EPA-AA-SDSB-85-5
Study of Gasoline Volatility and Hydrocarbon
       Emissions  from Motor Vehicles
               November 1985
  Standards Development and Support Branch
    Emission Control Technology Division
       :   Office of Mobile Sources
        Office of Air  and Radiation
   U. S. Environmental Protection Agency

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                            Abstract

     In-use  motor  vehicle  evaporative  hydrocarbon  emissions
greatly  exceed  their  applicable  EPA  emission standards.   The
primary reason  is  that the volatility of commercial gasoline is
substantially greater  than  that  of the certification  test fuel
specified  by EPA  (i.e.,  vehicles are simply not  designed  to
handle the fuel volatility they regularly experience).

     The  long-term solution  is  to equate  the volatilities  of
commercial and  certification test gasolines.  This  can be done
at:  1)  the current volatility of commercial  gasoline,  2) that
of  certification  test  gasoline,  or  3)   at  some  point  in
between.   However,  in  the short  term,  only  the reduction  of
commercial gasoline  volatility  has a  significant environmental
benefit,  since  the effect  of  certification  fuel  modifications
must  await  the turnover   of  the  vehicle  fleet.   This  study
examines   the  technological   feasibility,   costs,   emission
reductions,  air quality impacts  and  cost effectiveness  of  the
various long-term and short-term solutions to this problem.

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                     For  Further  Information

     For further  information  on  the technical contents  of this
study, please contact  Amy Brochu,  U.S.  Environmental Protection
Agency, 2565  Plymouth Road,  Ann Arbor,  MI   48105  (phone (313)
668-4270).   All  of  the  references used  in  this  study (except
those  which are  publicly  available),  as  well  as all  Agency
correspondence  associated  with the  study,  are  contained  in
Public  Docket  A-85-21.   This  docket  is  located  in  the  West
Tower   Lobby   at   EPA  Headquarters,   401   M   Street,   S.W. ,
Washington, D.C.   20460  (phone (202) 382-7548).   The docket can
be viewed  between 8:00 a.m. and 4:00 p.m., Monday  - Friday.   A
reasonable fee may be charged for copying.


                         Public Comments

     Written  comments  on   all   aspects   of  the   study  are
encouraged.  Please  send comments   to:   Central  Docket  Section
(LE-131),   U.S.   Environmental   Protection  Agency,  Attention:
Docket A-85-21,  401 M Street,  S.W., Washington,  D.C.  20460.

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                        Table of Contents

Chapter 1:  Introduction
     I.     Background and Purpose	1-1
     II.   Structure of the Report	1-2

Chapter 2:  Current In-Use Evaporative Emissions
     I.     Introduction	2-1
     II.   Ozone Violations and Seasonal Trends   .   .   .  2-1
     III.  Sources of Evaporative HC Emissions ....  2-16
     IV.   Factors That Can Impact Evaporative Emissions
             from Motor Vehicles   .	2-17
     V.     Results of In-Use Motor Vehicle Testing   .   .  2-45
     VI.   Summary of Evaporative Emissions Problem and
             Development of Possible Control Scenarios  .  2-79
     Appendix 2A:  Effect of Ambient Temperature on
             Motor Vehicle Evaporative Emissions  .   .   .  2-90
     Appendix 2B:  Breakdown of Motor Vehicle Evaporative
             Emission Factors into Their Components  .   .  2-111

Chapter 3:  Vehicle-Oriented Excess Evaporative HC Control
     I.     Introduction	3-1
     II.   Technology	3-1
     III.  Costs        	3-17
     IV.   Conclusions  .	3-22
     Appendix 3A:  Detailed Derivation of Evaporative ECS
                     Component Costs  	  3-26

Chapter 4:  Technological Feasibility and Cost of In-Use
             Volatility Control
     I.     Introduction	4-1
     II.   Refinery Control of Gasoline Volatility   .   .  4-1
     III.  The Bonner and Moore Study	4-4
     IV.   Effect of RVP Control on the Butane Market.   .  4-21
     V.     Fuel Economy Credit	4-24
     VI.   Economic Credit from Evaporative HC Recovery/
             Prevention	4-38
     VII.  Overall Cost of In-Use Gasoline RVP Control  .  4-40

Chapter 5:  Environmental Impact
     I.     Introduction	5-1
     II.   Motor Vehicle Evaporative HC Emission Factors  5-1
     III.  Motor Vehicle Exhaust Emission Factors .   .   .  5-16
     IV.   Effect of RVP Control on Gasoline
             Storage and Distribution Losses   ....  5-19
     V.     Hydrocarbon Emissions Inventory Analysis  .   .  5-23
     VI.   Ozone Air Quality Analysis 	  5-33
     VII.  Effect of RVP Control on Toxic Emissions  .   .  5-37

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Chapter 6: Analysis of Alternatives
I . Introduction 	
II. Methodology 	
III. Results 	
Appendix 6-A: Development of I/M Credits for Evaporative
Emission Control Systems 	
Appendix 6-B: Effects of Increased Canister Size on
Operating Costs 	
Appendix 6-C: Development of Non-Summer Evaporative
Emission Recovery Credits for Four-Month
Analysis . 	
6-1
6-3
6-14
6-47
6-63
6-66

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                            CHAPTER  1

                          Introduction

I.   Background and Purpose

     Current  violation  of   the  ambient  ozone   standard  is
somewhat  widespread  in  urban areas  across  the United  States.
The  Clean Air Act requires  all  areas  to be  in  attainment  by
December   31,   1987.*   Therefore,   additional   reduction  of
hydrocarbon emissions  has  become a growing  concern.  Of  late,
increasing  attention  has  been directed  toward  evaporative
hydrocarbon (HC) emissions from gasoline-fueled motor vehicles.

     Evaporative  HC   emissions  from  motor  vehicles  originate
from two  basic  components of  the vehicle's fuel  system — the
fuel tank and the carburetor.   Evaporative  emissions from the
fuel tank —  known as "diurnal" losses — occur as the gasoline
vapors  expand   in   response   to  daily  ambient  temperature
increases.  The  other type of  vehicle  evaporative emissions —
referred to as "hot-soak" losses — occur  just  after the engine
is turned off, when  residual  engine heat causes the evaporation
of some of  the  fuel  remaining  in the carburetor  bowl and fuel
lines.    In fuel-injected  vehicles,  some  hot-soak  losses  also
originate  from  the   fuel  tank  as   well,   probably   due  to
recirculation of gasoline that has been heated by the engine.

     Currently,   all   gasoline-fueled  vehicles   and  trucks  are
equipped  with evaporative  control  systems designed  to  capture
the  majority  of  these diurnal  and  hot-soak losses.   A  typical
system consists  of a  canister  filled  with  carbon granules which
adsorb  the  HC  vapors  generated  in  the  fuel  tank  and  the
carburetor.   Later,    while  the   engine   is   operating,   the
evaporative canister  is periodically purged with air  and the
collected HCs are stripped  from the canister and  burned  in the
engine.

     Light-duty  gasoline vehicles  (LDGVs) and  gasoline  trucks
weighing  less than 6000  Ibs.  GVW (rated gross  vehicle weight),
classified  as  LDG^s,  have  been  equipped  with  evaporative
canisters  since  1971,  when the  first evaporative  HC standards
came into effect.   Evaporative  control of heavier  trucks came
later,  with canisters first  installed  in  light-duty  gasoline
trucks over  6000 Ibs.  GVW (LDGT2s)  in 1979 and  in heavy-duty
*    1982 was the  original  date by  which attainment was  to be
     achieved;   however,    under  special   circumstances,   an
     extension  to  1987  is   permitted.    The  Act   makes  no
     provisions beyond 1987.

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                              1-2


gasoline  vehicles  (HDGVs)  in the  current  model year  (1985).
Current evaporative HC standards for  these classes —  required
to be  met during certification testing — are  as  follows:   2.0
grams/test  for  LDGVs, LDGT,s  and  LDGT2s;  3.0  grams/test  for
HDGVs  at  14,000  Ibs.  GVW or less;  and 4.0 grams/test  for  HDGVs
greater than  14,000  Ibs.  GVW.   These  standards  represent  the
sum  of diurnal  and  hot-soak  losses  measured  via  the  Sealed
Housing Emission Determination (SHED) test,  as outlined in  the
Code of Federal Regulations (Part 86,  Subparts B and M).

     Evaporative control  systems  are designed to  meet  these HC
standards  when  the vehicle  is fueled  with certification  test
gasoline  (Indolene),  which has  a  typical  Reid Vapor  Pressure
(RVP)  —  a measure  of volatility — of 9.0 psi.   Although  this
level  of  volatility  was  representative  of commercial  fuels in
the  early 1970's when  certification test fuel  specifications
were  developed,  the  RVP  of  commercial  gasoline  has  risen
steadily  since  then  due primarily  to  an  increasing  butane
content in response  to rising energy costs.  Results  of  EPA's
in-use  emission   factor   testing  indicate   that  evaporative
emissions  are  significantly  greater  with  fuels   of  higher
volatility;  therefore,   evaporative  emissions   from   vehicles
operating  on  commercial  fuels are well above the certification
standards.  Further,  EPA's testing has also revealed that  the
majority  of  in-use  carbureted  vehicles  are  unable to  meet  the
evaporative  standards even  while  operating on   Indolene  (9.0
psi),   which  suggests   possible  design  problems  such   as
inadequate  canister purge during typical  operating  conditions.
Fuel-injected vehicles  (a small  minority in  today's  fleet,  but
expected  to  dominate  late  1980's  sales)   perform   well   on
Indolene,  but greatly exceed 2 grams/test on commercial fuel.

     Based  on  these  findings,   EPA  has  concluded  that  the
majority  of  vehicles being  driven  in  the  field  today  are
exceeding   the   current   evaporative  HC  standards   and   will
continue  to  do so,  though to  a lesser extent,  in the  future.
This  evaporative excess  is  a  significant  contributor to  the
current  ozone  non-attainment  problem.    The  purpose  of  this
report  is  to  analyze  various  strategies designed to reduce this
evaporative excess  via in-use fuel  volatility  controls  and/or
modifications  to certification  fuel volatility specifications
and test procedure.

II.   Structure of the Report

     In addition to  this Introductory Chapter,  the  report is
divided  into  five  major  sections.    The  first  (Chapter  2)
discusses  the current in-use  situation  and  lays  the  groundwork
for the rest  of  the study.  Topics examined are:  1) the current
ozone non-attainment  problem and seasonal trends in violations,

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                               1-3


2) the sources of  evaporative  HC emissions (both  motor  vehicle
and  stationary),   3)  various  factors  affecting motor  vehicle
evaporative  emissions  (such  as   evaporative   control   system
design,  fuel  volatility,  use of  alcohol  blends,  and  ambient
temperature conditions),  4)  results  of  EPA's  in-use  vehicle
testing  (used  to  define the basic sources of the  motor  vehicle
evaporative excess  and  also the  effect of  fuel  volatility  on
exhaust  emissions),  and  5) the  HC  control  strategies to  be
evaluated in the remainder  of  the  study.   Next, Chapters 3  and
4   evaluate   the   technical   feasibility    and   cost    of
vehicle-related controls  and  in-use  fuel  volatility  controls,
respectively.   Chapter  5   assesses  the  environmental  impacts
associated with  each of  the  control  strategies,   in  terms  of
projected  HC  emissions   and  ambient  ozone   concentrations;
included in these estimates is the impact of  in-use RVP  control
on  gasoline   storage  and  distribution   losses   (from  bulk
terminals,  refueling,   etc.).    Finally,  in   Chapter  6,   the
various  control  strategies  are  analyzed  and  compared  on  the
basis  of emission  reductions,  costs,  and  cost-effectiveness.
This  final  chapter  also   addresses  the  sensitivity  of  these
estimates  to  various   factors   such   as   implementation   of
refueling loss controls (on-board or Stage II), development  of
an  inspection/maintenance   program  for  evaporative  control
systems,  exclusion of exhaust emission benefits, and others.

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                            CHAPTER  2

              Current In-Use Evaporative Emissions

I.    Introduction

     This  chapter  provides  the  basic  background  information
necessary  to put  this  study of  evaporative  hydrocarbon  (HC)
control  measures  into  the  proper  context.   The  first  section
following  this  introduction  discusses  the current  widespread
ozone  non-attainment  problem, which  has  prompted the  further
study  of  HC control strategies.  Section III  provides  a  brief
background on the origin of evaporative  HC emissions  from motor
vehicles and gasoline  storage and distribution sources.   As the
focus  of  this  study  is  motor  vehicle  losses,  Section  IV
addresses  various  factors  that  can  impact  the  level of  these
evaporative  emissions.   These factors  include:   1)  the  motor
vehicle  evaporative  control   system  design,   2)  in-use  fuel
volatility  (including  the  effect  of  weathering),   3)  use  of
alcohol   blends,    and   4)   ambient   temperature   conditions.
Following  this  discussion. Section V  explains  how  data  from
EPA's  in-use emission  factor test program have been  used  to
determine  the  major reasons  for excess  evaporative  emissions
from motor  vehicles in the field (i.e.,  improper design of the
purge  system,   malmaintenance and  defects,  higher  commercial
fuel  volatility,   and   evaporative  system  tampering).   Test
results are also used to estimate the effect  of fuel  volatility
on  exhaust  emissions.   Finally,  Section  VI  summarizes  the
current problem and discusses possible  measures  to control the
evaporative  emissions  excess, such as  the reduction  of in-use
fuel   volatility    and/or   revisions    to  certification   fuel
specifications and  test  procedure;  the  specific control  options
to be  evaluated throughout  the rest of this study  are outlined
here.

II.  Ozone Violations and Seasonal Trends
     Current  violation  of  the National  Ambient  Air  Quality
Standard (NAAQS) for  ozone is quite widespread, with  54*  urban
areas currently  designated as  "non-attainment"  by EPA's Office
of   Air   Quality   Planning  and   Standards   (OAQPS).tl]    As
projections  presented  later  in  Chapter  5  will  show,   this
non-attainment problem is  expected to continue  without further
control of HC emissions.
     Includes 7 California cities.

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                              2-2

     Examination of ozone monitoring  data  recorded at  sites  in
the non-attainment  areas  has revealed seasonal  trends  in ozone
violations.  As  might  be expected,  the majority  of all  ozone
violations  occur during  the warmer  months of  the year,  when
ambient  conditions  are  most  favorable  to  ozone  formation.
These seasonal  trends  are important  in  determining during what
period  (i.e.,  specific  months)  hydrocarbon  emission reductions
would be most  valuable.   This  is  an  important  consideration
with  respect  to any  in-use   fuel-related  control   measures,  as
they  include  the flexibility to  be  implemented throughout  the
year  or  during   only  specific   months.    However,   other
evaporative   HC   control   measures   such  as   revisions   to
certification  fuel  specifications  and  test   procedure  would
affect vehicle design and,  thus,  represent year-round control.

     The following paragraphs begin with a brief description of
the method by which  the 54  urban areas  mentioned above  were
designated  as  "non-attainment."   This  is  followed by  a review
of   seasonal   trends   in   ozone   violations   within   the
non-California areas.

     All  ozone  monitoring  data  recorded  in   the  Storage  and
Retrieval of  Aerometric  Data (SAROAD)  system  between  1981  and
1983  (inclusive)  were examined  for  ozone  violations.    If  the
sites within a  specific  Standard Metropolitan  Statistical  Area
(SMSA)   had   not  recorded  any  daily  maximum  1-hour  ozone
concentrations greater than the  level of the NAAQS  (0.125  ppm)
in  1982  or  1983,  then  the SMSA  was considered  to  be  in
compliance with  the standard  and  was not  examined  further.[1]
For each of the  SMSAs  that  failed this initial test, the fourth
highest  daily  maximum 1-hour  concentration during the  3-year
period was determined; if this value was less  than the standard
of 0.125 ppm, the  city was dropped from consideration.   With a
further  stipulation that  the area  have  a population greater
than   200,000,*   54   SMSAs  were   designated   as   current
non-attainment  areas  to be modelled   for  ozone  by  EPA.tl]
However,  since  California   has   already  implemented  its  own
gasoline volatility controls, only the  47  non-California cities
were  considered  in  this   study.    These  47  current  ozone
non-attainment cities, or SMSAs,  are  listed in Table 2-1, along
with  their respective  "design values",  or  base-year  ambient
ozone concentrations to be used in EPA's modelling.fi]
     This population  cutoff was  determined  as  part  of  EPA's
     rural ozone policy, outlined in Reference 2.

