Proposed Amendments to Enhanced Vapor Recovery Regulations November 18, 2004 Monitoring and Laboratory Division Air Resources Board California Environmental.

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  • Proposed Amendments to Enhanced Vapor Recovery RegulationsNovember 18, 2004Monitoring and Laboratory DivisionAir Resources BoardCalifornia Environmental Protection Agency

  • OutlineVapor Recovery Program BackgroundEnhanced Vapor Recovery (EVR)Proposed Regulatory AmendmentsEconomic & Environmental ImpactsStakeholder Comments and Proposed 15-day Changes

  • Vapor Recovery Program Background Phase I and Phase II Systems Phase IPhase II

  • Vapor Recovery Program Background VR Provides Large Emission ReductionsROG ReductionsLowEmissionVehiclesCleaner Burning GasolineVapor Recovery(SCAB 2010 tons/day)

  • OutlineVapor Recovery Program Background Enhanced Vapor Recovery (EVR)Proposed Regulatory AmendmentsEconomic & Environmental ImpactsStakeholder Comments and Proposed 15-day Changes

  • Enhanced Vapor Recovery HistoryEVR regulations approved March 2000 Technology progress review December 2002Regulation amendmentsDripless nozzle Delays in implementation schedule

  • Enhanced Vapor RecoveryEVR ModulesModule 1: Phase I vapor recovery

    Module 2: Phase II standards & specsModule 3: ORVR compatibilityModule 4: Liquid retention and nozzle spittingModule 5: Spillage and dripless nozzlesModule 6: In-station diagnosticsPHASE I SYSTEMPHASE II SYSTEM

  • Vapor Recovery Program Background ORVR - Phase II Incompatibility

  • Dotted box: time between start of 4-year clock and operative dateStart of solid bar: date required for new or modified facilities (operative date)End of solid bar: date required for existing facilities (installed before start of bar)Not required for dispensers installed before April 2003 Enhanced Vapor Recovery EVR Current Regulatory Timeline

  • Enhanced Vapor Recovery Previous Board DirectionDecember 2002 Board resolution directed staff to assess adequacy of lead time to install full EVR Phase II systems prior to the ORVR deadlineIntent was to avoid more than one equipment upgradeNot enough time to upgrade 3500 stations with full EVR systems by April 1, 2005

  • OutlineVapor Recovery Program Background Enhanced Vapor Recovery (EVR)Proposed Regulatory AmendmentsEconomic & Environmental ImpactsStakeholder Comments and Proposed 15-day Changes

  • Proposed Regulatory AmendmentsNeed for AmendmentPrevious Board direction to avoid two equipment upgradesNot enough time to modify 3500 stations to be ORVR compatible under current scheduleNo full EVR Phase II system available until January 2005

  • Proposed Regulatory AmendmentsSummaryExtend ORVR compatibility deadlines by up to 11 monthsAmend EVR implementation dates to reflect necessary delays due to full EVR systems not being commercially availableRevise the ISD effective dates to maintain the original phase-in schedule

  • OutlineVapor Recovery Program Background Enhanced Vapor Recovery (EVR)Proposed Regulatory AmendmentsEconomic & Environmental ImpactsStakeholder Comments and Proposed 15-day Changes

  • Economic and Environmental Impacts Economic Impacts$1,500 to $22,000 savings for station owners if only one equipment upgrade Possible cost savings if more ORVR compatible or EVR systems certified soonORVR compatible system equipment manufacturers could lose money due to investment made to meet April 2005 deadline

  • Economic and Environmental ImpactsEmission ImpactEmission reductions of 1.9 tons/day would be forgone for one yearEarly emission reductions of up to 8.3 tons/day for 2006, 2007 and 2008 due to early EVR Phase II implementation

  • OutlineVapor Recovery Program Background Enhanced Vapor Recovery (EVR)Proposed Regulatory AmendmentsEconomic & Environmental ImpactsStakeholder Comments and Proposed 15-day Changes

  • Comments and 15-day ChangesStakeholdersAir Pollution Control DistrictsState Water Resources Control BoardVapor Recovery Equipment ManufacturersPetroleum Marketers & AssociationsService Station Operators & Associations

  • Comments and 15-day Changes Stakeholder CommentsStakeholders supportive of extensionNeed to phase-in ORVR compatibility requirement to ensure all stations in compliance by deadline.Ensure availability of contractorsSpace out permitting workload

