August 11, 1995
South Coast Air Quality
Management District Board
INTRODUCTION
Rule 461 - Gasoline Transfer and Dispensing was originally adopted on January 9, 1976 and subsequently amended a number of times with the latest amendment on July 7, 1989. This rule requires the use of Phase I and Phase II vapor recovery systems that are certified by California Air Resources Board (CARB) to reduce 95% of the VOC emissions from both the filling of storage tanks and fueling of motor vehicles at gasoline transfer and dispensing facilities.
There are approximately 7,400 gasoline transfer and dispensing facilities (4,100 retail and 3,300 non-retail) in the AQMD. These gasoline transfer and dispensing facilities are characterized by numerous dispenser and vapor recovery configurations. CARB has issued seventy-five (75) Executive Orders, including forty-two (42) configurations for Phase I vapor recovery systems and thirty-three (33) configurations for Phase II vapor recovery systems.
Due to the tremendous number of gasoline transfer and dispensing facilities located in the AQMD, Rule 461 is one of the most significant control strategies for VOC emissions. It is imperative that Phase I and Phase II vapor recovery systems are properly constructed and operated so that the necessary control efficiency can be maintained. In order to further enhance the effectiveness of the Phase I and Phase II vapor recovery systems and therefore reduce the VOC emissions from gasoline transfer and dispensing operations, staff has incorporated new procedures and technologies into the Proposed Amended Rule 461. The proposed amendments include a self-compliance program and a number of new rule measures. A further VOC emission reduction of 3.43 tons per day is expected from these proposed amendments.
The self-compliance program includes the requirements of daily maintenance inspections conducted by facility managers and periodic compliance inspections conducted by certified auditors. Currently, self-inspection and auditing programs are in place at both major and independent oil companies. Staff intends to establish a uniform structure and parameters for these existing programs. In order to simplify the process and minimize the impacts on the owners/operators of all retail gasoline transfer and dispensing facilities, this proposed self-compliance program is primarily based on the standard practices required by most of the oil companies.
The new rule measures originated from the control measures identified in the Federal Implementation Plan (FIP) (rescinded by President Clinton on April 10, 1995), State Implementation Plan (SIP) and Air Quality Management Plan (AQMP) as well as the recommendations from the public and staff. These measures reflect the advancement of Phase I and Phase II vapor recovery technologies. Staff includes future compliance dates in the proposed amendment to provide the existing facilities with sufficient time to phase out the old equipment.
Staff has been working with the oil companies, industry associations, and other governmental agencies to address all issues and concerns regarding the self-compliance program and new rule measures. Both major and independent oil companies have participated in a self-compliance pilot program with a small number of selected facilities since July 1995. By inspecting the selected facilities and documenting where corrective measures are needed, staff will be able to identify and resolve potential problems associated with the implementation of self-compliance program and thereby enhance the effectiveness of the full-scale program.
CONCLUSIONS
The AQMD has prepared the appropriate California Environmental Quality Act (CEQA) document consisting of a Draft Environmental Assessment (EA) that does not identify any significant adverse environmental impacts resulting from the proposed amendments. This document was prepared pursuant to the AQMD's Certified Regulatory Program (Rule 110) and State CEQA Guidelines Section 15252. The Draft EA details each environmental topic analyzed, and includes supporting information for determining that the proposed amendments would not create any significant adverse environmental impacts. The EA was circulated for a 30-day public review period which ended July 17, 1995. All comments received on the Draft EA will be incorporated into the final EA for the proposed amendments.
A Public Workshop was held for this rule on June 1, 1995. The Public Hearing is scheduled for September 8, 1995. As per the Notice of Public Hearing, written comments will be accepted through August 29, 1995. All written comments received by this date will be reviewed and responded to by staff in the final Public Hearing Staff Report for the rule.
THEREFORE IT IS RECOMMENDED THAT YOUR BOARD
--Set a Public Hearing on September 8, 1995 to Amend
Rule 461 - Gasoline Transfer and Dispensing.
Respectfully,
James M. Lents, Ph.D.
Executive Officer
PL:WJF:LB:MAK
(i:\lbrules\461\rulepack\bdlt8-11.doc)
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
______________________________________________________________________________
Final Staff Report for Proposed Amendments to Rule 461 - Gasoline Transfer and Dispensing
July 1995
Deputy Executive Officer
Stationary Source Compliance
Patricia Leyden, A.I.C.P.
Assistant Deputy Executive Officer
Stationary Source Compliance
William J. Fray
Senior Manager
Stationary Source Compliance
Larry Bowen, P.E.
______________________________________________________________________________
Authors: Michael Krause Air Quality Engineer I
Randy Matsuyama Air Quality Engineer I
Maria Vibal Air Quality Inspector II
Reviewed By: Denice Brue Senior Deputy District Counsel
Allen Mednick Senior Deputy District Prosecutor
Brian L. Yeh, P.E. Air Quality Analysis and Compliance Supervisor
Technical Assistance: Lou Roberto Supervising Air Quality Inspector
Tran Vo, P.E. Senior Air Quality Engineer
ATTACHMENT A
SUMMARY OF PROPOSED AMENDMENTS
Rule 461 - Gasoline Transfer and Dispensing
Self-Compliance Program:
Amendment Description
Self-Inspections Owner/operator of retail gasoline transfer and dispensing
facilities shall implement a self-compliance program
consisting of the following inspections by July 1,1996:
Daily maintenance inspection
Periodic compliance inspection
Training and Any person conducting a daily maintenance inspection or
Certification periodic compliance inspection shall complete an
AQMD-approved training program and obtain a certificate, if
required.
Inspection Detailed protocols for the daily maintenance inspection and
Protocols periodic compliance inspection are specified in attachment C
& D.
New Rule Measures:
Amendment Description
Include Mobile Vapor recovery systems are required for truck/trailer with
Fuelers mounted tanks that fuel gasoline motor vehicles.
Installing Phase Any time an underground stationary storage tank installed or
I Certified CARB replace at any gasoline transfer and dispensing facility, a
Spill Box "CARB certified" spill box shall be installed. The spill
box shall be equipped with an integral vapor-tight drain
valve to return spilled gasoline to the underground
stationary storage tank.
Installing A person shall not install or permit the installation of any
Certified Phase I Phase I vapor recovery system of the coaxial design at any
Systems gasoline transfer and dispensing facility unless such system
was certified by CARB after January 1, 1994. A person shall
not install or permit the installation a Phase I vapor
recovery system of the dual-point design at any gasoline
transfer and dispensing facility unless such system
incorporates "CARB certified" poppetted drybreaks or
spring-loaded vapor check valves on the vapor return
coupler.
Phase II A person shall not install or permit the installation of any
Certified balance-system bellows equipped nozzle at any gasoline
Interlock transfer and dispensing facility unless the nozzle is
Mechanism equipped with a "CARB certified" insertion interlock
Required mechanism.
Phase II Vapor A person shall not install or permit installation of any
Check Valve balance system nozzle at a new or altered gasoline transfer
Required and dispensing facility unless a vapor check valve is
located in the nozzle. Effective January 1, 1997, a person
shall not operate or permit the operation of any
balance-system nozzle unless the vapor check valve is
located in the nozzle.
Phase II Coaxial A person shall not install or permit the installation of any
Hose Required nozzle at a new or altered gasoline transfer and dispensing
facility unless the nozzle is equipped with a coaxial hose.
Effective January 1, 1998, a person shall not operate any
gasoline-dispensing nozzle unless the nozzle is equipped
with a coaxial hose.
Required Diameter The nominal inside diameter of the connection between the
of Riser/ riser and dispenser cabinet shall not be less than 0.75
Dispenser inches. If flexible tubing is used for this connection, the
Connection material shall be listed for use with gasoline and shall be
capable of maintaining electrical continuity between the
riser and dispenser.
ATTACHMENT A (continued)
SUMMARY OF PROPOSED AMENDMENTS
Rule 461 - Gasoline Transfer and Dispensing
Amendment Description
Require All liquid removal devices required by CARB Executive Orders
Liquid-Removal shall be maintained to achieve a minimum liquid removal rate
Devices in Hoses of five milliliters per gallon transferred. This standard
shall apply at dispensing rates exceeding five gallons per
minute, unless a higher removal rate is specified by the
Executive Order.
Pressure-Vacuum A person shall not install or permit the installation of any
Relief Valve vent pipes on gasoline storage tanks at gasoline dispensing
Required on Vent facilities without a "CARB certified" pressure-vacuum relief
Pipe valve. Effective January 1, 1997, all open vent pipes on
gasoline storage tanks shall be equipped with a "CARB
certified" pressure-vacuum relief valve.
Pre-Backfilling Owner/operator of a new or altered gasoline transfer and
Inspection dispensing facility shall have all underground storage tank
installation and associated piping configuration inspected
prior to any backfilling to verify that all underground
equipment is properly installed in accordance with the
requirements specified in the applicable CARB Executive
Order. AQMD shall be notified by telephone at least 24
hours prior to the backfilling
Post-Construction Owner/operator of a new or altered gasoline transfer and
Inspection dispensing facility shall have all phase I and phase II
vapor recovery systems inspected upon completion of the
construction to verify that all components were installed in
accordance with the description specified in the Permit to
Construct and in compliance with all AQMD requirements.
AQMD shall be notified in writing of any changes to the
information and specifications submitted with the
application under which the Permit to Construct was issued.
Testing Within 30 days of operation, the following tests shall be
Requirements conducted to verify performance of Phase I and Phase II
vapor recovery systems:
Phase I: leak decay test
Phase II: leak decay, back pressure, air to liquid ratio,
or liquid removal rate (whichever is applicable)
In addition, reverification tests shall be conducted in
accordance with the following schedule:
Leak Decay - annually for vacuum assisted and every five
years for balance systems. Backpressure - every five years.
A/L (for bootless nozzle) - every five years
Recordkeeping The owner/operator is required to keep records of all
Requirements inspections and repairs, test results and throughput. All
records, except test results, shall be maintained for a
period of two years. Records of test results shall be
maintained for a period of five years.
Testing Methods All appropriate CARB test methods are referenced in this
subdivision.
ATTACHMENT B
RULE DEVELOPMENT PROCESS
RULE 461 - Gasoline Transfer and Dispensing
First Request For Public Input
February, 1995
Initial Rule Development, Identification of Alternatives and Initial Environmental Socioeconomic Assessment
March, 1995
Input from Other Agencies and Oil Industry
March-May, 1995
1 Public Workshop: June 1, 1995
4 Rule Reiterations
8055 Notices Mailed
Date Set for Hearing: August 11, 1995
Date of Hearing: September 8, 1995
Total Time Spent in Rule Development
Pre-Board Hearing: 7 months
ATTACHMENT C
KEY CONTACTS LIST
RULE 461 - Gasoline Transfer and Dispensing
INDUSTRY ORGANIZATIONS
Western States Petroleum Association (WSPA)
Automotive Trade Organizations of California (AUTO)
California Service Station and Automotive Repair Association (CSSARA)
National Association of Convenience Stores
California Independent Oil Marketing Association (CIOMA)
Petroleum Equipment Contractors of California
Society of Independent Gasoline Marketeers of America (SIGMA)
Petroleum Equipment Institute (PEI)
COMPANIES
Major Oil Companies ARCO
Chevron
Mobil Oil
Shell Oil
Texaco
Ultramar
UNOCAL
Independent Oil Companies G & M Oil
Thrifty Oil
United Oil
USA Petroleum
Winall Company
World Oil Company
GOVERNMENT AGENCIES
Environmental Protection Agency, Region IX
California Air Resources Board
Board of Equalization, State of California, Sacramento
Bay Area Air Quality Management District
San Diego Air Pollution Control District
Ventura County Air Pollution Control District
Los Angeles County, Department of Weights and Measures
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
GOVERNING BOARD
Chairman: JON D. MIKELS
Supervisor, Second District
San Bernardino County Representative
Vice Chairman: WILLIAM A. BURKE, Ed.D.
Speaker of the Assembly Appointee
MEMBERS:
MICHAEL D. ANTONOVICH
Supervisor, Fifth District
Los Angeles County Representative
MARVIN BRAUDE
Councilmember, City of Los Angeles
Cities Representative, Los Angeles County/Western Region
CANDACE HAGGARD
Mayor Pro Tem, City of San Clemente
Cities Representative, County of Orange
HUGH HEWITT
Governor's Appointee
MEE HAE LEE
Senate Rules Committee Appointee
RONALD O. LOVERIDGE
Mayor, City of Riverside
Cities Representative, Riverside County
LEONARD PAULITZ
Councilmember, City of Montclair
Cities Representative, San Bernardino County
JIM SILVA
Supervisor, Second District
Orange County Representative
NELL SOTO
Councilmember, City of Pomona
Cities Representative, Los Angeles County/Eastern Region
S. ROY WILSON, Ed.D.
Supervisor, Fourth District
Riverside County Representative
EXECUTIVE OFFICER
JAMES M. LENTS, Ph.D.
July 26, 1995
(PAR461R)
Proposed Amended RULE 461. GASOLINE TRANSFER AND DISPENSING
(a) PurposeApplicability
This rule is intended to control gasoline vapor emissions
from gasoline transfer and dispensing operations. This
rule applies to the transfer of gasoline from any tank truck,
trailer, or railroad tank car into any stationary storage tank
or mobile fueler, and from any stationary storage tank or mobile
fueler into any mobile fueler or motor vehicle fuel tank.
(b) Definitions
For the purpose of this rule, the following definitions shall apply:
(1) ALTEREDATION(S) AND/OR REPAIR(S) of a previously
exempted FACILITY is a Gasoline Transfer
Storage and/or Dispensing Facility
is with any of the following:
(A) The replacement of one or more existing storage tank(s);
(B) The removal or addition of storage tank(s),
or dispensing nozzle(s), piping or any other component
or changes in the number of fueling positions.
(B)(C) The replacement of storage tank(s),
or dispensing nozzle(s), piping
or any other component with different characteristics
or descriptions from those specified on of
the existing permit or original equipment.
(D) Any excavation (exposure to view by digging) of an
existing gasoline storage tank and/or the underground liquid piping
from the storage tank(s) to the gasoline dispenser(s);
(E) As determined in writing by the District, Office of
Operations.
(2) ASPIRATOR-ASSIST SYSTEM is a Phase II vapor recovery system that uses an aspirator to create a vacuum during gasoline dispensing to capture gasoline vapors. An aspirator-assist system may also incorporate a gasoline vapor incinerator and/or bellows-less nozzles.
(3) BALANCE SYSTEM is a Phase II vapor recovery system that operates on the principle of vapor displacement.
(4) BELLOWS-LESS NOZZLE is any nozzle that incorporates both an assist system and a gasoline vapor capture mechanism at the motor vehicle filler neck, such that vapors are collected at the vehicle filler neck without the need for an interfacing flexible bellows, and which is certified by the California Air Resources Board (CARB) for operation as a bellows-less nozzle.
(25) "CARB CERTIFIED" VAPOR
RECOVERY SYSTEM is any Phase I or Phase II vapor recovery system
which has been certified by the California Air Resources
Board CARB as capable of recovering or processing
displaced gasoline vapors to an efficiency of ninety-five (95)
percent or greater.
(6) CARB EXECUTIVE ORDERS are Orders published by the CARB that document the requirements of specific vapor control equipment and procedures used in Phase I and Phase II vapor recovery systems.
(7) COAXIAL HOSE is a hose that contains two passages with a configuration of a hose within a hose. One of the passages dispenses the liquid gasoline into the vehicle fuel tank while the other passage carries the gasoline vapors from the vehicle fuel tank to the storage tank.
(8) FUELING POSITION is a fuel dispensing unit consisting of nozzle(s) and meter(s) with the capability to deliver only one fuel product at one time.
(49) GASOLINE VAPORS means the
organic compounds in the displaced vapors, including any entrained
liquid gasoline. Gasoline is a fuel which is any petroleum
distillate or petroleum distillate/alcohol blend having a True
Vapor Pressure greater than 200 mm Hg (3.9 psi) and less than
760 mm Hg (14.7 psi) at 100 degrees F, or as approved
by CARB as determined by ASTM Method D323-89.
(310) GASOLINE STORAGE
TRANSFER AND DISPENSING FACILITY means an aggregate
of is a mobile system or a stationary facility consisting
of one or more stationary storage tanks,
any of and associated equipment which is
receive, store, and dispense gasoline subject to the provisions
of paragraphs (c), (d), or (e) of this rule,
together with dispensers and control equipment required by the
rule.
(11) GASOLINE VAPORS are the organic compounds in vapor form displaced during gasoline transfer and dispensing operations, and includes entrained liquid gasoline.
(12) INSERTION INTERLOCK MECHANISM is any CARB certified mechanism that ensures a tight fit at the nozzle fill pipe interface and prohibits the dispensing of gasoline unless the bellows is compressed.
(13) LIQUID REMOVAL DEVICE is a device designed specifically to remove trapped liquid from the vapor passages of a coaxial hose.
(514) LIQUID TIGHT means
is a liquid leak rate not exceeding three drops per minute.
(15) MOBILE FUELER is any tank truck or trailer that is used to transport and dispense gasoline from an onboard storage tank into any motor vehicle fuel tank.
(616) MOTOR VEHICLE is any self-propelled
vehicle registered or which requires registration for
use on the highway as defined in Section 415 of the
California Vehicle Code.
(17) OWNER/OPERATOR is any person who owns, leases, operates, controls, or supervises the operation of a gasoline transfer and dispensing facility.
(18) POPPETTED DRY BREAK is a Phase I vapor recovery device that opens only by connection to a mating device to ensure that no gasoline vapors escape from the underground storage tank before the vapor return line is connected.
(19) PRESSURE/VACUUM RELIEF VALVE is a valve that is installed on the vent pipes of the gasoline storage tanks to relieve pressure or vacuum build-up at preset values of pressure or vacuum.
(720) REBUILT EQUIPMENT is any component
of a vapor recovery system that has undergone repair or replacement
of any or all of its internal parts.
(21) RETAIL gasoline transfer and dispensing facility is any gasoline transfer and dispensing facility subject to the payment of California sales tax for the sale of gasoline to the public.
(22) SPILL BOX is an enclosed container around a Phase I fill pipe that is designed to collect gasoline spillage resulting from disconnection between the liquid gasoline delivery hose and the fill pipe.
(823) SUBMERGED FILL TUBE is any fill
tube the discharge opening of which is entirely submerged, when
the liquid level above the bottom of the tank is:
(A) 15.2 cm (6 inches), for tanks filled from the top, except
for flat bottom tanks which is 7.6 cm. (3 in), or
(B) 45.7 cm (18 inches) for tanks filled from the side.
(24) VACUUM-ASSIST SYSTEM is a Phase II vapor recovery system that uses vacuum-producing device such as a compressor or turbine to create a vacuum during gasoline dispensing to capture gasoline vapors. Vacuum-assist systems may also incorporate gasoline vapor incinerators and/or bellows-less nozzles.
(25) VAPOR CHECK VALVE is a valve that opens and closes the vapor passage to the storage tank to prevent gasoline vapors from escaping when the nozzle is not in use.
(926) VAPOR TIGHT means the detection
of less than 10,000 ppm hydrocarbon concentration, as determined
by EPA reference Method 21, using an appropriate
analyzer calibrated with methane at a distance of 1 cm
from the source.
(c) Requirements
(1) Gasoline Transfer Into Stationary Storage Tanks and Mobile Fuelers (Phase I).
A person shall not transfer, permit the transfer or provide equipment for the transfer of gasoline from any tank truck, trailer or railroad tank car into any stationary storage tank with a capacity of 950 liters (251 gallons) or more, or any mobile fueler tank of greater than 454 liters (120 gallons) capacity unless all of the following conditions are met:
(A) Such stationary storage tank or mobile fueler tank
is equipped with a "CARB certified" permanent
submerged fill tube or as defined by the applicable CARB
certification.
(B) Such stationary storage tank or mobile fueler tank is equipped with a "CARB certified" vapor recovery system, which is maintained and operated according to the manufacturer's specifications.
(C) All vapor return lines are connected between the tank truck,
trailer or railroad tank car, and the stationary storage tank
or mobile fueler. In addition, all associated hoses, fittings,
and couplings are maintained in a liquid-tight and vapor-tight
condition, as defined under subparagraph (b)(914)
and (b)(26).
(D) The hatch on any tank truck, trailer, or railroad tank car shall not be opened for more than three minutes for each visual inspection, provided that:
(i) Transfer or pumping has been stopped for at least 3 minutes prior to opening; and
(ii) The hatch is closed before transfer or pumping is resumed.
(E) Underground tank lines are gravity drained, and above-ground
tanks are equipped with dry breaks, or as approved by the AQMD
District, Office of Operations, such that upon
line disconnect the liquid leak rate does not exceed 3 drops per
minute.
(F) Equipment subject to this paragraph is operated and maintained, according to all of the following requirements:
(i) All fill tubes are equipped with vapor-tight covers, including gaskets;
(ii) All dry breaks are equipped with vapor-tight seals and dust covers;
(iii) Fixed or Spring-Loaded coaxial fill tubes are operated so
that there is no obstruction of the vapor
passage from the stationary storage tank or the mobile
fueler back to the tank truck, trailer, or railroad tank car
is not obstructed;
(iv) The fill tube assembly, including fill tube, fittings and gaskets, is maintained to prevent vapor leakage from any portion of the vapor recovery system; and
(v) All stationary storage tank or the mobile fueler vapor return lines without dry breaks are equipped with vapor-tight covers, including gaskets.
(G) Any time an underground stationary storage tank is installed or replaced at any gasoline transfer and dispensing facility, a "CARB certified" spill box shall be installed. The spill box shall be equipped with an integral vapor-tight drain valve to return spilled gasoline to the underground stationary storage tank.
(H) A person shall not install or permit the installation of any Phase I vapor recovery system of the coaxial design at any gasoline transfer and dispensing facility unless such system was certified by CARB after January 1, 1994.
(I) A person shall not install or permit the installation of any Phase I vapor recovery system of the dual-point design at any gasoline transfer and dispensing facility unless such system incorporates "CARB certified" poppetted drybreaks or spring-loaded vapor check valves on the vapor return coupler.
(2) Gasoline Transfer Into Vehicle Fuel Tanks (Phase II).
A person shall not transfer, or permit the transfer, or provide equipment for the transfer of gasoline from a stationary storage tank or a mobile fueler of greater than 454 liters (120 gallons) capacity into any mobile fueler of greater than 454 liters (120 gallons) capacity or any motor vehicle fuel tank of greater than 19 liters (5 gallons) capacity unless all of the following conditions are met:
(A) The dispensing unit used to transfer the gasoline from the stationary storage tank or mobile fueler to the mobile fueler or motor vehicle fuel tank is equipped with a "CARB certified" vapor recovery system.
(B) The vapor recovery system and associated components are operated and maintained in a vapor-tight and liquid-tight manner in accordance with the manufacturer's specifications and the applicable CARB certification.
(C) Equipment subject to this rule is operated and maintained
with none of the defects listed in California Code of Regulations,
Section 94006, Subchapter 8, Chapter 1, Part III of Title 17,
as summarized in on Attachment A of this
rule.
(D) A person shall not install or permit the installation of any balance-system bellows-equipped nozzle at any gasoline transfer and dispensing facility unless the nozzle is equipped with a "CARB certified" insertion interlock mechanism.
(E) A person shall not install or permit the installation of any balance-system nozzle at a new or altered gasoline transfer and dispensing facility unless a vapor check valve is located in the nozzle. In addition, effective January 1, 1997, a person shall not operate or permit the operation of any balance-system nozzle unless a vapor check valve is located in the nozzle.
(F) A person shall not install or permit the installation of any nozzle at a new or altered gasoline transfer and dispensing facility unless the nozzle is equipped with a coaxial hose. In addition, effective January 1, 1998, a person shall not operate any gasoline-dispensing nozzle unless the nozzle is equipped with a coaxial hose.
(G) Unless otherwise specified in the applicable CARB Executive Orders, the inside diameter of the connection between the riser and dispenser cabinet at a new or altered gasoline transfer and dispensing facility shall not be less than 0.75 inch. If a flexible tubing is used for this connection, the material shall be appropriate for use with gasoline and shall be equipped with a clearly visible bonding strap.
(H) Unless otherwise specified in the applicable CARB Executive Orders, all liquid removal devices installed for any gasoline-dispensing nozzle with a dispensing rate of greater than five gallons per minute shall be "CARB certified" with a minimum liquid removal rate of five milliliters per gallon transferred.
(3) Additional Requirements
(A) A person shall not offer for sale, sell, or install any new,
used, or rebuilt vapor recovery equipment unless the components
and the parts are clearly identified or marked
by the certified manufacturing company and/or the certified rebuilding
company.
(B) For a breakdown (as defined in Rules 102 and 430) of the central vapor incineration or processing unit, the provisions of Rule 430 shall apply. "End of Cycle" shall refer to the immediate 24 hours following the notification of the breakdown for the application of Rule 430 in subparagraph (c)(3)(B).
(C) A person shall not perform or permit the "pump-out"
(bulk transfer) of gasoline from a storage tank subject to paragraph
(c)(1); unless such bulk transfer is performed using a vapor collection
and transfer system capable of returning the displaced vapors
to the stationary storage tank or unless the storage tank
will be removed or filled with water for testing.
(D) A person shall not store, or allow the storage of, gasoline in any stationary storage tank with a capacity of 950 liters (251 gallons) or more unless such tank:
(i) Complies with Rule 463(a); or
(ii) Is equipped with a Phase I vapor recovery system; and
(iii) Is operated and maintained with an integral vapor-tight drain valve to return spilled gasoline to the storage tank, if the tank is equipped with a spill container.
(E) The owner/operator of any gasoline transfer and
dispensing facility shall conspicuously post DistrictAQMD-required
signs specified oin Attachment B of this
rule in the immediate gasoline dispensing area.
(F) A dispenser that is never not intended
to be used to fuel motor vehicles shall have a sign posted
on it to that effect.