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                               2-3


                            Table 2-1

         47 Current Non-California Ozone Non-Attainment
               Areas,  With Design Values*  (ppm)[l]

Region 1

Boston Metropolitan Area                            0.16
Greater Metropolitan Connecticut                    0.14
Providence-Pawtucket-Warwick, RI-MA                 0.14
Springfield-Chicopee-Holyoke, MA-CT                 0.19
Worcester, MA                                       0.13

Region 2

New York Metropolitan Area                          0.23

Region 3

Allentown-Bethlehem-Easton, PA-NJ                   0.14
Baltimore, MD                                       0.15
Harrisburg, PA                                      0.13
Huntington-Ashland, WV-KY-OH                        0.13
Norfolk-VA Beach-Portsmouth, VA                     0.14
Philadelphia Metropolitan Area                      0.18
Pittsburgh, PA                                      0.13
Richmond, VA                                        0.13
Scranton-Wilkes-Barre, PA                           0.13
Washington, DC-MD-VA                                0.16

Region 4

Atlanta, GA                                         0.17
Birmingham, AL                                      0.16
Charlotte-Gastonia, NC                              0.13
Chattanooga, TN-GA                                  0.14
Memph i S, TN-AR-MS                                   0.15
Miami, FL                                           0.14

Region 5

Akron, OH                                           0.14
Canton, OH                                          0.13
Chicago Metropolitan Area                           0.20
Cincinnati, OH-KY-IN                                0.13
Cleveland, OH                                       0.13
Dayton, OH                                          0.13
Detroit, MI                                         0.15
Indianapolis, IN                                    0.13
Louisville, KY-IN                                   0.16
Milwaukee Metropolitan Area                         0.14
St. Louis, MO-IL                                    0.14
Toledo, OH-MI                                       0.13
Youngstown-Warren, OH                               0.13

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                              2-4


                       Table 2-1 (Cont'd)
Region 6
Baton Rouge, LA                                     0.17
Dallas-Fort Worth, TX                               0.15
El Paso, TX                                         0.14
Houston, TX                                         0.28
New Orleans, LA                                     0.17
San Antonio, TX                                     0.14
Tulsa, OK                                           0.15

Region 7

Kansas City, MO-KS                                  0.13

Region 8

Denver-Boulder, CO                                  0.15
Salt Lake City-Ogden, UT                            0.15

Region 9

Las Vegas, NV                                       0.14
Phoenix, AZ                                         0.16
*    Each  area's  "design  value"  is  the  fourth highest  daily
     maximum  1-hour  ozone  concentration  recorded  during  a
     3-year period — in this case,  1981, 1982 and 1983.

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                              2-5

     In an effort to  determine  during what period HC control is
most valuable,  ozone  data  recorded   at  all  monitoring  sites
within each of these  47  SMSAs were examined for seasonal trends
in   ozone  episodes.    Reports   of   daily   maximum   1-hour
concentrations at  each monitor,  recorded for  each day  of  the
year, were obtained  for  two calendar  years  — 1983 because it
was  the most  recent  complete set of data available  at the time
of this analysis, and  1980  because it represents a  recent year
with a relatively high number of ozone violations.

     Results  of  the seasonal  analysis of  1983  and 1980 ozone
monitoring data are presented,  respectively,  in  Tables  2-2  and
2-3.   Included  in the  tables,  for  each of  the 47 SMSAs,  are
number of monitoring  sites, number of monthly violations,  and
maximum monthly  ozone  concentration.   The number of violations
represents the total number of days  in  which a  1-hour  average
ozone concentration  at  any given  site exceeded  0.125 ppm (the
NAAQS); because violations in a particular SMSA  are  summed over
all  monitoring sites  in the city, total  monthly  violations  can
exceed 31.  The maximum ozone concentration shown in the tables
is  the highest  1-hour  average concentration  recorded  at  any
site within an SMSA during the given month.

     As indicated in the tables, ozone violations tend to occur
in  the  warmer  months  when temperature conditions  are  most
favorable  for   ozone   formation.    According   to  1983  data
(summarized in  Table 2-2),  38 of  the 47 non-attainment areas
experienced  all   ozone  violations  during  the  summer  months
(i.e.,  May  through  September,  inclusive); further,  all  but  two
of the cities recorded  at  least 80 percent of  their violations
in  the  summer.   The  two excepted  cities experienced very  few
ozone  episodes  during  1983  — Scranton recorded  only  three
violations  with  one   in   April,   and  Miami's  only  reported
violation in 1983 fell during April.

     As shown in Table  2-3, non-summer  ozone violations were
slightly more prevalent  in  1980 than in 1983.   In  1980, 19 of
the  cities  experienced  at  least  one  ozone  episode outside of
the  May-September  period,   compared   to  only  9  cities  during
1983.  However,  the  vast majority of  1980 violations  occurred
during the  summer,  with 42  of  the 47 cities  recording  over 80
percent   of   all   exceedances  between   May    and   September
(inclusive).

     In both  1980 and  1983, Houston  experienced a relatively
large number  of  ozone violations,  recording  193  and 217 annual
exceedances (respectively)  over  its  13  monitoring sites.   In

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                                            2-6
City

Region 1
No. of
Sites
Boston        3
 Violations
 Max. ppm

Metro Conn   10
 Violations
 Max. ppm

Providence    4
 Violations
 Max. ppm

Springfield   3
 Violations
 Max. ppm

Worcester     1
 Violations
 Max. ppm

Region 2

New York      8
 Violations
 Max. ppm

Region 3

Allentown     3
 Violations
 Max. ppm

Baltimore    12
 Violations
 Max. ppm

Harrisburg    3
 Violations
 Max. ppm

Huntingtbn    1
 Violations
 Max. ppm
                    Table 2-2

     Monthly  Trends  in Ozone Violations - 1983


Jan   Feb   Mar   Apr    May    Jun   Jul   Auq   Sep    Oct   Nov   Dec
                                         7352
         .021  -     .037  .116  .092  .205  .133  .146  .149   .108   .030   .032
                             5          74    63     65    60      1
                           .181  .118  .294  .223   .224  .222   .129   -
                                         2223
         .038  .048  .051  .101  .073  .171  .137   .132   .150   .119   .056   .043
         .015  .077  .035
                    2
                  ,175
.097
                           ,103  .080
  7
.162
                                1
                              .132
 10
,255
            .120
  7
,185
              2
            ,145
  3
.145
              1
            .145
,107   .042   .035
            ,100   -
                             1          30    20    25    13
         .050  .067  .059  .138  .099  .209  .224  .160  .172   .113   .065   .038
                                        942
         .040  .054  .057  .112  .092  .173  .138  .143  .120   .103   .069   .041
                                         1           2
         .035  .075  .053  .071  .111  .149  .117  .151  .110  .082   .045   .034
         .039  .066  .054  .111  .108
         .039  .081  .075  .076  .088
                                7
                              ,200
                                2
                              ,130
            .123   .120   .109   .090   .056   .032
              541
            .138   .130   .150   .091   .054   .048

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                                            2-7
Cits
No. of
Sites
Norfolk       1
 Violations
 Max. ppm

Philadelphia 12
 Violations
 Max. ppm

Pittsburgh    7
 Violations
 Max. ppm

Richmond      3
 Violations
 Max. ppm

Scranton     4
 Violations
 Max. ppm

Wash. D.C.   12
 Violations
 Max. ppm

Region 4

Atlanta       2
 Violations
 Max. ppm

Birmingham    3
 Violations
 Max. ppm

Charlotte     3
 Violations
 Max. ppm

Chattanooga   2
 Violations
 Max. ppm

Memphis       3
 Violations
 Max. ppm

Miami         3
 Violations
 Max. ppm
                                   Table  2-2  (continued)
Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec
                                               1     1
         .041  .061  .072  .083  .092  .121  .130  .135  .119  .070  .064  .044
                 1                 1    56    38    32    22     1
         .039  .145  .073  .120  .134  .205  .182  .181  .162  .138  .065  .080
                                         4531
         .064  .066  .094  .091  .108  .133  .142  .175  .141  .088  .061  .038
                                         3132
         .040  .065  .075  .085  .090  .150  .150  .130  .140  .100  .055  .045
                             1           2
         .037  .052  .061  .127  .073  .135  .114  .107  .106  .086  .068  .040
                                        30    28    15    15
         .040  .077  .073  .092  .102  .176  .195  .249  .175  .092  .058  .034
                                         2    14    12
                           .080  .122  .133  .195  .155  .100  .108  .070 -
                                               2    10
         .058  .069  .085  .093  .098  .093  .142  .171  .113  .112  .072  .047
                                   1135
         .047  .6.71  .076  .086  .130  .135  .155  .148  .117  .117  .066  .057
         .058  .073  .090  .085  .090  .118  .095  .150  .108  .103  .063  .058
                                               3     6
         .045  .070  .090  .090  .080  .095  .150  .148  .120  .100  .050
         .070  .060  .115  .230  .095  .070  .065  .100  .055  .090  .085  .055

-------
                                            2-8
 City

 Region 5
No. of
Sites
                                   Table 2-2 (continued)
Jan   Feb   Mar   Apr   May   Jun   Jul   Aug    Sep    Oct   Nov   Dec
 Akron        4
  Violations
  Max.  ppm

 Canton        2
  Violations
  Max.  ppm

 Chicago      23
  Violations
  Max.  ppm

 Cincinnati   8
  Violations
  Max.  ppm

 Cleveland    6
  Violations
  Max.  ppm

 Dayton        4
  Violations
  Max.  ppm

 Detroit       3
  Violations
  Max.  ppm

 Indianapolis  6
  Violations
  Max.  ppm

 Louisville   3
  Violations
  Max.  ppm

 Milwaukee    9
  Violations
  Max.  ppm

 St.  Louis    9
  Violations
•  Max.  ppm

 Toledo       3
  Violations
  Max.  ppm

 Youngstown   1
  Violations
  Max.  ppm
                                         243
         .035  .068  .095  .095  .085  .130  .130   .130   .105   .115   .048   .035
                                         1           1
         .033  .052  .082  .075  .097  .125  .123   .125   .098   .080   .058   .037
                                        19    33      9      5
         ,043  .089  .072  .084  .089  .188  .180   .155   .141   .096   .065   .092
                                         2     4     20      1
         .050  .073  .080  .080  .087   .135  .162   .190   .147   .095   .057   .042
                                         49      6      2
         .040  .061  .075  .090  .085  .153  .158   .151   .135  .083   .083   .033
         .035  .075  .077  .077  .075  .122  .120   .132   .105   .095   .047   .035
                                         8241
         .044  .050  .087  .095  .116  .170  .136   .142   .125   .089   .038   .035
                                         325
         .044  .078  .076  .091  .094  .131  .138   .155   .104   .090   .065   .074
                                         2     12     14
         .042  .069  .071  .060  .075  .138  .148   .190   .116   .091   .060   .034
                                        15     9     15      5
         .030  .035  .047  .101  .090  .165  .179   .228   .140   .115   .037   .032
                                        10    15     34
         .037  .066  .096  .107   .090  .160  .177   .243   .121   .104   .019   .036
                                         3           11
         .035  .040  .055  .070  .085  .130  .115  .125  .130   .100   .035   .030
         .040  .065  .080  .087   .080  .125  .100   .100   .097
                                                            .035   .030

-------
                                         2-9


                                  Table  2-2  (continued)

           No. of
City       Sites    Jan   Feb   Mar    Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec

Region 6

Baton Rouge  6
 Violations                                   11132
 Max. ppm           .070  .061  .107  .090  .130  .130  .125  .169  .139  .120  .085  .100

Dallas       7
 Violations                                   6     5     6    23     3
 Max. ppm           .070  .080  .080  .090  .140  .170  .170  .170  .140  .120  .070  .050

El Paso      3
 Violations                                               2           1
 Max. ppm           .090  .090  .090  .080  .110  .100  .140  .120  .150  .100  .090  .090

Houston      13
 Violations                 3    12      4    62    30    28    33    25    16     1     3
 Max. ppm           .120  .140  .160  .140  .290  .230  .240  .250  .340  .190  .150  .180

New Orleans  4
 Violations
 Max. ppm           .066  .094  .113  .084  .124  .093  .115  .121  .117  .096  .064  .060

San Antonio  2
 Violations                                                           2
 Max. ppm           .080  .090  .070  .070  .090  .110  .100  .120  .140  .120  .060  .060

Tulsa        3
 Violations                                               4     2
 Max. ppm           .052  .067  .070  .083  .091  .099  .138  .132  .112  .097  .057  .041

Region 7

Kansas City  5
 Violations                                               1     2
 Max. ppm           .037  .080  .080  .079  .065  .095  .130  .142  .116  .093  .061  .046

Region 8

Denver       7
 Violations                .             1           2     6    11     1                 1
 Max. ppm           .077  .064  .120  .141  .106  ,155  .140  .176  .127  .075  .080  .128

Salt Lake
 City        6
 Violations                                   124
 Max. ppm           .046  .059  .079  .067  .130  .102  .135  .158  .113  .089  .051  .052

Region 9

Las Vegas    3
 Violations                                                           1
 Max. ppm           .098  .118  .086  .077  .091  .100  .110  .121  .138  .085  .074  .078

Phoenix      9
 Violations                                   21281
 Max. ppm           .069  .078  .n ni  .08S  . 1'. ?  .135  .160  .160  .139  .104  .07}  .050

-------
                                            2-10


                                         Table  2-3

                          Monthly Trends  in Ozone Violations  - 1980
City

Region 1
No. of
Sites
Boston       10
 Violations
 Max.  ppm

Metro Conn.  10
 Violations
 Max.  ppm

Providence   3
 Violations
 Max.  ppm

Springfield  1
 Violations
 Max.  ppm

Worcester    3
 Violations
 Max.  ppm

Region 2

New York     9
 Violations
 Max.  ppm

Region 3

Allentown    4
 Violations
 Max.  ppm

Baltimore    16
 Violations
 Max.  ppm

Harrisburg   2
 Violations
 Max.  ppm

Huntington   1
 Violations
 Max.  ppm
Jan   Feb   Mar   Apr   May   Jun   Jul    Aug   Sep    Oct    Nov   Dec
                                         7    11     8
                           .093  .079  .154  .150  .159  .098  .061  .032   .029
                                  12    44    89    50    30
         .043  .058  .060  .090  .189  .276  .303  .249  .230  .106  .034  .032
         ,040  .050  .070  .100  .140
                                6
                              ,190
                                         2
                                       ,185
  9
.208
                                      5
                                    .153
  8
.222
        1
      .155
  1
,135
        1
      ,150
.112   .060   .052
      .087   -
                                         231
                           .075  .095  .177  .193  .170  .106  .080  -
                       1           3    13    49    26     5
         .032  .036  .222  .095  .159  .190  .188  .174  .131  .077  .040  .092
           11                 23447           2
          ,139  .344  .050  .090  .127  .161  .152  .143  .151  .083  .152  .044
                             1     2     8    54    38    11
         .039  .041  .057  .137  .128  .162  .183  .195  .157  .091  .061  .058
         .078  .048  .078  .095  .115  .116  .112
                             11           2
         .037  .053  .056  .130  .129  .088  .147
                                            1
                                          ,128
              1
            .128
            .088   .068   .035
                                          ,120  .090  .089  .070  .052

-------
                                           2-11


                                   Table  2-3  (continued)
           No. of
City       Sites    Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   pet   Nov   Dec


Norfolk      2
 Violations                                               1
 Max. ppm           .031  .044  .050  .091  .115  .120  .126  .119  .116  .076  .061  .035

Philadelphia 17
 Violations                                   3    30    60    43     7           21
 Max. ppm           .043  .050  .070  .110  .142  .197  .228  .201  .168  .089  .349  .239

Pittsburgh   12
 Violations                                         7    14    10     1
 Max. ppm           .039  .051  .063  .087  .117  .174  .298  .160  .128  .087  .076  .044

Richmond     3
 Violations                                   1           1
 Max. ppm           .030  .055  .055  .095  .135  .115  .130  .120  .120  .075  .055  .045

Scranton     4
 Violations                                         3321
 Max. ppm           .034  .041  .054  .092  .120  .155  .148  .145  .151  .089  .041  .045

Wash. DC     15
 Violations                                   3     2    18    28     5
 Max. ppm           .040  .055  .055  .088  .147  .133  .195  .207  .167  .090  .071  .070

Region 4

Atlanta      4
 Violations                                         1442
 Max. ppm           .050  .090  .070  .100  .105  .135  .160  .150  .150  .080  .080  .070

Birmingham   3
 Violations                                               9     3
 Max. ppm           _____     .117  .157  .161  .115  .099  .092  .072

Charlotte    4
 Violations                                               5     4
 Max. ppm           .045  .075  .071  .092  .117  .118  .154  .145  .119  .098  .077  .056

Chattanooga  2
 Violations                                         1
 Max. ppm           .045  .070  .060  .090  .100  .135  -     -     .095  .090  .068  .060

Memphis      4
 Violations                             1172           2
 Max. ppm           .053  .070  .070  .165  .130  .140  .200  .110  .160  .072  .087  .060

