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Connecticut moving to repeal the Stage II Vapor Recovery Requirements?

January 3, 2012 (comments: 0)

Most of you are familiar with the Stage II rules and regulations as it relates to the equipment and activities at gasoline dispensing facilities.  Under the Clean Air Act, Stage I and II was established to minimize Volatile organic compounds (VOC) and hazardous air pollutants (HAP) VOC emissions to the atmosphere.  VOCs and HAPs are emitted from the refueling of light-duty gasoline vehicles and trucks (hereafter referred to as vehicles) at gas stations or, more formally, gasoline dispensing facilities (GDF) and from fugitive sources at GDF.


Controlling these emissions has been an issue for all stakeholders involved in the reduction of ozone and the production and dispensing of gasoline since the late 1980s. VOC and HAP emissions occur from two types of sources at GDF: Stage I and Stage II processes. Stage I refers to processes at GDF when the gasoline is delivered or transferred from the tanker truck to the underground storage tank (UST).  Stage II refers to processes at a GDF when the gasoline is delivered or transferred from the UST to the vehicle fuel tank. Emissions from Stage II processes are the focus of this article.  Stage I processes are mentioned only for clarity. Emissions from GDF are a nationwide problem, and gasoline use in vehicles and trucks is increasing annually however there has been a fundamental movement to eliminate the requirements for Stage II regulations. The reason is that the automotive manufacturers have been installing an  on-board refueling vapor recovery (ORVR) canisters for over a decade, (ORVR will be used forward in this article).  Basically the ORVR system in essence reclaims the vapor emission during the vehicle fueling process, negating the need for the complex and costly Stage II equipment at GDFs.


Eventually, given enough vehicles in use in the United States equipped with ORVR, technically Stage II equipment at the GDF is no longer required. In fact, continuing to have Stage II equipment during the fueling process for vehicles that have ORVR can actually CREATE and exasperate the emissions problem. CARB (California Air Resource Bureau) predicts that, as a result of ORVR/vacuum assist system incompatibility, “up to 35% efficiency loss could occur [in assist system control efficiency] based on theoretical calculations.”



The Clean Air Act (CAA) Section 202 (a) (6) states, with respect to ORVR requirements, “The requirements of Section 7511a (b) (3) of this title (relating to Stage II gasoline vapor recovery) for areas classified under Section 7511 of this title as moderate for ozone shall not apply after promulgation of such standards…”


The general interpretation of this is to indicate that states with Stage II programs in Moderate ozone nonattainment areas, as well as Marginal and attainment areas in the Ozone Transport Region (OTR), may begin to phase out their Stage II programs. The Northeast states are beginning to feel pressure to repeal their Stage II programs, as in the state of Maine, which essentially has begun the process of Stage II phase out process quite some time ago  as well as other states.


According to CAA Section 202 (a) (6), the EPA Administrator may repeal the federal requirement mandating Stage II vapor recovery programs upon determination that vehicles equipped with ORVR systems are in “widespread use.”


On the question to the definition of “widespread use,” the EPA took a position as a guidance to all States that such a determination would be based on “the percentage of the automobile fleet equipped with ORVR.”  To most industry stakeholders, this suggested that “widespread use” would occur when ORVR achieves emissions reductions on a one-to-one basis when compared to Stage II.  For heavily populated areas  with strong economic “engines” such as the Northeast, that time is already here.


Connecticut is now one of the Northeast states moving forward to establish a phase out of Stage II requirements  however they are potentially looking to “beef up” the Stage I requirements but I question why……….As far as Stage I,  I’m surprised CT would even pursue tougher standards given already a pretty tough federal standards under


 National Emissions Standard for Hazardous Air Pollutants (NESHAP), Subpart CCCCCC


Traditionally Connecticut moves relatively slowly as it relates to reg. changes but there is a keen interest by the impacted stakeholders, namely the owner/operators in CT wishing to see this come to pass quickly.


 - Joel Hershey, Director

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