(G) A dispenser and/or a storage tank shall be vented
to the atmosphere in accordance with the applicable "CARB
certified" requirements. A person shall not install
or permit the installation of any vent pipes on gasoline storage
tanks at any gasoline transfer and dispensing facility without
a "CARB certified" pressure-vacuum relief valve. A written
approval from the AQMD is required prior to the installation or
relocation of such vent pipes. In addition, effective January
1, 1997, all open vent pipes on gasoline storage tanks shall be
equipped with a "CARB certified" pressure-vacuum relief
valve. Unless otherwise specified in the applicable CARB Executive
Orders, pressure relief shall be set at 3 inches water column
and vacuum relief shall be set at 8 inches water column. For the
purpose of this requirement, vent pipes of gasoline storage tanks
may be manifolded to a single valve when the stationary storage
tanks are manifolded according to the applicable CARB Executive
Order.
(H) Gasoline shall not be stored in open container(s) of any size
or handled in any other manner (spillage, spraying,
etc.) that permits gasoline or gasoline vapors to enter
the atmosphere, contaminate the ground, or enter the sewer.
(I) The failure of an owner/operator of any gasoline transfer
and dispensing facility to meet any requirements of subparagraphs
(c)(1), (c)(2), or (c)(3) of this rule shall
constitute a violation. Such non-compliant equipment determined
to be in violation shall be tagged "Out of Order".
(J) Except during repair activity, the "Out of Order"
tag specified in subparagraph (c)(3)(I) shall not be removed and
the non-compliant tagged equipment shall
not be used, permitted to be used, or provided for use unless
all of the following conditions are satisfied:
(i) The non-compliant tagged equipment
has been repaired, replaced, or adjusted, as necessary;
(ii) The owner/operator District, Office of Operations,
has been notified the AQMD of the repairs
by completing, and signing, and
submitting the form supplied by the District
AQMD;
(iii) The non-compliant tagged equipment
has been reinspected and/or authorized for use by the District
AQMD.
(K) The owner/operator of a new or altered gasoline transfer and dispensing facility shall have all underground storage tank installation and associated piping configuration inspected prior to any backfilling to verify that all underground equipment is properly installed in accordance with the requirements specified in the applicable CARB Executive Order. The AQMD shall be notified by telephone at least 24 hours prior to the backfilling.
(L) The owner/operator of a new or altered gasoline transfer and dispensing facility shall have all phase I and phase II vapor recovery systems inspected upon completion of the construction to verify that all components were installed in accordance with the description specified in the Permit to Construct and in compliance with all AQMD requirements. The AQMD shall be notified in writing of any changes to the information and specifications submitted with the application under which the Permit to Construct was issued.
(4) Testing
(A) Within 30 calendar days of the initial operation, the owner/operator of a new or altered gasoline transfer and dispensing facility shall have the following performance tests conducted in accordance with the test methods specified in sub-division (d) to verify the proper installation and function of Phase I and Phase II vapor recovery systems. The written test results shall be submitted to the AQMD within 30 calendar days of each testing.
(i) Phase I vapor recovery system
(I) Static pressure (leak-decay) test
(ii) Phase II vapor recovery system
(I) Static pressure (leak-decay) test
(II) Dynamic pressure (back-pressure) test
(III) Air-to-liquid (A/L) ratio (only for bellows-less nozzles)
(IV) Liquid removal rate (only for systems with a liquid removal device required by CARB Executive Orders)
(B) The owner/operator of an existing gasoline transfer and dispensing facility shall have the following reverification tests conducted in accordance with the test methods specified in sub-division (d) and the following schedule, unless otherwise specified in the applicable CARB Executive Order, to verify the proper function of the Phase II vapor recovery system. For any of the required reverification testing which has not been conducted since January 1, 1993, the initial reverification testing shall be conducted by January 1, 1998. The written test results shall be submitted to the AQMD within 30 calendar days of each testing.
(i) For a facility with a vacuum-assist or aspirator-assist Phase II vapor recovery system, a static pressure (leak-decay) test shall be conducted once every calendar year.
(ii) For a facility with a balance Phase II vapor recovery system, a static pressure (leak-decay) test shall be conducted once every five calendar years.
(iii) For a facility with bellows-less nozzles, an air-to-liquid (A/L) ratio test shall be conducted once every five calendar years.
(iv) A dynamic pressure (back-pressure) test shall be conducted once every five calendar years.
(5) Self-Compliance Program
Effective July 1, 1996, the owner/operator of any retail gasoline transfer and dispensing facility shall implement an AQMD-approved self-compliance program as follows:
(A) The self-compliance program shall include, but is not limited to, the following elements:
(i) Daily maintenance inspections shall be conducted in accordance with the protocol specified in Attachment C to ensure proper operating conditions of all components of the vapor recovery systems.
(ii) Periodic compliance inspections shall be conducted at least once every calendar year and in accordance with the protocol specified in Attachment D to verify the compliance with all applicable AQMD rules and regulations, as well as all permit conditions. (B) Any non-compliant equipment identified during the daily maintenance inspections or periodic compliance inspections shall be removed from service, repaired, and brought into compliance before being returned to service.
(C) Only violations documented during AQMD inspections shall constitute a violation of Rule 461.
(D) Any self-compliance program as specified in subparagraph (c)(5)(A) developed by the owner/operator of a retail gasoline transfer and dispensing facility shall be submitted in writing to the AQMD for approval by:
(i) March 1, 1996 for an existing facility, or
(ii) the date that a permit application for a new facility is filed.
(6) Training and Certification
(A) A person shall not conduct daily maintenance inspections specified in clause (c)(5)(A)(i) unless such person has completed an AQMD-approved general training program.
(B) A person shall not conduct periodic compliance inspections specified in clause (c)(5)(A)(ii) unless such person has completed an AQMD-approved training program in the inspection and maintenance of vapor recovery systems and has received a certificate issued by the AQMD.
(7) Recordkeeping
(A) The owner/operator of any gasoline transfer and dispensing facility shall keep the following records:
(i) Records of all inspections and repairs (i.e. receipts for parts used in the repair, work orders, etc.)
(ii) Records of all test results.
(iii) Throughput records as required by permit conditions.
(B) All records except test results shall be maintained for a period of two (2) years. Records of test results shall be maintained for a period of five (5) years. All records shall be made available to the AQMD upon request.
(d) Test Methods
The performance and reverification tests specified in paragraph (c)(4) shall be conducted in accordance with the following test methods. All test methods referenced in this sub-division shall be the most recently approved version.
(1) The static pressure performance of a Phase I or Phase II vapor recovery system shall be determined by the CARB Test Procedure TP-201.3.
(2) The dynamic pressure performance of a Phase II vapor recovery system shall be determined by the CARB Test Procedure TP-201.4.
(3) The air-to-liquid volume ratio of a Phase II vapor recovery system shall be determined by the CARB Test Procedure TP-201.5.
(4) The liquid removal rate of a Phase II vapor recovery system shall be determined by the CARB Test Procedure TP-201.6.
(5) Any other test methods approved by the USEPA, CARB, and the AQMD.
(de) Exemptions
The provisions of this rule shall not apply to the transfer of gasoline:
(1) Into or from any stationary storage tank or mobile fueler if 75 percent or more of its monthly throughput is used for the fueling of implements of husbandry, such as vehicles defined in Division 16 (Section 36000, et seq.) of the California Vehicle Code, provided such a tank is equipped with a submerged fill tube.
(2) Into or from any stationary storage tank or mobile fueler used exclusively for fueling agricultural wind machines.
(3) From any mobile fueler of greater than 454 liters (120 gallons) into any motor vehicle fuel tank of greater than 19 liters (5 gallons) capacity until January 1, 1998.
(e) Compliance Schedule
(1) The owner/operator of a new facility subject to this
rule shall comply with the provisions of this rule at the time
gasoline receiving and/or dispensing is initiated.
(2) The owner/operator of any altered and/or repaired
facility, who was previously exempted from the provisions of this
rule shall comply with the provisions of this rule at the time
gasoline receiving and/or dispensing is initiated after completion
of the alteration and/or repair.
(3) The owner/operator of any other existing facility,
who was previously exempt from the provision of this rule, and
who has not earlier been required to come into compliance, shall
achieve compliance by March 4, 1990.
ATTACHMENT A
CALIFORNIA CODE OF REGULATIONS, SECTION 94006
SUBCHAPTER 8, CHAPTER 1, PART III OF TITLE 17
Section 94006. Defects Substantially Impairing the Effectiveness of Vapor Recovery Systems Used in Motor Vehicle Fueling Operations.
For the purposes of Section 41960.2 of the Health and Safety Code, the following constitute equipment defects in systems for the control of gasoline vapors resulting from motor vehicle fueling operations which substantially impair the effectiveness of the systems in reducing air contaminants:
(a) Absence or disconnection of any component required to be used in the Executive Order(s) that certified the system.
(b) A vapor hose which is crimped or flattened such that the vapor passage is blocked, or the pressure drop through the vapor hose exceeds by a factor of two or more the requirements in the system certified in the CARB Executive Order(s) applicable to the system.
(c) A nozzle bellows which is torn in one or more of the following manner:
1. triangular-shaped or similar tear 1/2 inch or more to a side, or hole 1/2 inch or more in diameter or,
2. Slit 1 inch or more in length.
(d) Faceplate or flexible cone which is damaged in the following manner:
1. For balance nozzles and for nozzles for aspirator and educator-assist
type systems, damage shall be such that the capability to achieve
a seal with a fill pipe interface is affected for 1/4 of the circumference
of the faceplate (accumulated).
2. For nozzles for vacuum assist-type systems, more than 1/4 of the flexible cone missing.
ATTACHMENT A - CONTINUED
(e) Nozzle shutoff mechanisms which malfunction in any manner.
(f) Vapor return lines, including such components as swivels, anti-recirculation valves and underground piping, which malfunction or are blocked, or restricted such that the pressure drop through the lines exceeds by factor of two or more requirements specified in the Executive Order(s) that certified the system.
(g) Vapor processing unit which is inoperative.
(h) Vacuum producing device which is inoperative.
(i) Pressure/vacuum relief valves, vapor check valves, or dry breaks which are inoperative.
(j) Any equipment defect which is identified in an Executive Order certifying a system pursuant to the Certification Procedures incorporated in Section 94001 of Title 17, California Code of Regulations, as substantially impairing the effectiveness of the system in reducing air contaminants.
All nozzles affected by the above defects are to be considered defective.
NOTE: Authority Cited: Sections 39600, 39601, 41960.2, Health and Safety Code.
ATTACHMENT B
DISTRICTAQMD-REQUIRED
SIGNS
I. The operator shall post the following signs:
(A) "NOZZLE" operating instructions:
(B) "SCAQMD" toll-free telephone number; and
(C) A "warning" stating:
"TOXIC RISK - FOR YOUR OWN PROTECTION
DO NOT BREATHE FUMES
DO NOT TOP TANKS"
II. All required signs shall conform to all of the following:
(A) For decal signs:
(i) Each sign shall be located adjacent to the dispenser price indicator (per gallon) on each side next to the driveway it serves; and
(ii) Sign shall be readable from a distance of 3 feet.
(B) All other signs:
(i) For pump toppers, one double-back sign per island;
(ii) For permanent (non-decal) signs, two single-sided or one double-sided sign(s) per two (2) dispensers.
(iii) All signs shall be readable from a distance of 6 feet.
ATTACHMENT C
DAILY MAINTENANCE INSPECTION PROTOCOL
A person shall at minimum verify the following during the daily maintenance inspections:
(A) PHASE I VAPOR RECOVERY SYSTEM INSPECTION
1. The spill container is clean and does not contain gasoline.
2. The fill caps are not missing, damaged or loose.
3. If applicable,:
a. the spring-loaded submerged fill tube seals properly against the coaxial fitting
b. the dry break (poppet valve) is not missing or damaged.
4. The submerged fill tube is not missing or damaged.
(B) PHASE II VAPOR RECOVERY SYSTEM INSPECTION
1. The fueling instructions are clearly displayed with the appropriate toll-free complaint phone number and toxic warning signs.
2. The following nozzle components are in place and in good condition:
a. faceplate/facecone; vapor splash guard/fill guard/efficiency compliance device (ECD)
b. bellows
c. latching device
d. spring
e. vapor check valve
f. spout (proper diameter/vapor collection holes)
g. insertion interlock mechanism
h. automatic shut-off mechanism
3. The hoses are not torn, flattened or crimped.
4. For vacuum-assist systems, the vapor processing unit and burner are functioning properly.
ATTACHMENT D
PERIODIC COMPLIANCE INSPECTION PROTOCOL
A person shall at minimum verify the following during the periodic compliance inspections:
(A) GENERAL INSPECTION
1. The AQMD permit is current.
2. The equipment and AQMD permit description match.
3. The facility complies with all permit conditions.
4. The required sign is properly posted and the sign contains all the necessary information. (i.e. toll-free compliant phone number, toxic warning sign, etc.)
(B) PHASE I VAPOR RECOVERY SYSTEM INSPECTION
1. The spill container is clean and does not contain gasoline.
2. The fill caps are not missing, damaged or loose.
3. If applicable,:
a. the spring-loaded submerged fill tube seals properly against the coaxial fitting
b. the dry break (poppet valve) is not missing or damaged.
4. The submerged fill tube is not missing or damaged.
5. The distance between the bottom of the submerged fill tube and the bottom of the stationary storage tank does not exceed six inches (6").
6. The Phase I vapor recovery system complies with required CARB certification and is properly installed.
7. The spill box complies with required CARB certification and is properly installed.
8. The vent pipes are equipped with required pressure/vacuum relief valves.
(C) PHASE II VAPOR RECOVERY SYSTEM INSPECTION
1. The fueling instructions are clearly displayed.
2. Each nozzle is the current CARB-certified model.
ATTACHMENT D - CONTINUED
3. Each nozzle is installed in accordance with the applicable CARB Executive Orders.
4. The following nozzle components are in place and in good condition :
a. faceplate/facecone; vapor splash guard/fill guard/efficiency compliance device (ECD)
b. bellows
c. latching device
d. spring
e. vapor check valve
f. spout (proper diameter/vapor collection holes)
g. insertion interlock mechanism
h. automatic shut-off mechanism
5. The hoses are not torn, flattened or crimped.
6. The vapor recovery hoses are the required size and length.
7. The hoses with retractors are adjusted to maintain a proper loop, and the bottom of the loop is within the distance from the island surface certified by the CARB Executive Order for that particular dispenser configuration.
8. The vapor recovery nozzles are equipped with required hoses.
9. The bellows-equipped vapor recovery nozzles are equipped with CARB certified insertion interlock mechanisms.
10. If required, the flow limiter is not missing and is installed properly.
11. The swivels are not missing, defective, or leaking, and the dispenser-end swivels are Fire-Marshall approved with 90-degree stops.
12. If required, the liquid removal devices comply with required CARB certifications and are properly installed.
13. For bellows-less nozzles, the hoses are inverted coaxial type and the vapor collection holes are not obstructed.
14. For vacuum-assist systems, the vapor processing unit and burner are functioning properly.
15. For aspirator-assist systems, the major components (i.e. aspirator or jet pump, modulating valve, vapor check valve) are present inside each dispenser. For aspirator-assist systems with certification-required calibration stickers, the current calibration sticker is present.
____________________________________________________________
T A B L E O F C O N T E N T S
Page
Introduction 1
Legislative Authority 1
Background 2
Process Description 2
Procedure and Technology Review 5
Proposed Amendments 13
Emissions Inventory 21
Emission Reduction 24
CEQA 25
Cost Effectiveness 25
Socioeconomic Analysis 25
Draft Findings 26
Appendix
A: Emission Calculations
B: Cost Effectiveness Calculations
C: Comments and Responses
INTRODUCTION
Volatile organic compound (VOC) emissions from stationary and mobile sources contribute to the formation of smog in the atmosphere. VOCs react photochemically with oxides of nitrogen to form ozone. Ozone is a strong oxidizer that irritates human tissue and damages plant life and certain materials. VOCs can also react in the atmosphere to form compounds with low volatility which contribute to PM10 (particulate matter less than 10 microns in size), another criteria pollutant which also affects human health and limits visibility.
Air quality in the South Coast Air Basin has shown substantial improvement over the past two decades. However, the District is still not in compliance with the federal and state ambient air quality standards for ozone and PM10. In 1993, the state and federal standards for ozone were exceeded in nearly all areas of the District. The most affected locations exceeded the state standard on 160 days and the federal standard on 96 days. These high ozone levels will continue to occur in the Basin unless additional VOC controls are implemented.
Furthermore, both annual and 24-hour state standards for PM10 were exceeded in almost all areas in 1993. The less stringent federal standards were exceeded at fewer locations. The highest 24-hour average concentration recorded in the Basin was about one and one-half times the federal standard and 4.6 times the state standard.
VOC emissions from the filling of storage tanks and fueling of motor vehicles at gasoline transfer and dispensing facilities serve as a precursor to ozone formation. They are also transformed into organic aerosols in the atmosphere, leading to higher PM10 levels and decreased visibility. Rule 461 - Gasoline Transfer and Dispensing was therefore developed with the goal of reducing the levels of the above pollutants.
LEGISLATIVE AUTHORITY
The California Legislature created the South Coast Air Quality Management District (SCAQMD) in 1977 (Lewis-Presley Air Quality Management Act, California Health and Safety Code Sections 40400 et seq.) as the agency responsible for developing and enforcing air pollution control rules and regulations in the South Coast Air Basin (Basin). By statute, the SCAQMD is required to adopt an Air Quality Management Plan (AQMP) demonstrating compliance with all state and federal ambient air quality standards for the Basin [Health and Safety Code Section 40460(a)]. Furthermore, the SCAQMD must adopt rules and regulations that carry out the AQMP [Health and Safety Code Section 40440(a)].
BACKGROUND
Rule 461 - Gasoline Transfer and Dispensing was originally adopted on January 9, 1976 and subsequently amended a number of times with the latest amendment on July 7, 1989. This rule requires the use of Phase I and Phase II vapor recovery systems to control the VOC emissions from both the filling of storage tanks and fueling of motor vehicles at gasoline transfer and dispensing facilities. VOC emissions during the filling of storage tanks are generated when gasoline vapors in the storage tanks are displaced by the liquid gasoline being loaded into the tanks and discharged to the atmosphere. By the same principle, VOC emissions during the fueling of motor vehicles are generated when gasoline vapors in the vehicle fuel tanks are displaced by the dispensed gasoline and discharged to the atmosphere.
There are approximately 7,400 gasoline transfer and dispensing facilities (4,100 retail and 3,300 non-retail) in the District. The gasoline transfer and dispensing facilities are characterized by numerous dispenser and vapor recovery configurations. In accordance with the California Health and Safety Code, Section 41954, these dispenser and vapor recovery configurations must be certified by the California Air Resources Board (CARB) and specified in the Executive Orders published by the CARB. These Executive Orders are periodically revised to reflect the technology advancement. Currently, the CARB has issued seventy-five (75) Executive Orders, including forty-two (42) configurations for Phase I vapor recovery systems and thirty-three (33) configurations for Phase II vapor recovery systems.
PROCESS DESCRIPTION
This rule contains two basic methods to control volatile organic compound (VOC) emissions resulting from the transfer and dispensing of gasoline. First, the VOC emissions from filling a storage tank can be controlled by the use of a Phase I vapor recovery system which utilizes a hose to return the displaced gasoline vapors back to the tank truck cargo compartments. Secondly, the VOC emissions from fueling a motor vehicle can be controlled by the use of a Phase II vapor recovery system which utilizes a dispensing nozzle and attached hose to collect and return the displaced gasoline vapors from the vehicle fuel tank back to the storage tanks.
Phase I Vapor Recovery
The Phase I vapor recovery system uses a hose to return vapors from the underground storage tank to the tank truck during filling. There are two types of phase I systems: the dual-point system and the coaxial system. It is common for dual-point systems to be installed at new or modified stations, and for coaxial systems to be installed in retrofit situations.
Figure 1
Phase I Vapor Recovery System
A dual-point system uses one pipe to dispense the liquid into the storage tank, and a separate pipe returns the vapors to the tank truck. Many stations tie the vapor spaces of the underground tanks together, resulting in one liquid fill pipe for each tank, and a common vapor return pipe.
A coaxial system uses a single coaxial pipe with the liquid fill pipe inside the larger diameter vapor return pipe. The liquid fill tube typically extends to within a few inches from the bottom of the tank to ensure submerged filling, and the vapor pipe is connected just below the top of the tank. The coaxial system requires a separate coaxial vapor/liquid pipe for each storage tank.
Phase II Vapor Recovery
Phase II vapor recovery systems control the vapors generated during the fueling of vehicle tanks. Unlike the tight-fit connectors typical of Phase I systems, Phase II systems must work effectively with a variety of vehicle fill pipes. With the exception of the recently designed bellows-less nozzle, a Phase II nozzle has a tubular bellows, or "boot", which covers the spout and captures the displaced vapors. The captured vapors flow through a vapor passage in the nozzle into a vapor hose and then through a plumbing system to the underground storage tank.
Figure 2
Phase II Vapor Recovery System
There are two types of Phase II systems: the balance system and the assist system. The type of Phase II vapor recovery system most commonly used in California today is the balance system. Balance systems use the pressure created in the vehicle fuel tank by the incoming liquid gasoline to force the vapors through the nozzle bellows, through the vapor passage, and into the underground storage tank. Because a slight pressure is generally created at the nozzle/fill pipe interface, effective operation requires that a seal be made at the interface during vehicle fuelings to minimize vapor leakage into the atmosphere. A faceplate at the end of the bellows creates a seal when the nozzle is inserted into the fill pipe. The resistance of the bellows to compression ensures that this tight seal is maintained throughout the fueling.
Assist systems use a vacuum-generating device to draw vapors from the fill pipes of vehicle tanks. These systems can be generally categorized as vacuum-assist and aspirator-assist systems. A vacuum-assist system, such as Hirt and Hasstech systems, uses a vacuum generating device (ie: compressor, turbine, etc.) to create a vacuum which pulls gasoline vapors from the motor vehicle tank to the storage tank. An aspirator-assist system, such as Healy and Red Jacket systems, creates a vacuum by the use of an aspirator which is activated by the flow of liquid gasoline.
Assist systems can recover vapors effectively without a tight seal at the nozzle/fill pipe interface because the vapors are not pushed into the system by the flow of gasoline into the vehicle tank. In fact, assist nozzles with bellows are specifically designed with a loose-fitting facecone rather than a faceplate to prevent a tight fit, in order to avoid creating a vacuum in the vehicle tank. Because it is not necessary to compress the bellows to ensure a tight fit with the vehicle tank, the assist nozzle is generally easier to insert than the balance nozzle bellows.
PROCEDURE AND TECHNOLOGY REVIEW
Due to the tremendous number of gasoline transfer and dispensing facilities located in the District, Rule 461 is one of the most significant control strategies for VOC emissions. This rule requires the use of Phase I and Phase II vapor recovery systems to reduce 95% of VOC emissions from both the tank-filling and vehicle-fueling operations at gasoline transfer and dispensing facilities. As a result, it is imperative that Phase I and Phase II vapor recovery systems are properly constructed and operated so that the necessary control efficiency can be maintained.
The District intends to incorporate new procedures and technologies into Rule 461 to further enhance the effectiveness of the Phase I and Phase II vapor recovery systems and therefore reduce the VOC emissions from gasoline transfer and dispensing operations. As a result, staff has reviewed a number of areas for inclusion in the proposed amendments as follows:
SELF-COMPLIANCE PROGRAM:
The District has been implementing an extensive compliance program on gasoline transfer and dispensing facilities since the adoption of Rule 461 in 1979. The District receives approximately 1,200 to 1,500 citizen complaints per year. A majority of the Notices of Violation (NOVs) issued by District inspectors over the years are a result of improper installation and/or maintenance of Phase I and Phase II vapor recovery systems. Usually, improper operation of a vapor recovery system results in total loss of emission capture and control. If the problem is due to improper design or installation, it can potentially cost the owner/operator a significant amount of money to correct the problems. If more attention can be devoted to the installation and maintenance of Phase I and Phase II vapor recovery systems, potential problems can be detected early avoiding expensive repair, redesign and noncompliance costs. As a result, it is prudent for the owner/operator of any gasoline transfer and dispensing facility to institute a "self-compliance program".
The self-compliance program is a part of the District's privatization effort. It requires the shared commitment from both the industry and the District. This program will increase industry's flexibility and compliance rate, create a net air quality benefit, and help the District to optimize the use of compliance resources. Furthermore, Senate Bill (SB) 1731 [Health and Safety Codes 44390-44394] requires that all facilities which may pose a significant health risk to reduce the risk to an acceptable level. SB 1731 [Health and Safety Codes 44390-44394] also requires CARB to provide assistance to small businesses in assessing health risk reduction methods as well as developing the techniques to implement successful mitigation. As a result, CARB formed a Gasoline Service Station Workgroup, consisting of government agencies and industry representatives, to identify the necessary health risk reduction measures. This workgroup has concluded that a "self-compliance program" is the most effective way to minimize emissions from gasoline transfer and dispensing facilities.
The incentives/benefits for implementing a self-compliance program are summarized as follows:
Incentives/Benefits Gained by the Industry from
Rule 461 Self-Compliance Program
Facilities have a guideline and clarification of the District's standards expected from a site inspection.
Workforce becomes more versatile, better informed and educated regarding safety responsibilities, equipment function and regulatory obligations.
A merit system will designate companies with a good track record as low priority on the District inspection list.
The owner/operator increases their compliance rate.
Save money correcting problems early before the inspector shows up. Companies will save money:
From reduction of violation fines.
By fixing items on their own schedule.
Through less facility down time.
From re-designs due to improper installation of equipment.
From cleanup due to undetected spillage and/or leak in the system.
Eventual fee reduction when the inspector presence can be decreased.
Reduce public nuisance.
Lessen site accidents.
Reduce both public and employee liability issues.
Eliminate negative publicity due to non-compliance.
Reduce stress of un-announced and unprepared inspections to the facility owner/operator.