Miami        2
 Violations                                                     111
 Max. ppm           .052  .100  .075  .070  .080  .050  .085  .155  .130  .150  .075  .070

-------
                                         2-12
                                  Table 2-3 (continued)
Cit\
No. of
Sites    Jan   Feb   Mar   Apr   May   Jun   Jul    Aug    Sep   Oct   Nov   Dec
Region 5

Akron        4
 Violations
 Max. ppm

Canton       2
 Violations
 Max. ppm

Chicago      27
 Violations
 Max. ppm

Cincinnati   7
 Violations
 Max. ppm

Cleveland    7
 Violations
 Max. ppm

Dayton       4
 Violations
 Max. ppm

Detroit      8
 Violations
 Max. ppm

Indianapolis 5
 Violations
 Max. ppm

Louisville   8
 Violations
 Max. ppm

Milwaukee    8
 Violations
 Max. ppm

St. Louis    19
 Violations
 Max. ppm

Toledo       2
 Violations
 Max. ppm

Youngstown   2
 Violations
 Max. ppm
                                               1            1
         .030  .040  .053  .088  .103   .103   .133   .118   .153   .073   .063   .040
         .035  .037  .070  -     .095   .100   .110   .105   .085   .080   .062   .040
                       4                 4     17      9      1
         .039  .056  .361  .111  .124   .148   .195   .163   .132   .074   .056   .091
                                        16     22      7
         .037  .050  .060  .102   .122   .165   .172   .137   .120   .100   .065   .050
         .038  .043  .060  .090  .104   .119   .152   .102   .099   .061   .061   .040
                                               3      1
         .040  .050  .055  .092   .115   .102   .156   .132   .100   .082   .052   .042
                             12173
         .040  .092  .083  .139  .145   .155   .149   .151   .121   .085   .082   .084
                                         2      3
         .107  .119  .073  .102   .123   .140   .142   .121   .117   .117   .056   .049
                                   1      5     18     15      2      1
         .045  .060  .060  .090  .175   .169   .190   .197   .158   .130   .081   .081
                                         3            81
         .033  .045  .045  .086   .119   .140   .124   .177   .126   .046   .035   .029
                       1     3      2     13     29     18      6      5            1
         .070  .078  .205  .161   .199   .199   .171   .177   ,162   .157   .105   .125
                                               3      1
         .035  .050  .060  .105  .105   .115   .140   .145   .105   .080   .050   .035
         .038  .037  .055  .085  .075   .160   .110   .095   .090   .060   .050   .050

-------
                                         2-13


                                  Table  2-3  (continued)

           No. of
City       Sites    Jan   Feb   Mar    Apr   May   Jun   Jul   Aug   Sep   Qct   Nov   Dec

Region 6

Baton Rouge  3
 Violations                                               4143
 Max. ppm           .057  .056  .064  .085   .087  .124  .154  .137  .193  .218  .102  .070

Dallas       7
 Violations                             127532
 Max. ppm           .060  .110  .120  .130   .180  .180  .150  .140  .160  .100  .090  .100
V
El Paso      2
 Violations                                         2           13           1
 Max. ppm           .080  .090  .070  .080   .120  .160  .080  .130  .160  .100  .130  .090

Houston      13
 Violations           6     1     1      4    27    19    31    36    31    22    10     5
 Max. ppm           .160  .190  .140  .150   .280  .220  .220  .260  .340  .350  .230  .160

New Orleans  1
 Violations                                               1
 Max. ppm           .031  .040  .032  .038   .023  .114  .126  .095  .068  .088  .072  .048

San Antonio  3
 Violations
 Max. ppm           .060  .100  .080  .110   .120  .120  .120  .110  .120  .120  .090  .070

Tulsa        3
 Violations                                         1544
 Max. ppm           .066  .068  .098  .088   .117  .129  .201  .145  .132  .087  .077  .047

Region 7

Kansas City  5
 Violations                                         1951
 Max. ppm           .040  .060  .080  .120   .090  .135  .160  .160  .140  .108  .087  .051

Region 8

Denver       8
 Violations                ;                               31
 Max. ppm           .086  .102  .068  .080   .116  .117  .165  .128  .103  .100  .072  .085

Salt Lake    5
 Violations                                         3721
 Max. ppm           .061  .085  .092  .088   .121  .155  .182  .178  .146  .105  .075  .040

Region 9

Las Vegas    3
 Violations           11                                                     11
 Max. ppm           .145  .135  .080  .113   .080  .090  .095  .093  .049  .118  .169  .143

Phoenix      8
 Violations                                         8    14     3     1     1
 Max. ppm           .049  .088  .095  ..08   .110  .148  .174  .143  .133  .129  .097  .078

-------
                              2-14

1980, 25  percent of  these  violations occurred  outside of  the
May-September period;  the 1983 figure  is  slightly lower  at 18
percent non-summer violations.

     In  evaluating various  seasonal  options  for  in-use  fuel
volatility  control,   it  is  important to  consider the  periods
during which ozone  reductions are most needed.  The  upper half
of Table  2-4 summarizes  the seasonal trends in ozone violations
indicated in the previous  two tables, outlining the  percentage
of total  annual  violations  that occurred in the 47 areas during
specific summer  periods  (i.e.,  various monthly combinations) in
1980 and  1983.   These percentages are based on total violations
summed  over all monitors  in  all  47 areas;  therefore,  those
cities  with  more  monitors  contribute  more  heavily  to  the
weighted average.  Because  Houston recorded a  relatively  large
number of  non-summer  violations,  results  are  presented for all
47 cities combined and then for all cities excluding Houston.

     As  shown,  the individual  month during  which the  highest
percentage  of  all  1980  violations  occurred  was July,  with 39
percent of  the total;  in 1983, August was the highest  with 31
percent of  total annual violations.   In addition  to individual
months,  the 2-,3-,4-,  and 5-month  periods  recording the highest
percentages  of  total  violations  are  presented.   As  shown,
in-use  fuel  volatility  control   between May  and  September
(inclusive)  could potentially  have  an impact on  94-97  percent
of  all  ozone  violations in  current  non-attainment  areas;  if
Houston  were  excluded,   this  5-month   period  would  encompass
essentially  all  ozone   episodes.    Four-month  control  would
impact just slightly  less of the  ozone  season —  89-92 percent
of total violations in  all  cities and 94-98 percent  if  Houston
were excluded.

     The  bottom  half  of  Table  2-4 summarizes  the  seasonal
trends in peak ozone  concentrations,  first showing  the average
of  all  47  cities'  peak ozone  levels by month, then including
only those concentrations over  the NAAQS (0.125  ppm).   The data
used  are  those   in   Tables   2-2  and  2-3  for  1983  and  1980,
respectively.    As   can   be    seen,    average   peak   ozone
concentrations show a definite trend between  highs of  0.156  -
0.162 ppm  in July or  August  to  lows of 0.050  -  0.055 ppm in
January.  When only peaks above the  standard  are  included, the
trend is  less pronounced.   The  reason  for  this  is that  the
summer   averages  are   a   mixture   of   marginal  and   severe
violations, while the winter  averages primarily consist of the
marginal  to  moderate  violations  of those   cities  with  more
severe  violations  in  the   summer.    Cities  with   marginal
violations  in  the  summer  generally  show  no violations in the
winter and, thus, are excluded from the averaging.

-------
                         2-15
                       Table 2-4

          Seasonal  Trends  in Ozone  Violations
              in 47 Non-Attainment  Areas 	
                 Percent of Total Annual Violations
Months


April
May
June
July
August
September
October
Jul-Aug
Jun-Aug
Jun-Sep
May-Sep

Months


January
February
March
April
May
June
July
August
September
October
November
December
All Cities

1980
1
5
13
39
27
10
2
66
79
89
94
Average of
All Ozone
Levels
1980
0.055
0.075
0.082
0.101
0.123
0.151
0.162
0.151
0.134
0.101
0.084
0.067
All Cities Except

1983
1
5
22
26
31
13
1
57
79
92
97
City-Specific

Houston*
1980
1
3
14
43
28
9
1
71
85
94
97
Monthly Peaks
Ozone Levels

1983
1
1
23
28
34
13
0
62
85
98
99
(ppm)
Above
Standard ( . 125 ppm)
1983
0.050
0.073
0.080
0.099
0.103
0.144
0.149
0.156
0.133
0.102
0.061
0.053
1980
0.148
0.223
0.232
0.145
0.160
0.166
0.174
0.165
0.158
0.189
0.206
0.167
1983
__
0.143
0.160
0.162
0.155
0.161
0.161
0.162
0.155
0.152
0.150
0.154
Houston is  excluded here due to  a  relatively large number
of non-summer violations.

-------
                              2-16

III.  Sources of Evaporative HC Emissions

     A.    Motor Vehicles

     Evaporative  HC  emissions  from  motor   vehicles  can  be
separated into two  basic  categories  — "diurnal" and "hot-soak"
losses  —  that  result   from  different   processes.    Diurnal
emissions consist of  HCs  both evaporated and displaced from the
vehicle's fuel tank  as  the vehicle tracks the diurnal  swing in
ambient  temperatures.   Each  day,  as the  fuel  in the  tank and
the  vapor  above  the fuel  heat  up,  more  of the  liquid  fuel
evaporates  and  the  vapor  itself  expands,  with both  phenomena
causing HCs to be released  into  the  atmosphere  (unless captured
by a control system).   Fuel  volatility,  size of vapor  space,
initial  ambient  temperature,  and  magnitude  of  the  diurnal
temperature  swing  can  all  impact  the  level  of  evaporative
emissions from a vehicle's fuel tank.

     Hot-soak  emissions  occur  during  the  period  immediately
following engine  shut-down  (i.e.,  at  the  end of each vehicle
trip).   These  losses will  occur  both  as distillation  from the
fuel  metering  system (either  a  carburetor  or a  fuel  injector)
and  as  evaporation  from the  fuel tank.  Evaporative  emissions
from  the fuel  metering  system  occur  as part  of a  different
process  than  that   described for  diurnal  losses.    When  the
vehicle's engine  is  shut  off,  so  is  the cooling system.   The
engine  block  and  surrounding  area  heat  the  engine  coolant
(which  is  no longer  circulating) and  other  engine  components,
usually  kept  cool  by the  circulating  coolant,  before natural
cooling  begins  to   take   effect.   Any  fuel  remaining in  the
carburetor  bowl,   or  leaking   from   a  malfunctioning   fuel
injector, will  undergo  a  distillation  process during  this time
and  vapors  will  be  released  ~to the atmosphere  unless captured
by a control  device.  This  was previously considered  the only
source  of  hot-soak  emissions,  but  there  have  been  recent
indications that  the fuel tank  in  fuel-injected vehicles  can
undergo  a   temperature  change  during   vehicle  operation  as  a
result  of  recirculation  of fuel  heated  by the  engine.   Vapor
production in the tank would be the same type  as  that  described
above  for  diurnal  losses;  however,  because  these tank  losses
are  not  in  response  to  ambient  temperature  changes,   they are
classified as hot-soak emissions.

     B.    Gasoline Storage and Transfer

     In  addition to diurnal and  hot-soak  losses  from  motor
vehicles, evaporative HC  emissions  are also  released  during
gasoline    storage     and    transfer.     These    stationary
gasoline-related  sources  can   be   divided   into  three  basic
categories:   l) bulk  storage  and bulk transfer of gasoline,  2)
service  stations  (Stage  I),  and  3)  vehicle refueling  (Stage
II).

-------
                              2-17

     Storage emissions  are  very similar to  diurnal  losses from
motor  vehicles  in that  they  occur  as  gasoline  'in  a  tank
responds  to  daily   increases   in  ambient   temperature.   The
transfer losses  (included in  all  three categories)  result from
the displacement  of  gasoline vapors within  a  previously closed
tank with  liquid  fuel;  as  the  liquid goes  in  the tank,  the
vapors   escape   through  available   openings   (primarily  the
refueling line).

     Gasoline  storage  and  distribution  losses  are  dependent
upon  such  factors  as  fuel  volatility,   ambient  temperature
conditions,  tank  configurations,  method  of  fill,  etc.   The
three  source categories  will be  discussed in  more detail  in
Chapter 5,  where the effect  of fuel volatility  on the magnitude
of stationary source evaporative losses will  be addressed.

IV.  Factors That  Can  Impact  Evaporative Emissions  from Motor
     Vehicles

     A.    Evaporative Control System Design

     1.    Description

     Present evaporative  emission  control systems  are  composed
of:  1)  an  activated  carbon  canister that  adsorbs  hydrocarbon
vapor  emitted  from the vehicle  fuel  tank and  carburetor bowl,
and 2)  the  associated  plumbing and  hardware that  control the
loading  and  purging  of  the   canister.    Additionally,  some
carbureted  systems  use  an  air  cleaner  with  an  integrated
charcoal element  to  further  adsorb  bowl and  intake  manifold
vapors.  When  the engine  is  running,  this  stored vapor  is
desorbed, or purged,  by drawing air through  the  canister to the
engine  intake  system.   The  purge rate  is   controlled   by the
source of  the  vacuum (air  cleaner,  carburetor  (above  throttle
blade)   or   intake manifold),  the pressure drop  through  the
canister and the size  of  the controlling  orifice  (located  in
either the  canister   or  purge port).   A diagram of a  typical
evaporative control system is presented in Figure 2-1.

     2.    System Working Capacity

     The actual  mass  of  gasoline  vapors that  an  evaporative
control  system  will   continually  adsorb   and  desorb  during
operation  is referred  to  as  the "system  working  capacity".
This working capacity will  be dependent upon many factors, some
of  which  are  internal  to  the  system  and  others  that  are
external.   Among  the  internal  factors  are:    the  volume  of
charcoal in  the  canister, the physical  characteristics  of the
charcoal, the  canister configuration,  and  the volume of purge
air drawn  through by the control  system.    Factors that  also

-------
                                               Figure 2-1

                              Typical  Evaporative  Control System
                                                   Carb. Bowl
                                                    Fitting
                                                                       Carb.
                                                                  Bowl Valves

                                                                  0.047" Bleed
                                                                  To Fuel Tank
                                                         Purge
                                                   Valve. Drilled
                                                     To 0.180"
Carton-
     TO
     PORTED
     VACUUM

 VAPOR TO
 INDUCTION
 SYSTEM
DIAPHRAGM;
 BODY
 COVER
                VALVE
                STEM
                                                                                       COVER
VAPOR
FROM
FUEL
TANK
                                   •Foam
                                     IrtMesh
                                   •Fiberglass Air Filter
TO
MANIFOLD
VACUUM
SIGNAL

 VAPOR
 FROM
 BOWL
 VENT

DIAPHRAGM

  ING
10

M
CD
                                FILTER
                                                                          RETAINER
                                                                                     UNDER
                                                                                     VACUUM

-------
                              2-19

play a  role in determining  system working capacity,  but  which
are  subject to  little  or  no  system  control,  include:    the
temperature   and   humidity   of   purge   air   and  the   vapor
concentration of the evaporative  emissions.   This latter  effect
was  noted  in  an  EPA  report  comparing the  ability  of  two
different charcoals to adsorb  and desorb HC vapors  using  fuels
of varying volatility, and will be discussed further in Chapter
3.[3]

     Manufacturers  can  design  evaporative  emission  control
systems to have a  specific system working capacity by adjusting
those   factors  that   are   subject   to   their    control,   with
consideration given  to the  variations  in the  external  factors
mentioned   previously.     Current   certification   tests    are
performed  using  Indolene,  which  has   an  average  Reid  Vapor
Pressure  (RVP)  of  9.0 psi;  therefore,  this  is  the volatility
level at which  current evaporative control  systems are designed
to meet  the current evaporative  HC  standard  of 2  grams/test.
Actual  in-use fuel,  however,   has an  RVP closer  to 11.5  psi
during  the  summer  months,  representing  higher   levels   of
evaporative  emissions  than  those  encountered  by the canister
during   the  certification   test.   Thus,   there   exists   a
significant difference in  the  levels of  emissions  that  current
evaporative control systems  are  designed to  capture  and  those
that are encountered in actual operation.

