a given age in relation to the total VMT/day in a given CY fo r all vehicle types of all ages. See Equation (3).

Equation (20): ) 1 ( * ) 1 ( * * PROC MS PER E ORVR ORVR PV EE INC

− − =



### Where: INC E 

### = Incompatible emissions from Stage II and ORVR technologies, grams/gal. EE = Excess emissions from incompatibility of Stage II and ORVR technologies, grams/gal. PV PER 

### = Adjusted percentage of GDFs equipped with functioning assist Stage II VRS and P/V valves on UST vents. ORVR MS 

### = Percentage of ORVR canist ers with mechanical seals. ORVR PROC 

### = Percentage of vacuum assist Stage II with processors.

Equation (21):

) 4536

. 0 * 4

. 8 /( * 4536

. 0 * ))) * ) /( ) (( ( * ) /( ) (( R AL AL AL EE EE EE AL AL AL EE EE E GIL WA GIL WA GIL GIL VA WA GIL WA GIL EE

− − − +

− − =



### Where: EE = Excess emissions from incompatibility of Stage II and ORVR technologies, grams/gal.

### GIL EE 

### = Excess emissions for the Gilbarco vacuum assist VRS, lb/1,000 gal. 1


### WA EE 

### = Excess emissions for the Dresser Wayne vacuum assist VRS with P/V valve, lb/1,000 gal. 2


### GIL AL 

### = Air to liquid ratio (A/L) for the Gilbarco VRS. 3


### WA AL 

### = A/L for the Dresser Wayne VRS. 4


### VA AL 

### = A/L for a vacuum assist VRS, as reported by CARB. E R 

### = Uncontrolled displacement losses from vehicle refueling, grams/gal. See Equation (9).

Equation (22): PV CE VA VA PER IU PER PV 

### = ∗ ∗ / /.

100 0 95



### Where: PV PER 

### = Adjusted percentage of GDFs equipped with functioning assist Stage II VRS and P/V valves on UST vents. CE IU 

### = In-use control efficiency of Stage II VRS. VA PER 

### = Percentage of GDFs equipped w ith vacuum assist Stage II VRS. VA PV 

### = Percentage of GDFs equipped with vacuum assist Stage II VRS and PV valves on UST vents.

Equation (23):
∑ =

= − − = 25

1 ] * * * ) 1 ( * ) ( * / [ n

i WT PI PER R ADJ CE R ADJ VEH ORVR PV TP ORVR ORVR FE E VEH



### Where: VHE ADJ 

### = Vehicle refueling and spillage emissions in a given CY for a specific vehicle type utilizing OR VR canisters at an adjusted ORVR control efficiency, grams/gal. i = Vehicle age. The vehicle age for a specific vehicle type ranges from one to twenty-five years, with vehicles twenty-five years and older grouped together. E R 

### = Uncontrolled displacement losses from vehicle refueling, grams/gal. See Equation (9). FE = Fuel economy of vehicle, based on MY E 

### of vehicle, miles/gal. ORVR CE 

### = Control efficiency of ORVR technology. ORVR ADJ 

### = Adjusted Control effici ency of ORVR technology. TP R 

### = tampering rate for ORVR canisters.

1 CARB Preliminary Draft Test Report , “Total Hydrocarbon Emissions from Two Phase II Vacuum Assist Vapor Recovery Systems During Baseline Operation and Simulated Refueling of Onboard Refueling Vapor Recovery (ORVR) Equipped Vehicles,” June 1999.
2 Ref. 1
3 Ref. 1
4 Ref. 1

### PV PER 

### = Adjusted percentage of GDFs e quipped with assist Stage II VRS and P/V valves on UST vents. ORVR PI 

### = ORVR phase-in rate, based on MY E 

### of vehicle. VEH WT 

### = Weighted fractional average of the number of VMT/day in a given CY for a specific vehicle type of a given age in relation to the total VMT/day in a given CY fo r all vehicle types of all ages. See Equation (5).