Allows businesses to empower themselves to safeguard their own compliance; reduce violations at the site while maintaining a more efficient emission reduction system.
The owner/operator is ensured proper installation and operation of Phase I and Phase II vapor recovery systems so that the required control efficiencies are achieved.
Maintain the expected reductions of overall air polluting emissions.
The owner/operator achieve the reduction in health risk required by SB 1731.
Achieve positive air quality results reflecting cooperation from industry and affecting future standards in the rule.
Pioneer and participate in new "model" self-compliance program as an important new step incorporating the private sector with the governmental regulatory process.
The District is including a self-compliance program in the proposed amendments. While the retail facilities represent approximately 55% of all gasoline transfer and dispensing facilities in the District, the quantity of gasoline sold at these retail facilities accounts for approximately 97% of the gasoline consumed in the District. As a result, it is prudent to focus our effort only on the retail gasoline transfer and dispensing facilities at this time. Currently, self-inspection and auditing programs are in place at both major and independent oil companies, who take the initiative to safeguard their own compliance and reduce violations at their sites. The District intends to establish a uniform structure and parameters for these programs that will allow everyone to meet the same air quality compliance standards. In order to simplify the process and minimize the impacts on the owners/operators of all retail gasoline transfer and dispensing facilities, this proposed self-compliance program is primarily based on the standard practices required by most of the oil companies. This program will consist of the following elements:
o Daily maintenance inspections
o Periodic self-compliances
o Training and Certification
The maintenance inspections and self-compliances are standard practices for most of the oil companies. It is our understanding that most of the oil companies require their facility operators to conduct daily maintenance inspections to ensure proper operating conditions of the equipment and the facility operators are typically required to keep certain records. In addition, most of the oil companies perform periodic self-compliance to ensure that their facilities comply with all applicable environmental laws.
As a part of our commitment in assisting the public, the District will provide the manager of retail gasoline transfer and dispensing facilities with training on general CARB and AQMD requirements/procedures in order to perform the daily inspections. In addition, the District will also conduct more extensive training in the maintenance and inspection of vapor recovery systems for the individuals who are designated by the owner/operator of retail gasoline transfer and dispensing facilities to perform the periodic self-compliance. The District will also deem certain established self-inspection and auditing programs with various companies as "equivalent" in order to validate and credit existing activities.
FEDERAL IMPLEMENTATION PLAN (FIP) CONTROL MEASURES:
Under the Clean Air Act (CAA), state and local agencies are required to develop State Implementation Plans (SIPs) to demonstrate the attainment of National Ambient Air Quality Standards (NAAQS) by specific dates. While California has traditionally been the leader in air quality control efforts, the current SIP has not yet been able to achieve the required attainment levels for certain areas.
As a result of a series of lawsuits and appeals that began in 1988, USEPA was ordered by the courts to establish a Federal Implementation Plan (FIP) to ensure the attainment of NAAQS for three areas - Sacramento, Ventura, and South Coast. As a result, USEPA promulgated the FIP on February 13, 1995 to attain the health-based ozone NAAQS in the Sacramento and Ventura areas, and to attain both the ozone and carbon monoxide (CO) NAAQS in the South Coast area.
At the same time, the 1990 CAA amendments required that all non-attainment areas for ozone submit complete SIPs to USEPA by November 15, 1994 for full approval. In California's SIP submittals, the state and local agencies committed to adopting a specific set of regulations which, when adopted and implemented, will achieve the goal of clean air for the non-attainment areas
The FIP was rescinded pursuant Bill HR889 which was signed by President Clinton on April 10, 1995.
The FIP included a comprehensive list of control measures. Even though the FIP is rescinded, these control measures should be included in the SIP and could be implemented by the state and local agencies to achieve timely attainment of NAAQS. Specifically a total of eleven (11) control measures are identified for gasoline transfer and dispensing facilities as follows:
1. Coaxial Phase I system certified after January 1, 1994
2. Pressure-vacuum relief valves on vent pipes
3. "CARB certified" spill box
4. Vapor check valve at the nozzle
5. Minimum Diameter of riser/dispenser connection
6. "CARB certified" insertion interlock
7. Phase II system with a coaxial hose
8. Minimum liquid removal rate in hoses
9. Limited exemptions for implements of husbandry
10. Performance and Reverification testing
11. Recordkeeping
A majority of these control measures reflect the advancement of technologies for Phase I and Phase II vapor recovery systems. The use of pressure-vacuum relief valves on vent pipes is an effective way to control the storage tank breathing loss and is already required in the Bay Area Air Quality Management District (BAAQMD). Staff recommends to incorporate ten (10) of the eleven (11) control measures in the proposed amendments.
One control measure to limit the exemption for the implements of husbandry will not be incorporated in the proposed amendments. California Health and Safety Code, Division 16, Section 36005, specifies that implements of husbandry are exempt from permitting requirement. If this control measure is incorporated in the proposed amendments, the challenge then exists to monitor the installation of the required vapor control systems. Without a permit, neither the equipment owner nor the District inspector will have any written guideline of the equipment description or conditional expectations applicable to comply with the rule.
The emission reduction associated with this control measure is expected to be minimal due to the limited number of sources (approximately 100 farms) within the District and the small throughput for these facilities. Staff has determined that this proposal is not cost-effective with an expected impact of $37,550 per ton of VOC emission reduced (see page 10 of Appendix B).
Furthermore, without incorporating this control measure in the proposed amendment, the increase in VOC emissions from the non-control of agricultural tanks is calculated to be significantly less than 5% of the total controlled emissions from all gasoline transfer and dispensing facilities. As a result, the 5% equivalency rule determination required by USEPA for the exemption of agricultural tanks is met, as demonstrated page 5 of Appendix A.
Due to the significant cost impacts on agricultural industry, difficulty in rule enforceability, and demonstrated compliance with 5% equivalency rule determination, staff recommends not to limit the exemption for tanks fueling implements of husbandry.
STATE IMPLEMENTATION PLAN (SIP) RULE COMMENT:
The latest amendment to Rule 461 was adopted by the Governing Board on July 7, 1989 and submitted to CARB/USEPA for inclusion in SIP on December 31, 1990. As a part of review process, USEPA provided the District with the following comments to be addressed in the next rule amendment:
1. Definition of "gasoline vapor"
2. Definition of "vapor tight"
3. Vapor tight condition for delivery vessels
4. Limited exemption for implements of husbandry
5. Recordkeeping
Most of these comments are considered administrative. The comments on recordkeeping is the same issue as identified in FIP. Staff recommends incorporating these comments except for the limited exemption for implements of husbandry in the proposed amendments. As mentioned above, staff decided not to subject the limited number of agricultural sites with rule requirements since the proposal is expensive, not cost effective and would be difficult to enforce since existing California Health and Safety Code regulations exempt "implements of husbandry" from permitting.
AIR QUALITY MANAGEMENT PLAN (AQMP) CONTROL MEASURES:
The District adopted its first Air Quality Management Plan (AQMP) in 1979. This AQMP contained an early action plan that emphasized control measures that had been targeted by USEPA and CARB as having high priority for implementation. The AQMP was subsequently revised in 1982, 1989, 1991, and 1994 to set forth a comprehensive control program that will lead the South Coast Air Basin into compliance with all federal and state air quality standards.
The 1994 AQMP revision identified the following control measures specifically for gasoline transfer and dispensing facilities:
AQMP CM NO DESCRIPTION
94RFL-01 Spill control Device
94RFL-02 Pressure-vacuum relief valves for vent pipes
Fail-safe Phase I vapor recovery system
"CARB certified" spill box
Licensing of contractors
Shutoff mechanism to prevent top-off
These control measures were also previously specified in the 1991 AQMP revision (CM #90A-B-1,2,5,6 & 7). The pressure-vacuum relief valves and "CARB certified" spill box in CM #94RFL-02 are the same control measures as identified in the FIP and therefore will be included in the proposed amendments. However, staff recommends not to incorporate the following control measures in the proposed amendments:
1. Spill Control Device (94RFL-01)
This control measure proposes that dispensing of gasoline into any container is allowed only if such container is equipped with a device consisting of a leak-proof spout and a locking interface to prevent gasoline spill. Such a control device is not yet commercially available. In addition, it is more effective to regulate at the level of manufacturer or at the point of sale. These issues should be further investigated as a separate rule development.
2. Phase I Fail-safe Mechanism (94RFL-02)
This control measure proposes the use of a fail-safe mechanism to shut-off gasoline flow at any time the Phase I vapor recovery system is not properly connected. This fail-safe mechanism is currently not yet commercially available for Phase I vapor recovery system. Based on staff's investigations, none of the equipment manufacturers have devoted any effort in the research and development of such mechanism. The cost associated with the installation of such mechanism is expected to be substantial while the associated emission reduction may be minimal. As a result, staff recommends not to implement this control measure.
3. Licensing of Contractors (94RFL-02)
This control measure proposes that all contractors performing installation or maintenance of any Phase I or Phase II vapor recovery systems be certified by the District. These contractors are already required to obtain contractor licenses issued by the California Department of Consumer Affairs, Contractor's State License Board. Since there are a total of 75 configurations currently certified by CARB, it is difficult for the District to determine the competency of the contractors who perform the installation and maintenance of such a variety of configurations. In addition, the equipment manufacturers indicated that they would prefer to certify their own contractors for their own systems. As a result, staff recommends not to implement this control measure.
4. Phase II Shut-off Mechanism (94RFL-02)
This control measure proposes the use of a shut-off mechanism on Phase II vapor recovery system to prevent gasoline top-off. Once the gasoline flow is shut-off, this mechanism can only be reset by the facility attendant. Based on our discussions with the equipment manufacturers and the CARB, it is very difficult to design such a mechanism to identify the shut-off resulting only from the gasoline top-off rather than other nuisance shut-off. Another concern is that this mechanism may cause a significant inconvenience to the customers and the attendant of gasoline transfer and dispensing facilities. As a result, staff recommends not to implement this control measure.
PUBLIC AND STAFF RECOMMENDATIONS:
The District has been implementing an extensive compliance program on gasoline transfer and dispensing facilities since the adoption of Rule 461 in 1976. As a part of the permitting process, certain reviewing procedures and permit conditions are developed from public and staff recommendations and utilized to ensure that the construction and operation of Phase I and Phase II vapor recovery systems are in compliance with all applicable District requirements. Based upon the comments from public and staff, the following are being considered:
1. Approval of new of relocated vent pipe location
2. Pre-backfilling inspection
3. Post-construction inspection
4. Performance testing requirement
5. Phase I & Phase II requirements for mobile fuelers
The vent pipe location approval, pre-backfilling inspection, post-construction inspection and performance testing are critical procedures to ensure that Phase I and Phase II vapor recovery systems are properly installed. Phase I and Phase II vapor recovery systems on mobile fuelers are already required in the Sacramento Metropolitan Air Quality Management District (SMAQMD) and in the San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD). CARB has established a test method (TP-205.2) which outlines the procedure to test the vapor recovery systems on mobile fuelers. They are preparing to release a certification for a vapor recovery equipped mobile fueler using certified Phase I and II products, which is required in the test method.
A Southern California mobile fueler manufacturer has already designed and constructed three local mobile fuelers with Phase I and II vapor recovery systems using both the vacuum assist and balance arrangements. These three units have not been formally tested or certified by CARB so the efficiency has yet to be established. However, CARB has been receptive to the idea of certifying the manufacturers, as opposed to strictly individual mobile fueler certifications, to assist the significant universe of existing mobile fuelers with achieving compliance. Staff has met with the two primary mobile fueler owners, who constitute approximately 50% of the universe, and discussed the availability of the required systems as well as their advances with installing vapor recovery systems. Staff has agreed to monitor the progress of the industry implementing the requirement by January 1, 1998 and to evaluate their progression and achievements one year before so the rule deadline may be revisited, if necessary. Staff recommends to incorporate all the above public and staff issues in the proposed amendments.
PROPOSED AMENDMENTS
The following summarizes the major proposed amendments for the rule. In addition, there are some removed and added words throughout the document to improve the clarity and understanding of the rule while not altering the meaning or interpretation. The major items are listed in the order in which they appear in the rule.
1. Deletion of "purpose" and addition of "applicability", subdivision (a)
The purpose statement has been replaced by the following more effective applicability statement incorporating mobile fuelers in the rule: This rule applies to the transfer of gasoline from any tank truck, trailer, or railroad tank car into any stationary storage tank or mobile fueler, and from any stationary storage tank or mobile fueler into any motor vehicle fuel tank or mobile fueler.
2. Addition of the following definitions, subdivision (b)
The definitions have been added to clarify, increase awareness and support the rule language as well as enhance the enforceability of the rule.
"Aspirator-assist system", paragraph (b)(2)
"Balance system", paragraph (b)(3)
"Bellows-less nozzle", paragraph (b)(4)
"CARB Executive Orders", paragraph (b)(6)
"Coaxial hose", paragraph (b)(7)
"Fueling positions", paragraph (b)(8)
"Gasoline vapors", paragraph (b)(11)
"Insertion interlock mechanism", paragraph (b)(12)
"Liquid removal device", paragraph (b)(13)
"Mobile fuelers", paragraph (b)(15)
"Owner/operator", paragraph (b)(17)
"Poppetted dry break", paragraph (b)(18)
"Pressure/vacuum valve", paragraph (b)(19)
"Retail", paragraph (b)(21)
"Spill box", paragraph (b)(22)
"Vacuum -assist system", paragraph (b)(24)
"Vapor check valve", paragraph (b)(25)
The "retail" definition specified in paragraph (b)(21) is slightly different from the "retail trade" (SIC 52-59), as defined in Standard Industrial Classification Manual published by the Office of Management and Budget, Executive Office of the President of the United States, which is used in the socioeconomic analysis.
3. Revision of the following definitions, subdivision (b)
The definitions have been revised to improve the understanding of the rule and enhance the enforceability of the rule.
"Alteration", subdivision (b)(1)
"Gasoline", paragraph (b)(8)
"Gasoline transfer and dispensing facility", paragraph (b)(9)
"Motor vehicle", paragraph (b)(15)
"Rebuilt equipment", paragraph (b)(19)
"Submerged fill tube", paragraph (b)(22)
"Vapor tight", paragraph (b)(24)
4. Addition of "mobile fuelers" in the rule requirement, subdivision (c)and(e)
Mobile fuelers will now be subject to the vapor recovery requirements as it has been proven that these systems exist with both Phase I and Phase II processes. CARB has established a test method (TP 205.2) which outlines the procedure to test the vapor recovery systems on mobile fuelers. They are preparing to release a certification for a vapor recovery equipped mobile fueler. A Southern California mobile fueler manufacturer has already designed and constructed three local mobile fuelers with Phase I and II vapor recovery systems using both the vacuum assist and balance arrangements. It is important to equate the regulatory field to include mobile fuelers since their contribution to air pollutant emissions can be reduced. The Phase II system has proven to be successful primarily using a vacuum-assisted in order to produce the necessary suction to return the vapors back to the tank truck. Staff estimates 100 mobile tankers exist in the South Coast Air Basin.
5. Addition of a requirement to install certified spill boxes, subparagraph (c)(1)(G)
Water quality regulations in California have required the installation of a spill box at all service stations to ensure that spilled gasoline does not end up in the surface or ground water supply. After installation of the spill boxes, it was found that they often were not vapor-tight, which caused leaks in the Phase I vapor recovery system. This paragraph requires that a "CARB-certified" spill box be installed any time an underground storage tank is installed or replaced. The reason for including this requirement is to reduce the possibility that the spill box could hamper the effectiveness of the Phase I vapor recovery system. The regulation will assist local facilities in reaching compliance early by installing the "CARB-certified" spill box when installing or replacing their stationary storage tank/associated piping on their own time. This spill box shall be equipped with an integral vapor-tight drain valve to return spilled gasoline to the stationary storage tank.
6. Addition of a requirement to install certified coaxial Phase I systems, subparagraph (c)(1)(H)
Any time a new Phase I system is to be installed at a facility, the Phase I system must be a dual point system or a Phase I coaxial system that is certified by CARB after January 1, 1994. It is common for dual point systems to be installed at new or modified facilities and for coaxial systems to be installed in retrofit situations. Several problems have been noted with coaxial systems that decrease the efficiency of Phase I vapor recovery due to a high rate of failure in the field. Coaxial drop tubes are more susceptible to damage due to improper connection of the fill nozzle. In the Bay Area, 300 defects affecting the system efficiency were identified in coaxial Phase I systems for every dual point defect. Further, often Phase II leak tests cannot be conducted at stations with coaxial Phase I systems because the coaxial systems often leaks.
7. Addition of a requirement to install certified poppetted drybreaks or spring-loaded vapor check valves, subparagraph (c)(1)(I)
Any Phase I system of dual point design installed must incorporate poppetted drybreaks or spring-loaded vapor check valves to ensure that there are no leaks in the vapor return coupler. When a truck operator makes a drop at a service station with a dual point Phase I system, the operator must unscrew the cap on the vapor line before the hose is connected. The poppetted drybreak on the vapor return coupler ensures that no vapors escape from the underground tank before the vapor return hose is connected. In this system, connecting the vapor return hose opens the poppetted drybreak and allows the flow of vapor through the hose.
8. Addition of a requirement to install a certified insertion interlock mechanism, subparagraph (c)(2)(D)
A person shall not install any balance-system bellows-equipped gasoline dispensing nozzle unless the nozzle is equipped with a "CARB certified" insertion interlock mechanism. The insertion interlock, or "no seal-no flow" device, ensures that gasoline cannot be dispensed unless the bellows of the balance nozzle is compressed to ensure a tight fit at the nozzle/fill pipe interface. In some balance nozzles, compression of the bellows opens a valve which permits the flow of air from the spout tip to the primary shutoff chamber. The insertion interlock mechanism is also a safety feature. In the event that the gasoline dispensing pump is on and the nozzle is in the open position, the insertion interlock will prevent the flow of gasoline unless the bellows is compressed. All current-generation nozzles designed for a vapor-balance system have a certified insertion interlock mechanism. It is unlikely that a balance system nozzle is still in operation without an insertion interlock.
9. Addition of a requirement to install balance systems with vapor check valves in the nozzle, subparagraph (c)(2)(E)
A person shall not install any balance system gasoline dispensing nozzle at a new or altered facility unless a vapor check valve is located in the nozzle. In addition, effective January 1, 1997, a person shall not operate any balance system nozzle unless the vapor check valve is located in the nozzle. Having the check valve in the nozzle rather than at a remote location will eliminate vapor losses from the gasoline trapped between the nozzle and the remote check valve. The vapor check valve opens and closes the vapor passage between the underground tank and the atmosphere (through the nozzle bellows). This valve closes when the nozzle is not in use to prevent vapors from escaping. This also prevents air leakage into the Phase II system and vapor leakage out of it during vehicle refueling at another nozzle or tank truck unloading.
Due to the cost impacts, staff has not included the requirement of removing remote vapor check valves in the proposed amendments. Remote check valves tend to be a potential source of fugitive emissions. In addition, the dynamic back pressure test, which measures the resistance to vapor flow back to the storage tank, cannot be conducted properly if the system contains a remote vapor check valve. As a result, remote check valves should be removed as they become defective. It is also important to note that CARB is currently in the process of decertifying certain nozzles with remote vapor check valves. Once the CARB Executive Order of decertification is issued, the facility owner/operator will be required to remove all remote vapor check valves.
10. Addition of a requirement to install only Phase II coaxial systems, subparagraph (c)(2)(F)
A person shall not install any gasoline dispensing nozzle at a new or altered facility unless the nozzle is equipped with a coaxial hose. In addition, effective January 1, 1998, a person shall not operate any gasoline-dispensing nozzle unless the nozzle is equipped with a coaxial hose. It is generally accepted that coaxial hose systems are much more effective than dual hose systems. Since dual hoses have a higher backpressure, they are less efficient and therefore have a potential to emit more pollution. Historically, dual hoses have been a source of problems, specifically with regard to their weight, durability, and propensity to kink. The original two hose system was heavy and proved to be awkward (due to hose twisting, etc.) for the consumer and gas pump attendant to use. The improved coaxial hoses are lighter and more durable.
11. Addition of a diameter requirement in the connection between the riser and dispenser, subparagraph (c)(2)(G)
The riser is the beginning of the vapor piping that is located either inside the dispenser or on the pump island. Typically a small piece of hose or pipe is used to make the connection between the riser and the vapor piping of the dispenser cabinet. If flexible tubing is used for the connection, the flexible tubing material shall be listed for use with gasoline and be equipped with a clearly visible bonding strap. The inside diameter of the connection between the riser and dispenser cabinet at a new or altered facility shall not be less than 0.75 inch. There is no anticipated environmental or economic impact of this requirement. This requirement is simply a codification of existing requirements that should already be in place at most service stations.
12. Addition of a requirement for liquid removal device with a designated liquid removal rate, subparagraph (c)(2)(H)
All liquid removal devices for any gasoline-dispensing nozzle with a dispensing rate of greater than five gallons per minute shall be CARB certified with a minimum liquid removal rate of five milliliters per gallon transferred. A liquid removal system allows for the removal of gasoline trapped in the vapor passage of the hose to drain into the fuel tank. A slight vacuum in the coaxial hose is created by the fuel flowing in the interior hose that draws the liquid out of the vapor passage and into the liquid gasoline stream. The intent of this requirement is to clarify the CARB certification by providing a specification of liquid removal rate. All existing systems are expected to be able to meet this requirement. In the event that a hose is improperly installed or is malfunctioning, this requirement will provide an enforcement tool to ensure that the system is repaired.
13. Addition of a requirement to install pressure-vacuum relief valves on the vent pipe, subparagraph (c)(3)(G)
A person shall not install any vent pipes at a new or altered facility unless such vent pipe is equipped with a CARB-certified pressure-vacuum relief valve. In addition, all open vent pipes on gasoline storage tanks at existing gasoline transfer and dispensing facilities shall be equipped with pressure-vacuum relief valves by January 1, 1997. Pressure relief shall be set at 3 inches water column and vacuum relief shall be set at 8 inches water column. It is expected that the addition of a PV-valve will eliminate the majority of emissions from the gasoline storage tank vent pipe. With no PV-valve on the vent pipe the cargo tank headspace pressure is exhausted to the atmosphere via the vent pipe. It will also eliminate the possibility of air being drawn into the storage tank during vehicle fueling and subsequent emissions from "vapor growth."
14. Addition of a requirement to inspect piping, etc. prior to backfilling, subparagraph (c)(3)(K)
Prior to backfilling of any underground storage tank and piping installation, the owner/operator of a new or altered facility shall have all piping and the tank installation inspected to verify that all underground equipment is properly installed in accordance with the requirements specified in the applicable CARB Executive Order. The owner/operator shall notify the AQMD at least 24 hours prior to any backfilling. The caller will receive a reference number to instantly verify the call was accounted for by the District. Once the District is notified, the facility owner/operator can proceed with the backfilling at the specified time even if the District inspector is not present. This proposed amendment ensures the owner/operator that the initial equipment installation and configuration was done properly to avoid future problems with system function.
15. Addition of a requirement to inspect the vapor recovery systems prior to a permit to operate issuance, subparagraph (c)(3)(L)
Upon completion of the construction of a new or altered facility, the owner/operator shall have all Phase I and Phase II vapor recovery systems inspected to verify that all components were constructed in accordance with the description specified in the Permit to Construct and in compliance with all AQMD requirements. The owner/operator shall notify the AQMD in writing of any changes to the information and specifications submitted with the application under which the Permit to Construct was issued. This requirement ensures that the installed equipment meets our requirements and is consistent with the permit issued.
16. Addition of testing requirements, paragraph (c)(4)
In order to verify that Phase I and Phase II vapor recovery systems fully meet the requirements of the CARB certification, performance tests are required for new or altered facilities and reverification tests are required for existing facilities. The initial performance tests ensure proper installation and operation while the reverification tests assist in ensuring the equipment is maintained in good operating order by monitoring the integrity of the systems. For any facility that has not conducted any of the required reverification testing since January 1, 1993, the initial reverification testing shall be conducted by January 1, 1998. The tests will detect leaks in the system as well as blockage to vapor flow. Leaks and blockage can severely reduce the effectiveness of these vapor recovery systems and cause an increase in emissions. The required performance and reverification tests are as follows:
P E R F O R M A N C E T E S T S:
(I) Phase I vapor recovery system
(1) static pressure (leak-decay) test
(II) Phase II vapor recovery system
(1) static pressure (leak-decay) test
(2) dynamic pressure (back-pressure) test
(3) air-to-liquid (A/L) ratio (only for bellows-less nozzle)
(4) liquid removal rate (only for system with a liquid removal system required by CARB Executive Orders)
R E V E R I F I C A T I O N T E S T S
(i) Static pressure (leak-decay) test shall be performed once every year (for vacuum-assist Phase II systems).
(ii) Static pressure (leak-decay) test shall be performed once every five years (for balance Phase II systems).
(iii) Air-to-liquid (A/L) ratio test shall be performed every five years (for bellows-less nozzles).
(iv) Dynamic pressure (back-pressure) test shall be performed once every five years.
17. Addition of a self-compliance program, paragraph (c)(5)
Currently, self-inspection and auditing programs are in place at both major and independent oil companies, who take the initiative to safeguard their own compliance and reduce violations at their sites. The District intends to establish a uniform structure and parameters for these programs that will allow everyone to meet the same air quality compliance standards. In order to simplify the process and minimize the impacts on the owners/operators of all retail gasoline transfer and dispensing facilities, this proposed self-compliance program is primarily based on the standard practices required by most of the oil companies. This program will consist of the elements of daily maintenance inspections and periodic self-compliance conducted by the owner/operator, as well as compliance audit inspections conducted by the District. The detailed procedures of the required inspections are included in Attachments C & D of the rule.
