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ORVR: Just Where Is It Taking Us?

According to law, 40 percent of the cars made in the US in 1998 are equipped with “Onboard Refueling Vapor Recovery”—and that percentage will double with 1999 models. Joe Totten talks to EPA officials and experts in private industry to learn more about the ramifications of the situation.



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Author: Totten Joe E.
Onboard Refueling Vapor Recovery ... a driving factor

It is no longer a matter of debate–Onboard Refueling Vapor Recovery is the law of the land, as well as a fact of life.

In my prior life as an investigative auditor for the US General Accounting Office, I once had to look into an allegation that the federal funds spent on Woodsy Owl, Johnny Horizon and Smokey the Bear promotional programs were duplicative and that two of them (take your pick) should be done in. When asked for specifics and supporting facts, the “alligator” had nothing beyond the general observation that all three of the programs were for protecting natural resources and the environment.

As you would expect, Department of the Interior and Forest Service officials vehemently defended their position that natural resources/environmental protection was a big enough job for all three programs. I was not saddened by GAO management’s decision that my time could be better spent on other matters. Much more dispiriting would have been deciding whether to do in Woodsy, Johnny or Smokey.

Big enough for both?
How does the above scenario parallel the assault on vehicle refueling vapors by Onboard Refueling Vapor Recovery (ORVR) and Stage II vapor recovery systems? It’s not entirely clear to me yet, except for one thing, which is like crystal: both ORVR and Stage II technologies are mandated by federal law and, although there are many who would do both of them in, the vapor recovery problem obviously is deemed big enough for both of them, at least for the next 15 to 20 years.

For quite a long time, though, the relative merits of the two systems were fair game for debate, as indicated by the following comments that appeared in a column in National Petroleum News (NPN):

“Charcoal Canister a Winner—Preliminary tests indicate the onboard charcoal-canister approach to vapor recovery is a viable solution to government demands for maximum elimination of emissions at service stations. Some data to this effect has already been given to Environmental Protection Agency by American Petroleum Institute, and more will be forthcoming about mid-October when final research reports are written up. Preliminary data confirm that the canisters, with tight fill-pipe connections, are ‘amazingly effective’ in recovering emissions during tank fills at service stations. They’re designed to persuade EPA that canisters are more effective and much easier to handle than the cumbersome nozzles now in use in some states.”

Amazingly, to me at least, the comments quoted above were made more than 20 years ago, in the October 1978 issue of NPN. Much debate has taken place, both before and after that date, about the pros and cons of ORVR and Stage II systems. For all practical purposes, the reasons for debating their relative merits stopped when both technologies became mandated by federal legislation enacted in 1990. ORVR got the nod as the “long-run” winner of the debate, and Stage II was pegged to serve an interim role (in certain locations) during the phasing in of ORVR.

But will it work?
The federally mandated phasing in of ORVR equipment on light duty vehicles began with model year 1998 and is to be completed in model year 2006 and later. In an ORVR system, the vehicle’s gas tank and fill pipe are designed so that vapor from refueling the vehicle travels to a carbon-filled canister, where it is kept until it is drawn into the engine intake manifold and burned during normal operation.

For ORVR systems to be effective, they must work in various service station equipment scenarios with respect to federally mandated Stage II vapor recovery: (1) stations without any Stage II systems; (2) stations with Assist Stage II systems that create vacuum or that create pressure; and (3) stations with balance Stage II systems. What assurances are there that ORVR systems will work effectively under these various scenarios?

To begin to get at the answer to this basic question, PE&T made inquiries to US EPA and CARB officials and three private industry individuals with expertise in vapor recovery technology. Unfortunately, our calendar did not allow sufficient time for CARB to respond. Information obtained from the other sources identified some additional organizations and individuals who should be consulted, as well as some other questions that should be addressed. We plan a future article or articles that will include information from CARB and others on the matters discussed.

The remainder of this article will present the questions posed in our inquiries and the information obtained in responses to date.

