Gasoline Dispenser Hose Permeation Workshop November 13, 2003 Monitoring and Laboratory Division Air Resources Board California Environmental Protection.
Gasoline Dispenser Hose PermeationWorkshopNovember 13, 2003Monitoring and Laboratory DivisionAir Resources BoardCalifornia Environmental Protection AgencyAgendaIntroductionsBackground for Regulating Hose Permeation Baseline Emission EstimateSuggested Standard Testing ConsiderationsCost-Effective Analysis ScheduleSIP Vapor Recovery MeasuresMeasureDescriptionFVR-1Enhanced Vapor Recovery for Aboveground Storage TanksFVR-2Gasoline Dispensing at MarinasFVR-3Hose PermeationON-RD HVY-DUTY-2Cargo TanksGasoline Dispenser HosesUL 330 - Standard for Safety for Hose and Hose Assemblies for Dispensing Flammable LiquidsSix day, 3150 cycle/day flex testRefill hose every 24 hoursDivide volume of fuel added over the six days by volume of the hoseAllows 30% total lossHose Permeation EmissionsAssume 12 hoses/station Assume gasoline permeation at levels allowed by UL 330Estimate 3 tons/day statewideSAE J1527 Marine Fuel HosesApplicable to hoses on pleasurecraft100 g/m2/day permeation limitup to 1.7 tons/dayemission reductionsstatewidePermeation RegulationsPortable fuel containers (CA)0.4 g/gal/day per TM 513 (SHED)Small off-road engine fuel tanks (CA)2 g/m2/day per TP-901Nonroad Large SI Engines and Recreational Engines (Marine and Land) fuel hoses (USEPA)5 g/m2/day @ 23 deg C per SAE J1527 Low Permeation Fuel Hose TechnologyEntire hose made with low permeation materialLow permeation barrier layer(s)Permeation TestingTest existing hoses to refine baseline emission estimateTest prototype hoses to set best achievable permeation limitIdentify options for certification testTesting ConsiderationsDurability - aging and cycle testsPre-Conditioningfill hose with fuel and wait for saturationType of fuelHose configurationsingle or co-axial Temperaturetypical or worst-case?Cost of testCost for Low Permeation HosesUSEPA estimates incremental cost of $1.00/ft for engine fuel hosesFor 12 foot coax hose => $24Used $50 increase/hose for initial cost estimateHoses today cost $100 - $200 (?)Cost-EffectivenessAssume hose life of one yearAssume cost increase of $50 per hoseTotal annual cost = $6,780,000 $6,780,000/yr 1 ton 1 yr 1.7 tons/day 2000 lb 365 days = $5.46/lbhosepermCost-effectiveness for ARB Major RegulationsTentative Rulemaking ScheduleFeb 2004 - complete preliminary testsMar 2004 - post draft standard and TPApr 2004 - second workshopJun 2004 - finalize staff proposalAug 2004 - release staff proposalSept 2004 - Board hearing** schedule may slip due to testing and/or other priorities, but expect Board hearing no later than December 2004Proposed Implementation ScheduleDec 2004* - approved by BoardSept 2005 - finalize rulemaking and begin certification Jan 2007* - required for new installationsJan 2011- required for all facilities * commitment dates in revised SIP Settlement Agreement (June 2003)Contact InformationCindy Castronovoccastron@arb.ca.gov (916) 322-8957www.arb.ca.gov/vapor/vapor.htmGasoline Dispenser Hose Permeation WorkshopCalifornia Air Resources BoardGasoline Dispenser Hose Permeation WorkshopReview agenda Conduct introductionsCalifornia Air Resources BoardGasoline Dispenser Hose Permeation WorkshopIt is no secret that California has air pollution problems. This map indicates that the ozone levels vary throughout the state, but only the northern CA areas in green meet the state ozone standards. The Clean Air Act requires that national air quality standards be met by 2010 or the state could face severe federal funding cuts. The CA SIP, or State Implementation Plan was revised and approved at our October 2003 Board meeting and contains several new strategies which seek to control emissions of reactive organic gases, or ROG, which contribute to ozone formation. California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopThere are dozens of measures listed in the SIP, ranging from new car standards to more limits on consumer products.The SIP measures relating to vapor recovery are listed here. The first measure, which will apply Enhanced Vapor Recovery to gasoline dispensing facilities with aboveground storage tanks, is scheduled to be considered by the ARB in February 2004. The second measure, which will seek to control gasoline vapor emissions during fueling of pleasurecraft at marinas, will be addressed in the next few years. The last measure will apply stricter standards to existing vapor recovery systems on gasoline cargo tank trucks.But today, we are here to talk about FVR-3, the measure to limit permeation emissions from gasoline dispenser hoses.California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopThis slide shows the dispenser hoses, also known as curb hoses, that are the