18. Addition of a training and certification requirements, paragraph (c)(6)
It is critical that individuals conducting the required daily maintenance inspections and periodic self-compliance are knowledgeable about District requirements as well as the CARB certification. As a result, these individuals will be required to complete an AQMD-approved training program. The District will provide this necessary training in order to initiate a successful self-compliance program. Such training would include equipment defect identification, pre-backfilling and post-construction inspection as well as periodic compliance expectations. The District will also deem established self-inspection and auditing programs with various companies that meet AQMD inspection and training standards as equivalent. In order to validate and credit the existing activities, any self-compliance program developed by any company should be submitted to the District for approval in accordance with the schedule specified in this paragraph.
19. Addition of recordkeeping requirements, paragraph (c)(7)
The District has designed simpler, flexible procedures and forms to reduce the difficulty in complying with this traditionally problematic requirement. The facility owner/operator will be required to keep the records of all inspections and repairs, as well as the test results and throughput records required by permit conditions. All records except test results shall be maintained for a period of two (2) years. Records of test results shall be maintained for a period of five (5) years. All records shall be made available to the AQMD staff upon request.
20. Addition of test methods, subdivision (d)
By publishing the proper test methods in the rule, the public is certain which procedure is applicable and expected. Fixed testing standards equalizes results from all facilities and reduces debate on the specific steps performed in the method. The following test methods are referenced in the rule:
(1) The efficiency of a Phase I vapor recovery system shall be determined by the CARB Test Procedure TP-201.1.
(2) The static pressure performance of a Phase II vapor recovery system shall be determined by the CARB Test Procedure TP-201.3.
(3) The dynamic pressure performance of a Phase II vapor recovery system shall be determined by the CARB Test Procedure TP-201.4.
(4) The air-to-liquid volume ratio of a Phase II vapor recovery system shall be determined by the CARB Test Procedure TP-201.5.
(5) The liquid removal rate of a Phase II vapor recovery system shall be determined by the CARB Test Procedure TP-201.6.
21. Revision of the exemption for rule applicability to include mobile fuelers, paragraph (e)(3)
Mobile fuelers are currently exempt from installing Phase I and II vapor recovery systems and this exemption will expire January 1, 1998. The future effected date is necessary for mobile fueler owners to retrofit their trucks and for CARB to certify the systems.
22. Deletion of the present "compliance schedule", subdivision (e)
The wording and schedule is outdated and serves no purpose in the rule.
EMISSION INVENTORY
There are approximately 7,400 gasoline transfer and dispensing facilities (4,100 retail and 3,300 non-retail) in the South Coast Air Basin (SCAB). Table 1 classifies the five different gasoline facility categories: major, independent, convenience, consumer and government.
Table 1
Gasoline Facility Categories
Gasoline Description
Facility
Category
Major Facilities that are provided with fuel from
a large oil corporation. These sites could
be owned and operated by the corporation or
could be leased out to be run by a dealer or
franchisee. A possible third scenario is
when the major has a contract to supply only
fuel to a site and the owner agrees to
operate as a major. There are seven majors
in the basin: ARCO, Chevron, Mobil, Shell,
Texaco, Ultramar and UNOCAL. These
facilities constitute 39% of the number of
stations and 77% of emissions.
Independent Facilities that purchase gasoline from
several refineries and sell gasoline under
the major name or under their own brand name
such as G&M Oil, Thrifty Oil, United Oil,
USA Petroleum, Winall Oil and World Oil
Company. These facilities constitute 9% of
the stations and 14% of the emissions.
Convenience Businesses whose primary interests are not
in gasoline sales including quick stop
markets, car washes and rental yards. They
purchase fuel from either a major or
independent oil company.
Consumer These are non-retail facilities located at
private companies, golf courses and car
dealers, etc.
Government These are non-retail facilities located at
government agencies.
The major, independent and convenience categories are all considered retail, since profit is accrued from the sale of the gasoline product, while the consumer and government facilities are non-retail. Based on the District 1994 database, the universe and maximum allowable throughput of gasoline transfer and dispensing facilities are estimated in Table 2:
Table 2
Gasoline Transfer and Dispensing Facilities
Universe & Maximum Allowable Throughput
Type Number of % of Maximum Allowable % of
Facilities Facilities Throughput Throughput
in (Gallons Per Month) in
Universe Universe
Major 2880 39 813,700,000 77
Independent 655 9 152,800,000 14
Convenience 549 7 59,220,000 6
TOTAL retail 4084 55 1,025,720,000 97
Consumer 2193 30 23,430,000 2
Government 1066 15 14,110,000 1
TOTAL non-retail 3259 45 37,540,000 3
Overall Total 7343 100 1,063,260,000 100
Figure 3 compares these sites within the overall scheme of facilities in the South Coast Air Basin.
Figure 3
The Universe - Gasoline Transfer and Dispensing Facilities
Figure 4 provides a view of the gasoline throughput from each category within the universe. This information is derived from the maximum allowable gasoline throughput for each category which was compiled in the District's permitting database.
Figure 4
Gasoline Throughput Contribution
Table 3 lists the 1993 annual throughput of retail stations ("majors and independents" constitute 91% of the overall emissions) in the four-county region, as determined from information accumulated by the State of California, Board of Equalization from their sales tax collection summary. This data includes sites in Riverside and San Bernardino counties which are not within the SCAQMD jurisdiction. However, it is estimated that the 9% of emissions from convenience, consumer and government facilities not included would be equivalent to the throughput of the non-SCAQMD retail stations.
Table 3
Annual Retail Gasoline Throughput Per County
SCAQMD County Annual Retail Throughput (in millions of Gasoline gallons) Los Angeles 3,798 Orange 1,059 San Bernardino 718 Riverside 576 T O T A L 6,151
The calculations for VOC emissions resulting from gasoline transfer and dispensing are primarily based on the emission factors identified in EPA's 1990 "Technical Support Document for the FIP" (TSD for FIP). Using the 6.15 billion gallons of gasoline sold in the four-county region according to the 1993 Board of Equalization data, the 1993 baseline VOC emissions are estimated to be 5,526 tons per year (15 tons/day), including 47 tons per year (0.13 ton/day) of benzene emissions.
EMISSION REDUCTION
With effective Phase I and II vapor recovery, the present emission is estimated to be 15 tons per day of VOC, including 0.13 ton per day of toxics (benzene). Inclusion of new procedures and new technology in the proposed amendments will enhance the effectiveness of Phase I and Phase II vapor recovery systems. Additional VOC and toxic emission reductions will be achieved from the following areas:
Installation of pressure/vacuum relief valves.
Improvement of Phase I system efficiency by implementing the coaxial system restriction, poppetted drybreak requirement, and the CARB certified spill box requirement.
Requirement of the vapor check valve in the nozzle.
Improvement of Phase II efficiency by implementing the requirements of minimum connector diameter, insertion interlock, coaxial hose, and liquid removal device performance.
Phase I and II requirements for mobile fuelers.
The emission reductions resulting from the implementation of control measures specified on the first four areas are calculated by using the 1993 data of 6.15 billion gallons per year and the emission factors contained in the TSD for FIP. The emission reductions resulting from the last area are calculated from the emission factors contained in the TSD for FIP and assumed throughput for mobile fuelers. The detailed calculations for emission reductions including throughput and assumptions are attached in Appendix A. Table 4 is a summary of the emission reductions.
Table 4
Emission Reductions
V O C B e n z e n e Amendment Action - Tons/Year Tons/Day Tons/Year Ton/Day Source of Reduction PV Relief Valve 224 0.61 1.90 0.005 Phase I Efficiency 584 1.60 4.96 0.014 Improvement Required Check Valve in 89 0.24 0.76 0.002 the Nozzle Phase II Efficiency 307 0.84 2.61 0.007 Improvement Mobile Fueler Requirements 52 0.14 0.43 0.001 T O T A L 1,256 3.43 10.66 0.03
CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
In accordance with the California Environmental Quality Act (CEQA), the South Coast Air Quality Management District (AQMD) is the Lead Agency and has prepared an appropriate CEQA document (Environmental Assessment) for the project identified above. The document includes a project description, the environmental setting and potential environmental impacts associated with the project. The Environmental Assessment (EA) concluded there is no significant adverse environmental impact as a result of these rule amendments. The EA was circulated for a 30-day public review and comment period from June 15, 1995 to July 17, 1995. The report is attached in this rule package.
COST EFFECTIVENESS
The proposed amendments incorporate a number of new procedures and technologies to further enhance the effectiveness of the Phase I and Phase II vapor recovery systems, and therefore reduce the VOC emissions from gasoline transfer and dispensing facilities. Staff has conducted an extensive cost analysis on each proposed procedure or technology and determined that some of the proposed amendments may result in an increase of capital costs. By examining the total annual cost subject to industry per amount of emissions reduced, the overall cost effectiveness for the proposed amendments is estimated to be $1531 per ton. The detailed analysis of cost effectiveness, including calculations and assumptions, is attached in Appendix B.
SOCIOECONOMIC ANALYSIS
The proposed amended Rule 461 contains amendments that may result in an increase of capital costs. The South Coast Air Quality Management District (SCAQMD) has performed a socioeconomic analysis to determine the impacts on the regulated communities.
DRAFT FINDINGS UNDER THE CALIFORNIA HEALTH AND SAFETY CODE
Before adopting, amending or repealing a rule, the California Health and Safety Code requires the AQMD to adopt written findings of necessity, authority, clarity, consistency, non-duplication, and reference, as defined in Health and Safety Code Section 40727. The draft findings are as follows:
Necessity - The Governing Board of the AQMD has determined that a need exists to amend Rule 461- Gasoline Transfer and Dispensing to assist gasoline facilities in achieving compliance through a self-compliance program and increasing vapor recovery efficiency through new control measures.
Authority - The AQMD Governing Board obtains its authority to adopt, amend or repeal rules and regulations from Health and Safety Code Sections 40000, 40001, 40440, 40441, 40463, 40702, 40725 through 40728.
Clarity - The AQMD Governing Board has determined that the proposed amendment to Rule 461 is written or displayed so that its meaning can be easily understood by persons directly affected by it.
Consistency - The AQMD Governing Board has determined that Proposed Rule 461 is in harmony with, and not in conflict with or contradictory to, existing statutes, court decisions, federal or state regulations.
Non-Duplication - The AQMD Governing Board has determined the proposed amendment to Rule 461 does not impose the same requirement as any existing state or federal regulation, and the proposed rule is necessary and proper to execute the powers and duties granted to, and imposed upon, the AQMD.
Reference - In adopting this regulation, the AQMD Governing Board references the following statutes which the AQMD hereby implements, interprets or makes specific: Health and Safety Code Sections 40001 (rules to achieve ambient air quality standards), 40440(a) (rules to carry out the Air Quality Management Plan), and 40440(c) (cost effectiveness), 44390-44394 (rules to reduce significant health risk) and Federal Clean Air Act Section 172 (c)(1) (RACT).
7/26/95
(i:\lbrules\461\rulepack\staff2.doc)
Appendix A:
Emission Calculations
Emission Factors
______________________________________________________________________________
U N C O N T R O L L E D (with submerged fill)
underground tank aboveground tank Tank Filling Loss 9.5 lbs/1000 gallon 10.0 lbs/1000 gallon Vehicle Fueling Loss 10.0 lbs/1000 gallon 10.0 lbs/1000 gallon Breathing Loss 1.0 lb/1000 gallon 7.5 lb/1000 gallon Spillage 0.7 lb/1000 gallon 0.7 lb/1000 gallon
C O N T R O L L E D (with Phase I and Phase II Vapor Recovery Systems)
Phase I Working 0.475 lb/1000 gallon (95% Loss reduction) Phase II Working 0.5 lb/1000 gallon (95% Loss reduction) Breathing Loss 0.1 lb/1000 gallon Spillage 0.7 lb/1000 gallon
From CARB Certification Testing
From EPA Air Pollution Emission Factors (Manual #42)
Total Throughput
______________________________________________________________________________
6,151,386,297 gallons/year, according to Board of Equalization 1993 Annual Report.
E X E M P T T H R O U G H P U T
(for equipment currently not subject to Rule 461 requirements)
Mobile Fuelers: (100 fuelers) x (200 gals/day/tank) x (4 days/wk) x (52 wks/yr)
= 4.16 million gallons/year
Agricultural: (100 tanks) x (1000 gals/month/tank) x (12 months/year)
= 1.2 million gallons/year
Total Exempt Throughput: (4.16 million + 1.2 million) = 5.36 million gals/year
N O N - E X E M P T T H R O U G H P U T
(for equipment currently subject to Rule 461 requirements)
Total Non-Exempt Throughput = Total Throughput - Total Exempt Throughput
=(6,151,386,297 gals/yr - 5,360,000 gals/yr)
= 6,146,020,000 gals/year
Baseline Emissions
______________________________________________________________________________
Throughput Phase I Phase II Breathing Spillage TOTAL-
( gallons) Loss - Loss - Loss - - tons
tons/year tons/year tons/year tons/year /year
(per day) (per day) (per day) (per
(per day) day)
Non-exempt 6,146,020,00 1,460 (4.0) 1,537 (4.4) 307 (0.84) 2,151 5,455
0 (5.89) (14.94)
Exempt 5,360,000 27 (0.07) 27 (0.07) 16 (0.05) 2 (0.01) 72
(0.20)
TOTAL 6,151,380,00 1,486 1,564 323 (0.89) 2,153 5,526
0 (4.07) (4.28) (5.9) (15.14)
E X E M P T E M I S S I O N S C A L C U L A T I O N W O R K S H E E T:
Throughput Phase I Phase II Breathing Spillage TOTAL-
( gallons) Loss - Loss - Loss - - tons/yea
tons/year tons/year tons/year tons/year r
(per day) (per day) (per
(per day) (per day)
day)
Agricultural 1,200,000 5.7 6.0 0.6 0.42 13
(0.016) (0.016) (0.002) (0.001) (0.04)
Mobile 4,160,000 20.8 20.8 15.6 1.46 59
Fueler (0.057) (0.057) (0.43) (0.004) (0.16)
TOTAL 5,360,000 27 (0.07) 27 (0.07) 16 (0.05) 2 (0.01) 72
exempt (0.20)
Emission Reductions
______________________________________________________________________________
P/V Valve on Vent Pipe
Total Non-Exempt Throughput: 6,146,020,000 gallons/year
Breathing Loss (Phase I & Phase II): 0.1 lb/1000 gallon
Control Efficiency 73% (field study)
Emission Reduction: [0.1 lb x 6,146,020/yr x 0.73] 2000 lbs/ton
= 224 tons/year = 0.61 ton/day
Increase Phase I Efficiency (from 95% to 97%)
(from requirement of P/V relief valve, CARB-certified spill box & Phase I system of newer design)
Emission Factors: 0.475 lb/1000 gallon (95% reduction)
0.285 lb/1000 gallon (97% reduction)
Total Throughput: 6,146,020,000 gallons/year
Emission Reduction: [(6,146,020,000 gal/yr) x (0.475 lb-0.285 lb)/1000 gal] 2000 lbs/ton
= 584 tons/year = 1.60 tons/day
Required Check Valve In The Nozzle
Coaxial hose dimensions: Volume = (do2 - di2) x lh
144 in2/ft2 x 4
length of hose (lh) = 12.5
outside diameter (do) = 1.25 Volume = (1.252 - 0.842) x
inside diameter (di) = 27/32 = 12.5
0.84 144 in2/ft2 x
4
Volume = 0.058 ft3
Density of Air saturated w/gasoline vapor: 0.05 lb/ft3
D E N S I T Y C A L C U L A T I O N W O R K S H E E T
Gasoline Molecular Weight = 68 lbs/mole
Volume of Gasoline (@STP) = 379 ft3/mole
Reid Vapor Pressure = 7.4 psia (5.2 psia @ 80F - vehicle fuel tank temperature)
Air Pressure @ 80F = (14.7) x (460 + 80) = 15.0 psia
(460 + 70)
Volume/Mole Fraction (%) = 5.2 = 25.7 %
15 + 5.2
Density of Gasoline = 68 lbs/mole X (25.7%) = 0.05 lb/ft3
379 ft3/mole
Gasoline dispersed per fueling: 10 gallons
Emission Factor: [0.058 ft3 x 0.05 lb/ft3] 10 gallons
= 0.00029 lb/gal = 0.29 lb/1000 gal
% of gasoline vapor emitted: 20%
(between fuelings and during expansions)
Emission Reduction: [(6,146,020 gal/yr) x (50%) x (0.29 lb/1000 gal) x (20%)]
2000 lbs/ton
= 89 tons/year = 0.24 tons/day
Increase Phase II Efficiency (from 95% to 96%)
(from requirements of coaxial hose, insertion interlock, vapor check valve at nozzle, etc.)
Emission Factors: 0.5 lb/1000 gallon (95% reduction)
0.4 lb/1000 gallon (96% reduction)
Total Non-Exempt Throughput: 6,146,020,000 gallons/year
Emission Reduction: [(6,146,020,000 gal/yr) x (0.5 lb-0.4 lb)/1000 gal]
2000 lbs/ton
= 307 tons/year = 0.84 ton/day
Mobile Fuelers (aboveground tanks)
Number of Fuelers: 100
Average Throughput: 200 gallons/day, 4 days/week
Overall Throughput: (100 fuelers) x (200 gallons/day) x (4 days/week) x (52 weeks/yr)
= 4,160,000 gallons/year
Emission Reduction:
Phase I [(4,160,000 gal/yr) x (10.0 lb/1000 gal) x 20.17 0.055
(97%)] 2000 lbs/ton tons/yea ton/day
r
Phase II [(4,160,000 gal/yr) x (10.0 lb/1000 gal) x (96%] 19.97 0.055
2000 lbs/ton tons/yea ton/day
r
Breathing [(4,160,000 gal/yr) x (7.5 lb/1000 gal) x (73%)] 11.39 0.003
2000 lbs/ton tons/yea ton/day
r
51.50 0.14
T O T A L tons/yea ton/day
r
Summary Of Emission Reductions
________________________________________________________________________
V O C B e n z e n e Amendment Action - Tons/Year Tons/Day Tons/Year Ton/Day Source of Reduction PV Relief Valve 224 0.61 1.90 0.005 Phase I Efficiency 584 1.60 4.96 0.014 Improvement Required Check Valve in 89 0.24 0.76 0.002 the Nozzle Phase II Efficiency 307 0.84 2.61 0.007 Improvement Mobile Fueler Requirements 52 0.14 0.43 0.001 T O T A L 1,256 3.43 10.66 0.03
Note:
Emission Reduction from Limiting Exemption for Fuel Tanks Fueling Implements of Husbandry
Due to the significant cost impacts on agricultural industry and difficulty in rule enforceability, staff recommends not to limit the exemption for tanks fueling implements of husbandry. The emission reduction calculations are performed for cost-effectiveness analysis and included for informational purposes. In addition, the VOC emissions due to the non-control of agricultural tanks are calculated to be less than the 5% equivalency rule determination specified by USEPA.
Number of Tanks: 100 (80% over 550 gallon capacity)
Average Throughput: 1000 gallons/month/tank
Overall Throughput: (100 tanks) x (1000 gallons/month) x (12 months/year)
= 1,200,000 gallons/year
Tanks Not Exempt: (>550 gallon capacity)
[1,200,000 gallons/year x 0.80] = 960,000 gallons/year
Emission Reduction:
Phase I [(960,000 gal/yr) x (9.5-0.285 lb/1000 gal)] 4.42 0.01
2000 lbs/ton tons/year ton/day
Phase II [(960,000 gal/yr) x (10.0-0.4 lb/1000 gal)] 4.61 0.01
2000 lbs/ton tons/year ton/day
Breathing [(960,000 gal/yr) x (1.0-0.027 lb/1000 gal)] 0.47 0.001
2000 lbs/ton ton/year ton/day
9.5 0.02
T O T A L tons/year ton/day
5% Equivalency Rule Determination:
Emissions from non-agricultural tanks (controlled):
14.94 ton/day (non-exempt) + 0.16 ton/day (mobile fueler) = 15.1 tons/day (P. A-2)
Emissions from agricultural tanks (controlled): = 0.04 ton/day (P. A-2)
(uncontrolled): = 0.02 ton/day (P. A-5)
Emission increase due to non-control of agricultural tanks
= 0.04 ton/day - 0.02 ton/day = 0.02 ton/day
Percent increase in emission: (0.02 ton/day) X (100%) = 0.1% < 5%
(15.1 tons/day + 0.02 ton/day)
7/26/95
(i:lbrules\461\rulepack\appa.doc)
Appendix B:
Cost Effectiveness Calculations
(1) Cost Effectiveness Analysis For Individual Proposed Amendments
Proposed Amendment Description / Rule Wording Cost
Phase I and II Require vapor recovery systems on Additional costs of installing the required Phase I and Phase
Requirements for truck/trailer with mounted tanks II vapor recovery systems onto mobile fuelers.
Mobile Fuelers that fuel fleet vehicles.
Cost of Installing Phase I, II Into Mobile Fuelers
EPA's Technical Support Document for the FIP (February 1994)
Number of Phase I Phase II CARB Annual Cost Cost
Mobile Capital Capital Cost Certification (at 4% for 10 Effectiveness
Fuelers Cost yrs) ($/ton)
South Coast 100 $290,000 $300,000 $600,000 $146,727 $2,822/ton
Area
Assumptions: Phase I capital costs is ~$2,900 ($800 piping, fittings,valves, etc.; $1100 de-gas tank; $1000 labor to
custom retrofit)
Phase II capital costs (vacuum assist system) is ~$3,000 ($400 hose/nozzle, $500 pump, $1100 de-gas tank, $1000 labor)
CARB certification is $6,000 per mobile fueler
Annual Cost = Present Total Capital Cost (A/P)4%. 10 yrs = ($1,190,000) x (.1233) = $146,727/year
Emission reductions are 52 tons/year
Certified CARB Spill Any time a gasoline storage tank or This requirement is assumed to have no associated costs.
Box Requirement associated piping is installed or Whenever a tank is replaced or installed, water quality
replaced in a gasoline transfer and regulations in California require the installation of a spill
dispensing facility, a CARB box with a drain valve that returns liquid to the storage
certified spill box shall be tank. The only additional requirement is that this system
installed. The spill box shall be must be CARB certified. There is no additional cost in
equipped with an integral purchasing a CARB-certified spill box versus a spill box that
vapor-tight drain valve to return is not CARB-certified.
spilled gasoline to the underground
stationary storage tank. No Additional Cost
Installing Certified A person shall not install any This requirement applies to new installations with
Phase I Systems Phase I vapor recovery system of approximately the same cost between coaxial and dual systems.
the coaxial design at a gasoline Dual point systems decrease the unloading or "drop" time.
transfer and dispensing facility The vapor return passage on a dual point system has a larger
unless such system was certified by volume than a coaxial system, allowing a faster drop in
CARB after January 1, 1994. gasoline. For dual point systems with manifolded vapor
piping, a tank truck operator can drop gasoline into more
than one tank at a same time, further reducing unloading
time.
No Additional Cost
Proposed Amendment Description / Rule Wording Cost
Certified Poppetted A person shall not install any Equipment manufacturers rarely offer Phase I systems without
Drybreaks or Spring Phase I vapor recovery system at a certified poppetted drybreaks and spring-loaded vapor check
Loaded Vapor Check gasoline transfer and dispensing valves on the vapor return coupler of the system. Therefore,
Valves Required facility unless such system there is no additional cost associated with this requirement
incorporates "CARB-certified" since it is the equipment standard in the industry.
poppetted drybreaks or
spring-loaded vapor check valves on No Additional Cost
the vapor return coupler.
Required Diameter of Unless otherwise specified in the This is a clarification of existing requirements and
Riser/ Dispenser applicable CARB Executive Orders, therefore, there is no anticipated costs.
Connection the nominal inside diameter of the
connection between the riser and
dispenser cabinet shall not be less
than 0.75 inche. If flexible
tubing is used for this connection,
the material shall be appropriate No Additional Cost
for use with gasoline and shall be
equipped with a clearly visible
bonding strap.
Certified Insertion A person shall not sell, offer for It is difficult, if not impossible, to purchase a vapor
Interlock Mechanism sale, or install any balance-system balance nozzle today without an insertion interlock
Required bellows-equipped gasoline mechanism.
dispensing nozzle unless it is
equipped with a "CARB-certified" No Additional Cost
insertion interlock mechanism.
Liquid-Removal Device Unless otherwise specified in the No additional cost would be expected since properly-operating
Rate Requirement applicable CARB Executive Orders , liquid removal devices exist. Only malfunctioning liquid
all liquid removal devices for any removal devices would constitute a cost yet it would be
gasoline-dispensing nozzle with a considered part of general maintenance of the system.
dispensing rates exceeding five
gallons per minute shall be
maintained to achieve a minimum
liquid removal rate of five No Additional Cost
milliliters per gallon transferred.
Proposed Amendment Description / Rule Wording Cost
Vapor Check Valve on A person shall not install any No Additional Cost The cost of an nozzle without an internal
Phase II Required balance system gasoline-dispensing vapor check valve is almost identical to the cost of a nozzle
nozzle unless a vapor check valve with an internal vapor check valve. Therefore, no additional
is located in the nozzle. In nozzle cost is expected.
addition, effective January 1,
1997, a person shall not operate Staff does not include the requirement of removing remote
any balance system nozzle unless vapor check valves in the proposed amendments at this time.
the vapor check valve is located in However, it is important to note that CARB is currently in the
the nozzle. process of de-certifying certain nozzles with remote vapor
check valves. Once the CARB Executive Order of
decertification is issued, the owner/operator of a gasoline
transfer and dispensing facilities will be required to remove
all remote vapor check valves. The cost effectiveness
associated with the removal of remote vapor check valves is
included for informational purposes.
Cost of Replacing The Remote Vapor Check Valve
EPA's Technical Support Document for the FIP (February 1994)
# of # of Total # % of Total nozzles Total Annual Cost Cost Effectiveness
retail non-retai of nozzles with remote capital/installa (at 4% for 10 ($/ton)
stations l nozzles with remote check valve tion cost yrs)
facilitie check valve
s
South Coast 4100 3300 78,800 50 % 39,400 $2,772,000 $341, 788 $3,840 / ton
Area
Assumptions: No difference in nozzle cost
16 nozzles per retail station, 4 nozzles per non-retail facility
3 hours labor (at $45/hr) average per facility.