## E. Definition (d)

The following equations in conjunction with E quations (2), (3), (4), (10), (11) and (12) were used to determine a widespread use date for definition (d):

Equation (24):


### ∑

= =

e vehicletyp j T PER GAS PER ORVR GU GU ORVR GAS / ] * [

_ _



### Where: GAS ORVR_PER 

### = Percentage of gasoline dispen sed to ORVR-equipped vehicles in a given CY. ORVR GAS_PER 

### = Percentage of vehicle fleet eq uipped with ORVR, gasoline basis. GU = Gasoline usage in a given CY for a specific vehicle type, gal/day. See Equation (11). GU T 

### = Total gasoline usage for a given CY for all ve hicle types, gal/day. See Equation (12).

### Equation (25):

FE AFE VEH ORVR ORVR WT n

i PI PER GAS / * * 25

1 _ 

### ∑ =

= =



### Where: ORVR GAS_PER 

### = Percentage of vehicle fleet eq uipped with ORVR, gasoline basis. i = Vehicle age. The vehicle age for a specific vehicle type ranges from one to twenty-five years, with vehicles twenty-five years and older grouped together. ORVR PI 

### = ORVR phase-in rate, based on MY E 

### of vehicle. VEH WT 

### = Weighted fractional average of the number of VMT/day in a given CY for a specific vehicle type of a given age in relation to the total VMT/day in a given CY fo r all vehicle types of all ages. See Equation (3). AFE = Average fuel economy for a spec ific vehicle type in a given CY, miles/gal. See Equation (10). FE = Fuel economy of vehicle, based on MY E 

### of the vehicle, miles/gal.

# Appendix C

Widespread Use Results for NESCAUM StatesVERMONT024681012141618202001 2006 2011 2016 2021 2026