focus of the proposed permeation limit. As these hoses are certified by ARB as part of the Phase II vapor recovery program, our goal is to add a permeation standard to the existing vapor recovery certification program. I want to point out several qualities that are necessary for these hoses. One, they must be flexible and light to allow easy vehicle fueling. Second, they must be strong and durable to handle all the stretching and twisting that can occur during normal use. Third, the hoses must be able to maintain these qualities under all ambient temperature conditions. Fourth, the hose material must be compatible with the type of fuel used, which could contain alcohols. Fifth, the hose material must not degrade in sunlight. The existing hoses have been developed with these characteristics in mind and it is important that changes to the hose to limit permeation not cause lower performance in one of these areas.California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopOur understanding is that current dispenser hoses must meet permeation standards for safety reasons. One standard for limiting fluid loss in hoses is described in Underwriters Laboratory standard 330. UL 330 requires a six-day, 3150 cycle/day flex test for a hose filled with fuel. During the test, you refill the hose every 24 hours with measured volumes. At the end of six days, you add up the total volume of fuel added during the test and divide that number by the volume of the hose assembly. UL permits a 30% total loss during the six days. California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopSo what are the actual current permeation emissions from these hoses? We dont know for sure at this time, but we have made some estimates as part of the SIP measure development. We assumed that there was an average of 12 hoses/station and that the existing hoses permeate at the level allowed by UL standard 330. The other assumptions that we used are outlined in a spreadsheet that I will make available on our webpage FYI. Our calculations lead to an estimate of 3 tpd statewide.But what we really wanted to know for the SIP was how much emission reductions might be possible. So, we looked at other existing hose permeation standards.California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopThe permeation standard we chose for our analysis was the SAE standard J1527. This standard applies to reinforced hose for conveying gasoline or diesel fuel aboard pleasurecraft whose fuel systems are regulated under federal law. The SAE standard allows a maximum permeation of 100 grams per square meter of hose per day. We recognize that the use of this hose is significantly different from gasoline curb hose. However, if this standard could be applied to the gasoline dispenser hoses, about 1.7 tons/day of emission reductions could be achieved.So that was how we left it in the SIP plan. This workshop marks the beginning of the rulemaking process for adoption of a permeation standard. What follows is some information Ive garnered in my limited research on options for the permeation limit and associated testing considerations.California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopThe ARB and USEPA have designated permeation standards, and associated test procedures in emissions regulations for other types of equipment.Our portable fuel container or gascan regulation included a permeation limit for the gasoline container of 0.4/gal/day as measured in a Sealed Housing Evaporative Determination or SHED test. Our new permeation limit for small off-road engine tanks is 2 g/m2/day as per TP-901. TP-901 involves durability testing, then a holding time (20 weeks) for fuel saturation, then daily weight measurement until a constant weight loss is observed.USEPA has proposed (or adopted?) a 5 g/m2/day standard for fuel hoses in non-road engines. The test method would be the same as that referenced in SAE J1527, which is the marine fuel hose standard we just discussed.If you know of other similar permeation regulations, Id appreciate if you would bring them to my attention. California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopAccording to the USEPA documents, there are two primary technologies to achieve low permeation hoses.The first approach is to replace the existing hose material with another material that permeates less. One advantage of this strategy is that perhaps it would not require too much change in the hose manufacturing process.The second approach is addition of a low permeation barrier layer to the existing hose material. If the barrier layer is very thin, this technique might retain most of the performance characteristics of the original hose.California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopOne of our first tasks will be to select