 

ORVR and Stage II mandates
Both ORVR and Stage II vapor recovery systems are mandated by the federal Clean Air Act (CAA) Amendments of 1990 (42 U.S.C. 7401-7601q). While the mandate for Stage II systems applies only in areas classified as “moderate to extreme” for ozone non-attainment, the ORVR mandate is nationwide. Conversely, while Stage II systems can already affect vapor recovery generally from all vehicles refueling at stations having such systems, ORVR requirements are being phased in over a period of several years for certain classes of light vehicles, beginning with 40 percent of model year 1998 passenger cars.

Federal EPA enforcement guidance implementing the Stage II mandate was issued in October 1991. Even before then, several states had already mandated Stage II systems in some locations. The regulations for ORVR, however, (1) were not issued until 1994, (2) did not begin to take effect until vehicle model year 1998 and (3) will not be in force for all new light-duty vehicles until model year 2006.

Under a mandated phase-in schedule, 40 percent of model year 1998 passenger cars were required to be equipped with ORVR systems; the requirement will be increased to 80 percent for model year 1999 and 100 percent for model year 2000 and later. Similar phase-ins are scheduled for two sizes of light trucks, starting with model years 2001-03 for the smaller size and continuing through model years 2004-06 for the larger size light-duty trucks. ORVR systems are not required on heavy-duty vehicles.

The ORVR requirements do not wipe out the mandates for Stage II vapor recovery systems. The CAA Amendments provide that, after issuance of ORVR regulations, Stage II requirements do not apply in areas classified as moderate for ozone. For areas classified as serious, severe or extreme for ozone, the legislation authorizes EPA to revise or waive the Stage II requirements after the required ORVR systems are in widespread use throughout motor vehicle fleets.

Widespread use is not expected to occur soon, because (1) ORVR systems will not be required on all new passenger cars and light-duty trucks until model year 2006, and (2) vehicles produced before the ORVR mandates took effect will be on the road for many years beyond 2006. EPA estimates that it will be sometime after 2010 before ORVR will be fully phased in, depending on fleet turnover.

Therefore, until sometime after 2010, vehicles equipped with ORVR systems will be refueled at service stations that have either no Stage II systems at all, balance Stage II systems, assist Stage II systems that create vacuum or assist Stage II systems that create pressure. The great majority of service stations installing Stage II systems went with assist systems. Still, a significant number of stations, particularly in Missouri, New Jersey and Oregon, opted for balance systems; California initially opted for balance systems only, and a majority of stations in California still have balance systems.

What provisions exist in the federal ORVR regulations on the design and manufacture of ORVR systems?
According to EPA officials, the ORVR regulations (40 CFR Part 86) contain many requirements that ORVR systems must meet. These requirements, however, generally do not include design and manufacturing specifications. For example, the ORVR standards require that during a specified ORVR test, refueling emissions cannot exceed 0.2 grams of hydrocarbon per gallon of fuel dispensed. The regulations do not specify how a manufacturer must attain this standard.

EPA officials say that the required test protocol for ORVR includes only testing with conventional refueling equipment (i.e., without Stage II equipment). They add, however, that EPA encourages manufacturers to test their ORVR systems with both conventional and Stage II nozzles. In this regard, EPA guidance letter (VPCD-97-02 dated March 21, 1997) states, in part, as follows:

“The provisions of 40 CFR 86.107-98 ( j ) currently require that for ORVR testing, ‘The dispensing nozzle shall be a commercial model, not equipped with vapor recovery hardware.’ EPA is concerned that a substantial number of service stations, especially those in nonattainment areas are equipped with vapor recovery hardware. EPA recognizes that since the inside diameter of the fuel dispensing portion of a vapor recovery nozzle is much smaller in diameter than that of a conventional nozzle, the fuel velocity is much higher. This difference, and other design differences between Stage II and conventional nozzles, may have an adverse impact on the ability of the ORVR canister to adsorb refueling vapors. EPA believes that it is appropriate to conduct ORVR tests with either conventional or Stage II nozzles, and intends to revise the regulations to provide assurance that ORVR vehicles will comply when tested with either type of nozzle. Manufacturers would be given an opportunity to discuss the ramifications of possible regulation changes prior to proceeding with the rulemaking. In the meantime, we encourage manufacturers to conduct ORVR tests using both conventional and Stage II nozzles.”