$45 average cost of new/retrofit splitter [$45 x 39,400 nozzles] + [($45/hr x 3 hrs) x 7400 facilities] = $2,772,000
Annual Cost = Present Total Capital Cost (A/P)4%. 10 yrs = ($2,772,000) x (.1233) = $341,788/year
Emission reductions are 89 tons/year
Proposed Amendment Description / Rule Wording Cost
Coaxial Hose Required A person shall not install any No Additional Cost for new facilities. For existing
with Phase II System gasoline-dispensing nozzle at a new facilities, cost for a splitter, high-hose retractor and labor
gasoline transfer and dispensing (one-time equipment modifications) will be needed to convert
facility unless the nozzle is dual hose for coaxial hose in order to be compliant. The cost
equipped with a coaxial hose. In is $365 for each dual hose nozzle replacement. However, the
addition, effective January 1, percentage of existing sites with dual hoses is very small
1998, a person shall not operate (2.03 %) so capital cost is minimal overall. Hoses are
any gasoline-dispensing nozzle usually replaced annually and the cost difference of a coaxial
unless the nozzle is equipped with hose and two equal lengths of regular gasoline hose is
a coaxial hose. incurred annually by the owner/operator. See chart below.
Cost of Changing Dual Hose Stations to Coaxial Hoses
EPA's Technical Support Document for the FIP (February 1994)
C a p i t a l / I n s t a l l a t i o
n C o s t
Total Estimated Total Splitter Retractor Labor / Difference in Total Total Annual Cost
Stations Stations Dual / / Per Dual Per Dual Hose Cost / Capital Cost (at 4% Effectivenes
with Dual Hose Per Dual Hose Hose Per Dual Hose Cost / Per for 10 s
Hoses Nozzles Hose Nozzle Nozzle Nozzle Dual Hose yrs)/per
Nozzle Nozzle Dual Hose
Nozzle
South Coast 7400 150 900 $54,000 / $54,000 / $40,500 / $180,000 / $328,500 / $205,510 / $669/ton
Area $60 $60 $45 $200 $365 $228
Assumptions: 6 nozzles per station
1 hour labor (at $45/hr) to install splitter and retractor
$230 cost of 10 ft coaxial hose, $30 cost of 20 ft regular hose (1 year life of hose)
$60 cost of new splitter, $60 cost of new retractor (10 year life)
Annual Cost = Present Cost splitter, retractor, labor (A/P)4%. 10 yrs + Present Cost of Hose (A/P)4%. 1 yr = [($148,500)
x (.1233)] + [($180,000) x (1.04)] = $205,510/year
Emission reductions are 307 tons/year
Proposed Amendment Description / Rule Wording Cost
Pressure-Vacuum Relief A person shall not install any vent New facilities will be subject to installing a PV-valve and
Valve Required on Vent pipes on stationary storage tanks existing stations need to come into compliance by 1/1/97. It
Pipe at a gasoline transfer and is assumed that the initial capital costs will consist of the
and dispensing facility without a "CARB capital cost of the PV-valves and the labor to install the
Review Plans For Vent certified" pressure-vacuum relief valves. Other than the annualized capital costs, no
Pipe Location valve. In addition, effective (6 additional annual costs will be incurred. PV-valves are
months from date of adoption), all required on all CARB-certified assist-type Phase II systems.
open vent pipes on stationary It is assumed, therefore, that all stations with assist Phase
storage tanks shall be equipped II systems (~ 6%) are already in compliance with this
with a "CARB certified" requirement. See chart below for the cost impact to those
pressure-vacuum relief valve. affected 94% of the universe.
Unless otherwise specified in the
applicable CARB Executive Orders,
pressure relief shall be set at 3
inches water column and vacuum
relief shall be set at 8 inches
water column. For the purpose of
this requirement, vent pipes of
stationary storage tanks may be No Additional Cost for 6% of the Universe
manifolded to a single valve when
the stationary storage tanks are
manifolded according to the
applicable CARB Executive Order.
Cost of Pressure-Vacuum (PV) Valves
EPA's Technical Support Document for the FIP (February 1994)
# of % stations # of stations Total Annual Cost (at Cost
service with without PV capital/installation 4% for 10 yrs) Effectiveness
stations PV-Valves valves cost
South Coast 7400 6 % 6956 $1,502,496 $185,258 $827/ton
Area
Assumptions: $57 cost of PV-valve
3 valves needed per station
1 hour labor (at $45/hr) to install 3 PV-valves
Annual Cost = Present Capital Cost (A/P)4%. 10 yrs = ($1,502,496) x (.1233) = $185,258/year
Emission reductions are 224 tons/year
Proposed Amendment Description / Rule Wording Cost
Pre-Backfilling Prior to backfilling of any No additional cost will be incurred as the owner/operator
Inspection underground storage tank and piping conducts his/her own self-inspection of the site to ensure
installation, the owner/operator proper configuration and installation of the tanks and
shall have all piping configuration piping. The AQMD will conduct the training class to teach
and tank installation inspected to the proper personnel on a self-inspection so no expense is
verify that all underground spent on behalf of the industry. Action will result in a
equipment is properly installed in reduction of complaint investigations and nuisance
accordance with the requirements complaints. The operator and installer should experience
specified in the applicable CARB only a slight delay in the project while this investigation
Executive Order. occurs which has no cost value if time is managed properly.
If the owner/operator chooses a third party to inspect, cost
would accrue to pay for that inspection. However, the
owner/operator has the option not to retain such services to
avoid costs.
No Additional Cost
Post Construction Upon completion of the construction Again, the AQMD will conduct the training class to teach the
Inspection of a new or altered facility, the proper personnel on a self-inspection so no expense is spent
owner/ operator shall have all on behalf of the industry. If the owner/operator chooses a
Phase I and Phase II vapor recovery third party to inspect, cost would accrue to pay for that
systems inspected to verify that inspection. However, the owner/operator has the option not to
all components were constructed in retain such services to avoid costs.
accordance with the description
specified in the Permit to
Construct and in compliance with
all AQMD requirements. The owner/
operator shall notify the AQMD in
writing of any changes to the No Additional Cost
information and specifications
submitted with the application
under which the Permit to Construct
was issued.
Performance Testing Within 30 days of operation, tests This requirement only applies to new installations. Testing
within 30 days after shall be conducted to verify already required as part of permitting procedure.
installation. performance of Phase I and Phase II
vapor recovery systems:
Phase I: leak decay
Phase II: leak decay, back No Additional Cost
pressure or A/L (whichever is
applicable)
Proposed Amendment Description / Rule Wording Cost
Reverification Tests In addition, reverification tests Dynamic Pressure (backpressure) test for balance systems -
shall be conducted in accordance every five years is ~ $113. Static Pressure Leak Decay test -
with the following schedule: every year for vacuum assist and every five years for balance
Leak Decay - annually for vacuum systems - is ~ $666. Air to Liquid Ratio test - every five
assisted and every five years for years for bootless nozzles - is $250. See chart below.
balance systems. Backpressure
(balance) - every five years. A/L
(for bootless nozzles) - every five
years
Cost of Testing Requirements
EPA's Technical Support Document for the FIP (February 1994)
Total % (#) of % (#) of % (#) of Backpressure Cost for Cost for Leak Air to Liquid TOTAL
Stations balance vacuum-ass bootless Test Cost Leak Decay Decay Test Ratio Test Annual Cost /
system ist (vacuum (balance) / Test (vaccum-assist) (bootless) / Average Annual
nozzles assist) annual cost (balance) / / annual cost annual cost Cost Per
nozzles annual cost Station
South Coast 7400 94% 6% (444) 1.5% $786,028 / $4,632,696 / $295,704 / $27,750 / $1,384,999 /
Area (6956) (111) $157,206 $926,539 $295,704 $5,550 $187
Assumptions: $113 cost of backpressure test (to be performed on the balance systems every 5 years)
$666 cost of leak decay tests (to be performed on balance systems every 5 years)
$666 cost of leak decay tests (to be performed on vacuum-assist nozzles every year)
$250 cost of air liquid ratio test (to be performed on the bootless nozzles every 5 years)
Compliance Inspection Require owner/operator to conduct This requirement is assumed to have no additional costs.
Program the following self inspections: Training classes will be conducted by the AQMD to assist in
Daily Maintenance Inspection the daily and audit inspections. The District will deem
Periodic Compliance Inspection certain established self-inspection and auditing programs
with various companies as "equivalent" in order to validate
and credit existing activities. These inspections already
occur at gasoline facilities so no excessive time/labor cost
is demanded. Easy forms have been created by the District
and will overlap present procedure. Will eventually save
time and money as problems can be resolved early, reduce
violation fees and have less facility "down" time when no
sale of product can occur.
No Additional Cost
Proposed Amendment Description / Rule Wording Cost
Training and A person shall not conduct daily Half-day training classes will occur at the AQMD which will
Certification maintenance inspections specified provide the teaching material and forms. There are
in clause (5)(A)(i) unless such negligible costs associated with attending the class, driving
person has completed a general to Diamond Bar and labor outside normal work activity. In
training program approved by the addition, some companies are planning to send a minimal
AQMD. number of representatives who will then "train the trainers"
A person shall not conduct periodic during normal meeting times with the station managers at the
compliance inspections specified in corporate site.
clause (5)(A)(ii) unless such
person has successfully completed
an AQMD-approved training program
in the inspection and maintenance
of vapor recovery systems and has No Additional Cost
received a certificate issued by
the AQMD.
Recordkeeping The owner/operator of any gasoline Negligible labor costs expected to organize and maintain site
Requirements transfer and dispensing facility recordkeeping. Already required to maintain site records of
shall keep the following records: throughput.
(i) records of all inspections and
repairs (i.e. receipts for parts
used in the repair, work orders,
etc.)
(iii) records of test results
(iii) throughput records as
required by permit conditions.
No Additional Cost
(2) Summary of Rule Amendment Cost Effectiveness:
Overall Annual Costs:
Annual Cost ($/yr) Mobile Fuelers $146,727 Phase II Efficiency $205,510 Improvement P/V Relief Valve $185,258 Testing Requirements $1,384,999 T O T A L $1,922,494
Overall Emission Reductions:
Emission Reduction
(ton/yr)
Mobile Fuelers 52
Phase II Efficiency 307
Improvement
P/V Relief Valve 224
Phase I Efficiency 584
Improvement
Required Check Valve in the 89
Nozzle
T O T A L 1256 tons/year
Overall Cost Effectiveness:
Annual Cost ($/yr) Overall Cost
/Emission Reduction Effectiveness ($/ton)
(tons/yr)
$1,922,494/1256 tons $1531/ton
(3) Cost Effectiveness Analysis for Tanks Fueling Implements of Husbandry
Proposed Amendment Description / Rule Wording Cost
Limit Exemption for Only tanks with a storage capacity Due to the significant cost impacts on agricultural industry
Implements of of 550 gallons or less used to and difficulty in rule enforceability, staff recommends not to
Husbandry exclusively fuel implements of incorporate this control measure at this time. The cost
husbandry will be exempt from the effectiveness is included for informational purposes and
requirements. therefore is not used in the calculations for overall rule
cost-effectiveness.
Cost of Removing Phase I, II Exemptions
EPA's Technical Support Document for the FIP (February 1994)
Number of Capital Capital TOTAL Estimated Estimated Phase Estimated Phase TOTAL Cost
Sources cost Cost Capital Annual Cost I Annual II Annual Annual Effectivenes
Exempted (Phase (Phase Cost (at 4% for 10 Maintenance Maintenance Cost s ($/ton)
I) II) yrs) Cost Cost
South Coast 100 $700,000 $712,000 $1,412,000 $174,100 $49,000 $152,400 $375,500 $37,550/ton
Area
Assumptions: $7,000 capital cost of Phase I system
$7,120 capital cost of Phase II system
Total Annual Cost = Present Total Capital Cost (A/P)4%. 10 yrs = ($1,412,000) x (.1233) = $174,100/year
Annual Maintenance Costs: Phase I is maintenance (3% of capital cost) and taxes/insurance (4% of capital cost) and
Phase II is $1,524 per system. Therefore ($700,000 x 7%) + ($1,524 x 100)= $201,400
Emission reductions are 10 tons/year
7/26/95
(i:\lbrules\461\rulepack\appb.doc)
Appendix C:
Comments and Response
USEPA AND CARB COMMENTS
USEPA Comments:
1. COMMENT:
Gasoline is defined as any petroleum distillate with a true vapor range. This rule should include a test method for determining true vapor pressure which would be necessary to verify applicability.
RESPONSE:
Paragraph (b)(9) has been revised to include ASTM Method D323-89 for determining true vapor pressure.
2. COMMENT:
This rule should include recordkeeping requirements.
RESPONSE:
Recordkeeping requirements are included in paragraph (c)(7) to require the facility owner/operator to maintain records of inspections, test results and throughput.
3. COMMENT:
Storage tanks used primarily to fuel implements of husbandry are currently exempt from the requirements of this rule. The Control Technique Guidance (CTG) only allows an exemption for tanks with a capacity of 550 gallons or less and used exclusively to fuel implements of husbandry. The exemption should be changed accordingly.
RESPONSE:
California Health and Safety Code, Division 16, Section 36005, specifies that implements of husbandry are exempt from permitting requirement. If this control measure is incorporated in the proposed amendments, the challenge then exists to monitor the installation of the required vapor control systems. Without a permit, neither the equipment owner nor the District inspector will have any written guideline of the equipment description or conditional expectations applicable to comply with the rule.
The emission reduction associated with this control measure is expected to be minimal due to the limited number of sources (approximately 100 farms) within the District and the small throughput for these facilities. Staff has determined that this proposal is not cost-effective with an expected impact of $37,550 per ton of VOC emission reduced (see page 10 of Appendix B).
Furthermore, the VOC emissions from not controlling agricultural tanks (<550 gallons of gasoline) is calculated to be significantly less than 5% of the total controlled emissions from all gasoline transfer and dispensing facilities. As a result, the exemption of agricultural tanks meet the 5% equivalency rule determination, required by USEPA, and demonstrated on page 5 of Appendix A.
Due to the significant cost impacts on agricultural industry, difficulty in rule enforceability, and demonstrated compliance with 5% equivalency rule determination, staff recommends not to limit the exemption for tanks fueling implements of husbandry.
4. COMMENT:
The definition of "vapor tight' includes a reference to the measurement at a distance of one centimeter from the potential leak source. In order to avoid significant dilution and capture losses, this reference of one centimeter should be deleted.
RESPONSE:
Paragraph (b)(26) has been revised to delete the reference to the measurement at a distance of one centimeter from the potential leak source.
5. COMMENT:
This rule should require that all delivery vessels be maintained at a vapor-tight condition.
RESPONSE:
The vapor integrity of gasoline delivery vessels is regulated under District Rule 462 - Organic Liquid Loading. Therefore, a duplicate requirement in Rule 461 is not necessary.
CARB Comments:
1. COMMENT:
"Vapor tight" is defined as the detection of 10,000 ppm or less as methane. However, the specification for "vapor tight" as listed in CARB Test Method TP-204.3 is 21,000 ppm or less as propane. The definition of "vapor tight" should be consistent with CARB requirements.
RESPONSE:
USEPA approved Rule 461 into the State Implementation Plan (SIP) in 1994 with "vapor tight" being defined as the detection of 10,000 ppm or less as methane determined by EPA Method 21. USEPA has indicated that the change of this definition to a less-stringent limit (21,000 ppm as propane determined by CARB Method TP-204.3) is considered a relaxation of the rule and therefore will affect the approvability of Rule 461.
Furthermore, the specification of 10,000 ppm as methane has been used in a number of other air quality agencies' rules, as well as other SCAQMD rules. Revision of the "vapor tight" definition only to Rule 461 will require District field staff to apply different test methods to similar equipment and will be inconsistent with the test methods for the same equipment in other Districts. As a result, staff recommends retention of the current definition until the new method is deemed to be equivalent to the EPA method. At that time, all rules should be amended concurrently to reflect the new test method.
2. COMMENT:
Clause (c)(4)(A)(i) requires efficiency testing for Phase I vapor recovery systems. California Health and Safety Code, Section 41954 (h) does not allow any civil or criminal penalties for failure to meet a specified efficiency if a system has already been certified by CARB. Other performance testing can be used to verify that a Phase I system is in good working condition. For the Phase I system, it currently suffices to cite the static pressure (leak-decay) test.
RESPONSE:
Clause (c)(4)(A)(i) has been revised to require the static pressure (leak-decay) test rather than the efficiency test.
3. COMMENT:
The minimum liquid removal rate of five milliliters per gallon transferred specified in Subparagraph (c)(2)(H) is less than some of the certification performance standards.
RESPONSE:
It is our understanding that not all CARB Executive Orders for liquid removal devices specify the minimum liquid removal rate. Subparagraph (c)(2)(H) requires a minimum liquid removal rate of five millimeters per gallon transferred unless otherwise specified in the applicable Executive Orders. As a result, if a liquid removal rate is specified in any CARB Executive Order, the facility owner/operator is required to comply with the specific requirement.
PUBLIC COMMENTS
1. COMMENT:
The District should provide an exemption on some of the requirements (i.e. vapor recovery systems, testing, compliance inspection program, recordkeeping, etc.) for any gasoline transfer and dispensing facility with a "de minimus" throughput.
RESPONSE:
The throughput information has been taken into the consideration for this proposed amendment. The District does not include the non-retail facilities in the requirement of the compliance inspection program specified in paragraph (c)(5) since the throughput for the non-retail facilities is typically low. For the same reason, the District also provides exemptions for mobile fuelers and fuel tanks fueling implements of husbandry, as specified in subdivision (e).
Other requirements in the Proposed Amended Rule 461 are essential elements to ensure that the anticipated emission reductions are achieved, and therefore cannot be exempted. Pursuant to California Health and Safety Code Section 41950, vapor recovery systems are required for all gasoline transfer and dispensing facilities regardless of the throughput. Testing and recordkeeping are important requirements to verify the effectiveness of Phase I and Phase II vapor recovery systems. Staff has simplified these requirements to minimize the impacts on affected facilities.
2. COMMENT:
Are facilities used exclusively to dispense methanol subject to the requirements of this rule?
RESPONSE:
The methanol fuel (M-85), currently used in motor vehicles, contains 15% gasoline and 85% methanol. Therefore, the facilities used exclusively to dispense M-85 are subject to the requirements of Rule 461 due to the existing presence of gasoline in the methanol fuel.
3. COMMENT:
The proposed amendments included various new requirements which will result in cost impacts on the affected facilities. The District should include in the staff report the cost analyses associated with these new requirements.
RESPONSE:
The proposed amendments incorporate a number of new procedures and technologies to further enhance the effectiveness of Phase I and Phase II vapor recovery systems and reduce VOC emissions from gasoline transfer and dispensing operations. The cost analysis on these proposed procedures and technologies is included in Appendix B of the staff report.
4. COMMENT:
Does this rule apply to aviation fueling?
RESPONSE:
Rule 461 only regulates gasoline dispensing operations for motor vehicles. It does not apply to aviation fueling.
5. COMMENT:
The definition of "owner/operator" needs further clarification as to who (dealers vs oil companies) has the specific responsibilities for complying the rule requirements.
RESPONSE:
Since the District needs to ensure that the responsible party of any facility, either owner or operator, complies with all requirements, "Owner/operator" is therefore defined as any person who owns, leases, operates, controls, or supervises the operation of a gasoline transfer and dispensing facility.
There are a variety of contractual agreements between the owners and operators of gasoline transfer and dispensing facilities. A typical arrangement is that the operator (dealer) is responsible for above-ground equipment (i.e. hoses, nozzles, etc.) while the owner (oil company) is responsible the underground equipment (i.e. storage tanks, fill tube, etc.). However, any contractual agreement between the owner and operator shall not in any way impair the District's authority to pursue enforcement actions on any violations.
6. COMMENT:
Federal and State laws require that all gasoline sold in California must be reformulated gasoline (RFG) by June 1996. Does the District incorporate the RFG emission data in the emission calculations?
RESPONSE:
One of the major characteristics of RFG is the lower benzene content (less than 1%) to reduce toxic emissions from gasoline transfer and dispensing operations. A benzene content of 0.85% is used in the emission calculations included in Appendix A of the staff report.
7. COMMENT:
Does the District intend to implement the control measure regarding the licensing of contractors who are engaged in the installation and maintenance of gasoline transfer and dispensing facilities?
RESPONSE:
AQMP Control Measure #94RFL-02 proposes that all contractors performing installation or maintenance of any Phase I or Phase II vapor recovery systems be certified by the District. These contractors are already required to obtain State contractor's licenses. In addition, CARB has currently certified a total of 75 configurations. It will be difficult for the District to determine the competency of the contractors for such a variety of configurations. The equipment manufacturers indicated that they would prefer to certify their own contractors for their own systems. As a result, staff recommends not to implement this control measure.
8. COMMENT:
It is not clear if the requirements specified in paragraphs (c)(1)(I), (c)(2)(D), and (c)(2)(H) apply to the existing facilities as well as the new or altered facilities. If these requirements apply to the existing facilities, the associated paragraph should include future compliance dates to provide facilities with sufficient time to comply with these requirements.
RESPONSE:
The requirements specified in paragraphs (c)(1)(I), (c)(2)(D), and (c)(2)(H) apply to both new and existing facilities when the equipment is installed. A future compliance date is not necessary because compliant equipment is commercially available and currently required by CARB.
9. COMMENT:
It is not clear if the inspections specified in subparagraphs (c)(3)(K) and (c)(3)(L) need be conducted by SCAQMD certified inspectors. Also, the District should provide the necessary forms for these inspections.
RESPONSE:
The pre-backfilling and post-construction inspections specified in subparagraphs (c)(3)(K) and (c)(3)(L) can be conducted by the owner/operator or designee. As a part of our commitment in assisting the public, the District will schedule training classes to provide the owner/operator with general training and necessary forms.
10. COMMENT:
The universe of mobile fuelers estimated in the draft staff report is too high since most of the companies providing fueling service (wet hosing) only dispense diesel fuel. In addition, the amount of dispensed is also over-estimated.
RESPONSE:
The number of mobile fuelers estimated in the draft staff report was based on a telephone survey. This number included the units used by contractors to provide fueling service (wet hosing) as well as the units owned by companies to fuel their fleet vehicles. Further discussions with various companies confirmed that the estimated number in the draft staff report is consistent with the universe of mobile fuelers.
11. COMMENT:
None of the Phase I or Phase II vapor recovery systems have been certified by the California Resources Board (CARB) for the mobile fuelers. It will be impossible to comply with the requirement if a certified Phase II vapor recovery system for a mobile fueler is not available by January 1, 1997. In addition, the costs associated with retrofitting mobile fuelers with Phase I and Phase II vapor recovery systems may be substantial.
RESPONSE:
CARB has established a test method (TP205.2) which outlines the procedures to test the vapor recovery systems on mobile fuelers. Based on this test method, CARB has recently certified a mobile fueler in the Sacramento area. Some of the manufacturers in southern California have already designed and constructed a number of mobile fuelers using either vacuum assist or balance Phase II vapor recovery systems.
In order to provide sufficient time for the certification process of mobile fuelers, the compliance date for mobile fuelers has been changed from January 1, 1997 to January 1, 1998. The District will continue to work with the industry and CARB in expediting the certification process for mobile fuelers. With respect to the retrofitting cost, staff has performed a cost-effectiveness analysis which is included in Appendix B of the staff report and shows that it is cost-effective to install Phase I and Phase II vapor recovery systems to control VOC emissions.
12. COMMENT:
It is not clear if the reverification testing requirements specified in paragraph (c)(4) apply to the mobile fuelers.
RESPONSE:
The reverification testing requirements specified in paragraph (c)(4) apply to any gasoline transfer and dispensing facility. Paragraph (b)(10) defines "gasoline transfer and dispensing facility" as "a mobile system or a stationary facility consisting of one or more storage tank and associated equipment ...." which includes both stationary facilities and mobile fuelers.
13. COMMENT:
The proposed amendments include the requirements of using balance dispensing nozzles with vapor check valves and removing all remote check valves at the existing gasoline transfer and dispensing facilities. By the use of dispensing nozzles with vapor check valves, it is not necessary to remove the existing remote check valves. Also, the owner/operator should not be required to use the new nozzles with vapor check valves until such time that the existing nozzles are no longer functional and need to be replaced.
RESPONSE:
Subparagraph (c)(2)(E) requires that all balance nozzles shall be equipped with the internal vapor check valve by January 1, 1997. The purpose of this future implementation date is to allow the owner/operator of existing facilities to use the new nozzles with vapor check valves until such time that the existing nozzles (without vapor check valves) are no longer functional and need to be replaced.
In addition, subparagraph (c)(2)(E) has been revised to specify that the removal of remote vapor check valves are not required. However, remote vapor check valves should be removed as they become defective. It is also important to note that CARB is currently in the process of decertifying certain nozzles with remote vapor check valves. This decertification process will require the removal of all remote vapor check valves. Once the CARB Executive Order for such decertification is issued, the facility owner/operator will be required to remove all remote vapor check valves.
14. COMMENT:
The owner/operator of gasoline transfer and dispensing facilities should not be required to use the coaxial-hose system until the existing dual-hose system is no longer functional and needs to be replaced.
RESPONSE:
Subparagraph (c)(2)(F) includes a future implementation date of January 1, 1998 to allow the owner/operator of existing facilities to use the coaxial-hose system until such time that the existing dual-hose system is no longer functional and needs to be replaced.
15. COMMENT:
The requirement of 24-hour notification before backfilling the underground storage tanks and associated piping specified in subparagraph (c)(3)(K) should be deleted. Currently, local Fire Departments inspect all underground storage tanks and piping installations. Also, if the District is not notified prior to the backfilling of underground installations, will the facility owner/operator be required to break the concrete for re-inspection after the construction is completed?