permeation test procedures for three main purposes. First, we want to develop a better baseline estimate for current hose emissions. Second, we need to test prototype low permeation hoses to establish our proposed standard. Third, we need a test to be used to certify the hoses to the permeation limit.These do not necessarily need to be the same test. We might choose a test where used hoses are subjected to diurnal temperature profiles when estimating current emissions. Whereas for certification, we might look for a fairly worst case test that might not represent ambient conditions, but allows for a simpler and cheaper test.California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopOn this slide we list some factors that we need to consider in our testing program. Do we want to test new hoses, or first require some aging and cycle tests before measuring permeability. Studies have shown that fuel requires some time to saturate the hose before steady permeation emissions occur. How long should we wait before starting the emission measurement? What fuel should we use? Fuels with alcohols normally have higher permeation rates. Vapor recovery hoses are coaxial, but do we need to test the hoses in that configuration? At what temperature do we conduct the tests? And last, but certainly not least in these economic times, how much will the test cost? Im sure you can think of some other factors that we should be considering - wed appreciate if youd let us know. California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopHow much more will a low permeation hose cost? USEPA estimates an incremental cost increase of about $1.00/foot. For a twelve foot co-axial hose, this works out to about $24.However, for our initial cost estimate, we are assuming double that, about $50 more per hose.I have limited information on the going price for dispenser hoses, but Im assuming they are in the range of $100 to $200. Am I close or way off? California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopAs many of you know, ARB rulemakings calculate a cost-effectiveness that allows comparison of different emission reduction strategies. We divide the total annual cost of the regulation (which is the incremental cost due to the new requirements) by the total annual emission reductions. In this calculation, we have assumed a hose life of one year, an incremental cost increase of $50/hose - which leads to a total annual cost of close to 7 million dollars. When we divide this by our estimated 1.7 tons/day of emission reductions and align the units correctly, we obtain a cost-effectiveness of $5.46 per pound. In other words, it will cost $5.46 for each pound of gasoline vapor emission reductions. Note that this calculation does not include (yet) gasoline savings due to the emission reductions. This is a very preliminary calculation, and will be modified as we gather more data, but we can use this initial estimate to compare with other ozone control measures.California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopCalifornia Air Resources BoardGasoline Dispenser Hose Permeation WorkshopHeres our tentative schedule for proceeding with this rulemaking. Our hope is to complete preliminary testing by February and post our draft standard and associated test procedure in March. We hope you would provide input before or at the next workshop in April. After the workshop, we will finalize our proposal and release 45 days before the Baord meeting for a formal comment period. We are aiming of the September 2003 Board meeting, but with the understanding that are schedule could slip due to the testing schedule and other projects.California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopBut we cant delay very long, because we made a legal commitment in the revised SIP settlement agreement to bring this measure to the Board by December 2004. If all goes well, then the regulation would be finalized by the end of of 2005 and we can begin certification of the low permeation hoses. Again, in accordance with the SIP settlement, we anticipate an effective date of January 2007 which would require all new vapor recovery installations to have low permeation hoses. As most of you know, existing facilities have four years after the effective date of the standard to come into compliance. Under this proposed timeline, this would mean all installed vapor recovery hoses in CA would meet the permeation limit by January of 2011.California Air Resources BoardGasoline Dispenser Hose Permeation WorkshopThat completes our presentation!We encourage you to contact us if you have any questions or to provide input on what we presented today. Here is our contact information - we look forward to hearing from you.Thanks for your attention today.California Air Resources Board