We asked EPA officials about the status of EPA’s efforts, as referred to in the above quote, to revise regulations to assure that ORVR vehicles will comply when tested with either conventional or Stage II nozzles. EPA officials advised us that:

“There has been no recent EPA regulatory activity to require compliance testing with Stage II nozzles. We continue to believe that refueling with non-Stage II nozzles will generate more vapors than Stage II nozzles. Also, since March 1997, we have become less concerned that the differences in Stage II and conventional nozzles will result in ‘adverse impact on the ability of the ORVR canister to adsorb refueling vapors.’ Any canister deterioration of in-use vehicles which were primarily refueled at Stage II service stations would show up in the current test procedure. In-use ORVR testing will be required in several years.”

Refueling Emission Control System

Are all ORVR systems the same? If not, do the differences pose any major problems on their ability to function effectively with or without Stage II systems?
EPA officials say that all ORVR systems are not the same, but all must meet the same standards and requirements. They add that some incompatibilities between a few Stage II nozzles and ORVR systems were discovered, and their resolution started, before ORVR was introduced into the market. Since then, they say, EPA has received no consumer complaints about refueling or other problems.

When asked the same question, Detlev (Ed) Hasselmann, P.E., co-developer of the first vapor recovery system certified by the California Air Resources Board (CARB), had another perspective. He points out that the variety of ORVR designs makes compatibility testing more difficult with conventional nozzles and Stage II systems.

Bart Scowley responds that, while there are some slight variations, auto manufacturers have presented a generic description of ORVR systems to CARB and seem obligated to stay within the basic guidelines of that design. Bart is the president and CEO of Shields, Harper & Co., a petroleum equipment distributor and PEI’s representative on CARB’s ORVR/Phase II Vapor Recovery Compatibility Committee.

 

What are the federal requirements on the testing and certification of ORVR systems before they are allowed to be installed on new vehicles?
According to EPA officials, all vehicles with ORVR systems must be certified by EPA as meeting the required standards. As a prerequisite, EPA regulations require that manufacturers test ORVR systems according to prescribed standards and testing procedures. Only those systems passing these tests are certified. Thus, only those systems that meet the 0.2 grams per gallon limit are to be certified. Vehicles with ORVR must also pass federal Department of Transportation safety requirements before they can be sold in the US.

As discussed previously, the current regulations require testing with only conventional (non-Stage II) systems for certification; EPA says that this is because (1) conventional systems generate more refueling emissions than Stage II systems and (2) testing with conventional systems also provides assurance that ORVR vehicles meet emission standards when refueled with Stage II nozzles.

What do federal law and regulations require on the testing and evaluation of ORVR systems after they have been installed on vehicles?
On this question, EPA officials say that EPA is authorized to conduct two types of tests to determine compliance with regulations. The first type of testing, called “selective enforcement auditing,” is performed before the vehicles are introduced into the marketplace. The second type, called “recall testing,” is to ensure compliance while the vehicle is in use. Again, only testing with conventional, or non-Stage II, systems is required under these programs.

EPA officials say that it is possible that states or cities with Stage II compliance programs could have requirements that apply to ORVR vehicles; however, they have not heard of any such systems.

What specific federal or other testing has been conducted on ORVR systems’ effectiveness during refueling at conventional stations and at stations using Stage II systems?
In response to this question, EPA officials referred to the many manufacturers’ tests to get their ORVR systems certified, as discussed above. Again, the officials point out that these tests were on conventional fueling systems, which they say comprise 70 percent of fuel dispensing systems. EPA officials also referred back to the compatibility testing previously discussed. They did not cite any federal test results or other testing of ORVR systems as described in our question. However, as shown in EPA’s comments on page 27, EPA says that “in-use ORVR testing will be required in several years.”