Emissions (tons/summer day)0%10%20%30%40%50%60%70%80%90%100% % PenetrationEmissions if only Stage II controlswere in place, without ORVREmissions with only ORVRrequirements, without Stage II controlsEmissions with Stage II and ORVR,including "incompatibility excessemissions" of 0.86 lb/1000 gal forVacuum AssistEmissions with Stage II and ORVR,without "excess emissions% ORVR Penetration, option (a)definition% ORVR Penetration, option (b)definition% ORVR Penetration, option (d)definition"Widespread use" dateunder option (c)"Widespread use"date under option (c2)TOTAL REFUELING EMISSIONS- VERMONTTons PerSummer DayCalendarYearStage IIControlsOnlyORVROnlyStage II withORVR, NoIncompatibilityStage II withORVR,Incompatibility% DecreasefromUncontrolledEmissionsStage IIControlsOnlyORVROnlyStage II withORVR, NoIncompatibilityStage II withORVR,Incompatibility Excess EmissionsEstimated inPeriodicInventory g/gal tpsdVehicles <10,000 lbGVWRAllGasVehiclesVehicles< 10,000lbGVWRAllGasVehiclesVehicles <10,000 lbGVWRAll GasVehicles,but notMCAll GasVehicles,with MCUnc.HDGVg/gal2001 1.519 3.094 1.349 1.377 61% 1.57 3.19 1.39 1.42 0.03 0.902 0.93 16% 16% 13% 13%15% 14% 14%0.8652002 1.519 2.899 1.272 1.313 63% 1.59 3.03 1.33 1.37 0.04 19965.930.846 0.88 22% 22% 19% 19%21% 20% 20%0.8792003 1.519 2.684 1.188 1.243 65% 1.61 2.84 1.26 1.31 0.06 0.795 0.84 30% 29% 26% 25%27% 26% 26%0.8942004 1.519 2.453 1.097 1.167 67% 1.56 2.52 1.13 1.20 0.07 0.734 0.75 37% 37% 33% 32%34% 33% 32%0.9062005 1.520 2.195 0.996 1.083 69% 1.65 2.39 1.08 1.18 0.09 0.669 0.73 45% 44% 41% 40%40% 39% 39%0.9192006 1.520 1.926 0.890 0.994 72% 1.67 2.12 0.98 1.09 0.11 0.596 0.66 53% 52% 50% 48%47% 46% 45%0.9322007 1.520 1.676 0.792 0.912 74% 1.69 1.87 0.88 1.02 0.13 0.533 0.59 60% 59% 57% 56%54% 53% 52%0.9462008 1.520 1.454 0.704 0.839 76% 1.71 1.64 0.79 0.95 0.15 0.483 0.54 67% 66% 64% 63%60% 59% 58%0.9622009 1.520 1.258 0.627 0.775 78% 1.71 1.42 0.71 0.87 0.17 0.441 0.50 73% 72% 70% 68%66% 65% 63%0.9772010 1.520 1.086 0.560 0.719 80% 1.76 1.25 0.65 0.83 0.18 0.407 0.47 78% 77% 75% 