     B.   Fuel Volatility

     1.   Proper Measure of Fuel Volatility

     A number  of  different  gasoline  properties may be used to
indicate  gasoline  volatility.    Each   year,  in   a   document
referred  to  as  D-439,   the  American  Society  of  Tests  and
Measurements  (ASTM)  publishes  recommended  limits   for  several
gasoline  volatility  parameters,  including  Reid  Vapor Pressure
(RVP), distillation characteristics (such as  the  temperature at
which a given percentage  of  gasoline  is evaporated), and  the
temperature  corresponding  to  a given gasoline vapor-to-liquid
ratio  (V/L).    For every  month  of  the  year,  each  state  is
assigned   a   "volatility   class"   that   represents   ASTM's
recommended limits  on  the volatility of gasoline sold in that
state.  The five gasoline  volatility  classes are designated as
A, B,  C, D,  and E; corresponding volatility  limits  for  these
five classes are shown in  Table 2-5.   As indicated, Class A is
the least volatile  and Class E is the most volatile.  It  should
be noted that these ASTM specifications are  merely  recommended
levels  and  are not  legally binding  for gasoline refiners.   A
number  of  states  have adopted  ASTM standards  as legal  limits.
However, the  effectiveness of  these  limits depends  directly on
enforcement  and  it is  questionable  how  strictly these  limits
are  enforced  in many  states  (California  being  an  exception).

-------
                    2-20





                  Table 2-5



ASTM D-439 Gasoline Volatility Specifications


Distillation Temp.
(°F) at


Given Percent Evaporated
ASTM
Volatility
Class
A
B
C
D
E

Max. RVP
(psi)
9.0
10.0
11.5
13.5
15.0
Max. Min.
@ 10% @ 50%
(T10) (Tso)
158 170
149 170
140 170
131 170
122 170
Max.
@ 50%
(Tso)
250
245
240
235
230
Min . Temp .
@ V/L =
f ^n
V ^ 2 O V / 1* t
140
133
124
116
105
20
,°F)






-------
                              2-21

Measured   in-use   RVP   levels   (grouped   according  to   ASTM
volatility  class)  and  the  effect  of  state  limitations  are
addressed in more detail in Section 2 below.

     The major  reason  behind ASTM's  assignment  of  volatility
limits  is  the   prevention  of  vapor  lock  at  high  ambient
temperatures and problems with  starting the engine  under colder
conditions.   As   shown   in   Table  2-5,   values   for   RVP,
vapor-liguid  ratio,  and distillation temperatures  are  defined
for each of the  five fuel  volatility classes (A through E).   In
turn, minimum and maximum  ambient  temperatures under which  no
problems with cold startability or  vapor  lock would  occur  are
calculated for each  volatility  class.   Then,  temperature data
for each geographical  area are used to select the appropriate
volatility classes for  each  month  of the  year.   A U.S.  map
indicating ASTM's state  volatility  class  recommendations  for
the month of July is provided in Figure 2-2.

     In  order  to   determine  the   most   significant  gasoline
volatility  parameters   with   respect  to   the  magnitude   of
evaporative HC losses,  it  is important  to  consider  the source
of  the  evaporative  emissions.   The measure  of  fuel volatility
relevant to diurnal  emissions should ideally reflect volatility
at  temperatures   typically  associated with a  vehicle's  fuel
tank.   The  most  widely  accepted  measure  of  volatility  in
relation to diurnal  emissions  is  RVP, a  measure  of the fuel's
vapor pressure at 100°F.[4,5]

     Hot-soak emissions originate   both from the fuel  tank  and
the fuel metering system,  as  indicated previously.   The process
occurring  in  the  fuel  tank  is  much the  same  as  with  diurnal
emissions.    Therefore,  RVP    is   an  appropriate   measure  of
volatility for this  portion of  the hot-soak  emissions.   On  the
other  hand,   since  the temperatures experienced  in the  fuel
metering system can  be  much higher  than  100°F,  RVP may not  be
ideal as an overall  indicator of hot-soak emission levels.  The
relationship  between temperature,   volatility  and  evaporative
losses  is  not as  clear  in a carburetor or  fuel  injector as  in
the fuel tank due to  the  complex  interactions  that  occur. [6]
Only limited work in this  area has been done with fuel-injected
vehicles,   but carbureted   vehicles  have  been  studied  fairly
extensively.   Hot-soak  losses   from a carbureted  vehicle  are
generally  felt to be related also to the mid-range volatility
of  the  fuel,  given  as  the percent  of fuel volume  distilled  in
an  ASTM D216 distillation  at the  peak  temperature  in  the
carburetor bowl.[4,6-9]   This  peak temperature will  vary from
vehicle to vehicle  and may  also  be  affected  somewhat  by  the
ambient  temperature.   An  average  value  for  the  peak  bowl
temperature is around 160°F and, therefore,  the percent  of fuel

-------
                                            Figure 2-2
                                   ASTM's July Volatility Classes
                   1^11*555

             .sssr—	
             17^
A = 9.0 psi
B = 10.0 psi
C = 11.5 psi
                                                "X.

-------
                              2-23

evaporated  at  160°F  (%iso),   in  addition  to  RVP,   may be  a
relevant  fuel parameter  for  estimating hot-soak  losses.[4,7]
EPA  is  currently  testing  several fuels  with the same  RVP  but
with  varying  %i6o  points;  hot-soak  and  diurnal  losses  are
being measured  for a total  of 40 carbureted  and fuel-injected
vehicles  to  determine  the  impact,  if  any,  of  %i6o-    As only
very  preliminary  data  are   available   at   this   time,   no
conclusions can be made.

     Theoretically,  because  total  evaporative HC  emissions  are
represented  by the  sum  of  hot-soak  and  diurnal losses,  the
ideal measure of  fuel  volatility  to   be  used  in  evaluating
various  evaporative  emission  control  strategies  would  most
likely  be   some   combination   of   both  RVP  and   %iso.    The
weighting given each of these  factors would be expected to vary
with vehicle type, as  fuel-injected  vehicles  have significantly
lower hot-soak emissions  and,  thus,  their relative losses would
be more  dependent upon RVP.   Also,  operating temperatures  can
vary from model  to  model,  so  160°F may  not  be  the appropriate
point on the distillation curve for all vehicles.

     Some  attempts have been  made  to incorporate both  RVP  and
various  distillation points  into  a volatility  index.    In an
effort to  correlate  evaporative emissions to the  volatility of
gasolines  and methanol/gasoline  blends, DuPont developed  the
Evaporative Index (El), as shown below:

     El = 0.85(RVP) + 0.14(%20o> - 0.32(%100).[10]

In their  application for a  waiver  of  methanol  blends,  DuPont
showed a  correlation of El  versus evaporative emissions with an
R2  value  of  0.86.[10]   However,  some  criticisms  have  been
raised  with  respect   to  DuPont's   analysis,   such  as  their
combining  the  results  of  two  independent  testing  programs
without   normalizing  the  results  and  the   lack  of   higher
volatility gasolines and blends in the analysis.[11,12]

     The Front End Volatility  Index  (FEVI), which was  developed
for  purposes  other  than  emissions  estimation   (primarily  the
control of vapor lock), is defined as:

     FEVI = RVP + 0.13(%1S.)•[13]

This index essentially  includes the  two terms most  relevant to
evaporative   emissions   (%isi   is   very   close   to   %ieo).
However,  it  is currently unknown  if its relative  weighting of
the two parameters is appropriate.

-------
                              2-24

     Another  gasoline property  used to  measure volatility  is
the   temperature   corresponding  to   a   specified   gasoline
vapor-to-liquid  ratio  (V/L)  at  atmospheric pressure.   This V/L
is the volume  of vapor formed at atmospheric pressure  and  test
temperature  divided by the  initial  volume  of  liquid  gasoline
tested.  The temperature at which this vapor-to-liquid  ratio is
equal  to  20  at  atmospheric pressure  is  designated  TZOVXL.
The  TZOVXL  parameter  is  included  in   the   ASTM  volatility
specifications  (shown  in  Table  2-5) and,  according to  API,  is
commonly  used   for   blending  purposes  by   refiners.    Since
limiting  TZOVXL  can  affect  the other evaporative-related  fuel
parameters, it deserves further discussion here.

     ASTM   D-439  provides   an   empirical  equation   defining
TZOVXL  as  a  function of  the following  parameters:  RVP,  the
temperature  at  which 10 percent  of  the gasoline  is evaporated
(Tio),  and  the  temperature  at  which  50   percent   of   the
gasoline is evaporated (T5o).   This equation is:

     TZOVXL - 114.6 - 4.KRVP) + 0.2(T10)  + 0 . 17(TS o ) - [ 14 ]

     In   the   above  equation   for   TZOVXL,    RVP   contributes
significantly   more   to   TZOVXL   than   does   Ti0  or   Tso.
According to  survey  data,  fuels  with RVPs ranging from  11.5  to
9.5  psi  have  Ti0s  ranging  from  108-120°F  and Tsos  ranging
from 210-220°F.[15]  This  2-psi  RVP  range accounts  for  roughly
an   8°F  change  in   TZOVXL,   if   TIO   and   Tso  are   held
constant.     If   the  corresponding  Ti0s   and  Tsos   for   the
different  RVPs  are  used  in the  TZOVXL  equation,  then  the
TZOVXL  changes  by  nearly  12°F.   This  indicates  that  RVP  is
the  major   factor   affecting TZOVXL,  but   Tio  and  T5o   are
not negligible.

     As mentioned earlier, El  and FEVI are  indices  relating RVP
and distillation curve characteristics to gasoline volatility.
The two are compared to TZOVXL in the following paragraphs.

     El is  similar  to T20VxL in  that both  equations   use RVP
and  two  points  on  the distillation  curve — one near  100°F
(Tio)   and   the   other    near   200°F  (Tso).    The   equation
estimating  TZOVXL  is  more   readily  understandable  than  that
for  El,  because   the positive  or  negative   signs   of   the
coefficients  reflect  the trend  in basic gasoline  volatility
changes with  the  specific parameters  of  the equation.    For
instance,   as  RVP  increases,  volatility  increases and  TZOVXL
decreases;  also, as  Tio   decreases,  volatility  increases  and
TZOVXL  decreases.   This  is not  the case  for  El (where a  high
El  indicates  high  volatility)  because   as   %ioo, increases,
volatility  should increase, yet  El  decreases.   Nevertheless, of
all the terms in the  equations, RVP has  the  most  significant
impact  on  both  El  and  TZOVXL.   In  each  case,  for   a  2-psi

-------
                              2-25

change in RVP  (11  psi to 9 psi) and  corresponding distillation
characteristics, the  change  in  RVP accounts for  70-80 percent
of the net change in the indices.

     According  to  industry,   FEVI  and  T20vxL   are  closely
related  and  serve the  same function  in  indicating  gasoline
volatility.    Examination of  the  fuel properties  reported  in
MVMA's summer  gasoline surveys  for  1977  through 1984 indicates
an   excellent  correlation   between   FEVI   and   T20v/i.   (as
calculated   from   ASTM's    emperical   equation).     The   R2
correlation  factor for  T20vxL  vs.  FEVI  ranged  from 0.90  to
0.99 when MVMA's  fuel samples  were broken  down by  year  and by
volatility   class.    Theoretically,   because   of   this   close
correlation  and the fact  that FEVI is dependent on only RVP and
%is«, controlling  these  two  parameters should  closely control
TZOVXL.    Again,  RVP  is   the  more  significant  of  the  two
parameters,   accounting for over 70 percent of  the change  in
FEVI for a 2-psi change in RVP (from 11.5 psi to 9.5 psi).

     From the  above  discussion, it appears that RVP  and %iso
are  the  most  relevant  of the available  fuel  parameters  to
indicate evaporative emission potential.   The  other parameters,
El,  FEVI   and  T20vxL   all    essentially  combine   RVP  with
higher-temperature volatility indicators, but  it is  not clear
that  any  of  the  three   particular   combinations  adequately
represent the  overall evaporative  emission  potential for motor
vehicles.   It  appears  safer to  address  the  two  parameters
separately at  this point.  However, as indicated above,  little
is  currently  known  of  the  effect  of  %ieo  on  evaporative
emissions.    Thus,  this  evaporative study will  focus primarily
on RVP  as  the most relevant  measure  of  fuel volatility until
such time as  sufficient  data  are available to conduct a similar
analysis of %i6 o•

     This limitation should not  be of major concern  since:   1)
RVP is the dominant factor  in both FEVI and El,  which have been
used  in the  past  to  indicate overall  evaporative  emission
potential,  and  2)  the vast majority of post-1990  vehicles  are
expected to  be fuel-injected, which means that an  even  larger
portion  of  their hot-soak  (and total) evaporative  losses will
originate in the fuel  tank — where RVP is the most appropriate
parameter — than  occurred  with the carbureted vehicles used in
the El and FEVI studies.

     2.   Historical and Future Trends in Gasoline Volatility

     Over  the  past   decade,  the  volatility   of   commercial
gasoline has gradually,  but  steadily,  been  increasing.   This
section  reviews  regional and nationwide  RVP trends  over time,
along with   a  state-by-state  comparison  of violations  of  the

-------
                              2-26

fuel volatility limits suggested by ASTM versus  the actual fuel
inspection  laws,  if  any,  enforced  by  the State  governments.
Trends in gasoline volatility  measures  other than RVP  are also
reviewed  here.   Summer   gasoline  volatility   is  the  focus
because,  as  concluded  in Section II  of  this  chapter,  in-use
fuel control only during  the summer  months could have an impact
on the majority of ozone violations.

     Trends in commercial gasoline volatility were  traced using
results  of  two separate  fuel  surveys  prepared each  summer  by
the  National  Institute  for   Petroleum   and   Energy  Research
(NIPER)   and   the  Motor  Vehicle  Manufacturers   Association
(MVMA).[16,15]   Table  2-6  presents  RVP  trends  for  the  15
non-California regions  included  in the  NIPER survey.  As shown,
overall  non-California  averages  indicate  a 9-percent  increase
in  summer unleaded  fuel  RVP   levels  over  the  past  10  years.
Increases  within  individual  regions  vary  between  6  and  19
percent,  with   the   greatest   summer   increase  occurring  in
northern Illinois (sample area is Chicago).

     To  examine volatility trends over  the past twenty  years,
it  is  necessary to  look at leaded  fuel  which, of  course,  has
been  in  use  longer   than unleaded   fuel.   National-average
results   of   NIPER   leaded  gasoline  surveys   are  presented
graphically in Figure 2-3.[16]   As  shown in the top graph,  the
most  significant  summer  RVP   "boosts"  occurred  first  in  the
1972-74 period, and then  again in 1981.  Prior to  1972,  summer
fuel RVP levels were  well  within  the  range  specified  in  the
Code of  Federal Regulations (CFR) for certification test fuels
(8.7 to 9.2  psi);  however, by the time  the SHED*  test began
with the  1978  model  year,  the  certification fuel  RVP  had been
exceeded by the  in-use  fuel national average (approximately 9.6
psi).  Since then, the CFR  specifications  have  become even less
representative of  commercial  fuel volatility,  based on  a 1984
summer  leaded fuel  average RVP of  10.3  psi   for  the  nation
(shown   in   the   figure).   Curves   for  T90,   Tso/   and  T10
(also presented in Figure 2-3) support the  trend  in increasing
gasoline volatility,  as well.

     Results of the other fuel survey mentioned — conducted by
MVMA[15]  —  are  presented  in  Table   2-7.   Here,  instead  of
segregating    by    geographic    region,    average   volatility
characteristics  for  unleaded  regular  gasoline are shown  for
ASTM classes  A,  B,  and C (as  defined  in Table  2-5).  According
to  these  survey  results,  the average RVP  in Class  C  areas has
increased by  almost  10 percent  over the  past  seven years to a
level   approaching  11.0   psi.    Trends   in other  volatility
parameters   such   as   TK>,   Tso/   %is«,   and   T2ov/L   (all
     Sealed  Housing  Evaporative  Determination,  which  is  the
     current test procedure.

-------
      Region
                                                  Table 2-6

                       NIPER Survey Results[16];  Summer Gasoline RVP Trends by Region*
Northeast
Mid-Atlantic Coast
Southeast
Appalachian
Michigan
Northern Illinois
Central Mississippi
Lower Mississippi
Northern Plains
Central Plains
Southern Plains
Southern Texas
Southern Mountain
Northern Mountain
Pacific Northwest

National Average**
(excluding California)
Years
1974
9.8
9.3
9.6
10.5
10.5
9.5
10.1
9.4
—
—
9.2
9.1
8.4
8.9
9.5
9.5
1975
10.0
10.1
9.6
10.6
10.4
10.5
10.1
9.6
9.6
9.1
9.3
9.5
8.9
10.1
9.9
9.8
1976
10.2
10.1
9.7
10.5
10.6
10.3
9.9
9.6
9.9
9.2
9.2
9.4
8.7
9.5
10.6
9.8
1977
10.7
10:4
9.5
10.4
11.0
11.0
9.9
9.5
—
9.0
9.3
9.6
8.8
9.9
10.4
10.0
1978
10.5
10.1
9.4
10.1
11.2
10.8
10.1
9.8
—
8.8
9.1
9.5
8.9
9.9
10.0
9.9
1979
10.5
10.2
9.6
10.6
10.9
10.9
10.4
9.5
9.2
9.2
9.5
9.4
8.7
9.6
10.3
9.2
1980
10.8
10.3
9.8
10.5
11.3
10.9
10.3
9.7
9.8
9.2
9.2
9.2
8.9
9.5
10.8
10.0
1981
10.8
10.6
9.9
10.9
10.9
11*1
9.7
9.3
—
—
9.7
9.4
8.4
9.2
11.0
10.1
1982
10.9
10.8
10.1
11.1
11.2
10.8
10.5
10.1
11.0
10.2
10.0
10.3
8.8
10.4
10.8
10.5
1983
10.5
10.7
10.3
11.4
11.6
11.7
11.0
10.1
11.0
10.0
9.8
10.2
9.1
10.4
11.2
10.6
1984
10.7
10.8
10.2
11.1
11.5
11.3
10.9
10.0
10.5
10.0
9.8
10.3
8.9
9.7
10.8
10.4
% Increase
over Decade
9
16
6
6
10
19
8
6
9
10
7
13
6
9
14
9
                                                                                                               to
*
**
Unleaded regular gasoline only (R + M/2 less than 90).
Calculated as a straight arithmetic average of the 15 regional averages listed.

