South Coast Air Quality Management District

Report on Rule 461 – Gasoline Transfer and Dispensing

SYNOPSIS: 

When Rule 461 was amended in April of 2000, the Board directed staff to evaluate the effectiveness of the reverification test schedules in improving compliance and to reassess the test schedules in conjunction with the in-station diagnostics system requirements of the statewide enhanced vapor recovery program. This report meets this directive and briefly summarizes program implementation.

COMMITTEE: 

Stationary Source, October 25, 2002, Reviewed

RECOMMENDED ACTION:

Receive and file.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

There are approximately 3700 retail gasoline dispensing facilities (GDFs) and 1,900 non-retail GDFs in AQMD’s jurisdiction, dispensing about six billion gallons of gasoline per year. Retail GDFs dispense over 95% of this throughput. GDFs in AQMD are required to be equipped with vapor recovery systems that are approved by Resources Board (CARB as capable of reducing the vapor emissions by at least 95%. Without the use of such vapor recovery systems, the hydrocarbon vapor emissions would be about 170 tons per day. As such, Rule 461 is one of the most significant AQMD control strategies for VOC emissions.

In 1999, an AQMD audit revealed that retail GDFs had numerous system leaks that were not detectable during a traditional visual inspection. Improper installation of equipment, faulty components and inadequate maintenance were the primary causes of the problems. In light of these findings, the Board took additional rule development action.

On April 21, 2000, the Board amended Rule 461- Gasoline Transfer and Dispensing, establishing new requirements to reduce excess emissions. New requirements included performance and semi-annual reverification testing for most retail gasoline dispensing facilities and improved operating and maintenance (O&M) programs. The increased testing frequency was intended to allow earlier detection and repair of system leaks, thereby allowing the systems to sustain higher control efficiencies for longer periods of time.

At the time of this amendment, the Board directed staff to complete the following:
(1) evaluate the effectiveness of the increased reverification testing frequencies in improving compliance and the appropriateness of the testing schedules in conjunction with in-station diagnostic system requirements; (2) monitor the implementation of the CARB enhanced vapor recovery (EVR) program and identify any modifications to Rule 461, which may be necessary to ensure compatibility with the EVR program; (3) work with representatives of the parties affected by amended Rule 461 to establish weekend re-testing procedures and develop a list of minor defects; and (4) identify opportunities to streamline or simplify the rule. Each of these Board directives is addressed in this report.

Impact of Increased Testing Frequencies on Compliance

Since the 2000 amendment of Rule 461, the combination of frequent testing and the implementation of an aggressive O&M program have dramatically improved compliance within this industry.

Testing results from 2001 and 2002 indicate that compliance, in terms of emissions, has been greatly improved. As a result, an estimated 15 additional tons per day of gasoline emissions are being recovered.

In the year prior to the 2000 rule amendment, less than 300 performance tests were conducted district-wide. Last year, approximately 8,000 tests were performed and passed. For most stations, this means that at least two times during the year their control systems are proven to be operating at certified efficiencies. Improved maintenance practices ensure that the systems sustain these higher control efficiencies for longer periods of time.

Physical inspections of stations are also showing improvements. The number of substantial (emission-causing) defects found by AQMD inspectors is down significantly. This year, less than 10% of the stations inspected had emissions-causing defects. By contrast, in 1998, 34% of the stations were found to have these defects. In addition, when inspectors do find emission problems at stations, they report far fewer defects per station than in the past.

Further improvements in maintenance and equipment durability are expected over the next few years, providing additional emission reductions. For the near term, the major oil companies and larger chain operators have implemented sound O&M programs and are considering increased inspection/testing options to further reduce emissions. Most of the independent station operator’s O&M programs are deficient in many areas and are therefore unable to achieve additional reductions at this time. Staff has developed special outreach materials and is committed to working with these smaller operators to establish effective O&M programs at these stations.

Impact of In-Station Diagnostics on Current Testing Schedule

CARB is in the process of implementing an EVR program for the state. This program will provide better, more reliable equipment for station operators, as well as providing in-station diagnostics (ISD). ISD will electronically monitor the operational status of the vapor recovery system and alert the station operator when a failure occurs.

EVR will further enhance the AQMD’s vapor recovery program over time and ISD will eventually reduce the need for testing. ISD is scheduled for implementation beginning in mid-2003, with full implementation in mid-2008. In October 2001, CARB began preliminary evaluation of ISD at five test sites statewide. While the initial data from this evaluation looks promising, staff anticipates that additional field evaluation will be necessary before a recommendation on testing frequencies can be made. It is recommended that staff continue to monitor CARB’s progress and report back to the Board in 2005.

Rule 461 Implementation Task Force

To accomplish the Board’s directives and ensure smooth implementation, the Executive Officer established a Rule 461 Implementation Task Force in May 2000. The Task Force is comprised of members of AQMD, Western States Petroleum Association, major oil companies, equipment manufacturers, representatives of small independent station owners and vapor recovery testing contractors. This group has addressed a variety of issues related to the implementation of Rule 461 and found ways to overcome most of the problems associated with transition to the new requirements.

Specifically, the Task Force was instrumental in the development of the following: (1) the July 2001 amendments to Rule 461 establishing procedures for weekend re-testing; (2) a list of common and minor defects, distributed to industry in 2001; (3) improved O&M programs; (4) rule summaries and other outreach materials; (5) training curriculum for testing contractors; and (6) alternative test methods following drive-offs.

Regular meetings have provided a forum to discuss the problems and successes observed in the field, as well as provided a means of staying current with EVR developments. The efforts of this Task Force have provided a better understanding of vapor recovery, compliance standards, and the components that are key to operating a compliant station in the South Coast Air Basin.

Opportunities to Streamline the Rule

All proposed changes were incorporated in the June 15, 2001 amendment of Rule 461 and no further changes are recommended at this time.

Conclusion

The testing schedule established by the April 2000 amendment of Rule 461 has significantly improved the control efficiency of Phase I and Phase II vapor recovery systems. By increasing the testing frequency to a semi-annual basis, potential leaks and defective components are being identified and repaired on a more timely basis. Consequently, the vapor recovery systems are operating within certification standards for longer periods of time, reducing excess emissions by about 15 tons per day.

Recommendation

Staff will continue to monitor the progress of ISD and evaluate the appropriateness of the current testing schedules once ISD has been implemented. A written report of the findings will be provided to the Board by July 2005.

/ / /