74%72% 70% 68%0.9892011 1.520 0.942 0.503 0.672 81% 1.78 1.10 0.59 0.78 0.20 82% 81% 80% 78%76% 75% 73%1.0012012 1.520 0.823 0.456 0.632 82% 1.78 0.97 0.54 0.74 0.21 85% 84% 83% 82%80% 78% 77%1.0122013 1.520 0.724 0.417 0.600 83% 1.82 0.87 0.50 0.72 0.22 88% 87% 87% 85%84% 82% 80%1.0212014 1.520 0.644 0.386 0.574 84% 1.84 0.78 0.47 0.69 0.23 91% 89% 89% 87%86% 84% 82%1.0302015 1.520 0.579 0.360 0.552 84% 1.86 0.71 0.44 0.68 0.23 92% 91% 91% 89%89% 87% 85%1.0382016 1.520 0.527 0.340 0.535 85% 1.88 0.65 0.42 0.66 0.24 94% 92% 93% 91%90% 88% 86%1.0452017 1.520 0.485 0.324 0.522 85% 1.90 0.61 0.40 0.65 0.25 95% 94% 94% 92%92% 90% 88%1.0512018 1.520 0.452 0.311 0.511 86% 1.92 0.57 0.39 0.65 0.25 96% 94% 95% 93%93% 91% 89%1.0572019 1.520 0.426 0.300 0.502 86% 1.94 0.54 0.38 0.64 0.26 96% 95% 96% 94%94% 92% 90%1.0632020 1.520 0.405 0.292 0.495 86% 1.96 0.52 0.38 0.64 0.26 97% 96% 96% 94%95% 93% 91%1.0692021 1.520 0.386 0.285 0.489 86% 1.98 0.50 0.37 0.64 0.27 98% 96% 97% 95%96% 93% 91%1.0692022 1.520 0.369 0.278 0.484 86% 2.00 0.49 0.37 0.64 0.27 98% 97% 97% 95%97% 94% 92%1.0692023 1.520 0.354 0.272 0.479 86% 2.02 0.47 0.36 0.64 0.28 98% 97% 98% 96%97% 95% 93%1.0692024 1.520 0.343 0.268 0.475 87% 2.05 0.46 0.36 0.64 0.28 99% 97% 98% 96%98% 95% 93%1.0692025 1.520 0.330 0.263 0.471 87% 2.07 0.45 0.36 0.64 0.28 99% 98% 99% 96%98% 96% 94%1.0692026 1.520 0.319 0.258 0.467 87% 2.09 0.44 0.35 0.64 0.29 99% 98% 99% 97%99% 97% 94%1.0692027 1.520 0.311 0.255 0.465 87% 2.11 0.43 0.35 0.64 0.29 99% 98% 99% 97%99% 97% 95%1.0692028 1.520 0.301 0.251 0.461 87% 2.13 0.42 0.35 0.65 0.29 100% 98% 100% 97%100% 97% 95%1.0692029 1.520 0.290 0.247 0.458 87% 2.15 0.41 0.35 0.65 0.30 100% 98% 100% 98%100% 98% 95%1.0692030 1.520 0.286 0.245 0.456 87% 2.17 0.41 0.35 0.65 0.30 100% 99% 100% 98%100% 98% 95%1.0690.85714286ORVR PenetrationVehicle BasisGrams Emitted Per Gallon GasolineVMT Basis Fuel Usage BasisTons Per Summer Day Environ ReportVT Algorithm3.xls, Emissions9/30/2005, 2:00 PMNH ChartPage 1NEW HAMPSHIRE024681012141618202001 2006 2011 2016 2021 2026