RESPONSE:
The pre-backfilling requirement is a critical procedure to ensure that Phase I and Phase II vapor recovery systems are properly installed. Improper installation of vapor recovery systems can result in total loss of emission control and significant repair costs to the owner/operator. As a result, the District should be notified prior to the backfilling so that the District inspector will have an opportunity to check the installation of underground storage tanks and associated piping. It is expected that a certain percentage of the construction sites will be inspected. Once the District is notified, the facility owner/operator can proceed with the backfilling at the specified time even if the District inspector is not present.
There are approximately 100 local Fire Departments in the four-county District jurisdiction area. It is not a uniform practice for all Fire Departments to verify that all underground equipment is properly installed and sloped in accordance with applicable CARB Executive Orders. The District has communicated with some of the local Fire Departments to ensure there is no duplication of effort in underground equipment inspections.
With respect to the failure of notification, the facility owner/operator will not be automatically required to break the concrete simply just for the re-inspection of underground installation. However, if the results from required tests show failure of the vapor recovery systems, the facility owner/operator will have to perform the necessary repair, including breaking concrete and digging up the underground piping, if necessary.
16. COMMENT:
Federal law requires that all underground storage tanks be upgraded by December 2, 1998. As a result, the deadline of January 1, 1998 to conduct the initial reverification tests specified in subparagraph (c)(4)(B) should be postponed to January 1, 1999.
RESPONSE:
Reverification testing at the existing facilities is critical in verifying the integrity and effectiveness of a Phase II vapor recovery system. Any defect on a Phase II vapor recovery system will result in a considerable impact on the required control efficiency. A facility that operates a defective Phase II vapor recovery system for a long period of time without being detected by testing will cause a significant amount of VOC emissions. As a result, the District does not agree with this suggestion to further postpone the deadline for testing.
Furthermore, subparagraph (c)(4)(B) has been revised to clarify that the deadline of January 1, 1998 to conduct the initial reverification tests only applies to any of the required reverification testing which has not been conducted since January 1, 1993.
17. COMMENT:
Are the performance tests and reverification tests specified in paragraph (c)(4) required to be conducted by independent testing firms?
RESPONSE:
District Rule 304 specifies that all required testing shall be performed by an independent testing laboratory. This rule further states that an independent testing laboratory shall meet all criteria listed in Rule 304 (k).
18. COMMENT:
The biennial leak-decay testing requirement for Phase II balance systems is too excessive and will result in a substantial financial burden. Balance systems typically operate at a very low pressure. With the requirement of a self-compliance program, leaks will be detected and repaired in a timely fashion. Therefore, leak-decay tests should only be conducted every five years.
In addition, bootless nozzles have recently been incorporated into Phase II vapor recovery systems. The limited source test data does not support the need of annual tests for air-to-liquid (A/L) ratio. Furthermore, annual A/L testing for each bootless nozzle will result in a significant financial burden on the facility owner/operator.
RESPONSE:
Based on our discussion with CARB and other air quality agencies as well as further review on test data and cost issue, staff has revised subparagraph (c)(4)(B) to change the frequency of balance system leak-decay test and bootless nozzle A/L ratio test to five years. However, for the purpose of rule enforceability, staff has also revised subparagraph (c)(7)(B) to require that all records of testing be maintained for a period of five years.
It is important to note that CAPCOA Vapor Recovery Committee is working with CARB to develop standardized specifications (including test requirements) for Phase I and Phase II vapor recovery systems. CARB and Bay Area AQMD are currently conducting extensive testing on bootless nozzles. Based on the test results, a more frequent testing requirement may be imposed on bootless nozzles. Should a CARB Executive Order for a bootless nozzle be issued with a more stringent testing requirement, the facility owner/operator will required to conduct more frequent testing.
19. COMMENT:
Paragraph (c)(5) requires a self-compliance program consisting of daily maintenance inspection and periodic compliance inspections. In order to provide the own/operator of retail facilities with necessary guidelines, the protocols for daily maintenance inspection and periodic compliance inspection should be included in this rule. Also, what is the minimum frequency for the periodic compliance inspection?
RESPONSE:
Paragraph (c)(5) has been revised to reference the necessary protocols. The protocols for daily maintenance inspection and periodic compliance inspection are included in Attachment C and D respectively. This paragraph has also been revised to require, at a minimum, annual periodic compliance inspections. However, more frequent compliance inspections are strongly recommended.
20. COMMENTS:
For any facility owners/operators who develop their own self-compliance program, when shall such a program be submitted to the District for approval?
RESPONSE:
Subparagraph (c)(5)(D) has been added to specify the schedule for the submittal of any self-compliance program developed by the facility owner/operator.
21. COMMENT:
The proposed amendments will eliminate the exemption for all tanks with greater than 550-gallon capacity used to fuel implements of husbandry. This proposal will result in significant cost impacts on farmers and therefore should be removed.
RESPONSE:
Staff reviewed the cost-effectiveness and enforceability issues associated with the tanks fueling implements of husbandry and determined that the proposed amendment will result in a significant cost impact to the affected farmers. In addition, since permits cannot be required pursuant to state law, enforceability would be difficult. As a result, sub-division (e) has been revised to not include this proposed amendment.
7/26/95
(i:\lbrules\461\rulepack\appc.doc)
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
ADDENDUM TO STAFF REPORT
DRAFT
SOCIOECONOMIC IMPACT ASSESSMENT
PROPOSED AMENDED RULE 461
JULY 1995
Prepared by: Shah Dabirian
Air Quality Specialist
Reviewed by: Sue Lieu
Program Supervisor
Cindy Greenwald
Planning Manager
Jack Broadbent
Director of Planning
EXECUTIVE SUMMARY
Socioeconomic Impacts
The potential impacts of proposed amendments to Rule 461 are summarized as follows:
o Proposed amendments to Rule 461 will incorporate new procedures and technologies to enhance the effectiveness of the Phase I and Phase II vapor recovery systems used in gasoline transfer and dispensing facilities. The proposed amendments will directly affect gasoline transfer and dispensing facilities in the SCAQMD. These facilities mainly belong to gasoline service stations (SIC 554), public utilities, including electric, gas, and sanitary services (SIC 49), communication services (SIC 48), amusement and recreation (SIC 79), and passenger transit (SIC 41).
o The total annual cost of implementing the proposed amendments is estimated at approximately $1.92 million in 1995 dollars. Gasoline service stations (SIC 554) will incur about $1.77 million. Public utilities (SIC 49) will incur about $0.1 million. Each of the sectors of communication services (SIC 48), amusement and recreation (SIC 79), and passenger transit (SIC 41) will incur about $0.016 million.
o On an average annual basis between 1997-2010, the proposed amendments will result in approximately 63 jobs forgone in the four-county area. The retail sector (SIC 52-57, 59) will incur the largest employment impact with 20 jobs forgone annually. An average of 5 additional jobs will be created in fabricated metals (SIC 34) annually.
o The projected impacts of the proposed amendments on the prices of products produced by regional industries is minimal. The proposed amendments could result in increased selling prices in retail trade (SIC 52-57, 59), public utility (SIC 49) and passenger transit (SIC 41) by 0.0042 percent, 0.0009 percent and 0.0018 percent, respectively in the year 2000 and 0.0033 percent, 0.0008 percent and 0.0090 percent, respectively in the year 2010. The proposed amendments are not expected to affect the profit of national industries.
o The proposed amendments will result in a VOC emissions reduction of 1256 tons per year. The overall cost-effectiveness of the proposed amendments is about $1,531 per ton.
Socioeconomic Analysis of
Proposed Amended Rule 461
Proposed amendments to Rule 461 will incorporate new procedures and technologies to enhance the effectiveness of the Phase I and Phase II vapor recovery systems used at gasoline transfer and dispensing facilities. The major amendments are: (1) addition of phase I and phase II requirements for mobile fuelers, (2) phase II efficiency improvements, including replacing of dual hoses with coaxial hoses, (3) installation of pressure vacuum valves on vent pipes, and (4) testing requirements. These major amendments will become effective on January 1, 1998 except for the requirement of pressure vacuum valves on vent pipes, which will become effective on January 1, 1997.
On October 14, 1994, the Governing Board adopted a resolution that requires staff to address whether proposed rules being considered for adoption are in ranking order by cost-effectiveness as defined in the 1994 AQMP. One of the proposed amendments to Rule 461 requires installation of PV relief valves, which is part of the 1994 AQMP control measure RFL-02. The cost-effectiveness of this amendment is within the order of cost-effectiveness ranking of the 1994 AQMP. The remainder of the proposed amendments are not covered by the 1994 AQMP.
Affected Facilities
The proposed amended rule will directly affect gasoline transfer and dispensing facilities. These facilities mainly belong to the gasoline service station sector (SIC 554). According to the SCAQMD's permitting database, there are approximately 7,400 gasoline transfer and dispensing facilities in the district. About 62 percent of all gasoline transfer and dispensing facilities are located in Los Angeles County. The share of facilities for the other three counties is 18 percent for Orange, 11 percent for Riverside, and 9 percent for San Bernardino. In 1994, gasoline transfer and dispensing facilities in the district had a total gross sales of about $8.1 billion (State of California Board of Equalization, 1994).
Facilities using mobile fuelers will also be impacted by the proposed amended rule. About 100 mobile tankers exist in the south coast air district. More than half of these mobile fuelers belong to public utilities such as Southern California Edison Company, Los Angeles Department of Water and Power (LADWP), and Metropolitan Water District (MWD). The remaining mobile fuelers belong to General Telephone Company of California (GTE), Pacific Bell, Universal Studios Hollywood, Walt Disney Pictures & Television, and the Los Angeles Department of Harbors. These facilities mainly belong to the sectors of communication services (SIC 48), public utilities (SIC 49), amusement and recreation (SIC 79), and passenger transit (SIC 41).
Compliance Costs
The total annual cost of implementing the proposed amendments to Rule 461 is estimated at approximately $1.92 million in 1995 dollars. This total annual cost includes the following requirements of the proposed amendments: mobile fuelers ($146,727), Phase II efficiency improvement ($205,510), PV relief valves ($185,258) and testing requirements ($1,384,999). Gasoline service stations (SIC 554) will incur about 92 percent or $1.77 million of the proposed amended rule's total cost.
Public utilities (SIC 49) will incur about 5 percent of the $1.92 million cost or $0.1 million and each of the sectors of communication services (SIC 48), amusement and recreation (SIC 79), and passenger transit (SIC 41) will incur about 1 percent of the total annual cost or $0.016 million. Appendix B has a detailed description of the methodology used to develop the cost estimates.
The REMI Model
The potential job impacts of the proposed amendments to Rule 461 were projected through the use of the Regional Economic Models, Inc. (REMI) model. A detailed description of methodologies used to develop the employment impact estimates can be found in Appendix B.
The REMI model is an economic and demographic forecasting and simulation model designed to examine the economic and demographic effects resulting from policy initiatives or external events in a local economy. The REMI model used in this analysis contains historical economic data of the four-county area throughout 1992. Appendix A has a detailed description of the REMI model.
Employment Impacts
The proposed amendments to Rule 461 are expected to result in about 63 jobs forgone annually, on average, between 1997 and 2010. Table 1 shows the estimated job impacts of the proposed amendments by industry for the years 2000, 2005, and 2010 and the average annual job impacts between 1997 and 2010.
The retail trade sector (SIC 52-57, 59) to which the bulk of affected facilities belong could experience about 20 jobs forgone annually. Projected jobs forgone in this sector are due mainly to the increased cost of doing business for the gasoline service station sector (SIC 554). The fabricated metals sector (SIC 34) could experience an additional 5 jobs created annually, on average. This expansionary job impact could be due to increased spending on the Phase I and Phase II vapor recovery control equipment made to this sector.
Table 1
Employment Impact of Proposed Amendments to Rule 461 by Industry by Year
SIC Industry Title 2000 2005 2010 Average
Annual
(1997-2010)
07-09 Agriculture, Forestry and 0 -1 -1 -1
Fishery Service
10-14 Mining 0 0 0 0
15-17 Construction -4 -4 -4 -4
20 Food and Kindred 0 0 0 0
21 Tobacco Manufacture 0 0 0 0
22 Textile 0 0 0 0
23 Apparel 0 0 0 0
24 Lumber and Wood 0 0 0 0
25 Furniture and Fixtures 0 0 0 0
26 Paper and Allied 0 0 0 0
27 Printing and Publishing -1 -1 -1 -1
28 Chemicals and Allied 0 0 0 0
29 Petroleum and Coal 0 0 0 0
30 Rubber and Misc. Plastic 0 0 0 0
31 Leather 0 0 0 0
32 Stone, Clay, and Glass 0 0 0 0
33 Primary Metal 0 0 0 0
34 Fabricated Metals 4 4 3 5
35 Industrial Machinery and 0 0 0 0
Equipment
36 Electronic and Electric 0 0 0 0
371 Motor Vehicle and Equipment 0 0 0 0
372-379 Rest of Transportation 0 0 0 0
Equipment
38 Instruments 0 0 0 0
39 Misc. Manufacturing 0 0 0 0
40 Railroad 0 0 0 0
41 Passenger Transit 0 0 0 0
42 Trucking and Warehousing 0 -1 -1 0
43-4,46-7 Other Transportation 0 0 0 0
45 Transportation by Air 0 0 0 0
48 Communication 0 0 0 0
49 Electric, Gas, and Sanitary 0 0 -1 0
50,51 Wholesale Trade -2 -3 -3 -2
52-7,59 Retail Trade -17 -24 -26 -20
58 Eating and Drinking -3 -4 -5 -4
60 Depository Institutions -1 -2 -2 -2
Table 1 (Cont.)
SIC Industry Title 2000 2005 2010 Average
Annual
(1997-2010)
63-4 Insurance -1 -2 -2 -2
61-2,67 Credit and Finance -1 -1 -1 -1
65 Real Estate -3 -3 -3 -3
70 Hotels and Other Lodging 0 -1 -1 -1
72,76 Personal and Repair Services -1 -2 -2 -1
73 Misc. Business Services -3 -5 -6 -4
75 Auto Repair, Service, and -1 -1 -1 -1
Parking
78 Motion Pictures 0 0 0 0
79 Amusement and Recreation -1 -1 -1 -1
80 Health services -6 -7 -8 -6
81,86,89 Misc. Prof. Service -3 -4 -4 -3
82 Educational Service -1 -1 -1 -1
83-84,86 Non-Profit service -2 -3 -3 -3
88 Private Household -1 -1 -1 -1
91-7 Government -3 -8 -10 -6
TOTAL -55 -78 -87 -63
Competitiveness of Affected Industries
Affected industries can either pass on the additional cost of doing business to consumers or absorb this cost. The projected impacts of the proposed amendments on the selling prices of regional industries and profits of national industries is minimal. Regional industries, such as retail trade (SIC 52-7,59), passenger transit (SIC 41), public utilities, including electric, gas, and sanitary services (SIC 49) are most likely to pass cost increases on to consumers. Product prices could increase by an estimated 0.0042 percent for retail trade, 0.0018 percent for passenger transit, and 0.0009 percent for public utilities in the year 2000. Product prices could increase by approximately 0.0033 percent, 0.0008 percent and 0.0090 percent in 2010, respectively for those three industries, to cover the costs of the proposed amendments. The proposed amendments could result in an estimated reduction in real estate (SIC 65) selling prices by 0.0004 percent in the year 2010. The proposed amendments would most likely have no impact on the profits of national industries whose vast sales territories are outside of the SCAQMD.
Table 2
Impacts on Selling Prices of Regional Industries
(percent of sales)
for the Proposed Amendments
Industry (SIC) 2000 2010
Retail Trade (52-7,59) .0042 .0033
Public Utilities (49) .0009 .0008
Passenger Transit (41) .0018 .0090
Real Estate (65) .0000 -.0004
Job Impacts by Ethnic Group
Using the 1990 Census of Population's distribution of jobs among ethnic group in the four-county area, Whites would experience the largest reduction in the number of jobs forgone resulting from the proposed amendments. Whites would have a 58 percent share of the reduction in job impacts, followed by Asians (24 percent), African Americans (10 percent), Latinos (7 percent), and others (1 percent).
Job Impacts by Industry, Occupation, and Income Groups
The analysis of job impacts of the proposed amendments were further disaggregated by dividing the four-county area's industries and occupations into 5 groups according to annual wages of industries and weekly earnings of occupations, respectively.
The proposed amendments could result in few changes in job growth, i.e., a reduction ranging from 0.0001 to 0.0012 percent of the baseline jobs in all industry groups. Table A-1 in Appendix A has a detailed list of industries in each group.
Table 3
Employment Impact of Proposed Amendments
by Industry Group
Group Average Annual % Job Impact SIC Codes
Wage from Baseline
(Year)
2000 2010
1 < $17,355 -.0009 -.0012 07-09,21,41,58,65,72,
75,76,82,83,84,86,88
2 $17,692 - $22,393 -.0006 -.0006 23,24,25,31,33,39,42,
52-57,59,70,73
3 $22,982 - $30,278 -.0007 -.0008 15-17,20,22,27,30,32,
34,371,44,46,47,79
4 $30,405 - $37,467 -.0001 -.0002 10,12-14,26,35,36,45,
50,51,60,63,64,80,81,87,89
5 $38,668 - 54,954 -.0004 -.0005 28,29,372,379,38,40,
48,49,61,62,67,78
Source: Bureau of Economic Analysis, 1992.
Occupational impacts are also expected to vary between years and occupations. All occupational groups are expected to face reduced job growth in 2000 and 2010, as shown in Table 4. Occupations in Group 1 include farm workers, private household workers, textile workers, and retail salespersons. Table A-2 in Appendix A shows the classification of 94 occupations to different occupational groups.
Table 4
Employment Impact of Proposed Amendments
by Occupational Group
Median % Job Impact No. of
Group Weekly Earnings from Baseline Occupations
(Year)
2000 2010
1 $179 - $298 -.0009 -.0012 19
2 $306 - $382 -.0005 -.0007 19
3 $384 - $494 -.0006 -.0008 19
4 $496 - $612 -.0005 -.0007 19
5 $618 - $1085 -.0005 -.0006 18
Source: Current Population Survey, 1992.
The proposed amendments will have minor impacts on the price index of consumer goods. In the year 2000, the average price of consumer goods is projected to increase by 0.0006 percent for all income groups. That increase is expected to fall to 0.0004 percent for income group one and 0.0005 percent for other groups in the year 2010. Table 5 shows the impacts on price indices for households with different income levels. The increase in price indices will have a potential to decrease the purchasing power of consumers.
Table 5
Impact of Proposed Amendments on the Price
Index of Consumption by Income Group
Annual % Change in
Group Income Price Index
of Consumption
2000 2010
1 less than $5,000 0.0006 0.0004
2 $5,000 - $9,999 0.0006 0.0005
3 $10,000 - $14,999 0.0006 0.0005
4 $15,000 - $19,999 0.0006 0.0005
5 $20,000 - $29,999 0.0006 0.0005
6 $30,000 - $39,999 0.0006 0.0005
7 $40,000 - $49,999 0.0006 0.0005
8 $50,000 and over 0.0006 0.0005
Source: Consumer Expenditure Survey, 1992.
Comparative Socioeconomic Impacts
To add perspective to the potential socioeconomic impacts, proposed amendments were examined relative to other VOC rules affecting the four-county area. These comparisons made for the total cost, cost-effectiveness, employment impacts, and emission reduction potentials appear in Table 6.
The proposed amendments to Rule 461 are within the range of total annual cost, cost-effectiveness and job impacts of the other projects. In addition, the potential costs and job impacts of the proposed amendments are relatively minor when compared with other projects and when viewed in the context of the macroeconomy of the four-county area. It must be noted that the employment impacts that could result from the proposed amendments and previously adopted rules may not be direct job losses, but instead, may reflect a slower rate of future job growth.
Table 6
Comparison of Total Cost, Cost-Effectiveness and Employment Impacts
Projects Total Annual Cost Cost-Effectiveness Change in VOC Reduction
( in 1995 $) (1995 $ / ton) Jobs (Tons/Day)
Rule 1142 $35.2 $10,700 -304 8.1
Rule 461 $1.92 $1,531 -63 3.4
Rule 1153 $1.5 $1,865-$2,413 N/Aa 3.4
Rule 1122 $1.4 $285-$1,140 -40 8-16
Rule 1151 -$6.4 -$1,206 537 1.2
aJob impacts were not quantified at the time of rule adoption.
The REMI Model
At the March 17, 1989 Air Quality Management Plan (AQMP) adoption hearing, the SCAQMD's Governing Board adopted a resolution calling for the incorporation of an analysis of impacted industries, range of control costs, cost-effectiveness, and public health benefits into the evaluation of economic impacts of all proposed rules. Since then, the SCAQMD has provided an analysis of socioeconomic impacts for each proposed rule.
In an effort to expand socioeconomic impact assessments for proposed rules and AQMP revisions, the SCAQMD has purchased a computerized economic model from Regional Economic Models, Inc. (REMI) for the counties of Los Angeles, Orange, Riverside, and San Bernardino. The structure and assumptions of the model are briefly described below.
The REMI model links the economic activities in the counties of Los Angeles, Orange, Riverside, and San Bernardino. The model is comprised of a standard module, a demographic/migration module, and an input-output module. The standard module has 53 industries (2-digit SIC) or 214 industries (3-digit SIC), 94 occupations, and 25 final demand sectors. The demographic/migration module captures population changes due to births, deaths, and migration; and has 202 age/sex cohorts. The input-output module contains detailed inter-industry relationships for 466 sectors. The input-output module is used to assess the detailed inter-industry effects of a policy change. The effects are then fed into the standard module to allow for the assessment of total effects.
The standard module can be divided into the following five components: (1) production (output); (2) labor and capital demand; (3) population and labor supply; (4) wages, and prices, and profits; and (5) market share. These five components are interrelated and the linkages are depicted in Figure A-1.
Each component is built upon a two-step process. First, producers and consumers throughout all regions of the country have similar behavioral characteristics. Because of these similarities, statistical techniques can be used to estimate economic responses based on studies done throughout the United States. The second step of the modeling process is region specific, and involves calibration of the model based on region-specific historical data.
The REMI model has been built based on well-established economic theory and is updated regularly to incorporate new findings in economic theory and new historical data. Major assumptions behind the REMI model fall into the following three categories: overall, production, and population and labor. The major assumptions behind the REMI model are as follows:
FIGURE A-1
Components of REMI Model
1. Production costs, such as capital equipment, labor and fuel, are allowed to be substituted based on the changes in relative costs of these inputs to those in the United States. Total production costs are the sum of input costs weighted by their usage.
2. Location of a firm is driven by profitability.
3. All industries sell to both local and national markets. The model calculates the proportions of local demand that an industry can satisfy and its export share. Exports are divided into shipments from one county to the remaining counties (e.g., counties of Los Angeles, Orange, Riverside, and San Bernardino) and sales outside of the four-county region.
4. For pricing purposes, industries are classified as national or regional. Goods sold in national markets must be priced at the average national price to be competitive. National industries, on average, supply more than 50 percent of their output to national markets. Regional industries sell more than 50 percent of their output locally. The national industries in the model are hotels and manufacturing sectors with the exception of stone, clay, and glass; printing and publishing; and petroleum and coal products. The regional industries consist of mining, construction, finance, wholesale and retail trade, services (except hotels), and agriculture.
5. The REMI model consists of exogenous and endogenous economic variables. Values of exogenous variables are determined outside of the model. Exogenous variables are a driving force of change in the regional economy. The resulting changes are reflected in the values of endogenous variables calculated by the model. Therefore, policy changes can be simulated by changing exogenous variables whose values are developed by SCAQMD staff as inputs to the REMI model. For example, increases in demand for control equipment due to a rule can be simulated by increasing the sales of the supplier of control equipment. The impact of such a policy change includes changes in employment, among others.
6. There will be two avenues for market expansion. First, as the cost of production decreases, firms become more competitive in the export market and more competitive with imports. Second, markets are assumed to expand as a region's economy grows.
1. Production costs affect regional competitiveness which impacts the shares of local and export markets. As the relative production costs increase, there will be a reduction in the proportion of local demand which can be satisfied locally as imported goods are substituted for local goods.
2. Production levels drive labor demand which interacts with labor supply to determine wage rates. Combined with other production costs, e.g., capital and fuel costs, wages determine relative production costs in the four-county region compared to the rest of the United States.
3. Production levels are determined by the total demand which consists of consumption, investment, government spending, and net exports. Employment is determined by the level of production and labor intensity, i.e., number of employees per unit of production.
4. An increase in demand will increase production by a factor greater than one because of indirect impacts.
1. There are four types of migrants: international migrants, retired migrants, former military personnel, and economic migrants. These economic migrants are individuals moving to the region for employment opportunities. They respond to both economic and amenity factors.
2. The demographic section of the model predicts the number of births and deaths that occur in the population.
3. Labor supply is derived from the indigenous labor force and potential job migrants.
4. Labor is segmented by occupation as well as by industry. Employment within an industry is translated to occupation level employment through the use of occupational skill requirements by industry.
The SCAQMD's version of the REMI model was independently evaluated by the University of Pittsburgh in 1989 to determine its forecasting and simulation capabilities. The model's performance was judged to meet accepted standards of practice (Cassing and Giarratani, 1992).
The SCAQMD's socioeconomic assessment is an evolving process. The assessment has expanded from impacts on directly-affected industries to include employment impacts on all industries. In 1992, enhancements were made to the REMI model to allow the assessment of impacts on different income groups and on low- versus high-wage groups.