In his PE&T column in the March 1998 issue, TRI president and technology expert Wolf H. Koch, Ph.D., reported that CARB contracted in 1996 for a study to estimate the level of fugitive emissions present when ORVR vehicles are fueled with Stage II systems (“ORVR Cars Are Safe and Efficient,” page 53). Wolf added that the contracting company had completed work on Balance Stage II systems and would soon complete work on Assist Stage II systems, after which the contractor would issue a draft report.

According to Wolf, CARB plans to use the study to guide its engineering evaluation of CARB certified Stage II systems. Questions about the results of any such testing were in our inquiry to CARB in preparation for this article; hopefully, we will have CARB’s response for our next article on ORVR.

Will auto manufacturers’ warranties provide assurance that ORVR systems actually do what they are supposed to do? How will owners know when their ORVR systems are not working properly?
EPA officials said that (1) manufacturers’ warranties cover ORVR components on the vehicles up to two years or 24,000 miles; and that (2) recall regulations (which could force a vehicle recall) apply for the full useful life of the vehicle (10 years or 100,000 miles for passenger cars).

The officials add that an ORVR vehicle’s diagnostic system will detect leaks in the fuel system in the gas tank and canister lines. In the event of a leak, the “check engine” light will warn the driver of a problem. They also noted that the smell of gasoline during refueling or the inability to refuel could also indicate an ORVR problem and that any problems should be referred to the car dealer. Stay tuned for more on this subject as we learn more about it.

What kind of maintenance will be needed on ORVR systems and what will compel owners to provide it?
According to EPA officials, the ORVR systems on vehicles certified by EPA to date will be maintenance free for the full useful life of the vehicle (100,000 miles). This is another area for further inquiry.

ORVR Equipment used in Preliminary testing

 

Some of the equipment used in 1997 preliminary testing of ORVR for refueling compatibility. Below: a complete ORVR system with a charcoal canister alongside the fillpipe (top); a box for maintaining the test paperwork (bottom left); and the fuel tank (bottom right). Center: A close up of the fillpipe with its vapor recirculation line. Right: the inside view of an uncapped fillpipe is not visibly different from a conventional fillpipe.

 
 

What are the major unresolved issues, if any, on the effectiveness of ORVR systems when used with conventional and Stage II systems?
The major issue cited by EPA officials was that EPA has not yet conducted ORVR tests on in-use vehicles. They said that such tests will be required in several years. Both Ed Hasselmann and Bart Scowley lament the absence of test data—data they deem essential to identifying and resolving problems they believe are being or will be encountered with ORVR systems.

Ed Hasselmann points to the following problems or potential problems that need to be addressed:

1) Questionable ability of ORVR systems to regenerate the carbon canisters for any length of time when refueling (as distinguished from evaporative) vapors are collected. (He has asked for but has not been provided with data showing that this is not a problem).

2) Possible damage to ORVR systems when conventional nozzles fail to shut off. Ed says that tests have not been done to see what happens when conventional nozzles fail to shut off, which they frequently do, especially when the car’s tank is being topped off. He explains that this was one of the problems with early Balance Stage II nozzles that used the conventional shut-off mechanism, which resulted in gasoline flowing through the vapor recovery line back to the UST as fast as it was being pumped into the car tank.

In some cases, he adds, the gasoline pressure in the car tank was sufficient to bulge and distort the tank As a result, says Ed, all Balance Stage II systems had to be recertified with an additional low-pressure shut-off mechanism. He says that, despite repeated requests, he has not seen any test data showing that ORVR systems are not damaged by the failure of conventional nozzles to shut off.

3) Impractical field testing capability. Ed notes that the only available means of testing the performance of ORVR systems is a very expensive laboratory shed test. Field testing (e.g., at service stations) is not practical because the vents from the carbon canisters are inaccessibly located deep underneath the car; this does not enable one to stand next to a car being fueled and test the vent with an explosimeter.

4) Questionable performance with Balance Stage II systems. Ed says that balance systems have always had fugitive emissions. By design, he adds, these systems are not tight. When the nozzle is depressed, the vapor valve is opened so that the storage tank is vented to the atmosphere. This happens not only as the nozzle is being attached to and removed from the car’s fillneck, but frequently during the refueling itself, because of gaps between the nozzle faceplate and the fillneck.

