San Diego APCD Revises EVR Permit Deadline

In a memo dated 2/28/2008 and distributed by email on 3/05/2008, the San Diego County Air Pollution Control District (SDAPCD), stated that the deadline to submit permit applications for Enhanced Vapor Recovery (EVR) installation has been moved back to 10/01/2008. The memo further stated that the reason for the change was, "...to allow GDF operators more time to evaluate Phase II Enhanced Vapor Recovery (EVR) systems currently certified and other systems which may be certified prior to the revised application submittal deadline."

The memo also provided guidance for ISD installation permits, stating that permit applications should be submitted at least six months prior to the installation deadline for In-Station-Diagnositcs (ISD).

Facilities that dispense more than 1.8 million gallons/year must install ISD before 09/01/2009 and facilities that dispense between 600,000 and 1.8 million gallons/year must install ISD before 09/01/2010.

The full text of the memo can be found here: http://airqualitycs.com/EVRDeadline.pdf

CARB Urges Local Air Districts to Give EVR Exemptions for ORVR and E-85

In a letter dated 2/20/2008, the CARB Executive Officer, James Goldstene, urged local Air District Control Officers to rewrite local vapor recovery rules to allow exemptions from Enhanced Vapor Recovery (EVR) installation at sites that have captive fleets with on-road refueling vapor recovery (ORVR) or dispense E-85. The recommendations are in line with a memo provided by the US EPA. The letter and supporting attachments can be found here: http://airqualitycs.com/e85orvrletter022008.pdf. The CARB and the US EPA's rationale for this policy change is simple: if the vast majority of vehicles that are fueled at a filling facility are equipped with ORVR, then phase 2 vapor recovery is redundant and provides no emission reductions. In the case of E-85, CARB staff has estimated that less than 0.10 tons of ozone producing VOCs will be released by the operation of E-85 dispensers with no phase 2 vapor recovery. On October 22nd, I wrote about the San Diego APCD's plan to implement phase 2 vapor recovery exemptions at ORVR and E-85 sites. The changes recommended by CARB are essentially identical with the planed rule changes proposed by the SDAPCD. That article can be found here: http://airqualitycs.blogspot.com/2007_10_01_archive.html#1865506486205554569
It contains useful information on how to determine if a vehicle is ORVR equipped.

All Portable Diesel Engines Must be Tier Certified by 2010

The deadline to replace older, non-tier certified portable engines with new, cleaner engines is less than two years away. the California Air Toxics Control Measure (ATCM) that regulates portable engine emissions can be found in 17 CCR 93116. It states:
"all portable diesel-fueled engines shall be certified to meet a federal or California standard for newly manufactured nonroad engines pursuant to 40 CFR Part 89 or Title 13 of the California Code of Regulations (that is, certified to Tier 1, 2 or 3 nonroad engine standards)"

the full text of the regulation can be found here: 17 CCR 93116 http://www.arb.ca.gov/portable/perp/peatcm091207.pdf.

However, the same regulation also mandates fleet emission levels with deadlines in 2013, 2017 and 2020. The 2013 fleet standard is 0.3 g/bhp-hr. If you are planning on replacing older non-Tier engines with used Tier 1 and 2 engines, you may then have to replace them again in 2013 to achieve fleet compliance standards. AQCS advises purchasing the highest engine tier available before 2010.

Table of fleet emission standards and deadlines:

Table of Tier 1, 2, 3 and 4 emission standards and phase-in dates:

Portable Diesel Engine Reports are Due on March 1, 2008

Owners and operators of portable diesel engines registered with the California Air Resources Board (CARB) under the Portable Equipment Registration Program (PERP) must submit an annual usage report on or before March 1, 2008. The report must include the registration number, the locations of operation, and the hours of operation or gallons of fuel used. This form can be found at: http://www.arb.ca.gov/portable/perp/records/form28rev1.pdf.

Additional PERP forms can be found at: http://www.arb.ca.gov/portable/perp/records.htm.

The PERP regulation is part of the California Code of Regulations, Title 13, 2450. The entire text of the regulation can be found at: 13 CCR 2450 http://www.arb.ca.gov/portable/perp/perpreg091207.pdf

Comparison of Franklin Fueling and Vapor System Technologies Phase II EVR Systems: Which System Provides the Best Value

