Tuesday, July 31, 2007

VST Produces "Balance" EVR System that Misses the Mark

On July 11th, AQCS Environmental attended a meeting sponsored by Northwest Pump in San Diego California. The primary function of the meeting was to sell EVR upgrade components to gasoline station owners and operators. As part of the meeting, VST, the producer of the only "balance" EVR Phase 2 system that has passed the CARB 180 day performance test gave the audience a preview of the system that should be approved for installation before the end of 2007. We were glad to get the opporitunity to take a look at the system and compare it to the existing Healy system that has already been approved.

The VST system consists of new hanging hardware (nozzles, hoses and breakaways) and a membrane vapor-processor that will control tank-pressure and virtually eliminate vapor losses from the vent pipes. Like other Phase 2 EVR systems, the VST system has the potential to pay for itself in 2-5 years due to the near elimination of inventory losses from the vent pipe. I applaud the effort of VST in producing the first and only balance EVR Phase 2 system that has successfully passed CARB performance tests. However, it appears that in their rush to be first to market, they did not research the market as well as they should have. What is the key element that VST missed? The VST system will only be available with "Exhibit 10" hoses that require the "Liquid Removal Test" . This small detail may entirely undermine the market position VST hoped to gain by being the first balance EVR Phase 2 system to market. Why you ask? The simple answer is "Cost of Ownership"

Balance systems have become very popular in the last four years because they are ORVR compatible, have a small number of moving parts and if configured correctly (as Exhibit 9 or Exhibit 5) can save owners substantial money in testing costs, repair costs, lost operational time and Air District fines. For a typical 36 fueling-point site, I would estimate that Cost-of-Ownership is increased by at least $1800-$2000/year, excluding potential regulatory fines and revenue lost due to down-time during testing.

It is true that the alternative to installing the VST balance system is the Healy Vac-Assist system that requires annual or semi-annual V/L testing. However, this testing can be conducted much more quickly, resulting in less lost revenue to down-time and has a lower failure rate, resulting in lower equipment replacement costs and lower potential regulatory fines.

Overall, the decision by VST to develop a system that requires liquid removal testing has made the choice of whether to go balanc or vac-assist much less obvious. I think it will now come down to cost of installation and owner preference. There is also the potential that other balance systems will be approved in the future that eliminate the need for liquid removal and by installing the VST system now moving to that system will be easier and less expensive. That, however, is speculation and must be weighed by the owners and operators that will be bearing the cost of the upgrade.

What are the top 10 UST Violations in San Diego County?

Originally Published in May, 2007


The San Diego County Department of Environmental Health held a free UST compliance seminar on May 31, 2007, during which they announced the 10 most commonly cited UST violations:
1. Line leak detectors not functional
2. Monitoring system not functional
3. Dispenser containment not adequately monitored
4. Designated Operator monthly checklist missing or incomplete
5. Certificate of financial responsibility not on site
6. Raised sensors
7. Secondary Containment results not complete or not submitted
8. Audible/Visual alarm not working
9. Unapproved repairs
10. Liquid in sumps

The seminar also included several other presentations on the responsibilities of owners and operators of USTs, significant UST violations and repair permit requirements. AQCS Environmental attends workshops like these to stay current on regulatory requirements and changes in enforcement policy. This is part of our ongoing effort to provide our customers with the best compliance management and consulting available.

City of La Mesa Awarded $290,250 Grant to Replace Older Heavy-Duty Off-Road Vehicles.

Originally Published in May, 2007

The California Air Resources Board (CARB) awarded the City of La Mesa a $290,250 grant to replace older heavy-duty off-road vehicles with cleaner, less polluting ones. The grant came from a 25 million dollar pool of money authorized by state ballot proposition 1B. The City of La Mesa will replace a backhoe, a loader and a paver with equipment powered by clean Tier 3 diesel engines and are expected to reduce emissions by 2700 pounds over the life of the equipment. The grant will pay for approximately 75% of the cost of replacement. The grant proposal was prepared by AQCS Environmental and included a careful analysis of residual emissions reductions to maximize the competitiveness of the bid.
The funding comes at a good time. CARB is considering a regulation that will require emission reductions from off-road diesel vehicles.

CARB Releases Notification of Requirement to Upgrade Stations Before March, 2009

From March, 2007

The California Air Resources Board released “Advisory #359” regarding the upcoming deadline for the installation of Phase II EVR systems. The advisory goes on to say: “ Approximately 13,000 GDFs will need to obtain permits, purchase EVR Phase II equipment and arrange for installation by a certified contractor in the next two years. One EVR Phase II system is currently certified (Franklin Fueling/Healy). Franklin Fueling is prepared to meet the equipment demand; however, there is a potential shortage of certified contractors if GDF operators wait too long to install EVR systems.” The advisory also recognized that only one Phase II EVR system has been certified and further states: “Other EVR Phase II systems are under test and could be available by the end of 2007; but there is no guarantee that any system currently in the certification process will successfully complete all performance testing and legal requirements to obtain EVR certification.” The Advisory also emphasized the importance of having a “Certified Vapor Recovery Installer” conduct the installation work.

AQCS is available to discuss EVR installations at your facilities and review contractor certification and installation timelines