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