Emissions (tons/summer day)0%10%20%30%40%50%60%70%80%90%100% % PenetrationEmissions if only Stage II controls werein place, without ORVREmissions with only ORVRrequirements, without Stage II controlsEmissions with Stage II and ORVR,including "excess emissions" of 0.86lb/1000 gal for Vacuum AssistEmissions with Stage II and ORVR,without "excess emissions"% ORVR Penetration, option (b)definition% ORVR Penetration, option (d)definition"Widespread use" dateunder option (c)"Widespread use" dateunder option (c2)TOTAL REFUELING EMISSIONS- NEW HAMPSHIRETons PerSummer DayCalendarYearStage IIControlsOnlyORVROnlyStage II withORVR, NoIncompatibilityStage II withORVR,Incompatibility% DecreasefromUncontrolledEmissionsStage IIControlsOnlyORVROnlyStage II withORVR, NoIncompatibilityStage II withORVR,Incompatibility Excess EmissionsEstimated inPeriodicInventory g/gal tpsdVehicles <10,000 lbGVWRAllGasVehiclesVehicles< 10,000lbGVWRAllGasVehiclesVehicles< 10,000lbGVWRAll GasVehicles,not MCAll GasVehicles,with MCUnc.HDGVg/gal2001 1.149 2.604 1.020 1.044 65% 2.41 5.46 2.14 2.19 0.05 0.902 1.89 16% 16% 14% 14% 0.5322002 1.149 2.416 0.956 0.992 67% 2.46 5.17 2.05 2.12 0.08 19965.930.846 1.81 23% 23% 21% 20% 0.5382003 1.164 2.236 0.895 0.945 69% 2.54 4.88 1.95 2.06 0.11 0.795 1.74 32% 31% 29% 28% 0.5532004 1.164 1.998 0.814 0.879 71% 2.59 4.45 1.81 1.96 0.15 0.734 1.63 41% 40% 37% 37% 0.5592005 1.164 1.752 0.731 0.811 73% 2.64 3.98 1.66 1.84 0.18 0.669 1.52 49% 49% 46% 45% 0.5652006 1.164 1.505 0.647 0.743 76% 2.70 3.49 1.50 1.72 0.22 0.596 1.38 58% 57% 55% 54% 0.5712007 1.164 1.299 0.578 0.687 77% 2.75 3.07 1.36 1.62 0.26 0.533 1.26 65% 64% 62% 61% 0.6022008 1.164 1.099 0.510 0.632 79% 2.81 2.65 1.23 1.52 0.29 0.483 1.16 71% 71% 69% 68% 0.5842009 1.165 0.951 0.460 0.591 81% 2.86 2.34 1.13 1.45 0.32 0.441 1.08 76% 76% 75% 74% 0.6272010 1.165 0.817 0.415 0.554 82% 2.92 2.05 1.04 1.39 0.35 0.407 1.02 81% 80% 80% 78% 0.6382011 1.164 0.695 0.373 0.520 83% 2.98 1.78 0.95 1.33 0.38 85% 84% 84% 83% 0.6062012 1.165 0.618 0.347 0.499 84% 3.04 1.61 0.91 1.30 0.40 88% 87% 87% 85% 0.6572013 1.164 0.538 0.320 0.477 84% 3.10 1.43 0.85 1.27 0.42 91% 90% 90% 88% 0.6202014 1.165 0.481 0.301 0.461 85% 3.16 1.30 0.82 1.25 0.44 93% 92% 92% 90% 0.6272015 1.165 0.434 0.285 0.449 85% 3.22 1.20 0.79 1.24 0.45 94% 93% 93% 92% 0.6342016 1.165 0.395 0.272 0.438 86% 3.29 1.12 0.77 1.24 0.47 96% 95% 95% 93% 0.6412017 1.165 0.368 0.263 0.430 86% 3.36 1.06 0.76 1.24 0.48 96% 96% 96% 94% 0.6902018 1.165 0.338 0.253 0.422 86% 3.42 0.99 0.74 1.24 0.50 97% 96% 97% 95% 0.6562019 1.165 0.319 0.246 0.417 86% 3.49 0.96 0.74 1.25 0.51 98% 97% 97% 96% 0.6632020 1.165 0.304 0.241 0.413 86% 3.56 0.93 0.74 1.26 0.52 98% 97% 98% 96% 0.6702021 1.165 0.293 0.238 0.410 87% 3.63 0.91 0.74 1.28 0.54 99% 98% 98% 97% 0.6772022 1.165 0.282 0.234 0.407 87% 3.70 0.90 0.74 1.29 0.55 99% 98% 99% 97% 0.6842023 1.165 0.273 0.231 0.404 87% 3.78 0.89 0.75 1.31 0.56 99% 98% 99% 98% 0.6912024 1.165 0.269 0.229 0.403 87% 3.85 0.89 0.76 1.33 0.58 99% 98% 99% 98% 0.6982025 1.165 0.265 0.228 0.402 87% 3.93 0.89 0.77 1.36 0.59 100% 99% 99% 98% 0.7052026 1.165 0.261 0.227 0.401 87% 4.01 0.90 0.78 1.38 0.60 100% 99% 100% 98% 0.7122027 1.165 0.258 0.226 0.400 87% 4.09 0.91 0.79 1.41 0.61 100% 99% 100% 98% 0.7192028 1.165 0.255 0.225 0.399 87% 4.17 0.91 0.80 1.43 0.63 100% 99% 100% 98% 0.7252029 1.165 0.250 0.223 0.398 87% 4.26 0.91 0.82 1.45 0.64 100% 99% 100% 98% 0.7322030 1.165 0.249 0.223 0.398 87% 4.34 0.93 0.83 1.48 0.65 100% 99% 100% 98% 0.7390.85714286ORVR PenetrationVehicle BasisGrams Emitted Per Gallon GasolineVMT Basis Fuel Usage BasisTons Per Summer Day Environ ReportNH Algorithm3.xls, Emissions9/30/2005, 2:04 PMMA ChartPage 1MASSACHUSETTS024681012141618202001 2006 2011 2016 2021 2026