-------
                                   2-28


                                 Figure  2-3

                 Volatility Trends  in Leaded Gasoline

                        (NIPER Survey Results)[16]
KŁ
25
«Ł
13.0
10.0
9.0
nn


H *

»-



-n



=—




' — 1 —

^v

-


•_•*




P-— «
























Su

nttr

IMM





k




-^







^




x,





























x'1




^^


.


— ^











  en
  o
     1959'60'61 '62 '63 '64 '65 '66 '67 '68 '69 '70 Tl '72 '73 '74 '75  T6 77 '78 '79 '80 61 82  83 84
                 - Trends of certain characteristics of leaded (regular) grade
                  gasoline through summer 1980; leaded antiknock (R+M)/2
                  below 93.0 grade gasoline beginning winter 1980-81.

-------
                                                     Table 2-7
                                             MVMA Survey Results[15]:
                                 Summer Gasoline Trends by ASTM Volatility Class*
                   No. of
     Volatility  Gasolines
Year    Class     Sampled
1977
1978
1979
1980
1981
1982
1983
1984
A
B
C

A
B
C

A
B
C

A
B
C

A
B
C

A
B
C

A
B
C

A
B
C
 37
 66
121

 38
 68
123

 37
 67
120

 39
 66
124

 41
 66
126

 37
 65
125

 39
 64
128

 39
 60
125
Avg.
RVP
(psi)
8.53
8.72
9.94
8.25
8.56
9.67
9.79
10.10
11.33
8.27
8.71
9.88
8.65
9.30
10.46
9.16
9.79
11.06
9.06
9.65
10.84
8.80
9.54
10.89
% of Sample
Above ASTM
RVP Max.
27.0
0.0
0.0
13.2
0.0
0.8
64.9
55.2
37.5
20.5
0.0
1.6
22.0
6.1
1.6
37.8
33.8
28.8
33.3
31.2
15.6
28.2
28.3
22.4
Avg.
T,0
(°F)
131.6
128.0
121.9
129.0
127.8
120.8
124.4
123.6
115.2
123.8
120.9
113.0
122.4
122.0
114.6
123.8
122.5
114.0
122.4
120.1
113.2
118.7
117.5
108.8
Avg.
Tso
<°F)
225.9
218.3
220.9
222.9
219.8
220.0
223.7
219.4
221.4
222.5
217.9
218.5
219.1
218.1
215.6
220.0
218.4
215.6
220.2
216.6
214.7
210.9
210.7
206.7
Avg.
%l 58
(%)
21.5
23.4
25.5
22.5
23.2
25.8
24.0
25.0
28.0
23.4
25.6
28.4
25.8
25.9
29.3
25.2
26.0
29.6
25.4
26.5
29.6
28.5
28.7
32.7
 Avg.
TZOVXL
 (°F)
144.3
141.6
135.8

144.5
142.4
136.5

137.4
135.2
128.8

143.3
140.1
133.8

140.9
137.9
131.3

139.2
136.1
128.7

139.4
135.9
129.3

138.1
134.8
126.8
% of Sample
Below ASTM
 Minimum
 _T_20V/L_
   24.3
    4.6
    0.0

   23.7
    4.4
    0.0

   62.2
   47.8
   22.5

   28.1
    4.6
    0.8

   26.8
   10.6
    4.0

   43.2
   30.8
   11.2

   46.2
   29.7
   10.9

   51.3
   43.3
   30.4
                                                                                                                     to
                                                                                                                     to
     Unleaded regular gasoline only  (R  + M/2  less  than  90),

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                              2-30

defined  in  the previous section)  are  also shown  in Table 2-7.
These trends also  indicate  increasing  fuel volatility  over  the
past  few   years  (i.e.,  lower  Ti0,  TSo,   and   T20v/L,  and
higher  %ist).    It  is  important  to  note  that  %is«  —  close
to  the   %iso  parameter  associated with  hot-soak  emissions  in
the  previous  section  —  has  increased  significantly  by  28
percent  (from  25.5 percent to  a  current average  level of 32.7
percent) in Class C areas.

     Pool average  gasoline volatility  properties  for  Class  C
gasolines are  similar  to  those  of  unleaded regular  gasoline
described above.   From 1977  to   1984,  pool  average  RVP  and
%ist, as determined  from  MVMA survey  data  (unleaded  regular,
unleaded  premium,   and  leaded  regular  gasolines  weighted  65
percent,  18 percent,  and  17 percent,  respectively) have both
increased significantly.  RVP has  increased from 9.94  to 10.89
psi, and %ist increased from 26.6  to 32.6 percent.

     Alcohol blends have, as  a  whole,  higher volatility than do
alcohol-free gasolines.   The MVMA  survey  data  reviewed  above
for alcohol-free gasoline volatility properties  did not contain
data on methanol blends, but did have volatility properties for
ethanol  blends.[15]    Average  RVP  for   eight   1984  gasoline
samples  containing  an average of  9.4  percent ethanol  was 12.3
psi.  Average  %ist  was 44.6  percent.   These levels  are very
similar  to those  of  twelve   1983   gasoline  samples   also
containing  an average  of 9.4  percent  ethanol.  Average RVP from
these  1983  gasoline  samples was  12.3  psi,  and   average %is»
was 42  percent.   Over  these  two  years, %is§  ranged from 30 to
55  percent  while RVP  ranged  from  12  to  13.3 psi.    These data
indicate  that  Class  C  ethanol  blends  are  significantly more
volatile than Class C alcohol-free gasolines.

     According   to   some  theories,   the   increase   in   fuel
volatility  seen  in alcohol-free gasoline is  linked to  the lead
phasedown in  gasoline  over  the past  decade.   Because of  the
reduction and/or elimination  of the traditional octane-booster
—  lead —   refiners  must  process  heavier  crudes  in  order  to
obtain   the clear,   high-octane   fractions.    As   more  crude
undergoes  hydro-cracking,   more  butane  is  produced;   because
butane enhances  octane,  and because the supply is in excess, it
is   allowed   to   remain   a   component   of   the   gasoline.
Unfortunately,  butane  is also  a  major volatility  enhancer  and
its abundance is most  likely  the  major reason for  the  increase
in RVP over  time.

     As mentioned earlier, ASTM's  volatility specifications are
not enforceable  by law, but  are  merely levels  agreed upon  by
members  of  the  refining  industry.  However,  some  states have
adopted  ASTM's  RVP  limits  as  part  of  their  own  gasoline
inspection  laws, which are enforceable.

-------
                              2-31

     Among  the  states  which   have  adopted  fuel  volatility
controls, the  assigned RVP  limits vary from  month-to-month (as
they  do in  the  ASTM specifications)  according  to  temperature
conditions.*   For  the purposes  of  comparison  to ASTM's  D-439
limits,  July  was  focused  on,   as   this  summer   month  is
characteristic  of  high  ozone   violations   (as   mentioned  in
Section II of this chapter).

     A  comparison  of  state laws  versus  ASTM limits  on RVP for
the summer months  is  presented  in Table  2-8.   As shown,  21 of
the states  do  not currently have inspection  laws governing the
RVP of gasoline sold within their boundaries.**   Sixteen states
have  simply  adopted ASTM's current  year-round D-439  limits as
law;  in addition  to  these, four more states  have  RVP limits
that  correspond  to ASTM's  specifications  at  least during July.
Among those  state  laws that differ from ASTM's D-439,  there is
a  month-to-month  variation  involved  in the  comparison;  for
example,  Alabama  is  more  restrictive than  ASTM  in  June  and
July,  but  less restrictive in  August and  September.   However,
as  July  is  the   focus  here,  the  comparison  is  simplified.
During  this  month, three states  are more restrictive than ASTM
and six are less  restrictive (as indicated in Table 2-8).

     In  an  effort to determine  the  effectiveness  of  ASTM's
recommendations and State   laws,  fuel  survey  data were compared
to  these  standards.   Part  of  this   comparison   was  shown
previously in  Table  2-7.    As indicated  there,  over  22 percent
of the  Class C fuels sampled  by MVMA in 1984 exceeded ASTM's
maximum RVP  specification  of 11.5 psi;  of these  same samples,
over 30 percent were below  ASTM's  recommended minimum level for
T20V/L.[15]

     In Table  2-9, this  comparison  is put on  a  state-by-state
basis.  Here,  the  states are  divided between  those  that  have
implemented gasoline RVP standards and those  that have not.  In
turn,  post-1982  NIPER summer  survey  results for these states
were  compared  to  both ASTM  and State   RVP  standards  for  the
month of  July.  As  shown,  11  states have  average  RVPs  above
their respective  ASTM specifications; 10 of these  states have
their own RVP  standards  and the  other one does  not.   Further,
of the  28  states having  their  own RVP limits (Hawaii excluded),
roughly one-third  of  them  had  average summer RVPs  above these
State standards.    Therefore, enforcement  appears  to be somewhat
ineffective.
*    The  only  exceptions  to  this  are  Louisiana, Wyoming,  and
     Hawaii, which  hold  RVP  constant  throughout the year  at
     13.5, 13.0, and 11.5 psi, respectively.
**   Washington, D.C. is included as one of the 24 states.

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                                               Table  2-8
                   Comparison of  Summer RVP  control:   State Laws versus ASTM Limits*
 States Same as ASTM**

Arizona (A)
Arkansas (B)
Colorado (B/A)
Delaware (C)
Florida (C)
Georgia (C/B)
Hawaii (C)
Idaho (B)
Illinois (C,C/B)
Iowa (B/C)
Missouri (B)
Nebraska (B)
New Mexico (A)
No. Dakota (B)
Rhode Island (C)
So. Carolina (C/B)
Tennessee (C/B)
Utah (B/A)
Virginia (C)
Wisconsin (C)
                             States More
                        Restrictive than ASTM

                       Alabama (C/B)
                       Mississippi (C/B)
                       No. Carolina (C/B)
      States Less
 Restrictive than ASTM

Indiana (C)
Louisiana (C/B)
Maryland (C)
Montana (B)
So. Dakota (B)
Wyoming (B)
  States With No
RVP Specifications

Alaska (D)
Connecticut (C)
Wash., D.C. (C)
Kansas (B)
Kentucky (C)
Maine (C)
Massachusetts (C)
Michigan (C)
Minnesota (C)
Nevada (A,B)
New Hampshire (C)
New Jersey (C)
New York (C)
Ohio (C)
Oklahoma (C)
Oregon (B,C)
Pennsylvania (C)
Texas (A,B)
Vermont (C)
Washington (B,C)
West Virginia (C)
                                                                                                           CJ
                                                                                                           NJ
**
Summer month examined is July; California is excluded from the comparison.
ASTM volatility class specifications for each state given in parentheses.
Sources:
     ASTM's Standard Specification for Automotive Gasoline, D-439-83.
     API's Digest of State Inspection Laws—Petroleum Products, Fourth Edition.

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                                           2-33
                                         Table 2-9

  Comparison of Post-1982 NIPER Survey Results [16] to July ASTM and State RVP Standards

                       States with RVP Standards           States without RVP Standards
                     A*
A/B
 B
B/C
Max. ASTM RVP (psi)  9.0   10.0   10.0   11.5   11.5
Avg. of State
RVP Standards (psi)  9.0
 9.8
10.1   10.5   11.7
A*
                               9.0
A/B
                                      B
B/C
                              10.0   10.0   11.5   11.5
No. of States**

No. of States
 with Average
 RVPs above
 ASTM Specs.

No. of States
 with Average
 RVPs above
 State Stds.
                                                          14
*    "A" through  "C" designate  ASTM volatility classes  as  defined in ASTM's
     D-439 and reviewed in Table 2-5.
**   Hawaii and Alaska excluded due to lack of fuel survey data.

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                              2-34

     Several basic conclusions can be made  from  the information
presented  in  the  above  discussions.   One,  gasoline  volatility
has been gradually  increasing  over  the  past two decades  and no
substantial data exist  to  indicate  that  this  trend will  not
continue.   Two,  ASTM   recommendations   and  State-implemented
volatility  limits   appear  to   be  somewhat   ineffective   in
controlling gasoline  volatility.   Even  if  ASTM  specifications
were  currently  restricting  RVP  — and  they may  indeed be —
there  is some  speculation  that they  could be  changed  in  the
future.  Revisions  have  been made in the past as  vehicles  have
been  designed  to  handle more  volatile  fuels.   The  projected
widespread use  of fuel  injection systems  continues this trend,
so  a  relaxation  of  the  current  ASTM   RVP   limits   is   not
inconceivable.   Third, the current  average  RVP in Class C areas
is  roughly 11.0  psi, which is  approaching  the  maximum  ASTM
specification of  11.5 psi.   Based on these observations, then,
this study assumes  that,  by  1988,  gasoline RVP will  on  average
rise to  equal the ASTM limits for each state.   (Chapter 6  will
address  the  sensitivity  of  this  assumption  by  examining  the
cost  effectiveness  of the  control strategies  starting  from  a
baseline RVP of  0.5 psi  below ASTM limits,  instead of  just at
the limits.)

     3.    Effect of Weathering on Fuel  Volatility

     The volatilities reported in  various  fuel surveys (e.g.,
NIPER, MVMA)  represent  those  levels  measured  at  the  gasoline
pump.  However,  as the  gasoline in  the vehicle's  fuel system
responds to daily diurnal temperature  changes and  engine heat,
some   of  the   lighter   hydrocarbons   are  lost.    Thus,   the
volatility of the fuel gradually decreases.  This  phenomenon of
"weathering"  is  an  important   consideration   in   assessing
evaporative emissions that actually occur in the field.

     An  EPA-sponsored study recently  conducted  by  Southwest
Research Institute  (SwRI) examined  the  effects of  weathering on
the  RVP  of gasoline  as   the vehicle's  fuel  tank  is  gradually
emptied.   Two vehicles  were driven approximately  50  miles  each
day and  allowed  to  soak  overnight in a  shaded area; each  day,
the RVP  of the  fuel  remaining  in the tank  was  measured.  This
process  was  continued over  roughly five  days until  the  fuel
tank   (which  started out   completely   full)   was  essentially
empty.  Three fuels of varying  initial  RVP  (roughly  9.0, 10.5,
and  12.0 psi)   were examined.   Test  results indicate that, in
general,  as a vehicle's  fuel tank goes  from full to  empty,  the
RVP of the originally dispensed  fuel  decreases by an average of
9 percent. [17]   For example, a fuel  dispensed with  an  RVP of
11.5 psi could  weather to a  final RVP of about  10.5  psi if the
fuel  tank  was  allowed  to empty  out  completely  without  being
refilled.  Of  course, this  is not  the norm  in the field, so
dispensed  fuels most  likely never  weather  to this  great  an

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                              2-35

extent  before refueling  takes place.   This weathering  effect
appears to  be independent of  the fuel tested,  but could  vary
with other  test  parameters (i.e.,  length of soak  period,  soak
temperature,  distance   driven,   number   of   trips  per   day,
etc.).[17]

     General  Motors  has  also conducted tests  examining  the
effect  of  weathering   on  fuel   volatility   and   evaporative
emissions.   Unlike  the SwRI  work,  chassis  dynamometer  tests
(i.e.,  FTP  and  HFET) and  standard diurnal and  hot-soak  cycles
were used  to simulate  typical urban  driving  conditions instead
of  actual  highway  driving and   24-hour   outside  soaks.    GM's
testing of  two  fuels showed  the  original RVP  to decrease from
between  9  and   15  percent  from  tank  fill-up  to  the   empty
point.[18]   As  mentioned  earlier,  most  vehicles  in the  field
are not permitted to  go completely empty, so a  mid-range  level
is probably more representative.   At  the 40-percent  fill  level
specified in EPA's evaporative test procedure,  GM showed  an RVP
decrease  of 6-13 percent  due to  weathering.[18]   According to
GM's  data,  this  change  in  RVP  results  in  a  decrease  in
uncontrolled* diurnal evaporative  emissions  of  approximately 15
percent (again at the 40-percent fill level).[18]

     At this point,  the effect of  weathering  on fuel  RVP and,
thus,  evaporative  emissions  has   not been  factored into  this
analysis.   Additional work in this area is required before this
could be  done confidently.  However,  GM's estimated 15-percent
decrease in diurnal emissions  is  used in  an initial  attempt to
account  for  weathering  in  Appendix  2-A, which  examines  the
effects  of  various  environmental  conditions  on  evaporative
emission  levels.   Although  more  work   is  required,  at  this
point,  the  absence  of  an  explicit consideration of  weathering
should not  have  a  significant net impact  on the results  of the
study.