The ES-202 data (excluding self-employment) from the BLS for the four-county area provide the average annual wage per worker (full-time and part-time) for the 49 private non-farm industries at the 2-digit SIC level in the REMI model. By ranking the 49 industries in ascending order of the average annual wage per worker, they have been divided into five equal groups, as shown in Table A-1:
Table A-1
Breakdown of Industrial Wages
Average Annual
Industry Wage Group
PER $10,899 1 SERV/REPR(72,76 ) RESTRETAIL(52-5 $16,611 1 7,59) AGRI/F/F $11,982 1 SERV(07-09) EATING/DRINKING $11,155 1 (58) AUTO $17,355 1 REP/SERV(75) REAL $ 8,834 1 ESTATE(65) TOBACCO $365 1 MANUF(21) PRIV. $ 9,388 1 HOUSEHOLD(88) MISC. BUSI. $17,056 1 SERV(73) APPAREL(23) $15,838 1 TRUCKING(42) $20,419 2 LOCAL/INTERURBA $18,153 2 N(41) LEATHER(31) $17,692 2 EDUCATION(82) $18,158 2 HOTELS(70) $17,842 2 LUMBER(24) $22,393 2 NON-PROFIT(83,8 $18,915 2 4,86) FURNITURE(25) $20,577 2 MISC. $19,642 2 MANUF.(39)
Table A-1
(Continued)
Average Annual
Industry Wage Group
FURNITURE(25) $20,577 2 CONSTRUCTION(15 $20,421 2 -17) MINING(10,12-14 $30,278 3 ) PRIMARY $30,170 3 METALS(33) FOOD(20) $28,104 3 OTHER $27,807 3 TRSP(44,46,47) STONE,CLAY,ETC. $23,906 3 (32) FABRICATED $27,707 3 METAL(34) PRINTING(27) $27,752 3 AMUSE&RECREATIO $22,991 3 N(79) RUBBER(30) $25,292 3 TEXTILES(22) $22,982 3 BANKING(60) $31,917 4 AIR $36,546 4 TRANSP.(45) INSURANCE(63,64 $30,600 4 ) PAPER(26) $34,344 4 CREDIT&FIN(61,6 $32,239 4 2,67) MISC $32,746 4 PROF(81,87,89) ELECT. $37,467 4 EQUIPMENT(36) MOTOR $30,405 4 VEH.(371) WHOLESALE(50,51 $31,842 4 ) MEDICAL(80) $31,794 4 RAILROAD(40) $47,639 5 NON-ELEC $40,891 5 MACHINE(35) REST TRANS $42,986 5 EQUI(R37) CHEMICALS(28) $39,121 5 MOTION $42,548 5 PICTURES(78) PETRO PROD(29) $54,954 5 COMMUNICATION(4 $38,668 5 8) PUBLIC $42,782 5 UTILITIES(49) INSTRUMENTS(38) $43,091 5
The percentage change in employment, wage bill, and wage rate resulting from a policy can thus be reported for each quintile of industrial wages.
Using the nationwide medium weekly earnings of full-time workers from the 1992 Current Population Survey (CPS), 94 occupations in the REMI model were ranked in ascending order of earnings and divided into five equal groups. Table A-2 shows how the 94 civilian occupation were divided. In doing so, the percentage changes of a policy on each quintile of earnings can thus be reported for occupational wage rate, employment, and wage bill.
Table A-2
Breakdown of Occupational Earnings
Median Weekly
Occupation Earnings Group
FARM OCCUPATIONS $237 1 TEXTILE & REL $236 1 OPER PERSONAL SERVICE $265 1 OCC PRECISION $298 1 TEXT,APPAR HEALTH SERVICE $277 1 OCC NON-FARM $276 1 GARDENERS FOOD PREP & SRV $236 1 OCC FISHERS,HUNTER&TRA $296 1 P CLEANING $283 1 OCCUPATIONS OTHER SERVICE, $283 1 NEC OTHER SALES $269 1 WKRS,NEC CASHIERS $219 1 STOCK CLERKS, $252 1 SALES FORESTRY & LOG $296 1 OCC RETAIL $270 1 SALESPERSONS PRIVATE HOUSEHOLD $179 1 WK NON-FARM ANIMAL $280 1 CARE OTHER AGRI REL, $263 1 NEC COUNTER & RENT $252 1 CLERK OTHER CLERICAL, $362 2 NEC FARM OPERAT & $382 2 MNGRS PRECISION FOOD $308 2 WRKRS COMB MACH TOOL $330 2 OPER FIN RECORD PROC $368 2 OCC PRECISION PRINT $343 2 WKRS INFORMATION $319 2 CLERKS NUM CTRL MACH $330 2 TOOL MAIL CLERKS & $306 2 MESSAN METAL FABR MACH $330 2 OPER HAND $308 2 HELPERS,LABORER WOODWORKING MACH $306 2 OP OTHER PRECISION, $343 2 NEC MACH TOOL CUT & $330 2 FORM
Table A-2
(Continued)
Median Weekly
Occupation Earnings Group
NON-FIN REC PROC $355 2 OCC OTHER MACH OPER, $367 2 NEC HAND WORKERS $369 2 PRECISION $343 2 ASSEMBLERS SECR,STENOG,&TYPIS $370 2 TS METAL & PLASTIC $413 3 MACH VEH & MOB EQUIP $448 3 MECH REC, SCHED, DISP $384 3 OCC TRAVEL AGENTS $403 3 PRINT, BIND&REL $418 3 WKRS MOTOR VEHICLE $416 3 OPER COMM EQUIP $394 3 OPERATORS MATERIAL MOVING $432 3 OPER SOC, REC & REL $479 3 WRKRS SUPS, $412 3 FARM,FOR,AGRI OTHER MECH,INST, $485 3 NEC OTHER TRANS $427 3 OPER,NEC COMP & REL EQU $406 3 OPER HEALTH TECH & $427 3 TECHNO ADJUS, INVES, & $399 3 COLL PROTECTIVE SRVC $486 3 OCC PRECISION $385 3 WOODWORKER CONSTRUCTION $494 3 TRADES OTHER $585 4 TECHNICIANS PRECISION $496 4 INSP,TSTR PRECISION METAL $511 4 WKRS OTHER PLANT&SYS $612 4 NEC WATER & LIQUID $503 4 WASTE ELEC EQUIP $604 4 MECH,INST POSTAL CLERKS & $570 4 MAIL INSURANCE SALES $579 4 WKRS ENGIN & SCIENCE $550 4 TECH TEACHERS,LIBR,CNS $561 4 LRS REAL ESTATE $531 4 AGENTS BLUE COLLAR WKR $574 4 SUPS CHEM PLANT&SYS $612 4 OPER
Table A-2
(Continued)
Median Weekly
Occupation Earnings Group
MACH & REL $498 4 MECH,INST ELEC POWER $612 4 OPER,DIST WRITERS,ARTIST,EN $557 4 TER MANAGEMENT SUPPT $594 4 OCC COMM EQUIP $496 4 MECH,INST GAS&PETROL PLANT $612 4 OCC MANAGERIAL&ADMIN $650 5 OCC JUDGES, $1079 5 MAGISTRATES STATIONARY $618 5 ENGINEERS SOCIAL $705 5 SCIENTISTS MINING,QUARRYING $635 5 OCC PHYSICAL $731 5 SCIENTISTS SECUR&FIN SRVCS $775 5 WRKS COMP,MATH RES $799 5 ANALYS HEALTH ASSESS, $666 5 TREAT RAIL TRANSP $715 5 WORKERS LAWYERS $1085 5 WATER TRANSP $699 5 WORKERS OIL & GAS EXTRAC $635 5 OCC LIFE SCIENTISTS $663 5 HEALTH DIAGNOS $962 5 OCC OTHER PROF WKRS, $659 5 NEC OTHER EXTRACTION $635 5 NEC ARCHITECTS&SURVEY $692 5 ERS ENGINEERS $ 862 5
The annual Consumer Expenditure Survey (CEX), published by the BLS, provides a continuous flow of information on the buying habits of American households. The CEX reports average annual expenditures and characteristics of households by income group. There are eight income groups, i.e., less than $5,000; $5,000 to $9,999; $10,000 to $14,999; $15,000 to $19,999; $20,000 to $29,999; $30,000 to $39,999; $40,000 to $49,999; and $50,000 and over.
By linking consumption expenditures in the REMI model with spending patterns of eight income groups in the CEX, we can then develop a composite price change on consumer goods for each income group.
Appendix B
Assumptions of Socioeconomic Analysis
for Proposed Amended Rule 461
The socioeconomic impacts of the proposed amendments on the four-county economy were analyzed using policy variables in the REMI model. These policy variables represent direct impacts of a policy initiative and were used as inputs to the REMI model. Two types of policy variables were chosen: changes in the costs of doing business for affected industries and changes in spending on goods and services which are required to comply with the proposed amendments. A 14 - year analysis period (from 1997 to 2010) was used.
Spending on Goods and Services
The proposed amendments will result in additional spending on both Phase I and II vapor recovery systems, including spending on bellows, pumps, hoses, valves, etc. The spending includes purchase, installation, operation and maintenance of products and services required by proposed amendments. This spending is assumed to be made to the manufactures of these products i.e., fabricated metals sector (SIC 34). The spending is distributed to the fabricated metals sector (SIC 34) in each county according to each county's share of total gasoline transfer and dispensing facilities.
Cost of Doing Business
While stimulating the local economy, spending on the purchase, installation, operation and maintenance of products and services required by proposed amendments need to be financed by borrowing or using the internal capital of affected businesses which in turn increases the cost of doing business. The cost of the proposed amendments was estimated based on the February, 1994 U.S. Environmental Protection Agency (EPA) Technical Support Document for the Federal Implementation Plan (FIP).
There are four major amendments to Rule 461: (1) addition of the phase I and phase II requirements for mobile fuelers, (2) phase II efficiency improvements, including replacing of dual hoses with coaxial hoses, (3) installation of pressure vacuum valves on vent pipes, and (4) testing requirements. The total annual cost of the proposed amendments was distributed to the affected facilities in each county according to the county's share of total gasoline transfer and dispensing facilities, i.e., 62 percent for Los Angeles, 18 percent for Orange, 11 percent for Riverside, and 9 percent for San Bernardino counties. The capital cost is annualized at a 4-percent real interest rate and a 10-year equipment life. The annualized capital cost was added to the annual operating and maintenance cost to arrive at the total annual cost.
About 100 mobile tankers exist in the south coast air district. The total cost of Phase I and Phase II vapor recovery systems per mobile fueler includes Phase I capital costs of $2,900 ($800 for piping, fitting, and valves; $1,100 for in tank de-gassing; $1,000 for labor to custom retrofit these devices) and Phase II capital costs of $3,000 ($400 for hose/nozzle, $500 for pumps, $1,100 for tank de-gassing, and $1,000 for labor). The cost of CARB certification is $6,000 per mobile fueler. The total capital cost plus the certification cost for 100 mobile fuelers would be about $1,190,000. The total annual cost to these mobile fuelers is estimated to be $146,727. The cost of installing the required Phase I and Phase II vapor recovery systems was distributed among users of mobile fuelers: 67 percent to public utilities (SIC 49) and 11 percent to each of the remaining users, which include communication services (SIC 48), amusement and recreation (SIC 79) and passenger transit (SIC 41).
The phase II efficiency improvements will require the use of coaxial hoses at any gasoline dispensing nozzle. Staff estimates about 150 gasoline service stations currently use dual hose nozzles. These facilities will be required to replace their dual hose nozzles with coaxial hoses. The total capital cost of changing dual hoses to coaxial hoses is estimated to be about $328,500 for 150 gasoline stations with 6 nozzles per station. This includes 1-hour of labor (at $45/per hour) for installation, a $200 difference in the cost of hoses (a 10-ft. coaxial hose costs $230 and a 20-ft. regular hose costs $30), $60 for a new splitter, and $60 for a new retractor per dual hose. The total annual cost to the industry is estimated to be $205,510.
The proposed amendments will also require installation of pressure-vacuum (PV) relief valves on vent pipes. According to the SCAQMD's database, about 6 percent of all existing service stations (7,400) currently use PV relief valves. The remaining 94 percent of the service stations will be required to install PV relief valves. The total capital cost of installing PV relief valves is estimated to be about $1,502,496 for the whole industry. This estimate was based on a 1-hour labor (at $45/per hour) to install 3 PV valves per station at $57 for a PV valve. The total annual cost to the industry is estimated to be about $185,528.
Finally, the proposed amendments will require performance and reverification testing. Staff estimates that 6,956 gasoline service stations (94 percent) will be required to perform backpressure tests and leak decay tests on balanced systems, and air-liquid ratio tests on bootless nozzles every five years. About 444 gasoline service stations (6 percent) will be required to perform leak decay tests on vacuum-assist nozzles every year. It is assumed that for balance systems, the cost of a backpressure test is $113 and the cost of a leak decay test is $666. The cost of an air-liquid ratio test is estimated at $250. The cost of a yearly leak decay test for vacuum-assist nozzles is estimated at $666. The total annual cost of testing requirements for the industry as a whole is estimated to be about $1,384,999.
REFERENCES
California State Board of Equalization, Annual Report 1993-1994.
U.S. Environmental Protection Agency, "Technical Support Document for the FIP", 1990.
U.S. Environmental Protection Agency, "Technical Support Document for the FIP", February 1994.
California Manufacturers Association, California Manufacturers Register, 1990.
U.S. Department of Commerce, Bureau of Census, "Current Industrial Reports, Paint and Allied Products," 1990.
U.S. Department of Commerce, Bureau of Census. 1990 Census of Population and Housing. Public Use Microdata Samples, 1993.
Cassing, Shirley and Giarratani, Frank, 1990. An Evaluation of the South Coast Air Quality Management District's REMI Model, January 1990.
DFS-53 Forecasting and Simulation Model for Counties of Los Angeles, Orange, Riverside, and San Bernardino 1991. Regional Economic Models, Inc., Amherst, MA, 1993.
Model Documentation for the Counties of Los Angeles, Orange, Riverside,
and San Bernardino, Volumes 1-3, 1990. Regional Economic Models,
Inc., March 1993.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
Final Environmental Assessment for:
Proposed Amended Rule 461 - Gasoline Transfer and Dispensing
July 20, 1995
SCAQMD No. 950615TS
Deputy Executive Officer
Barry R. Wallerstein, D.Env.
Director of Planning
Jack P. Broadbent
Planning Manager
Cindy S. Greenwald, J.D.
AUTHOR: TARA SHEEHY - TECHNICAL WRITER
REVIEWED BY: DENICE BRUE - SENIOR DEPUTY DISTRICT COUNSEL
JONATHAN D. NADLER - AIR QUALITY SPECIALIST
BRIAN YEH - AIR QUALITY ANALYSIS & COMPLIANCE SUPERVISOR
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
GOVERNING BOARD
Chairman: JON D. MIKELS
San Bernardino County Representative
Vice Chairman: WILLIAM A. BURKE, Ed.D.
Speaker of the Assembly Appointee
MEMBERS:
MICHAEL D. ANTONOVICH
Los Angeles County Representative
MARVIN BRAUDE
Cities Representative, Los Angeles County, Western Region
CANDACE HAGGARD
Cities Representative, Orange County
HUGH HEWITT, Esq.
Governor's Appointee
MEE HAE LEE
Senate Rules Committee Appointee
RONALD O. LOVERIDGE
Cities Representative, Riverside County
LEONARD PAULITZ
Cities Representative, San Bernardino County
JAMES SILVA
Orange County Representative
NELL SOTO
Cities Representative, Los Angeles County, Eastern Region
S. ROY WILSON, Ed.D.
Riverside County Representative
EXECUTIVE OFFICER
JAMES M. LENTS, Ph.D.
PREFACE
This document constitutes the Final Environmental Assessment (EA) for Proposed Amended Rule 461 - Gasoline Transfer and Dispensing. The EA analyzed potential impacts to air quality, solid waste and public services as a result of the proposed amendments. No significant adverse environmental impacts were identified. The Draft EA was circulated for a 30-day public review and comment period that ended July 17, 1995. No comments were received on the Draft EA.
The Draft EA has been converted into a Final EA with only minor
modifications from the original document. It should be noted that
any typographical errors found in the Draft EA have been corrected.
Any significant deletions or additions from the Draft EA to the
Final EA are noted in strikethrough or italics,
respectively.
TABLE OF CONTENTS
CHAPTER 1 - INTRODUCTION & project description
Introduction 1-1
Legislative Authority 1-1
Background 1-1
Process Description & Amendments 1-2
Preparation of an Environmental Assessment 1-5
Emission Reductions 1-5
Conclusion 1-6
chapter 2 - Environmental assessment
Existing Setting 2-1
Potential Environmental Impacts 2-6
Impacts found not to be Significant 2-9
APPENDIX A - ENVIRONMENTAL CHECKLIST
Introduction A-1
General Information A-1
Potentially Significant Impact Areas A-1
Determination A-2
Introduction
Legislative Authority
Background
Process Description & Amendments
Preparation of an Environmental Assessment
Emission Reductions
Conclusion
INTRODUCTION
Pursuant to the California Environmental Quality Act (CEQA) (California Public Resources Code Section 21000 et seq.), this document analyzes the potential environmental impacts of the proposed amendments to Rule 461 - Gasoline Transfer and Dispensing. This Draft Environmental Assessment (EA) analyzes the potential environmental impacts to air quality, solid waste, and public services. No significant adverse environmental impacts were identified.
Rule 461 - Gasoline Transfer and Dispensing, contains two basic
methods of control. The VOC emissions resulting from filling a
storage tank can be controlled by the use of Phase I vapor recovery.
Phase I equipment utilizes a dispensing nozzle and attached
hose to capture the gasoline vapors displaced by filling the storage
tank and returns them to the tank truck cargo compartment. The
VOC emissions from fueling a motor vehicle can be controlled by
the use of Phase II vapor recovery. Phase II equipment utilizes
a dispensing nozzle and attached hose to collect the displaced
gasoline vapors from the vehicle fuel tank and return them back
to the storage tanks. The proposed amendments have been developed
to enhance the effectiveness of Phase I and Phase II vapor recovery
systems and therefore, further reduce emissions of volatile organic
compounds (VOCs) from the filling of storage tanks and fueling
of motor vehicles at gasoline transfer and dispensing facilities.
Legislative Authority
Rule Development
The California Legislature created the South Coast Air Quality Management District (SCAQMD) in 1977 as the agency responsible for developing and enforcing air pollution control rules and regulations in the South Coast Air Basin (Basin) and portions of the South East Desert Air Basin (SEDAB). The area under jurisdiction of the SCAQMD shall, for the purpose of this document, be referred to as the district. By statute, the SCAQMD is required to adopt an air quality management plan (AQMP) demonstrating compliance with all state and federal ambient air quality standards for the district.2 Furthermore, the SCAQMD must adopt rules and regulations that carry out the AQMP.3 Rule 461 - Gasoline Transfer and Dispensing, is currently being amended pursuant to those mandates.
BACKGROUND
Rule 461 - Gasoline Transfer and Dispensing, was originally adopted on January 9, 1976, and subsequently amended a number of times with the latest amendment on July 7, 1989. Rule 461 requires the use of Phase I and Phase II vapor recovery systems to control the VOC emissions from both the filling of storage tanks and fueling of motor vehicles at gasoline transfer and dispensing facilities. VOC emissions are generated during the filling of storage tanks when gasoline vapors in the storage tanks are displaced by the liquid gasoline being loaded into the tanks. The vapors are discharged to the atmosphere unless a vapor recovery equipment is employed. By the same principle, VOC emissions are generated during the fueling of motor vehicles when gasoline vapors in the vehicle fuel tanks are displaced by the dispensed gasoline and discharged to the atmosphere.
There are approximately 7,400 gasoline transfer and dispensing
facilities (4,100 retail and 3,300 non-retail) in the district.
The gasoline transfer and dispensing facilities are characterized
by numerous dispenser and vapor recovery configurations. In accordance
with the California Health and Safety Code, Section 41954, these
dispenser and vapor recovery configurations must be certified
by the California Air Resources Board (ARB). Certified systems
are then specified in the Executive Orders published by the ARB.
These Executive Orders are periodically revised to reflect technology
advancement. Currently, the ARB has issued sixty-seven
(67) seventy-five (75) Executive Orders, including
38 42 configurations for Phase I vapor
recovery systems and 29 33 configurations
for Phase II vapor recovery systems.
PROCESS description and amendments
This rule contains two basic methods to control volatile organic compound (VOC) emissions resulting from the transfer and dispensing of gasoline. The VOC emissions that result from filling a storage tank can be controlled by the use of Phase I vapor recovery. Phase I equipment utilizes a hose to capture the gasoline vapors displaced by filling the tank and return them back to the tank truck cargo compartment. The VOC emissions that result from fueling a motor vehicle can be controlled by the use of Phase II vapor recovery. Phase II equipment utilizes a dispensing nozzle and attached hose to collect the displaced gasoline vapors from the vehicle fuel tank and return them to the storage tanks.
Phase I Vapor Recovery
Phase I vapor recovery systems use a hose to return vapors from the underground storage tanks to the tank truck during filling. There are two types of Phase I systems: the dual point system and the coaxial system. It is common for dual point systems to be installed at new or modified stations, and for coaxial system to be installed in retrofit situations.
The dual point system uses one pipe to dispense the liquid into the storage tank, and a separate pipe to return the vapors to the tank truck. Many stations tie the vapor spaces of the underground tanks together, resulting in one liquid fill pipe for each tank, and a common vapor return pipe.
A coaxial system uses a single coaxial pipe with the liquid fill pipe inside the larger diameter vapor return pipe. The liquid fill tube typically extends to within a few inches from the bottom of the tank to ensure submerged filling, and the vapor pipe is connected just below the top of the tank. The coaxial system requires a separate coaxial vapor/liquid pipe for each storage tank.
Phase II Vapor Recovery
Phase II vapor recovery systems control the vapors generated during the fueling of vehicle tanks. Unlike the tight-fit connectors typical of Phase I systems, Phase II systems must work effectively with a variety of vehicle fill pipes. With the exception of the recently designed bellows-less nozzle, all Phase II nozzles have a tubular bellows, or "boot," which covers the spout and captures the displaced vapors. The captured vapors flow through a vapor passage in the nozzle into a vapor hose and then through a plumbing system to the underground storage tank.
There are two types of Phase II systems: the balance system and the assist system. The type of Phase II vapor recovery system most commonly used in California today is the balance system. Balance systems use the pressure created in the vehicle fuel tank by the incoming liquid gasoline to force the vapors through the nozzle bellows, through the vapor passage, and into the underground storage tank. Because a slight pressure is generally created at the nozzle/fill pipe interface, effective operation requires that a seal be made at the interface during vehicle fuelings to minimize vapor leakage into the atmosphere. A faceplate at the end of the bellows creates a seal when the nozzle is inserted into the fill pipe. The resistance of the bellows to compression ensures that this tight seal is maintained throughout the fueling.
Assist systems use a vacuum-generating device to draw vapors from the fill pipes of vehicle tanks. These systems can be generally categorized as vacuum-assist and aspirator-assist systems. Vacuum-assist systems, such as Hirt and Hasstech systems, use a vacuum generating device (i.e., compressor, turbine, etc.) to create a vacuum which pulls gasoline vapors from the motor vehicle tank to the storage tank. Aspirator-assist systems, such as Healy and Red Jacket systems, create a vacuum by the use of an aspirator which is activated by the flow of liquid gasoline.
Assist systems can recover vapors effectively without a tight seal at the nozzle/fillpipe interface because the vapors are not pushed into the system by the flow of gasoline into the vehicle tank. In fact, assist nozzles with bellows are specifically designed with a loose-fitting face cone rather than a faceplate to prevent a tight fit, in order to avoid creating a dangerous vacuum in the vehicle tank. Because it is not necessary to compress the bellows to ensure a tight fit with the vehicle tank, the assist nozzle is generally easier to insert than the balance nozzle bellows.
The proposed amendments to Rule 461 are designed to further enhance
the effectiveness of the Phase I and Phase II vapor recovery systems.
Enhancements will be made through the replacement or retrofit
of existing equipment or devices with new procedures and technologies.
In addition, the amendments propose a self-compliance inspection
program for the retail facilities, and the addition of performance
testing for new or modified facilities and reverification testing
for existing facilities. The current exemption for implements
of husbandry is being limited in the proposed amendments and n
New test methods are being included.
The proposed amendments specifically include the following provisions:
o Requirements for mobile fuelers: Mobile fuelers were previously exempt from the provisions of Rule 461 but are now proposed for inclusion.
o Requirements for implements of husbandry: Implements
of husbandry were previously exempt from the provisions of Rule
461 but are now proposed for limited inclusion. Please
refer to the Staff Report for Rule 461 for an explanation of why
this requirement was removed from the proposed amendment.
o Phase II requirements specifying the minimum connector diameter between the riser and dispenser: This requirement specifies that the insider diameter of the connection between the riser and dispenser shall not be less than 0.75 inches.
o Installation of insertion interlock mechanism: The insertion interlock mechanism must be ARB-certified. It is unlikely that a balance system nozzle is still in operation without an insertion interlock.
o ARB-certified coaxial Phase I system: Any Phase I system installed at a facility must be a dual point system or a Phase I coaxial system that is certified by ARB on or after January 1, 1994.
o Elimination of remote check valve: The remote check
valve must be replaced with Requirement of vapor check
valve at the nozzle: For a balance system, a vapor
check valve shall be which is located
at the nozzle rather than at a remote location.
o Addition of pressure/vacuum (PV) relief valve requirements: The PV valve installed at the storage tank vent pipe will reduce emissions from this source category and eliminate the possibility of air being inhaled into the storage tank.
o Addition of pre-backfilling requirements: The backfill requirement will apply to new facilities or modifications to existing facilities whereby the owner/operator of the facility must inspect all piping configurations and tank installation prior to backfilling.
o Addition of test methods and testing requirements: New test methods have been included in the proposed amendments along with performance testing of new or modified facilities and reverification testing for existing facilities.
o Addition of a self-compliance inspection
requirement: Retail service stations will be trained by the SCAQMD
on enhanced self compliance. The compliance inspection program
will include daily maintenance inspections and periodic compliance
inspections.
Please refer to the Draft Staff Report for Rule 461 for detailed analysis of the proposed amendments. The Draft Staff Report for Rule 461 can be obtained by contacting the SCAQMD's Public Information Center at (909) 396-3600.
Many of the aforementioned provisions require the replacement
or retrofit of existing equipment with new procedures or technologies
as well as an enhanced self-compliance inspection
program for retail service stations. The future implementation
dates of January 1, 1997, and January 1, 1998, have been given
for the replacement or retrofit so that the equipment will most
likely have depleted its operating capacity and will need replacing.