Emissions (tons/summer day)0%10%20%30%40%50%60%70%80%90%100% % PenetrationEmissions if only Stage II controls werein place, without ORVREmissions with only ORVRrequirements, without Stage II controlsEmissions with Stage II and ORVR,including "excess emissions" of 0.86lb/1000 gal for Vacuum assistEmissions with Stage II and ORVR,without "excess emissions"% ORVR Penetration, option (b)definition% ORVR Penetration, option (d)definition"Widespread use"date under option (c)"Widespread use"date under option( 2)TOTAL REFUELING EMISSIONS-MASSACHUSETTSTons PerSummer DayCalendarYearStage IIControlsOnlyORVROnlyStage II withORVR, NoIncompatibilityStage II withORVR,Incompatibility% DecreasefromUncontrolledEmissionsStage IIControlsOnlyORVROnlyStage II withORVR, NoIncompatibilityStage II withORVR,Incompatibility Excess EmissionsEstimated inPeriodicInventory g/gal tpsdVehicles <10,000 lbGVWRAllGasVehiclesVehicles< 10,000lbGVWRAllGasVehiclesVehicles< 10,000lbGVWRAllGasVehicles,not MCAllGasVehicles,with MCUnc.HDGVg/gal2001 0.682 2.307 0.617 0.635 76% 5.92 20.02 5.35 5.51 0.16 0.902 7.83 16% 16% 14% 14% 0.6462002 0.682 2.147 0.585 0.613 77% 6.01 18.93 5.16 5.41 0.25 19965.930.846 7.46 24% 23% 21% 20% 0.6552003 0.689 2.005 0.556 0.594 78% 6.18 17.97 4.98 5.33 0.34 0.795 7.13 32% 31% 28% 27% 0.6792004 0.690 1.813 0.518 0.567 79% 6.28 16.51 4.72 5.17 0.45 0.734 6.68 40% 40% 36% 35% 0.6892005 0.690 1.599 0.476 0.537 80% 6.38 14.78 4.40 4.97 0.57 0.669 6.19 49% 48% 45% 44% 0.7012006 0.690 1.373 0.432 0.506 81% 6.48 12.90 4.06 4.75 0.69 0.596 5.60 57% 57% 54% 53% 0.7112007 0.690 1.166 0.391 0.477 82% 6.57 11.12 3.73 4.55 0.82 0.533 5.08 65% 64% 62% 61% 0.7232008 0.690 0.982 0.355 0.451 83% 6.67 9.50 3.44 4.36 0.93 0.483 4.67 72% 71% 70% 68% 0.7342009 0.690 0.823 0.324 0.429 84% 6.77 8.08 3.18 4.21 1.03 0.441 4.33 78% 77% 77% 75% 0.7452010 0.690 0.687 0.297 0.410 85% 6.87 6.84 2.96 4.08 1.12 0.407 4.05 83% 82% 82% 80% 0.7552011 0.690 0.578 0.276 0.395 85% 6.97 5.84 2.79 3.99 1.20 88% 86% 86% 85% 0.7642012 0.690 0.494 0.259 0.383 86% 7.07 5.06 2.66 3.92 1.27 91% 90% 90% 88% 0.7722013 0.690 0.428 0.246 0.374 86% 7.17 4.45 2.56 3.88 1.32 93% 92% 93% 91% 0.7792014 0.690 0.378 0.237 0.367 86% 7.27 3.98 2.49 3.86 1.37 95% 94% 95% 93% 0.7852015 0.690 0.342 0.230 0.362 87% 7.36 3.65 2.45 3.86 1.41 96% 95% 96% 94% 0.7912016 0.690 0.317 0.225 0.358 87% 7.46 3.43 2.43 3.88 1.44 97% 96% 97% 95% 0.7972017 0.690 0.299 0.221 0.356 87% 7.56 3.27 2.42 3.90 1.48 98% 97% 98% 96% 0.8012018 0.690 0.286 0.219 0.354 87% 7.66 3.17 2.43 3.93 1.50 98% 97% 98% 96% 0.8052019 0.690 0.275 0.217 0.352 87% 7.76 3.09 2.44 3.96 1.53 99% 98% 99% 97% 0.8082020 0.690 0.267 0.215 0.351 87% 7.86 3.04 2.45 4.00 1.55 99% 98% 99% 97% 0.8122021 0.690 0.260 0.214 0.350 87% 7.95 3.00 2.46 4.04 1.58 99% 98% 99% 97% 0.8122022 0.690 0.253 0.212 0.349 87% 8.05 2.96 2.48 4.08 1.60 100% 98% 99% 98% 0.8122023 0.690 0.249 0.211 0.349 87% 8.15 2.94 2.50 4.12 1.62 100% 98% 100% 98% 0.8122024 0.690 0.246 0.211 0.348 87% 8.24 2.94 2.52 4.16 1.64 100% 99% 100% 98% 0.8112025 0.690 0.242 0.210 0.348 87% 8.34 2.92 2.54 4.20 1.67 100% 99% 100% 98% 0.8102026 0.690 0.241 0.210 0.348 87% 8.43 2.95 2.57 4.25 1.68 100% 99% 100% 98% 0.8102027 0.690 0.241 0.210 0.348 87% 8.53 2.98 2.59 4.30 1.70 100% 99% 100% 98% 0.8112028 0.690 0.240 0.210 0.347 87% 8.62 3.00 2.62 4.34 1.72 100% 99% 100% 98% 0.8102029 0.690 0.239 0.209 0.347 87% 8.71 3.01 2.64 4.39 1.74 100% 99% 100% 98% 0.8102030 0.690 0.238 0.209 0.347 87% 8.81 3.04 2.67 4.43 1.76 100% 99% 100% 98% 0.8100.85714286ORVR PenetrationVehicle BasisGrams Emitted Per Gallon GasolineVMT Basis Fuel Usage BasisTons Per Summer Day Environ ReportMA Algorithm3.xls, Emissions9/30/2005, 2:05 PM