     C.    Use of Alcohol Blends

     As a result of the oil crisis in  the early 1970's, efforts
were begun  in the  United States  to  reduce  the dependence on
imported oil.  One  idea eventually  introduced  was  the use of
alcohols  in gasoline  to  extend  the  supply  of gasoline.  .The
Environmental Protection Agency (EPA),  under Section 211(f) of
the  Clean  Air Act,  must  approve  any new unleaded  fuels  which
are not substantially similar  to fuels already  permitted  in the
market.   Since  1978,  the EPA  has   granted  waivers  for  two
ethanol/gasoline    blends    and     four    methanol     (and
     "Uncontrolled"  refers  to  the   lack  of  an  evaporative
     control system on the vehicle.

-------
                              2-36

cosolvent)/gasoline blends.  The most  recent  waiver  granted for
the  DuPont  application places  an evaporative index  (El)  limit
on the waived  fuel  to assure that evaporative emissions do not
increase compared to  those with typical in-use gasolines.[19] A
list of all waivers granted is shown  in Table 2-10.   Currently
in  the  United  States,  ethanol blends comprise 6-7  percent  of
the  total gasoline market  and methanol  blends  comprise  3-4
percent of the total gasoline market.[20,21]

     l.     Effect on Fuel Volatility Parameters

     The  addition  of a polar alcohol  affects  the  properties  of
the  non-polar   gasoline  to  which  it   is  added.   The  primary
effect is  on  the distillation  curve  and,  thus, the parameters
associated  with  volatility.   Three  of   these   parameters,
discussed in detail in Section  IV.B  of this  chapter,  are RVP,
FEVI, and El.

     Although   the   exact   distillation   effects    of   alcohol
addition to gasoline  vary for every base gasoline, some general
effects  are common.   Theoretically,   the  addition   of  a  pure
compound  to  gasoline  causes   the  percent  evaporated  at  a
specified temperature,  compared to  the straight  gasoline,  to
decrease  at  temperatures   below   the  boiling   point  of  the
compound added.  At that  point,  that  compound is  distilled off
and  the  percent evaporated  at  higher  temperatures (compared to
straight  gasoline)   is   increased  by  the  presence   of  the
compound.  However, both  methanol  and ethanol  form azeotropes
with many of  the  components  in  gasoline.   An  azeotrope  is  a
mixture of  a  particular  composition  of two  or  more components
which,  in the  case of alcohols  and  gasoline,  has  a  constant
boiling point  lower  than that of  either  individual compound.
The combination of these two effects causes  the  percent  of fuel
evaporated at certain temperatures  to  be greater for an alcohol
blend than for straight gasoline, and  to an  extent much greater
than  the  percentage of   the  alcohol  alone.   This effect  on
distillation occurs primarily  in  the  boiling  temperature  range
from  the   lowest-boiling  azeotrope   to  the  highest-boiling
gasoline component  forming an azeotrope.

     As  discussed  earlier,  RVP   is   a  measurement   of  the
volatility  of  a fuel  at  100°F.  Since the vapor  pressures  of
methanol  and  ethanol  are  lower  than gasoline at   100°F,  the
addition  of  these  alcohols to a  gasoline  could  theoretically
cause the RVP of the alcohol blend to be lower than  that of the
straight gasoline.  Once  again,  however, the presence of highly
volatile  azeotropes erases this effect and  causes  an  increase
in the RVP.  The precise increase in  RVP  varies for every base
gasoline, but  the  increases from  each alcohol  are generally
similar.    For   the  addition  of  methanol  alone  to  gasoline  at

-------
                              2-37
                           Table 2-10

              Clean Air Act,Section 211(f) Waivers
      Name
1. Gas Plus Inc.
   "Gasohol"

2. Synco 76 Fuel
   Corp.

3. Sun Petroleum
   Products Co.

4. Anafuel
   "Petrocoal"
5. ARCO "Oxinol"
6.  DuPont
Date Granted

12/16/78
(w/o decision)

5/18/82


6/13/79


9/28/81



11/7/81
1/14/85
        Limitations
-up to 10% (vol.) anhydrous
 EtOH

-up to 10% (vol.) EtOH
-proprietary additive

-up to 5.5% (vol.) of a 1:1
 MeOH/TBA mixture

-up to 12% (vol.) MeOH
-up to 6% (vol.)  butanols
-proprietary inhibitor

-up to 4.75% (vol.) MeOH
-up to 4.75 (vol.) TEA
-ratio of MeOH: TEA cannot
 exceed l

-up to 5% (vol.)  MeOH
-at least 2.5% (vol.)
 cosolvent (EtOH, propanol,
 butanols)
-proprietary corrosion
 inhibitor
-must meet El
 specifications set for
 ASTM class areas
EtOH = ethanol.
MeOH = methanol.
TEA = tertiary butyl alcohol.

-------
                              2-38

2-10 percent  (by  volume),  the increase in RVP is  around  3  psi.
For  the  addition   of   methanol   with  a  cosolvent  (ethanol,
propanols,  and/or butanols)  to  gasoline at  5-10  percent  of
total volume,  the increase in RVP is slightly less  — around 2
psi.  The increase  in RVP  for the addition of 2-10  percent  (by
volume) ethanol to gasoline is around 1 psi.[11]

     A  second  volatility  measure  discussed earlier  is  FEVI.
The addition  of  alcohol  to gasoline  will increase the FEVI  by
the same  amount  as  the  RVP is increased, plus by  an additional
amount  due  to  the  increase  in  volatility  at  158°F  (%iss).
From  a  review of data,  it appears  that  for both methanol  and
ethanol  blends allowed  by  waiver,  the  %isi  is  increased  by
roughly 10-15 percent, resulting  in  an additional  1.3- to 2-psi
increase  in the  FEVI.[10,22-24]   (Typical distillation  curves
for methanol  and ethanol  blends  are  shown  in Figures 2-4  and
2-5).   The  total  increase in FEVI  is  around 4.3-5  psi  for  a
methanol  blend,   approximately  3.3-4  psi for  a methanol  with
cosolvent blend,  and approximately  2.3-3  psi  for  an  ethanol
blend.

     A  third  volatility measure  discussed  earlier is El.   The
addition of alcohol to gasoline will increase the  El  because of
the resulting  increase  in RVP  and  an increase  of  5-10  percent
in  the  %20o.[10,22-24]   (See Figures 2-4  and  2-5).   However,
the effect  of  alcohol   on the  %ioo  is  rather  unpredictable.
In  some  cases the alcohol causes the %ioo  to  decrease  by  1-2
percent, but  in many cases neither  the gasoline  nor the alcohol
has begun to  boil  at 100°F.   The  combination  of the  alcohol
effects produces  increases in El  over the straight  gasoline of
approximately  3-4  psi   for   methanol  blends,   2.5-3  psi  for
methanol  with  cosolvent  blends, and 1.5-2  psi  for  ethanol
blends.

     The effects of alcohol addition on RVP,  FEVI  and  El  can be
counteracted by adjusting  the contents  of the gasoline to which
the alcohol  is added.   By removing  lighter  hydrocarbons (such
as  butanes  and/or pentanes), the RVP,  %is«,  FEVI or  El  of  the
final  blend  can  be  controlled   to  levels  of  the  original
straight  gasoline.    However,  the   evaporative  emissions   of
automobiles  using   the  volatility-controlled   alcohol   blends
could still be  significantly  greater than straight gasoline, as
some data show.

     2.     Effect on Evaporative Emissions

     The  reported  effects of  alcohol  blends  on  evaporative
emissions vary  widely  and can be examined in two ways:   1)  by
comparing a gasoline and a volatility-controlled blend of egual
RVP, FEVI or El, and 2)  by comparing a gasoline and a high-RVP

-------
               2-39
                Figure 2- 4
Typical Methanol Blend Distillation Curves  [22]
                      Cv«Mr«U4

-------
                2-40
                Figure 2-5
   Typical Ethanol Blend Distillation Curves [23]
I
           Tft      «
              Percent Evaporated

-------
                              2-41

blend  in which  the  alcohol  (with or  vithout  cosolvent)  is
simply  splash-blended  into  a  similar gasoline.   In the  first
case,  the  results  for  methanol  blends  show  anywhere  from  no
effect  to  a 95-percent  increase  in evaporative  emissions  with
the    volatility-controlled    blend    over    the    straight
gasoline.[11,22,25,26]    For  the   second   case,   the  reported
increase in  evaporative emissions  with the  methanol blend  is
between 40 percent and 325 percent.[26-28]

     Reported  increases  in  evaporative  emissions with the use
of  ethanol  blends  also   vary  widely.   In  the   controlled
volatility   case,   the  increases   in  evaporative   emissions
reported for  ethanol  blends  are between  25  percent  and  170
percent.[29,30]   For   the  splash   blend   case,   evaporative
emissions  are  reported   to   increase  between  5  and   220
percent.[29-34]   Currently, ethanol  can be  added directly  to
gasoline without any legal  requirement  for  volatility controls,
whereas  methanol  blends  generally must   meet   the  same  ASTM
specifications applicable to gasoline.

     Even with control  of  alcohol  blend volatility,  there  can
be an  increase in evaporative  emissions due to intermittent use
of blends  and gasoline.   A phenomenon  called commingling  can
occur when an  alcohol blend is added to a tank partially filled
with straight  HC  gasoline,  wherein the  RVP of the mixture can
be significantly  higher  than the RVP  of the  original  gasoline
or blend.   Commingling  is  depicted in  Figure 2-6,  where  the
increase in  RVP (over  the  straight HC gasoline level)  is  shown
as a function  of  blend  ratio and type  of  blend.   For  example,
in the  top plot,  if a  1:1 MeOH/isopropyl alcohol  blend (9.6% by
volume) is added to fill a 60-percent full tank  of  straight  HC
gasoline, the  RVP of the new mixture (i.e.,  full tank) will  be
roughly 1.0  psi  higher   than that of the  original straight  HC
gasoline.

     This commingling  effect could  possibly  lead to increased
evaporative  emissions.    One   report   calculated   an   average
increase of  33  percent  in evaporative  emissions due  to  the
intermittent use  of Oxinol in every  third  tank,  if both  the
Oxinol  and   gasoline  had  the   same  RVP. [11]   The increase  in
evaporative emissions due to commingling has been shown to  be a
function  of  the  percentage of  stations  selling blends,  the
amount  of fuel remaining in the  fuel  tank when  refilling,  and
the habits of  the buyer  (i.e.,  whether fuel is bought at  random
or loyally).

     The   above  results   apply   to    short-term   evaporative
emissions impacts  and do  not   include  any effects which  could
arise from degradation of the evaporative control system due  to
methanol contamination of the  carbon canister through long-term

-------
                                 2-42

                         Figure  2-6

          COMINGLING VAPOR PRESSURE EFFECTS M.OH/IPA
            BLENDS WITH ALL HYDROCARBON GASOLINE
               2.0
            i  «••
             *
            a
            f  1.0
            i
            i,
          IM/IMOM iOO«OtOro«OM«O3020iO  0
                o   io2030*oso«OTo«o»OiOO
                             •UNO II»TIO.%
               COMINGLING VAPOR. PRESSURE EFFECTS
                EtOH AND M*OH/EtOH BLENDS WITH
                   ALL HYDROCARBON GASOLINE
               2.0
               1.9
             i
             i
               1.0
               0.9
               •as
                tOO  »0  *0   10  *0  SO   «C  »  20   '0  0
           CAMLIMC  0   iO  20   JO  40  90   (0  TO  M   K  <00
                              •UNO MTIO.%

Source;ARCQ Petroleum Products  Company, March 12,  1985
         (in letter to  Craig  Harvey, EPA)

-------
                              2-43

use of  alcohol  blends.  There  has  been widespread  speculation
about  contamination  of  charcoal with  alcohols,  but  several
studies have failed  to show a definitive effect on  the  working
capacity of the canister.

     For  methanol  blends,  most  reports  (including  recent  EPA
contract  work)  show  no  substantial  difference  in  canister
working capacity when  compared  to the use of straight gasoline,
even  with  high  mileage  accumulation.[26,35,36]   (Prior  EPA
contract work  on canisters in  a  laboratory  situation had shown
an effect of the blends on the  working capacity,  but this could
be  attributed  to  a  difference  in  loading  of  the  canisters
during the experiment.)[37]  One report does state that  the use
of methanol blends can decrease the working capacity of carbon,
resulting in increased evaporative  emissions.[27]  However,  the
mileage  accumulation  fuel  was  a splash blend,  and  thus,  the
effect  could  be due  to  higher  volatility.   Possible  alcohol
effects  have  been  attributed  to the  formation of  azeotropes
between  methanol and  heavier  hydrocarbons.   These  azeotropes
are more  volatile  than either  component and become  adsorbed on
the  carbon.   Then,  apparently,  the methanol  breaks  off  and
leaves the hydrocarbon portion  attached  to the carbon, which is
difficult to purge.[38]

     The reported effects of ethanol  blends  on carbon canisters
are  limited,  but suggest  no degradation  of working capacity.
The reports did show that ethanol was adsorbed  in preference to
some hydrocarbons and  that a lesser  degree  of  regeneration was
achieved  during a defined  purge period;  however,   an extended
purge period tended to remove all the ethanol.[30]

     3.     Summary

     The   addition   of   alcohols   to   gasoline  affects   the
properties of  the  blend.   The  addition of  either  methanol  or
ethanol results  in  higher percentages of  fuel  to be evaporated
at given  temperatures, and greater  RVP, FEVI,  and  El  values.
The effects of  methanol on these parameters are more dramatic
than for ethanol.

     This increase  in  volatility can cause higher  evaporative
emissions  during the   use  of  alcohol  blends.   However,  some
reports show that controlling the volatility characteristics of
the blend to that  of current  gasolines is sufficient  to  keep
evaporative  emissions  at  current   levels  and  prevent   any
permanent reduction in working capacity.

-------
                              2-44

     The  intermittent  usage of  blends  also causes  an  increase
in  evaporative emissions  because of  the  nonlinearity  in  RVP
upon mixing  alcohol blends and  gasoline  (i.e.,  the commingling
effect).  Thus, even if the RVP  of alcohol  blends  is controlled
to current gasoline levels, the  amount  of evaporative emissions
could theoretically still  increase.   However,  this  study  does
not  take  the  commingling effect   into  account,  and  alcohol
blends  are  treated essentially  as straight gasolines of  equal
volatility.

     D.     Ambient Temperature Conditions

     In addition  to weathering,   ambient  temperature conditions
can  also  impact  the level of  evaporative emissions.   Diurnal
losses  are  dependent  upon  not  only  the  ambient  temperature
excursion (daily  maximum minus daily minimum),  but  also on  the
absolute magnitude  of  these temperatures.  Hot-soak losses  are
also dependent on ambient  temperature.   For example, a  vehicle
undergoing a  30°F diurnal change at an  average temperature of
90°F would  be expected  to have significantly greater  diurnal
and  hot-soak  losses  than a  vehicle experiencing  only a  15°F
diurnal difference  at  an  average temperature of  75°F.   In an
effort  to  quantify  the  magnitude   of  such  differences,   an
EPA-sponsored test  program was initiated  several months ago to
measure  diurnal   and   hot-soak   losses  at    various   ambient
temperature conditions.

     This  test program  (currently being conducted for EPA at
the Automotive Testing Laboratories, or  ATL)  includes  a matrix
of three  fuel RVPs, three diurnal  starting temperatures,  four
diurnal  temperature  excursions,  and  three  average  hot-soak
temperatures.[39,40]   However,  some  vehicles  are  being  tested
over only part of the  full matrix in the interest  of including
more vehicles in the  sample.  The  standard EPA test procedure
(i.e.,   diurnal temperatures  between  60°F and  84°F,  and average
hot-soak  temperature of  roughly 82°F)  is  represented  in  the
full test matrix.   Preliminary   analysis  of  test  data  on  24
light-duty vehicles certified  to the  2-gram standard  suggests
that increasing  the diurnal temperature  excursion  from  24°F to
30°F can  increase controlled diurnal losses by a factor of  1.3
to 2.7,  depending on  the  starting temperature,  the RVP of  the
fuel,   and   the   fuel   metering   system    (carburetor    or
fuel-injector).   Data  on  these  24 vehicles also  indicate  that
an  increase  in   ambient   temperature  from  70 °F  to  82 °F  can
increase  controlled hot-soak  losses  by 29-60  percent,  again
depending on  fuel RVP  and fuel  metering  system.    It should be
noted that these  data  are  preliminary;  testing on more vehicles
(most over  only  part  of  the  full   test  matrix)  is set to be
completed by  the  end of this year.