California State Law requires the installation of Phase II Enhanced Vapor Recovery (EVR) equipment at nearly all gasoline-dispensing facilities (GDF) statewide on or before April 1, 2009. As of February 2007, approximately 13,000 GDFs had not conducted the required installation. Currently there are only two systems available that meet the requirements of Phase II EVR: the Franklin Fueling System, manufactured by Franklin Electric and the Vapor System Technologies system, manufactured by Vapor System Technologies, Inc. The following report discusses the relative merits of each system in order to provide guidance to GDF operators in selecting which system to purchase. In summary, it appears that the Franklin Fueling Systems is superior. The reasons that the Franklin Fueling System is best are numerous: Franklin Fueling is the only system that is currently certified for GDFs that dispense more than 600,000 gallons/year. It has a greater supply of certified installation technicians, lower cost of installation, lower parts costs, and lower testing costs than the Vapor System Technologies system. Detailed explanations of each evaluation category are included in the following document:
http://airqualitycs.com/AQCS_EVR_EVAL_0219_CAPX.pdf

Balance EVR System Approved by CARB

The California Air Resources Board (CARB) has approved the Vapor Systems Technology (VST) Phase 2 Enhanced Vapor Recovery (EVR) System. The system is based on the balance principle (the vapor exchange between vehicle fuel tank and gas station fuel storage system is achieved through positive displacement). The system is not currently approved for In-Station Diagnostics (ISD), which will be required in 2009 for facilities that dispense more than 600,000 gallons of gasoline per year.

The VST system utilizes an electric pump-driven membrane vapor processor to virtually eliminate vapor losses from the vapor vent line. Operators who install this system should expect to see reductions in inventory losses through evaporation.

The VST system is one of only two systems certified by the state as Phase 2 EVR compliant. It is also the only balance system certified to date. The deadline for EVR installation for most facilities will be in April 2009. Because no other systems are currently certified, existing gasoline stations will most likely need to choose between the VST system and the Healy system.

Listed below are some of the operational parameters required for compliance for the VST system:

• Flow rate must be between 6 and 10 gallons per minute
• Maximum hose length of hose and breakaway combination cannot exceed 15 feet
• System must be installed with liquid removal hoses
• Breakaways are not reconnecting and must be replaced after a drive-off
• Components reused after a drive-off must be tested before returned to service
• No flow limiters are allowed in the system
• Operators must maintain records of vapor processor alarms and maintenance
• The system must be maintained as directed by the VST Installation , Operation and Maintenance Manual

Additional operational parameters can be found in the CARB Executive Order: http://www.arb.ca.gov/vapor/eos/eo-vr203/vr203a.pdf

Operators who choose to install the VST system will be required to conduct the following tests:

• Liquid Removal
• Hydrocarbon Sensor Verification
• Vapor Pressure Sensor Verification Test
• Determination of VST Processor Activation Pressure
• Nozzle Bag Test
• Additional tests as dictated by the Phase 1 system

On November 27th, CARB released an approval letter allowing the installation of VST hanging hardware as replacement parts for existing (non-EVR) balance equipped gasoline stations. This will allow operators to replace with parts that will be compliant with the VST EVR in anticipation of eventual conversion.

Attention: Forklift Fleet Operators

By Ms. Erin Sheehy and Ms. Rosalie Skefich

After California Air Resources Board (CARB) dropped a proposed ban of all but zero-emission forklifts, a revised rule was recently adopted and became effective May 12, 2007. The final rule, commonly referred to as "Off-Road Large Spark-Ignition Engines" applies to older units [13 CCR, Article 2, Section 2775] and newer units [13 CCR, Article 4.5, Section 2430] produced on or after January 1, 2001.

Off-road large spark-ignition (LSI) equipment subject to the rule are mobile sources greater than 25 horsepower and >1 liter engine displacement that are powered by gasoline, liquefied petroleum gas (LPG) aka propane, and other alternate fuels. Typical applications that use LSI engines include forklifts, airport ground support, sweepers, scrubbers, large turf care equipment, portable generators, and industrial tow tractors.

In accordance with the regulations, fleet operators in California, defined as 4 or more units, are required to complete a baseline inventory of their forklift and nonforklift units within 6 months of rule adoption. This baseline inventory is due by November 10, 2007. The inventory must include equipment type, make, model, serial number, and emission certification standards or retrofit verification level. Fleet operators must also maintain on file a written statement, product delivery ticket or receipt from the fuel supplier stating that the fuel supplied meets all applicable state and federal laws for use in their engines. Inventories must be maintained on-site until 2016.

By January 1, 2009, initial reductions for fleet average emissions for large forklift fleets, medium forklift fleets and non-forklift fleets must be met either by retrofitting, replacing, or retiring the engine. Two CARB-verified retrofit kits are currently available. Additional lower fleet average emission standards are required for 2011 and 2013. Some exemptions from the requirements are available for limited use, rented and leased equipment, and military tactical vehicles.For more information, visit the CARB website. For consulting assistance in identifying exempt equipment, establishing fleet average emissions, assessing appropriate retrofit kits, and complying with future emissions standards, contact , Ms. Erin Sheehy, ECS, 310-664-1396.