BOARD MEETING DATE: November 5, 2004
AGENDA NO. 19

Report on Rule 461 – Gasoline Transfer and Dispensing

SYNOPSIS:

At its April 21, 2000 meeting, the Board amended Rule 461 – Gasoline Transfer and Dispensing. At that time, staff made a commitment to conduct a technical assessment and report back to the Board before 2005. The purpose of the assessment is to determine the rule effectiveness in meeting the action level identified in Rule 1402 and if necessary the state of control technology to achieve further reductions in emissions and health risk to meet the action level.

COMMITTEE:

Stationary Source, October 22, 2004

RECOMMENDED ACTION:

Receive and file.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

At the April 2000 public hearing for the amendment of Rule 461 – Gasoline Transfer and Dispensing, staff made a commitment to perform a technical assessment by 2005 to determine the effectiveness of PAR 461, along with other regulations, in meeting the March 2000 Air Toxics Control Plan. In addition, this commitment included a) an assessment of gasoline dispensing facilities (GDFs) meeting the action level identified in Rule 1402 (25-in-one-million), and b) assessing the state of technology and the potential for further reductions in emissions and health risk achievable, if necessary, to meet the risk reduction action level. It was anticipated that the implementation of CARB’s enhanced vapor recovery (EVR) requirements would be completed no later than 2007 or 2008. This implementation has yet to be completed, and will likely continue through the fall of 2009.

The Rule 1402 action risk level is implemented either through the adoption of a source-specific rule or risk-based individual facility approach. The source-specific rule, Rule 461, was amended April 2000 to implement Rule 1402. The April 2000 staff report for Rule 461 stated that about 1% (55) of the existing facilities that were estimated at that time to exceed the 25-in-one-million would meet that action risk level with implementation of CARB’s EVR and Phase III reformulated gasoline. This board letter serves to refine the previous analysis by using the throughput data and receptor distance submitted by facilities. It was determined that no facility has a risk equal to or greater than 25-in-one-million after the implementation of Rule 461.

There are approximately 3,000 retail GDFs in the Basin. There has been a definite downward trend over the past several years in the number of retail GDFs and an increase in the gasoline dispensed (throughput) per facility. The following information summarizes the implementation of Rule 461, meeting the Rule 1402 action risk level, the state of the technology, and the potential for further emission reductions.

Air Toxics Control Plan and Benzene Emission Reductions

AT-STA-07 - Further Reductions from Gasoline Dispensing Facilities (Amend Rule 461), in the March 2000 Air Toxics Control Plan, stated the objective of the control measure to be: "further reduce emissions from gasoline dispensing through enhanced rule effectiveness. Control of benzene emissions from gas stations depends on effectiveness of the control system as well as compliance with allowable throughput limits. This strategy includes reducing emissions through vent pipes caused by ‘vapor growth’ at Stage I systems occurring during storage tank fuel delivery and transfer. Also included is improved control performance of the Stage II vapor recovery system for vehicle refueling. Large stations may be required to record and report throughput to ensure that the permitted toxics levels are not exceeded." The control strategy projected an eight percent reduction of benzene from gasoline vapor losses. This strategy was implemented in the April 2000 amendments to Rule 461 which achieved, and exceeded, reduction commitments in the ATCP.

Meeting Rule 1402 Action Risk Level

Rule 461 paragraph (e)(6) requires owners of GDF equipment to submit the facility's monthly gasoline throughput data to the Executive Officer in conjunction with the reverification test report for each testing and reporting period. Reverification tests are required annually. The throughput data gathered in 2003 was used to determine risk. According to the staff report for the Rule 461 amendment, the analysis of the risk was to be based on the throughput data to be submitted under PAR 461. Using CAPCOA’s screening risk assessment procedures for gas stations, no facility was estimated to have a risk greater than the 25-in-one-million Rule 1402 action risk level based on reported throughput in 2003. As described below, additional reductions are expected from future implementation of CARB’s regulations.

State of Technology

CARB’s enhanced vapor recovery (EVR) program, which was highlighted in the December 6, 2002 Board meeting report on Rule 461 – Gasoline Transfer and Dispensing, is still in the implementation stage. There are six parts to the program with various timelines for implementation. Phase I EVR is well along in implementation statewide with a final compliance date of April 2005. It requires more durable and reliable equipment that should reduce Phase I losses substantially. Phase I addresses gasoline transfer into stationary storage tanks and mobile fuelers. The losses from this type of transfer occur primarily from leaking equipment seals and pressure relief valves.

Phase II EVR was originally scheduled to be implemented by 2008. Full implementation is now expected by October 2009. It will require better dispensing equipment and continuous in-station electronic monitoring for leaks and vapor recovery.

Two other EVR requirements will further enhance vapor recovery at GDFs. All new dispensers must have only one dispensing hose per side. This "unihose" configuration reduces the number of potential failure points in the stations. This regulation is currently in effect for all new stations. Finally, after April 2005, all stations must be compatible with Onboard Refueling Vapor Recovery (ORVR). This prevents the built-in vapor recovery systems on new cars from competing with some types of emission controls at the stations.

Taken together and fully implemented, these enhancements are designed to increase collection efficiencies by two to four percent. In addition, the in-station diagnostics should reduce emissions due to equipment failure by five percent or more. The phase-in period is four years (ending in April, 2009) for full EVR. There is currently no new technology identified that would achieve further reductions beyond the EVR program.

Potential for Further Emission Reductions

From the April 2000 board letter to amend Rule 461, VOC emissions were estimated to be as high as 18.9 tons/day. The total VOC emission reduction estimate for the EVR program is 10.6 tons/day. This translates to 21,200 lbs/day of VOCs and 76 lbs/day of benzene. Continued implementation of the EVR program and effective field enforcement presence will ensure these reductions are materialized.

Conclusions

This board letter fulfills the April 21, 2000 commitment to conduct a technical assessment. Gasoline dispensing facilities, in aggregate, continue to be a significant source of VOC and toxic emissions. This review shows that good progress has been made over the last four years. The CARB EVR program is progressing for statewide implementation with final implementation scheduled for 2009. Current estimates are that no facility exceeds the 25-in-one-million action risk level for Rule 1402. When fully implemented, the EVR program will result in further VOC and toxic emission reductions.

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