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Interim White Paper - Midwest RPO Candidate Control Measures

3/10/2006 Page 9

TIMING OF IMPLEMENTATION

For the purposes of this White Paper, we have assumed that SIP rules would be adopted in early 2007. If the MRPO states chose to adopt the CARB EVR requirements for Stage I and II, a four-year window is

provided for existing facilities to upgrade equipment to meet the new standards reductions would not occur until 2011 for Measures SOLV7A and SOLV7B.

Thus, emission

COST EFECTIVENESS AND BASIS

CARB (Reference 12) estimated the cost effectiveness of upgrading existing systems to meet Phase I of the EVR program to to be $7,640 per ton of VOC reduced, with the costs for low capacity facilities about three times more costly than for an average sized facility. For stations without Stage I vapor recovery systems, the cost effectiveness of new systems is estimated to be between $100 to $4,742, depending on the size of the station (Reference 8).

CARB (Reference 12) estimated the cost effectiveness of upgrading existing systems to meet Phase II of the EVR program to be $36,260 per ton of VOC reduced, with the costs for low capacity facilities about three times more costly than for an average sized facility. For stations without Stage II vapor recovery systems, the cost effectiveness of new systems is estimated to be about $13,400 in 2009, and rises to $28,500 by 2015 (Reference 10).

For underground storage tank breathing losses, commercially available membrane vapor recovery systems are said to pay for itself with the value of the recovered gasoline.

RULE DEVELOPMENT ISSUES

EPA has not yet issued final rules for implementing the RACT/RACM provisions associated with the 8- hour ozone SIPs. The proposed implementation rule contained different options for residual 1-hour areas and 8-hour basic, marginal, and moderate areas. For ozone nonattainment areas, States can work from existing authority under state and federal law. States may need additional authority to impose VOC RACT/RACM requirements outside on nonattainment areas.

GEOGRAPHIC APPLICABILITY

We developed two options for geographic applicability for the candidate control measures. The first

option is the 8-hr

to apply the candidate control measure

ozone

standard.

The

second

option

only in those counties designated as is to apply the candidate control

nonattainment for measures to both

nonattainment counties and all counties that phase-on of vehicles with ORVR will result in

are adjacent to a nonattainment county. emission reductions in all counties.

The

continued

TEMPORAL APPLICABILITY

Emission reductions would be realized throughout the year.

AFFECTED SCCs

Area source SCCs affected by this control measure include:

2501060050

Stage I Total

Disclaimer: The control measures identified in this document represent an initial set of possible measures. The Midwest RPO States have not yet determined which measures will be necessary to meet the requirements of the Clean Air Act. As such, the inclusion of a particular measure here should not be interpreted as a commitment or decision by any State to adopt that measure. Other measures will be examined in the near future. Subsequent versions of this document will likely be prepared for evaluation of additional potential control measures.

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