The provision regarding the installation of the PV valve and spill
box are components of Control Measure RFL-02 of the 1994 Air Quality
Management Plan (AQMP).
Preparation of aN ENVIRONMENTAL ASSESSMENT
Environmental Assessment
The proposed amendments to Rule 461 - Gasoline Transfer and Dispensing, are a "project" as defined by CEQA. SCAQMD is the lead agency for the project and has prepared the appropriate environmental analysis pursuant to its certified regulatory program (California Public Resources Code Section 21080.5). California Public Resources Code Section 21080.5 allows public agencies with regulatory programs to prepare a plan or other written document in lieu of an environmental impact report once the Secretary of the Resources Agency has certified the regulatory program. SCAQMD's regulatory program, Rule 110, was certified by the Secretary of the Resources Agency on March 1, 1989. Pursuant to Rule 110, SCAQMD has prepared this Draft Environmental Assessment (EA) which identifies no significant environmental impacts.
CEQA requires that the potential environmental impacts of proposed projects be evaluated and that feasible methods to reduce or avoid adverse environmental impacts of these projects be identified. To fulfill the purpose and intent of CEQA, the SCAQMD has prepared this Draft EA to address the potential environmental impacts associated with the proposed amendments to Rule 461. All comments received during the public comment period on the analysis presented in the Draft EA will be responded to and included in the Final EA. Prior to making a decision on the proposed amendments, the SCAQMD Governing Board must review and certify the EA as providing adequate information on the potential adverse environmental impacts of the amended rule.
emission reductions
Emission reductions from the proposed amendments will be achieved from the following areas:
o Installation of pressure/vacuum relief valve;
o Improvement of Phase I system efficiency by implementing coaxial system restriction, poppetted dry break requirement, and CARB certified spill box requirement;
o Elimination of remote check valve;
o Improvement of Phase II efficiency by implementing the requirements of minimum connector diameter, insertion interlock, coaxial hose, and liquid removal device performance; and
o Limited exemption for implements of husbandry; and
o Phase I and II requirements for mobile fuelers.
The emission reductions resulting from the implementation of control
measures specified on the first four areas were calculated using
the 1993 data of gasoline throughput which was obtained through
the Board of Equalization. The emission reductions resulting from
the last two areas were calculated
from the emission factors contained in the Technical Support Document
for the Federal Implementation Plan and assumed throughput for
fuel tanks for implements of husbandry and for mobile fuelers.
Implementation of the six aforementioned components would result
in VOC emission reductions of 3.43 between 3 and
3.5 tons per day. The Draft EA identified a range of
potential emission reductions as a result of the proposed amendments.
Since the Draft EA was circulated, the analysis of subject
facilities has been refined and indicates that the emission reductions
from the proposed amendments will be 3.43 tons per day which is
consistent with the range analyzed in the Draft EA. The
range of emission reductions is included as further research is
currently being conducted on several of the proposed rule's provisions.
CONCLUSION
The proposed amendments to Rule 461 - Gasoline Transfer and Dispensing, are necessary in order to further reduce VOC emissions from this source category and help attain the National Ambient Air Quality Standards. The amendments have been analyzed and have not been found to result in any adverse environmental impact. In addition, the amendments will not adversely impact SCAQMD's resources.
Existing Setting
Potential Environmental Impacts
Environmental Impacts Found Not To Be Significant
existing SETTING
The SCAQMD has jurisdiction over approximately 12,000 square miles consisting of the four-county South Coast Air Basin and the Los Angeles County and Riverside County portions of the Southeast Desert Air Basin (SEDAB). This combined area is hereafter referred to as the "district." The Basin is bounded by the Pacific Ocean to the west and the San Gabriel, San Bernardino, and San Jacinto mountains to the north and east. It includes all of Orange County and the nondesert portions of Los Angeles, Riverside, and San Bernardino counties. The Los Angeles County portion of the SEDAB (known as North county or Antelope Valley) is bounded by the San Gabriel Mountains to the south and west, the Los Angeles/Kern county border to the north, and the Los Angeles/San Bernardino county border to the east. The Riverside County portion of the SEDAB is bounded by the San Jacinto Mountains in the west and spans eastward up to the Palo Verde Valley. The federal nonattainment area (known as the Coachella-San Jacinto Planning Area) is a subregion of the Riverside County and SEDAB that is bounded by the San Jacinto Mountains to the west and the eastern boundary of the Coachella Valley to the east (Figure 2-1).
Figure 2-1
South Coast Air Quality Management District
The existing air quality setting for the district is presented below. The setting is based on 1994 air quality data. For a detailed discussion of projected future air quality in the district, with and without additional control measures, please refer to the Final 1994 AQMP, including its Appendices and the 1994 AQMP Final EIR. In addition, the 1994 Final AQMP EIR contains information on the existing setting for other environmental areas (e.g., water resources, energy, land use, etc.). Copies of the above-referenced documents are available from the SCAQMD's Public Information Center by calling (909) 396-3600.
Air Quality
Air quality in the district has shown substantial improvement over the last two decades. Nevertheless, some federal and state air quality standards are still exceeded frequently and by a wide margin. Ozone, carbon monoxide, and PM10 continue to be the area's most severe air pollution problems. The following paragraphs briefly summarize the status of the district's air quality in terms of the criteria pollutants as identified in Tables 2-1 and 2-2.
The district exceeds the federal ozone standard far more frequently than any other area in the United States. Ozone levels exceeded the federal standard by the widest margin compared to other criteria pollutants, with a maximum concentration that was 250 percent of the standard. Ozone concentrations exceeded the state standard at all monitored locations.
The CO standard was monitored at 20 locations in 1994. The federal and state 8-hour CO standards were exceeded at four locations. Source/Receptor Area No. 12, South Central Los Angeles County, reported by far the greatest number of exceedances of federal and state standards (22 and 26 days, respectively).
Concentrations of NO2 declined over the period 1976 to 1994. By 1991, exceedances of the federal standard were limited to one location in Los Angeles County, which is the only county in the United States classified as nonattainment for the federal NO2 standard. For the first time in 1992, and again in 1993 and in 1994, no district location exceeded the federal standard. 1994 was the first year that the state NO2 standard was not exceeded.
In 1994, PM10 was monitored at 19 locations. The federal annual standard was exceeded at four locations and the federal 24-hour standard was exceeded at one locations. The state annual standard was exceeded at 15 locations and the state 24-hour standard was exceeded at 18 locations.
Though SO2 concentrations have been reduced to levels well below state and federal standards, further reductions in emissions of sulfur oxides (SOx) are needed to comply with standards for other pollutants (sulfate and PM10).
Though not exceeded in 1993, the state sulfate standard was exceeded at three locations in 1994.
Lead concentrations once exceeded the state and federal standards by a wide margin, but have not exceeded state or federal standards at any regular monitoring station since 1982. Special monitoring sites immediately downwind of lead sources have recorded very localized violations of the state standard in 1994.
It should be noted that there are no state or federal ambient air quality standards for volatile organic compounds (VOCs) because they are not classified as criteria pollutants. VOCs are regulated, however, because in the presence of sunlight they undergo photochemical reactions with NO2 molecules to form photochemical oxidants, most notably ozone. They are also transformed into organic aerosols in the atmosphere, contributing to higher PM10 and lower visibility.
Solid Waste
The four-county region comprising the district has 44 landfills currently permitted to accept municipal solid waste. The total permitted capacity is almost 100,000 tons per day. Solid wastes consist of residential wastes (waste produced by households), constructions wastes, commercial and industrial wastes, home appliance and abandoned vehicles, and sludge residues (waste remaining at the end of the treatment process). There are no landfills in the Basin permitted to accept Class I - hazardous waste and only one that is permitted to accept other designated types of hazardous waste.
Public Services - SCAQMD
The SCAQMD is a regional government agency that consists of 776 full-time personnel that work in areas such as engineering, facility inspections, planning, public affairs and rule development. The SCAQMD is responsible for developing, adopting and enforcing rules and regulations applicable to facilities located in the district. Rules and regulations are approved by SCAQMD's Governing Board, which is a 12-member body comprised of elected and appointed officials. The SCAQMD Headquarters is located in Los Angeles County.
Potential ENVIRONMENTAL IMPACTS
CEQA Requirements
CEQA Guidelines require environmental documents to identify and focus on the significant adverse environmental effects that may result from a proposed project (CEQA Guidelines Section 15126(a)). If significant adverse environmental impacts are identified, CEQA requires a discussion of measures that could either avoid or reduce those impacts to the greatest extent feasible (CEQA Guidelines Section 15126(c)).
The CEQA Guidelines recognize that the degree of specificity required in a CEQA document will depend on the type of project being proposed (CEQA Guidelines Section 15146). It is recognized that the detail of the environmental analysis for certain types of projects cannot be as great as for other types of projects. CEQA also recognizes that the identification of potential environmental impacts for proposed projects requires a degree of forecasting. CEQA Guidelines, Section 15144, states "while foreseeing the unforeseeable is not possible, an agency must use its best efforts to find out and disclose all that it reasonably can."
Environmental topics in a CEQA document that are evaluated for adverse impacts from a proposed project are established by the California Environmental Quality Act, Public Resources Code, Section 21000 et seq., and the state CEQA Guidelines as promulgated by the Secretary for Resources. The CEQA Guidelines recommend an analysis of impacts from a project for a variety of environmental categories. Projects are evaluated against these environmental impact categories in an Initial Study. Those environmental categories that could be adversely affected by the proposed project, based upon a preliminary analysis in the Initial Study (Environmental Checklist), are carried forward for analysis in the draft and final environmental document.
An environmental checklist for the proposed amendments to Rule 461 can be found in Appendix A of this document. Of the potential environmental impact categories examined, only air quality, solid waste and public services were initially determined to be potentially affected by the implementation of the proposed amendments. The following sections discuss how air quality may be affected by the proposed amendments.
Significance Criteria for Air Quality
The project will be considered to have a significant impact on the environment if:
o Emissions associated with the proposed amendments are greater than the daily emission significance thresholds established by the SCAQMD in the CEQA Air Quality Handbook (SCAQMD 1993).
o Emissions associated with the proposed project violate any ambient air quality standard, contribute substantially to an existing or projected air quality violation, or expose sensitive receptors to substantial pollutant concentrations. (1994 State CEQA Guidelines)
Air Quality
PROJECT-SPECIFIC IMPACT: The proposed amendments will reduce
emissions of Volatile Organic Compounds (VOC) between
3.0 and 3.5 by 3.43 tons per day. The emission
reductions will result from the following proposed amendments:
installation of the pressure/vacuum relief valve; improvement
of the Phase I system efficiency by implementing the coaxial system
restriction, poppetted dry break requirement and ARB-certified
spill box requirement; elimination of the remote check
valve; requirement of a vapor check valve at the balance
nozzle; minimum connector diameter requirements; insertion
interlock requirements; coaxial hose requirements; liquid removal
device performance requirements; limitation of the previous
exemption for implements of husbandry; and, Phase I and
Phase II requirements for mobile fuelers. Please refer to the
Draft Staff Report for Rule 461 for a complete breakdown of emission
reductions anticipated from each source category.
There are no adverse air quality impacts expected as a result of the propose amendments. The amendments will result in an air quality benefit from the decreased amount of VOCs being emitted into the atmosphere. The amendments do not mandate any type of control equipment that would create an adverse air quality impact. There are no adverse air quality impacts expected from the proposed amendments.
PROJECT-SPECIFIC MITIGATION: None required.
Significance Criteria for Solid Waste
The project will be considered to have a significant impact on the environment if:
o It will breach published national, state, or local standards relating to solid waste or litter control;
o The generation and disposal of nonhazardous or hazardous waste as a result of the project would exceed the capacity of designated landfills.
Solid Waste
PROJECT SPECIFIC IMPACT: There are several provisions in the proposed amendments that call for the replacement of existing equipment with new, CARB-certified equipment in order to increase capture efficiency. The proposed amendments call for the replacement or addition of the following types of equipment: certified spill box; certified coaxial Phase I system; certified poppetted drybreaks; certified interlock mechanism; balance system with vapor check valve in nozzle; Phase II coaxial system; pressure-vacuum relief valves. There is the potential that replacing existing equipment with ARB-certified equipment could generate significant amounts of solid waste since the replaced parts or equipment would require disposal. The majority of the aforementioned equipment types would need to be replaced regardless of the amendments, however, a few of the proposed amendments could create additional solid waste.
The provision which mandates the installation of Phase II coaxial systems would require the replacement of approximately 900 dual hose nozzles which still exist at 150 service stations throughout the district. In addition, the requirement to install a balance system with a vapor check valve would require that existing facilities remove the remote valve and install a splitter as well. There are approximately 39,400 nozzles with remote check valves that would require disposal in the district. It is not likely that these equipment pieces will be recycled due to the cost of recycling or melting down the pieces.
All of the provisions requiring equipment replacement specify a future implementation date of 1997. The equipment currently in place would likely need replacement by that time regardless of the amendments. In the majority of cases, there would, therefore, be no additional waste generated. In the cases of the remote check valve and Phase II coaxial system replacements, however, there will be a small amount of solid waste generated due to the 900 dual hose nozzles and 39,400 remote check valve nozzles that would need replacement. These replacements are located throughout the district and would likely be replaced on a gradual basis from the time of rule adoption until 1997. The current landfill capacity in the district is approximately 100,000 tons per day and is more than sufficient to cover the slight, one-time increase of solid waste from the remote check valves and coaxial system replacements.
PROJECT-SPECIFIC MITIGATION: None required.
Significance Criteria for Public Service Impacts - SCAQMD
The impact would be significant if the following were to occur:
o The project-related impacts are beyond that allocated in the district's budget and would cause a financial shortfall.
o The training, inspections, etc., required by the project exceed SCAQMD staff resources or expertise.
Public Services - SCAQMD
PROJECT-SPECIFIC IMPACT: The proposed amendments contain a provision for a self-compliance inspection program to be implemented by facility operators or designated personnel. Training classes for this rule provision will be given by the SCAQMD but attendance is not mandatory. The classes will consist of a half day for one time only. It is estimated that approximately 1000 facilities will take advantage of the self-compliance training. Classes will have no more than 40 attendees. It is expected to take approximately 200 hours to train all interested parties. The self-compliance provision would not take effect until 1997 so the SCAQMD will, therefore, have approximately nine months to complete the training. The SCAQMD will use inspectors from its Small Business Assistance Office to train the facility owners/operators. The Office currently has over 30 inspectors who can teach the self-compliance training program.
The SCAQMD has a sufficient amount of inspectors as well as time allotted in order to teach the training courses. If additional staff is needed, more inspectors and/or engineers can be reallocated from other divisions within the SCAQMD on a temporary basis. The implementation of the training program is not expected to adversely affect the SCAQMD's ability to provide its full range of necessary services to the public.
PROJECT-SPECIFIC MITIGATION: None required.
IMPACTS FOUND NOT TO BE SIGNIFICANT
The environmental topics in the following subsections were considered in the Environmental Checklist (Appendix A) to determine if Proposed Amended Rule 461 could create significant adverse impacts in any of these areas. For all environmental topics discussed below, no significant adverse direct or indirect impacts were identified.
Land Use and Planning
The proposed amendments will have no impact on general plan designation or zoning, agricultural resources, environmental plans, or established communities. The amendments seek to add compliance requirements for the transfer and dispensing of gasoline as well as require ARB-certified replacement equipment. The amendments will have no impact on current or future land use or planning.
Population and Housing
There are no provisions in the amendments that would affect current or anticipated population or housing. The amendments apply to gasoline dispensing facilities and will have no bearing on population or housing.
Geophysical
The amendments will not adversely impact any geophysical condition in the district. The amendments relate to existing facilities and do not require any type of construction or control equipment for implementation. The amendments require the replacement of some pieces of equipment at gasoline dispensing facilities but will not require construction or excavation in order to execute the replacement. There is no potential for the creation of landslides or mudslides, changes in topography, or unstable soil conditions as a result of the amendments.
Water
The amendments to Rule 461 will not alter the operating practices of any gasoline transfer or dispensing facility in the South Coast Air Basin except to further reduce VOCs from these source categories. The amendments provide for further enhanced self-compliance and incorporate provisions for the use of ARB-certified equipment. There is nothing in the amendments that would affect water quality or consumption.
Transportation/Circulation
There will be no increase in vehicle trips, impacts on parking, or conflicts with adopted policies associated with alternative transportation as a result of the proposed amendments. The amendments will not require any additional vehicle trips as the self-compliance will be conducted by a representative at the facility. There is no potential for additional trip generation or traffic congestion.
Biological Resources
There are no natural communities or migration corridors that could be impacted by the proposed amendments. The amendments apply to existing facilities and any future gasoline dispensing facilities that would be created in the district would not be a result of the proposed amendments. There is no potential for the amendments to impact biological resources.
Energy and Mineral Resources
While the amendments pertain to the transfer and dispensing of fuel within the district, there is no potential for increased fuel usage or the depletion of any non-renewable resources as a result of the amendments. The amendments specify practices for the transferring and dispensing of fuel but do not mandate any amount of fuel usage.
Hazards
The proposal will not involve a potential risk of explosion or accidental release of a hazardous material nor would it interfere with an emergency response plan or evacuation plan. The amendments apply to gaseous fuels but do not increase the use, transport, or potential explosion of these fuels.
Noise
There are no noise impacts associated with the proposed amendments. The amendments will not increase noise above currently existing levels.
Aesthetics
The amendments will not create an aesthetic impact in any manner as they pertain to existing service stations in the district. Any future service stations created would not be as a result of the proposed amendments. There will be no obstruction of a scenic vista, nor will any light or glare be created. The amendments have no potential to impact aesthetics in the district.
Cultural Resources
There will be no land use disruption, construction, or excavation as a result of the proposed amendments. There is no possibility that cultural resources could be impacted as a result of the amendments.
Recreation
There will be no recreation impacts as a result of the proposed amendments for the reason cited above under "Cultural Resources."
Economics
State CEQA Guidelines Section 15064(f) states the following:
"Economic or social changes resulting from a project shall not be treated as significant effects on the environment. Economic or social changes may be used, however, to determine that a physical changes shall be regarded as a significant effect on the environment. Where a physical change is caused by economic or social effects of a project, the physical change may be regarded as a significant effect in the same manner as any other physical change resulting from the project."
The proposed amendments are not expected to result in any changes in economic or social conditions that could have adverse secondary impacts on the environment.
Introduction
General Information
Potentially Significant Environmental Impacts
Determination
INTRODUCTION
The environmental checklist provides a standard evaluation tool to identify a project's adverse environmental impacts. A sample checklist form is provided in the State CEQA Guidelines, Appendix I. The SCAQMD has slightly modified the Appendix I checklist, but it still addresses all areas identified in the Appendix I checklist. This checklist identifies and evaluates potential adverse environmental impacts that may be created by the proposed project.
GENERAL INFORMATION
Name of Proponent: South Coast Air Quality Management District
Address of Proponent: 21865 E. Copley Drive
Diamond Bar, CA 91765
Lead Agency: South Coast Air Quality Management District
Name of Project: Proposed Amended Rule 461
POTENTIALLY SIGNIFICANT IMPACT AREAS
The following environmental impact areas are determined to be affected by the proposed project. As indicated by the checklist on the following pages, environmental topics marked with an "X" may be adversely affected by the proposed project. An explanation relative to the determination of each of the areas checked below can be found in Chapter 2 - Environmental Assessment.
X Air Quality X Public Services X Utilities
and Service
Systems
Water Land Use and Mandatory Findings of
Planning Significance
Geophysical Biological Resources Cultural Resources
Hazards Noise Recreation
Transportation Aesthetics Energy and Mineral
Resources
DETERMINATION
On the basis of this initial evaluation:
X I find the proposed project, in accordance with those findings made pursuant to CEQA Guideline Section 15252, could NOT have a significant effect on the environment, and that an ENVIRONMENTAL ASSESSMENT will be prepared.
I find that although the proposed project could have a significant effect on the environment, there will NOT be significant effects in this case because the mitigation measures described on an attached sheet have been added to the project. An ENVIRONMENTAL ASSESSMENT will be prepared.
I find that the project MAY have a significant effect(s) on the environment, and an ENVIRONMENTAL ASSESSMENT will be prepared.
Date: Signature: Steve Smith, Ph.D.
Program Supervisor
Potentially No
Significant Impact
Impact
I. LAND USE AND PLANNING. Would the proposal:
a) Conflict with general plan designation or zoning? X
b) Conflict with applicable environmental plans or
policies adopted by agencies with jurisdiction over
the project? X
c) Affect agricultural resources or operations (e.g.
impacts to soils or farmlands, or impacts from
incompatible land uses)? X
d) Disrupt or divide the physical arrangements of an
established community (including a low-income or
minority community)? X
II. POPULATION AND HOUSING. Would the proposal:
a) Cumulatively exceed official regional or local
population projections? X
b) Induce substantial growth in an area either
directly or indirectly (e.g. through projects in
an undeveloped area or extension of major
infrastructure)? X
c) Displace existing housing, especially affordable
housing? X
III. GEOPHYSICAL. Would the proposal result in or expose people to potential impacts involving:
a) Seismicity: fault rupture, ground shaking, seiche or
tsunami? X
b) Landslides or mudslides? X
c) Erosion, changes in topography or unstable soil conditions
from excavation, grading or fill? X
d) Subsidence of land? X
Potentially No
Significant Impact
Impact
IV. WATER. Would the proposal result in:
a) Changes in adsorption rates, drainage patterns, or
the rate and amount of surface runoff? X
b) Exposure of people or property to water related
hazards such as flooding? X
c) Discharge into surface waters or other alteration
of surface water quality (e.g. temperature,
dissolved oxygen or turbidity? X
d) Changes in the amount of surface water in any water
body? X
e) Changes in currents, or the course or direction of
water movements? X
f) Change in the quantity of ground waters, either
through direction additions or withdrawals, or
through interception of an aquifer by cuts or
excavations? X
g) Altered direction or rate of flow of groundwater? X
h) Impacts to groundwater quality? X
i) A need for new water treatment, distribution, sewer
or storm water drainage systems? X
V. AIR QUALITY. Would the proposal:
a) Violate any air quality standard or contribute to an
existing or projected air quality violation? X
b) Expose sensitive receptors to pollutants? X
c) Alter air movement, moisture, or temperature, or
cause any change in climate? X
d) Create Objectionable odors? X
e) Diminish an existing air quality rule or future
compliance requirement resulting in a significant
increase in air pollutant(s). X
Potentially No
Significant Impact
Impact
VI. TRANSPORTATION/CIRCULATION. Would the proposal result in:
a) Increased vehicle trips or traffic congestion? X
b) Hazards to safety from design features (e.g. sharp
curves or dangerous intersections) or incompatible
uses (e.g. farm equipment)? X
c) Inadequate emergency access or access to nearby uses? X
d) Insufficient parking capacity on-site or off-site? X
e) Hazards or barriers for pedestrians or bicyclists? X
f) Conflicts with adopted policies supporting alternative
transportation (e.g. bus turnouts, bicycle racks)? X
g) Rail, waterborne or air traffic impacts? X
VII. BIOLOGICAL RESOURCES. Would the proposal result in impacts to:
a) Locally designated natural communities (e.g. oak
forest, coastal habitat, etc.)? X
b) Wildlife dispersal or migration corridors? X
VIII. ENERGY AND MINERAL RESOURCES. Would the proposal:
a) Conflict with adopted energy conservation plans? X
b) Use non-renewable resources in a wasteful and
inefficient manner? X
IX. HAZARDS. Would the proposal involve:
a) A risk of accidental explosion or release of
hazardous substances (including, but not limited to:
oil, pesticides, chemicals or radiation)? X
b) Possible interference with an emergency response
plan or emergency evacuation plan? X
c) The creation of any health hazards or potential
health hazard? X
Potentially No
Significant Impact
Impact
d) Exposure of people to existing sources of potential
health hazards? X
e) Increased fire hazard in areas with flammable brush,
grass, or trees? X
X. NOISE. Would the proposal result in:
a) Increases in existing noise levels? X
b) Exposure of people to severe noise levels? X
IX. PUBLIC SERVICES. Would the proposal have an effect upon, or result in a need for new or altered government services in any of the following areas?
a) Fire protection? X
b) Police protection? X
c) Schools? X
d) Maintenance of public facilities, including roads? X
e) Other governmental service? X
XII. UTILITIES AND SERVICE SYSTEMS. Would the proposal result in a need for new systems, or substantial alterations to the following utilities:
a) Power or natural gas? X
b) Communications systems? X
c) Landfills? X
XIII. AESTHETICS. Would the proposal:
a) Affect a scenic vista or scenic highway? X
b) Have a demonstrable negative aesthetic effect? X
c) Create light or glare? X
Potentially No
Significant Impact
Impact
XIV. CULTURAL RESOURCES. Would the proposal:
a) Disturb paleontological resources? X
b) Disturb archaeological resources? X
c) Have the potential to cause a physical change which
would affect unique ethnic cultural values? X
XV. RECREATION. Would the proposal:
a) Increase the demand for neighborhood or regional
parks or other recreational facilities? X
b) Affect existing recreational opportunities? X
XVI. MANDATORY FINDINGS OF SIGNIFICANCE.
a) Does the project have the potential to degrade the
quality of the environment, substantially reduce the
habitat of a fish or wildlife species, cause a fish
or wildlife population to drop below self-sustaining
levels, threaten to eliminate a plant or animal
community, reduce the number or restrict the range of
a rare or endangered plant or animal or eliminate
important examples of the major periods of California
history or prehistory? X
b) Does the project have the potential to achieve short-term,
to the disadvantage of long-term, environmental goals? X
c) Does the project have impacts that are individually
limited, but cumulatively considerable? X
("Cumulatively considerable" means that the incremental
effects of a project are considerable when viewed in
connection with the effects of past projects, the effects
of other current projects, and the effects of probable
future projects)
d) Does the project have environmental effects which will
cause substantial adverse effects on human beings,
either directly or indirectly? X