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                              2-45

     Diurnai  emissions  data on  these 24 vehicles  are anlayzed
in Appendix 2-A at the end of this  chapter.   There,  the diurnal
averages   are  compared   to   theoretical    emissions   indexes
calculated for each ATL  test condition via a diurnal  emissions
model  developed  and published  in 1967.[41]  This  model,  which
uses the  Ideal  Gas Law  to predict uncontrolled  diurnal  losses
as a function of  fuel  characteristics and temperatures, is used
in Appendix  2-A  to relate  the  various ATL test conditions  to
the standard  EPA  test procedure  in terms of  relative predicted
diurnal emissions.  This model  is  also used there to compare
typical summertime temperature  and  RVP conditions in several of
the  ozone non-attainment  areas  to EPA's  current  evaporative
test   procedure.    Relative  diurnal   emissions   indexes   are
calculated  for   17 selected cities   in  the  last  section  of
Appendix  2-A.  More  details on the methodology  and inputs used
are provided there.

     As with weathering  (discussed  earlier),  the  preliminary
nature of  these  results have prevented the  effects  of ambient
temperature  conditions  on  the  level  of  evaporative  emissions
from being  accounted  for  in the emissions projections made in
this  report.   Work  continues  in both  of these  areas  (i.e.,
temperature  and   weathering) in  hopes  of  incorporating  their
effects into future analyses.

V.   Results of In-Use Motor Vehicle Testing

     This  section presents  test  data  from EPA's  in-use  motor
vehicle emission  factor  (EF) program  in an attempt to quantify
the effect  of the factors  mentioned  in the previous section
(i.e., fuel  volatility  and evaporative control  system design)
on emissions from current  vehicles.   The section begins with a
brief  description of  the  current  evaporative   test  procedure
used  in  certification   and changes  made  for  the  in-use  EF
program (i.e., the addition of commercial  fuels  and the switch
in fuel sequence).  Next,  general evaporative emission results
from the  EF  program are  presented for various RVP levels with a
comparison  between  the   revised  estimates   and  the  MOBILES
figures  published in  June 1984.   In  the  following  section,
these  revised hot-soak  and  diurnal  emission  levels  are  broken
down into several  basic  components  of motor vehicle evaporative
emissions, based  on an  analysis  of  the vehicle  test  fleet.  By
attributing  certain  portions   of   current  total   evaporative
losses    to    different    sources    (i.e.,    excess    RVP,
malmaintenance/defect,  improper  design of  purge  system,  etc.),
it is  possible  to estimate  the effect that  changes  in  in-use
RVP or  certification  fuel  and test procedure will  have on each
component  and,  thus,  on  total  evaporative emissions.    (The
effects of  the  various control strategies  will  be  outlined, in
detail,  for  various  model  years  in  Chapter  5).   Also,  as

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                              2-46

discussed in  the  final  part of this section, exhaust HC  and  CO
emissions have been  found  to be dependent upon RVP;  this effect
is  quantified in this  final  section.    (Again,  the  specific
adjustments  that  have   been made  to  MOBILES  exhaust  EFs  to
account for the RVP effect  under  various  control strategies are
detailed in Chapter 5.)

     A.    Test Procedure

     The  standard  evaporative   test   procedure  used   in  the
certification of  new  vehicles is  outlined in detail in  Part  86
of  Title  40  of  the  Code  of Federal  Regulations (40 CFR 86).
Briefly, the  vehicle  is first drained of  its fuel and  refueled
with   Indolene   (with  an   average   RVP  of  9.0  psi)   to  the
40-percent  full   level.   The vehicle  is  then  preconditioned
using  the  Urban  Dynamometer  Driving Schedule  (also  referred to
as  the "LA-4" cycle),   which lasts  approximately 23  minutes;
under   special    circumstances   (e.g.,   if   the  vehicle  was
transported via  carrier instead  of being driven to  the  test
site),  manufacturers  can  request  up  to  three  LA-4 cycles  to
•assure adequate purging of  the  evaporative canister.   Following
preconditioning,   the vehicle  is  stored  (or  "soaked")   for  a
period  of   12-36  hours   before   the  SHED   (Sealed   Housing
Evaporative Determination)  test is conducted.

     Just prior  to beginning the SHED  test  for  diurnal  losses,
the vehicle  is  drained  and refueled  with chilled  Indolene  to
the  40-percent  fill  level.*   Beginning  with a fuel and tank
temperature of 60°F,  the fuel is heated  to  84°F  over  a period
of  one hour,  at  which  time  the  final HC concentration  in the
SHED enclosure is recorded as the total diurnal loss.

     Following the diurnal  test,  a  cold-start  LA-4,  followed by
the first  half  of a  hot-start  LA-4 is performed, during which
exhaust emissions are  measured.    At  the  completion  of  these
tests,  the  engine is shut off and the vehicle  is  pushed into
the SHED  enclosure  for the  hot-soak  test.    The test  vehicle
remains there for one hour at an average ambient temperature of
81°F**  and  the  increase in  HC concentration  is recorded  and
converted into a total hot-soak mass emission.

     The estimation   of  evaporative emissions  as  a  function of
fuel RVP used to  evaluate  the control options examined  in this
study  was  based  on  data   generated  as  part  of  EPA's  ongoing
in-use  emission   factor  (EF)   test  program.    This   program
*    The  fuel  is chilled to  about  50°F to  counteract the warm
     fuel  tank  (70-75°F),  which  is  already  warmer  than  the
     lower end of the temperature excursion (60°F).
**   The  hot-soak temperature  range  specified  in  the CFR  is
     68-86°F.

-------
                              2-47

involves  the  testing  of  in-use  (privately-owned)  passenger
cars,   selected    at   random   from    State   of    Michigan
vehicleregistration  files.    Prior   to  November  1983,  in-use
(privately-owned)  vehicles  were  evaluated  for  hot-soak  and
diurnal losses  only while operating on  certification test fuel
(Indolene) with a 9.0-psi RVP.  Since then, however,  the effect
of  fuel volatility  on  emissions has  been  examined with  the
addition of two  commercial fuels  with  nominal RVPs of  11.5  psi
(added in November 1983) and  10.5 psi (added in August 1984).

     The test  procedure used  in the  EF program has basically
followed certification practices  except  for certain differences
in  vehicle  preconditioning  and,  of  course,  the  addition  of
commercial  fuels.    (These   in-use  EF  test  sequences   are
summarized  in  Table 2-11).   Between  November 1983 and  July
1984, vehicles were  preconditioned  over  a shortened  LA-4  cycle
which lasted  only 10 minutes instead of the  entire 23 minutes.
Commercial  fuel  with an ll.5-psi  RVP  was  added  to the  test
sequence following  all  evaporative  and exhaust emission  tests
conducted on Indolene.

     In July 1984, the shortened prep cycle was  dropped and the
entire  LA-4  cycle  (used  in  certification)  was  reinstated.
Also, at this time,  it was concluded that  the evaporative  tests
on  11.5-psi  commercial  fuel  may  have  been  unrepresentative
because they  were  run  following a  battery  of  tests  on  9-psi
Indolene  over  which the  evaporative   canister  was  repeatedly
purged.    Therefore,   the commercial  test  was  begun  with  an
essentially  "unloaded"  canister,  which  would  probably  bias
results toward  lower emissions  than those  experienced in  the
field.  Further, because vehicles had  been operated on 11.5-psi
commercial fuel prior  to arriving at EPA,  it follows  that  the
most accurate measurement of  in-use emissions would be obtained
by testing commercial fuel first.   Therefore,  the  test sequence
was changed and  the  11.5-psi  fuel was  tested first, followed by
Indolene.

     In August  1984, testing of  the mid-range  commercial  fuel
with an RVP of  roughly  10.5  psi was added to the  sequence just
after the 11.5-psi fuel and before  any  Indolene testing.  Other
minor changes  (initiated in  July 1984)  involve the  storage of
the vehicle prior to any evaporative tests.   To avoid premature
saturation  of  the canister,  the gas cap  is   loosened  to  allow
vapors to bypass  the control system and the  vehicle  is stored
inside at a fairly constant temperature.

-------
                              2-48
                           Table 2-11
               Comparison of  In-Use Test Sequences
        Nov. 83 - July 84
1.   Park indoors and/or outdoors
2.   Shortened dynometer prep
      (10-min.)
3.   Indolene evaporative tests
4.  Exhaust emission tests
      (HFET and short tests)
5.  Commercial (11.5 psi)
      evaporative tests
  Post - July 1984
Park indoors; loosen
gas cap.
LA-4 dynometer prep
  (23-min.)
Commercial (11.5 psi)
  evaporative tests
Mixture (10.5 psi)
  evaporative tests*
Indolene evaporative
   tests
Exhaust emissions tests
  (HFET and short tests)
     10.5 RVP added in August 1984.

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                              2-49

     B.    General Test Results

     Vehicle samples used in EPA's in-use EF  testing both prior
to  and after the  July  1984  test procedure changes  are  broken
down   by  manufacturer   in   Table   2-12.*    Carbureted   and
fuel-injected  samples   are   outlined   separately,   and  sample
distributions are compared to 1984 market shares.

     Evaporative  emissions   from  these   test  vehicles   are
summarized in Table 2-13.  Results are  shown  for  both Indolene
and  commercial   (11.5-psi)   fuels,  and  are  separated  out  by
vehicle  type  and test  procedure.  The  MOBILE3 emission rates
published  in  June  1984  are  from a  subset  of  the  November
1983-July  1984  tests  and are  listed separately for comparison.
Revised MOBILES estimates are listed as July 1984 -  April  1985
results.

     As  indicated   from  the  results  shown in  Table  2-13,  the
change  in  the  test  procedure  has   led  to   slightly  lower
emissions  with  Indolene and somewhat  higher  emissions  with
commercial  fuel  in  almost   all  cases.   (This  is  as  to  be
expected from the previous  discussion  on the reasons behind the
changes  in fuel test sequence.)  For   fuel-injected  vehicles,
higher  emissions  also  may  be   partially  due  to  the  higher
average  mileage of  the  vehicles being tested;  the  vehicles
tested  after July  1984 have an average  mileage over twice  that
of those tested previous to that time.   Results of  the July 84
- April  1985 testing  are shown graphically in Figure 2-7, which
plots revised hot-soak and diurnal emissions versus fuel RVP.

     Both  sets  of   vehicles  tested   show  average  emissions
exceeding  the 2-gram  standard for total evaporative emissions,
even   while   operating   on   Indolene:    carbureted   vehicles
averaging  4.64  grams/test and fuel-injected  vehicles averaging
2.15  grams/test.    When   tested   on  11.5-psi  commercial  fuel,
these  evaporative emissions are  much  larger:   12.85 grams/test
for carbureted  vehicles  and  7.34 grams/test for  fuel-injected
vehicles.   The  possible   causes of   the   excess  evaporative
emissions  are  the  subject  of  discussion  in  the  following
section.
     The post-July 1984 vehicle sample  includes  vehicles tested
     only through  April  1985, the  point  at which  test  results
     were "frozen" for this  analysis.   Subsequent  test  results
     are currently being analyzed.

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                                   2-50
Manufacturer

GM
Ford
Other Domestic*
Toyota
Nissan
Other Imports**
Total
                                Table 2-12

                   In-Use  EF Vehicle  Sample Distribution
                         Carbureted
Nov. 83-
July 84
31(33%)
38(41%)
12(13%)
2( 2%)
3( 3%)
7( 8%)
93(100%)
July 84-
April 85
32(29%)
26(24%)
17(16%)
13(12%)
14(13%)
7( 6%)
109(100%)
1984
Market
Share
46%
13%
11%
4%
5%
21%
100%
Fuel-Injected
Nov. 83-
July 84
57(74%)
9(12%)
3( 4%)
8(10%)
77(100%)
July 84-
April 85
15(27%)
2( 4%)
13(24%)
13(24%)
8(14%)
4( 7%)
55(100%)
1984
Market
Share
42%
25%
11%
10%
9%
3%
100%
* *
AMC, Chrysler, VWA.
Honda, VWG, Mitsubishi, Toyo-Kogyo, Audi.

-------
                         2-51
                      Table 2-13

      Comparison  of  Evaporative  EF Test Data  from
Non-Tampered Vehicles (g/test)
Indolene (RVP =9.0 psi)
Test Period
Nov 83 -
July 84
Published
MOBILES*
July 84 -
April 85**
Technology
Garb.
Fuel-Inj .
Garb.
Fuel-Inj .
Garb.
Fuel-Inj .
N
93
77
53
62
109
55
Commercial
Test Period
Nov -
July 84
Published
MOBILES*
July 84-
April 85**
Technology
Garb.
Fuel-Inj .
Garb.
Fuel-Inj .
Garb.
Fuel-Inj .
* The MOBILES results
July 84
** Revised
*** This ie
N
93
77
53
62
109
55
are
data pool.
MOBILES estimates
•hhp »ve»raap nf ai
Mileage
45000
20000
60000
20000
55000
46000
Fuel (RVP = 11
Mileage
45000
20000
60000
20000
55000
46000
from a subset
, used in this
r?1-iial 1-est- resi
Diurnal

4.16
1.64
4.22
2.21
2.32
1.25
.5 psi)
Diurnal

8.64
2.33
9.31
3.13***
9.01
5.51
of the
study .
l"]1-R_ Hftt
Hot-Soak

2.19
0.96
2.74
1.12
2.32
0.90
Hot-Soak

3.29
1.28
3.98
1.55
3.84
1.83
Nov . 83 -
jpv*»r . diip
to  uncertainties  associated  with the  low  mileage,  the
value   for   carbureted   vehicles  was   also   used   for
fuel-injected vehicles in MOBILES.

-------
                        Figure 2-7
    EVAPORATIVE EMISSIONS VS. FUEL RVP
   12
   10-
CO
§
    6-
    0
          8.5
T
9
"T"
9.5
    10   10.5
FUEL RVP (PSI)
T
11
11.5
-r
12
                                                                  NJ
                                                                  I
                                                          Legend
                                                         A HOTSOAK/RNJ

                                                          HOTSOAK/RNJ AVG

                                                         D HOTSOAK/CARB ___

                                                          HOTSOAK/CARB AVC

                                                         O DIURNAynNJ _______

                                                          DIURNAL/HNJ AVC
                                                          DIURNAl/CARB AVG

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                              2-53

     C.    Components of Excess Motor
           Vehicle Evaporative Emissions

     For purposes  of analysis,  it  is  useful  to  segregate  the
evaporative  emission excess  described  above  according  to  its
probable  causes.    Using   EF   test   data,  these   four  basic
categories were  chosen  as:   1)  effect of  insufficient design
capacity/purge,  2)  effect  of  malmaintenance  and  defects,  3)
effect  of  excess   RVP,  and  4)  effect  of evaporative system
tampering.  The  causes  and magnitude  of each of  these effects
(for current vehicles)  are  detailed  below;  more information on
the methodology used to separate  these  four sources is provided
in Appendix 2-B.

     1.    Insufficient Design Capacity/Purge

     Even  with    properly   functioning   evaporative   emission
control systems,  many current  vehicles fail to meet the 2-gram
standard  on  Indolene.   This  is primarily seen  in  carbureted
vehicles  which  average  2.75  grams/test  when  there  are  no
apparent malfunctions.*  Conceivably,  this failure could be due
to an  insufficient capacity to  store or  purge  vapors  inherent
in the  system  design.    It  may also be valid  to attribute some
of  these  excess  emissions  to  lingering  effects  of   high  RVP
fuels and  alcohols on charcoal  working capacity.   (However,  as
discussed  in  Section   IV,  the   effects  of  low-level  alcohol
blends and the use  of  high RVP fuels  do  not  appear to be long
lasting.)