  • Comments and 15-day Changes Proposed ORVR Compatibility Phase-In

    Station Annual Throughput (gal/yr)

    ORVR Compatible System Installation Deadline

    > 2 million

    September 1, 2005

    1 million to 2 million

    January 1, 2006

    < 1 million

    March 1, 2006

  • Summary and Staff RecommendationConsistent with previous Board directionAvoids costs associated with two upgradesSignificant emission reductions associated with early EVR Phase II implementationNo oppositionRecommend approval of staffs proposal with suggested 15-day changes

    EVR Date Changes Board PresentationThank-you, Ms. Witherspoon. Good afternoon Chairman Lloyd and members of the Board. Today I will present proposed revisions to the Enhanced Vapor Recovery regulations for gasoline dispensing facilities. California Air Resources BoardEVR Date Changes Board PresentationOur presentation will begin with some background on the vapor recovery program, including the current implementation schedule for Enhanced Vapor Recovery or EVR, which the Board approved in March 2000. We will discuss the need for staffs proposed amendments to extend EVR deadlines. Then we will cover the cost impacts of the proposal as well as changes in emission reductions. Well provide a summary of comments received and our proposed revisions in response to those comments to be considered as 15-day changes. California Air Resources BoardEVR Date Changes Board PresentationThe EVR regulations affect two types of gasoline transfer that take place at service stations, which are characterized as Phase I and Phase II. (mouse click). As shown in this slide, Phase I vapor recovery returns vapors (shown in pink) from the service station underground storage tank to the cargo tank truck, and eventually to the terminal vapor control system. (mouse click). Phase II vapor recovery routes the vapors displaced from fueling vehicles back into the underground storage tank. Phase I and Phase II equipment must be certified by ARB to meet emission standards. California districts began controlling vapor emissions from gasoline stations as early as 1970. In 1987, California adopted the benzene air toxic control measure, which led to use of vapor recovery systems statewide to reduce toxic exposure to benzene. Under the federal Clean Air Act, ARB certified equipment is required in non-attainment areas outside California and is the standard for many countries around the world.

    California Air Resources BoardEVR Date Changes Board PresentationVapor recovery is an important program for control of reactive organic gas emissions. This chart compares the emission reductions in tons/day for the South Coast Air Basin for three major emission control strategies. As shown here, the emissions reductions attributable to vapor recovery are estimated at 108 tons/day, more than the reductions for low emission vehicles and cleaner burning gasoline.In March 2000, this Board approved the Enhanced Vapor Recovery program to gain an additional 25 tons/day of emission reductions statewide and increase durability and reliability of vapor recovery systems.California Air Resources BoardEVR Date Changes Board PresentationNow we will focus on the Enhanced Vapor Recovery program which is currently being implemented. California Air Resources BoardEVR Date Changes Board PresentationAs already mentioned, the Board approved the Enhanced Vapor Recovery or EVR regulations in March 2000. Because several of the EVR standards were technology-forcing, the Board directed staff to conduct a technology review for standards with future effective dates. The results of the technology review, presented to the board in December 2002, showed that all but one of the EVR standards could be met by current or newly designed vapor recovery equipment. Amendments to modify the dripless nozzle standard to an achievable level, and to adjust the EVR schedule to provide an additional year to develop equipment to meet Phase II standards, became effective in 2003. California Air Resources BoardEVR Date Changes Board PresentationThe EVR program is divided into six parts, which we call EVR modules. Each module represents one or more standards for vapor recovery systems. The first module applies to Phase I vapor recovery systems. As you will recall, Phase I captures vapors during filling of the underground storage tank.(mouse click) Modules 2 through 6 are requirements for Phase II vapor recovery systems, which capture vapors from vehicle refueling.Module 3, the ORVR compatibility standard, is the focal point of staffs proposed amendments, as we will discuss in the next few slides.California Air Resources BoardEVR Date Changes Board PresentationThe 1990 federal Clean Air Act amendments mandate use of vapor recovery equipment on motor vehicles, which is known as onboard refueling vapor recovery or ORVR. ORVR vehicles were phased in beginning with the 1998 model year.ARB field tests show that some Phase II vapor recovery systems are not compatible with ORVR vehicles. During the fueling of an ORVR vehicle, vapor that would normally be recovered by the Phase II system is instead collected on the vehicle canister. However, Phase II assist systems with vapor pumps are still trying to draw in vapors. Since vapor is not available, the Phase II system draws in air through the nozzle. The air becomes saturated with gasoline which leads to an increase in vapor volume in the underground storage tank. The excess volume, which is rich in hydrocarbon vapors, exits the service station vent valve shown on the left.California Air Resources BoardEVR Date Changes Board PresentationThese EVR standards are being phased in with different effective dates based on the time needed to develop and certify equipment to the new standards. Here is the current EVR timeline. The start of each colored bar represents the start date for each EVR standard. New stations must comply with the requirements in effect at the time of installation. Under state law, existing stations have up to four additional years to comply. The final compliance date for all facilities to meet a standard is the date at the end of the colored bar. (mouse click) Note that all stations must be ORVR compatible by April 2005, about 5 months from now. Existing stations do not have to meet the additional requirements of full EVR until April 2008 (mouse click).Some stations have installed ORVR compatible systems over the past years - it has been available since 1998. Others planned to wait until a full EVR system was available. Full EVR also meets ORVR requirements, and thus only one modification to the station would be needed. Unfortunately, certification of the first full EVR system is not expected until January 2005. Those stations that waited, now find themselves unable to complete installation of EVR by the April 2005 deadline for ORVR compliance. They will have to shift plans and make ORVR modifications right away. As a result, they will also likely install additional full EVR compliant equipment in 2008. This will increase costs and delay achieving the extra emission reductions realized by full EVR systems.