Bart Scowley says that ORVR systems need to be tested and maintained to see if they work properly and provide the desired results. His specific concerns are as follows:

1) There does not seem to be an ongoing testing program in place. Therefore, we do not know what the results of widespread use of ORVR systems will be.

2) Possible ORVR equipment maintenance problems and the tendency of owners to either ignore the problems or to disable the systems.

3) Incompatibility between ORVR and Assist Stage II equipment that creates pressure and fills the pipes and UST with fresh air, developing new vapors that enter the atmosphere through the vapor vent valves or as fugitive emissions through the inevitable breaches in the system.

According to Bart, this problem is why CARB has an ORVR/Phase II compatibility committee that has been meeting regularly since 1996. He adds that CARB does not yet know how the problem will be resolved, but that the agency is considering the addition of monitors that will display for local regulators the effectiveness of the vapor recovery system while it is operating.

Wolf Koch’s July 1998 PE&T column on vapor recovery touched on ORVR’s compatibility with both Balance and Assist Stage II systems. He said that:

1) Balance systems will cause fugitive emissions when used with ORVR cars unless the Balance systems are required to (1) pass periodic tightness tests and (2) use a pressure/vacuum vent valve, which is required by local authorities in California.

2) When Assist Stage II systems are used to fuel ORVR vehicles, fugitive emissions come from saturating returned air in the UST. CARB, says Wolf, will require one of two control strategies for avoiding such fugitive emissions. Station operators will either need to install a vent processor, or control the vapor pump operation during the refueling of ORVR cars.

3) CARB is proposing a new certification test procedure (TP-201.2D) that will measure the amount of air returned by assisted systems. Systems returning more than 50 percent air relative to the dispensed liquid will fail unless they incorporate a vent processor. It appears that CARB will decertify existing equipment after the new rules are finalized.

 

EPA to respond to issues
EPA officials questioned our introduction of the issues presented above, stating that several of the issues have been addressed by EPA or automobile manufacturers. They commented that they would have liked the time and opportunity to give PE&T readers the whole picture on these issues. Our future coverage of ORVR developments will ensure that EPA has such an opportunity.

Where are we and what’s next?
In summing up, the effectiveness of ORVR systems to limit refueling vapors to 0.2 grams per gallon of gasoline dispensed depends on their ability to successfully perform when used at service stations equipped with conventional nozzles and various types of Stage II systems. Recognized experts on vapor recovery technology have raised serious questions about ORVR systems’ ability to work under these varying conditions.

The regulatory authorities (EPA and CARB) recognize that tests of ORVR systems’ actual performance under such conditions are needed, although it has not been established that the authorities recognize the performance issues and testing difficulties discussed in this article. Also, their plans on future testing of ORVR systems and resolution of the issues are unknown, at least to PE&T. We will keep you updated.

Bart Scowley surmises that CARB’s strategy may be to accept the immediate equipment incompatibility problems for a few years, while developing longer-term solutions through a proposed “Enhanced Vapor Recovery Program.” According to Bart, this proposed program will call for monitors on Stage II systems (as mentioned above), extended warranties and new testing standards for all proposed vapor recovery systems. Bart projects it will take several years for such a program to affect vapor recovery refueling.

Wolf Koch’s outlook is that, while there may be problems with ORVR vehicles, the auto industry will solve them quickly to avoid future large-scale recalls. Says Wolf, “ORVR is a federal mandate. Short of changing the mandate, the auto makers must comply, and provide durable systems that meet the mandated performance standard.” In a future article, I plan to update our readers on ORVR developments. Just the thought of this makes me yearn for another chance at Woodsy, Johnny and Smokey.

Joe E. Totten was Director of the Office of Internal Evaluation for the U.S. General Accounting Office (GAO) from 1990 through 1994. In this capacity, he directed and managed internal audits of GAO operations. Joe now works as editor/quality contral manager for Petroleum Equipment & Technology.

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