    California Air Resources BoardEVR Date Changes Board PresentationThe Board has been aware of the possibility of delays in the availability of full EVR systems for some time. As a result of the December 2002 technology review, the Board directed staff to evaluate whether there would be sufficient lead time for station owners to install EVR Phase II systems before the ORVR compatibility deadline.The intent was to avoid the need for station owners to upgrade vapor recovery equipment more than once. With the first certified full EVR system expected in January, only two months would remain for 3500 stations to install either a full EVR system or an ORVR compatible system. This is not enough time.

    California Air Resources BoardEVR Date Changes Board PresentationNow that we have outlined the current EVR situation, we are ready to turn to our proposed regulatory proposal.California Air Resources BoardEVR Date Changes Board PresentationThis slide summarizes what we have just discussed regarding the need for the proposed amendments.First, the Board has already indicated that two equipment upgrades should be avoided if possible,Second, staffs analysis has found that more time is necessary to convert the estimated 3500 stations to systems that are compatible with ORVR vehicles. Note that many of these station operators have been waiting for certification of an EVR Phase II system to avoid two equipment upgrades.Finally, the first EVR Phase II system is not expected to be available until January 2005. The Healy EVR Phase II system has successfully completed all field test requirements and the Executive Order is being finalized.California Air Resources BoardEVR Date Changes Board PresentationThe proposal will extend the ORVR compatibility deadline by up to eleven months, depending on station gasoline throughput. The existing regulations provide that pre-EVR systems may continue to be used if the ARB Executive Officer finds that systems meeting the EVR standards are not commercially available. The Phase II EVR deadlines have been modified twice under these conditions, the first time to October 1, 2004 and again to January 1, 2005. The proposal would make the regulation consistent with these Executive Officer actions.Also, the proposal includes a change to the in-station diagnostics or ISD implementation dates to maintain a one-year difference between high and medium throughput stations that was in the original ISD phase-in schedule.

    California Air Resources BoardEVR Date Changes Board PresentationIn the next two slides, we will address the economic and environmental impacts associated with staffs proposal.California Air Resources BoardEVR Date Changes Board PresentationAs discussed in the staff report, the proposed amendments will save money for station owners by providing an option to avoid two vapor recovery system upgrades to meet full EVR requirements. If a station were to install an ORVR system that was not eventually certified as part of a full EVR system, the loss of investment could be as high as $22,000 depending on the ORVR system chosen.Additional cost savings may be possible if more ORVR compatible or EVR systems are certified in the next year, providing a more competitive market and possibly reducing system prices.Manufacturers of currently certified ORVR compatible systems may be adversely affected by the delay as it will delay product sales and allow more time for their competitors to certify ORVR compatible systems.California Air Resources BoardEVR Date Changes Board PresentationOur analysis indicates that emission reductions of 1.9 tons/day would be delayed by extending the ORVR compatibility deadline.However, those station owners who avoid two upgrades will be installing full EVR systems 3 years earlier tha...

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