     The plausibility of insufficient  design capacity  and purge
is  evident  from  the  limitations of  the  evaporative emission
test procedure and certification process.   To be  certified,  a
vehicle  must  meet  the  standard after  applying  an  additive
deterioration factor to  low mileage  emission test  data.  Also,
MSAPC Advisory Circular  No. 50A  states that vehicles  should be
able to pass  the  evaporative  emission  test when  starting  the
test seguence with a saturated canister.   (Many EF vehicles are
probably  received  in this  condition.)  This  means that purge
systems  should  be  designed   to  completely   purge  a  loaded
canister  with  the  LA-4  prep  cycle.   However,  there  is  no
reguirement  for   this   in  the  certification  test  procedure.
Thus, it is possible that a  certification  vehicle,  as  currently
designed,  would fail were  it to begin the test with a saturated
canister.
     As shown in Appendix  2-B,  Table 2-B-2,  for  "problem-free"
     vehicles (to be explained in the next few paragraphs).

-------
                              2-54

     The derivation of  the  magnitude  of the insufficient design
capacity/purge effect is detailed in Appendix  2-B.   The general
concept involved  was  to compare the average emission levels of
the "problem-free" vehicles, as defined in Table  2-14,  with the
standard   level   of    2   grams/test    for   total   evaporative
emissions.  The  difference  between the two  levels was  assumed
to be due  to  the emission control system design.   Summarized in
the top portion  of Table  2-15,  this  effect  is  not  seen  in
fuel-injected  vehicles,  but   averages  0.70  grams/test   for
carbureted  light-duty   vehicles.   This effect of  insufficient
design  capacity  and purge  is  noted here because  it  presumably
would   be   eliminated   for  new  vehicles   by   revising   the
evaporative emission  test  procedure to require that a vehicle
begin the test with a saturated canister.

     2.     Malmaintenance and Defects

     Non-tampered  vehicles  with  the  maintenance problems  and
hardware defects  listed in Table 2-14  (tampering is considered
separately  below)  will  generally  have  higher  evaporative
emissions  than well-maintained  vehicles.  These problems  can
lead to either  a partial  increase  in emissions  (e.g.  from  a
dirty canister  filter)  or  to  completely  uncontrolled emissions
(e..g.,  from  an  inoperative canister  purge solenoid  or valve).
On  average,  excess emissions  would not  be expected to be  as
high as the uncontrolled emission baseline because some purging
would   still  occur.    This  is   different  from  the  case  of
tampering  where  complete system  disablement   is   generally  the
result.

     The magnitude  of  the  effect of malmaintenance and defects
for current  vehicles  operating  on  Indolene   is  estimated  by
considering the  difference  between the non-tampered EF vehicle
sample  average  and the problem-free  vehicle  sample  average
tested  on  Indolene.    Inherent  in  this  calculation  is  the
assumption   that   the   EF   sample    has   a   representative
malmaintenance  and defect  rate.   For carbureted  vehicles  (see
Table 2-16),  the malmaintenance  and  defect rate  from EF  cars
tested  since  July  1984 (32 percent)  is within  the range  and
essentially equal  to  the average  of  all other  available  data
samples.  For fuel-injected vehicles, the newer EF sample has a
slightly higher  rate  than  the other  samples   (e.g.,  16 percent
versus  only 5 percent  in the  pre-July 1984 in-use EF  sample).
However,  this  is  probably due  to  the  fact  that  the  fuel
injected  vehicles  in  the  old EF sample averaged  fewer  total
miles on  their  odometers  than  those  in  the  current  sample
(20,000  vs.  46,000).    Overall,  then,  the  malmaintenance  and
defect  rates  in the July  1984 -  April  1985  EF  sample  appear
representative.

-------
                              2-55
                           Table 2-14

                 Conditions Excluding Vehicles
                    From Problem-Free Sample
I.    Fuel System
     A.     Carburetor Assembly
           1.     Loose on Manifold
           2.     Leaks Fuel
           3.     Exceptionally Dirty

     B.     Fuel Injection Components
           1.     Injectors Leaking

II.   Evaporative System

     A.     Canister
           1.     Saturated with Fuel
           2.     Broken
           3.     Missing*

     B.     Canister Filter
           1.     Dirty
           2.     Saturated with Fuel
           3.     Missing

     C.     Canister Purge Solenoid/Valve
           1.     Leaks Vacuum
           2.     Sticking
           3.     Inoperative
           4.     Missing*
           5.     Disconnected*

     D.     Hoses, Lines, Wires
           1.     Vacuum Line Plugged
           2.     Vacuum Line Disconnected*
           3.     Vacuum Line Damaged
           4.     Vacuum Line Misrouted*
           5.     Vent Line Damaged
           6.     Vent Line Disconnected*

     E.     Other
           1.     EFE TVS Stuck Open/Closed
           2.     Non-OEM Gas Cap
           3.     Bowl Vent Control Valve Always Open/Closed
           4.     VCV Vacuum Control Valve Inoperative
           5.     Gas Cap Leaks
           6.     Sending Unit Gasket Leaking
           7.     Fuel Tank Rollover Valve Leaking
           8.     Air Cleaner Assembly Gasket Broken/Missing
           9.     EFE Control Switch Missing*
           10.    Gas Cap Missing*
     Considered to be tampering.

-------
                                 2-56
                              Table 2-15

              Magnitude of Excess  Evaporative Emissions
                    from Current Vehicles (q/test)
Vehicle
 Class

LDV/LDT
HDV
     Insufficient Design Capacity/Purge Effect


                             Diurnal           Hpt_Soak
Fuel Metering
	System
            Carb
            FI

            Carb
                         0.30
                         0.00

                         0.48
   0.40
   0.00

   0.64
             Malmaintenance/Defect and Excess RVP Effects
Vehicle
 Class
LDV/LDT
HDV
        Fuel Metering
 RVP        System
 9.0        Carb
            FI
 9.5        Carb
            FI
10.0        Carb
            FI
10.5        Carb
            FI
11.0        Carb
            FI
11.5        Carb
            FI

 9.0        Carb
 9.5        Carb
10.0        Carb
10.5        Carb
11.0        Carb
11.5        Carb
                    Malm./Defect
Diurnal
1.11
0.34
1.21
0.44
1.31
0.54
1.41
0.64
1.51
0.74
1.61
0.84
1.77
1.93
2.09
2.25
2.41
2.57
Hot Soak
0.83
0.29
0.91
0.42
0.99
0.55
1.07
0.67
1.15
0.80
1.24
0.93
1.32
1.45
1.58
1.71
1.84
1.97
Excess RVP
Diurnal
0.00
0.00
0.62
0.24
1.54
0.48
2.78
0.79
4.33
2.03
6.19
3.76
0.00
0.98
2.46
4.43
6.90
9.85
Hot Soak
0.00
0.00
0.06
0.05
0.20
0.11
0.42
0.18
0.73
0.24
1.11
0.29
0.00
0.09
0.31
0.67
1.15
1.77

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                              2-57


                           Table 2-16

            Malmaintenance and Defect Rate Comparison
Sample

EF (new)*

EF (old)**

SwRI[42]

API (NIPER)[43]

API (ATL)[44]

Average***


*    Vehicles  tested on  three  fuels  w/LA-4  prep,  commercial
     fuel first; July 1984-April 1985.
**   Vehicles  tested on  two  fuels  w/10-minute prep,  Indolene
     fuel first; November 1983-July 1984.
***  Sample-size weighted.
Carbureted
Sample
Size



!43]
t]

108
93
27
19
28
—
Defect
Rate
32%
44%
26%
11%
25%
33%
Fuel Injected
Sample
Size
55
77
—
32
10
_ —
Defect
Rate
16%
5%
—
13%
0%
10%

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                              2-58

     While  the   above   methodology   appears   satisfactory  for
estimating  the magnitude  of  the malmaintenance/defect  effect
for vehicles  operating  on 9-psi  Indolene,  it is  expected that
the effect  would  increase with  the  level  of  in-use RVP.   The
same  would  be true for  a  tampered  vehicle.   Basically,  if
excess  emissions  are  being  released  from  the  canister  or
elsewhere,  increased vapor  loadings  that  result  from  higher
in-use   RVPs  will   lead   to   increased   emissions.     While
redesigning vehicles  for higher  RVP  fuel should lower emissions
when  the  control  system  is  fully  operable,  the  effect  of
malmaintenance or a defect would be  expected  to be independent
of  the RVP  for  which  the  vehicle was designed and  dependent
only on the RVP of the fuel actually used.

     Estimation of the  magnitude of  this effect at various RVPs
is  described  in  detail  in  Appendix  2-B;   the  results  are
summarized  here   in  the  center   portion  of  Table  2-15.   This
effect can  be  quite  large  with  11.5  RVP fuel —  approaching 3
grams/test  for  carbureted  light-duty vehicles  and  2  grams/test
for light-duty fuel-injected vehicles.

     While the insufficient design/purge  and  excess RVP effects
(discussed  below)  are assumed to be  totally eliminated  in new
vehicles via changes  to certification fuel and  test  procedure,
the malmaintenance/defect effect  can  only be controlled through
reduction  of  in-use  fuel  volatility  or  through  an  effective
evaporative system inspection and maintenance program.

     3.    Excess RVP Effect

     The  excess RVP effect is defined as  the  emissions  impact
of operating vehicles on a  fuel  of higher  volatility than that
for   which  their   evaporative   control   systems  have   been
designed.  Canisters  and purge systems on  current  vehicles are
designed to meet  the 2-gram  evaporative standard if operated on
9.0   RVP  Indolene   over   the   standard  certification   test
procedure.   However,   as  discussed   in  Section  IV  of  this
chapter,  the RVP  of current  in-use  gasoline  in  many of  the
ozone  non-attainment  areas   of   the  country  is  significantly
higher  than 9.0  psi.   Because  of their  higher  volatilities,
these  commercial  fuels  emit more   evaporative HCs  than  the
vehicles' canisters  can accommodate,  which results  in  canister
saturation and "breakthrough" of HC vapors to the atmosphere.

     The  magnitude  of this excess RVP  effect  can be calculated
by   first   subtracting  total    average   emissions   of   the
non-tampered sample  on  Indolene  from  those on commercial fuel.
However, because part of this  difference  between commercial and
Indolene  emissions  has  already  been  accounted  for   in  the
malmaintenance and  defect  effects, an  adjustment to the  total

-------
                              2-59

difference    is    needed.    The    difference   between    the
malmaintenance/defect  effect  on  Indolene  and commercial  fuel
must .  be   subtracted  from   the   total   difference   between
non-tampered emissions at Indolene and commercial fuel  to  yield
the  excess  RVP effect.   This  is  explained  in  more detail  in
Appendix 2-B.

     The  magnitude  of this  remaining  excess  RVP  effect  on
current vehicles  is  shown in Table  2-15 (along with the  other
two effects).  With  an in-use fuel RVP of  11.5 psi,  the excess
RVP  effect   is  7.30   and  4.05  grams/test  for  carbureted  and
fuel-injected   light-duty   vehicles,    respectively.     These
represent respective  increases of 265  percent and  103 percent
from the 2 gram/test standard level.

     As with the  insufficient design/purge effect,  this excess
RVP  effect   is  assumed  to  be  completely  eliminated   for  new
vehicles if certification  fuel  RVP  is raised to a  level  egual
to  or  greater  than  in-use   fuel  RVP.    However,  for  vehicles
certified prior to any change in certification fuel  RVP (i.e.,
1990 in  this analysis), the  excess  RVP effect will remain and
be dependent upon in-use RVP.

     4.     Tampering Effect

     Intentional  system  disablement  also  contributes  toward
excess evaporative  emissions.  EPA's  in-use  EF  sample is  not
thought to  have  a representative  number  of  tampered vehicles,
since  those  who  tamper  with  their   emission  controls  may
generally be  reluctant   to   lend  their  vehicles  to  EPA  for
testing.   The  EF sample  is  also  relatively  small  due to  the
high cost  of emission testing.   For  these  reasons,  tampering
rates to  be used in  emissions  modeling are  developed  from EPA
tampering surveys  involving  thousands  of  vehicle  inspections.
Those  conditions   considered   as   tampering  are   primarily
disconnected, misrouted or missing hoses,  missing  canisters and
missing fuel caps (as indicated previously in Table 2-14).

     Because emissions from tampered vehicles are not developed
from  the EF sample,  the  MOBILES  program  accommodates  them
separately.    Tampering   incidence   rates   are  developed   from
survey data  and  excess emissions  are determined from  emission
tests  on  completely  disabled  systems.    Since  the  original
MOBILES  estimates  were  published  in  June  1984,   additional
tampering   data  has  become   available   that   has   allowed
improvement  over  the June 1984  estimates.   These revisions  to
the MOBILES  tampering estimates are discussed below.

-------
                              2-60

     The   original   MOBILES  LDV   tampering   incidence   rates
published  in  June  1984  were based  on a  linear regression  of
tampering  frequency versus mileage using  the results  of  EPA's
1982  Tampering Survey. [45]   For LDTs  and  HDVs,   the  rate  of
increase of tampering with mileage  for LDVs was applied  to the
average  LDT-sample  tampering frequency  and  vehicle  mileage,
because  the  LDT  sample was  too small  to derive  a change  in
tampering  over  time and no  HDVs were surveyed.  The  zero-mile
tampering  rates,  however,  were  developed  from the  LDT sample;
these LDT zero-mile rates were also  used for HDVs.

     As mentioned  above,  updated EPA  survey  results from  1983
and  1984 have  since become available, so these  data were added
to  the 1982  tampering  data  used  to  develop  the  June  1984
MOBILES  estimates.[46,47]    The   resulting   information   was
sufficient  to  develop  separate  tampering  rate  estimates  for
both LDVs  and  LDTs;  the  HDV rates were still  assumed to  be the
same as  those  for  LDTs.   Additional  revisions  to  the MOBILES
tampering  estimates  include  the designation  of vehicles  with
misrouted  hoses  and  missing  fuel caps  as tampered vehicles.*
Since  these conditions  were not considered as tampering  in the
June 1984  version of MOBILES, previously  estimated effects  of
tampering  may  have been  somewhat  understated.   Plots of  the
revised MOBILES  tampering  rates versus  mileage  for   LDVs  and
LDTs are shown, respectively, in Figures 2-8 and 2-9.

     One possible  form  of  tampering/malmaintenance that  still
remains to be  investigated is the use  of replacement  gas  caps
not  meeting  the  same specifications  as the  original  gas  cap
(referred  to as non-OEM (original  equipment  manufacturer)  gas
caps).  Such gas  caps may  not seal  properly and could result in
either  partially  or completely uncontrolled emissions.   The
extent of  their use and their effect on emissions  is  currently
being investigated.

     In  addition to  revising tampering  incidence  rates,  the
emission rates  for  tampered  vehicles  have  also been modified by
supplementing the pre-June  1984  data  with  more recent  data and
by incorporating emission  excesses associated with missing fuel
caps.  With certain exceptions, it is assumed  that  all  types of
tampering  result  in completely  uncontrolled  emissions.  A case
in which this  assumption may not be  strictly valid is for the
disconnection  of  a carburetor bowl vent line  at the carburetor
end  (i.e.,  not  at the canister).  In this case,  only  hot-soak
     As  misrouted   hoses   and  missing  fuel   caps   could  be
     unintentional,   there  remains  some question as to  whether
     they     should     be    considered     "tampering"     or
     "malmaintenance".    However,  as these  conditions were not
     felt to be  properly represented  in the EF sample, they are
     currently regarded as  tampering.

-------
                               Figure 2-8
s
111
2
                  LDV  TAMPERING RATES
                        MOBILEJ AND NEW SURVEYS
   S U RVE YS- EVAPfcCAP
MILEAGE (1000 MILES)
   +   SURVEYS-EVAP
  100


MOBILE 3

-------
                             Figure 2-9
111
                  LOT  TAMPERING RATES
                       MOBILES AND NEW SURVEYS
   SURVEYS- EVAPfcCAP
MILEAGE (1000 MILES)
   -I-  SURVEYS-EVAP
                                                                 to
                                                                 I
                                                                 to
                                               80
     100


o  MOBILES

-------
                              2-63

emissions   would  be   uncontrolled.    However,   because   the
tampering  survey  does  not  make this  distinction,  a  better
estimate is not available at this time.

     The  uncontrolled   evaporative   emission  rates   used  to
quantify  the tampering  effects  are based on  SHED testing  of
vehicles  with  removed canisters  and/or fuel  caps.   These are
summarized  in  Table 2-17,  which also  shows the  increase  with
in-use  fuel  RVP.   Several  assumptions  that  were   made  in
deriving these emission rates are described below.

     First, with  respect to diurnal losses, the effect of  fuel
cap removal  is  assumed to be the same  as  canister  removal for
both  carbureted  and  fuel-injected vehicles,   since  diurnal
emissions  result  entirely  from  the fuel  tank.    Also,  diurnal
emissions  from  fuel-injected vehicles  with either  missing gas
caps  or  canisters  is  assumed  to be  the  same as  those  from
uncontrolled carbureted  vehicles (for  which more data exist).
Again,  diurnal  emissions  occur  entirely  from  the  fuel  tank
where the  two  technologies do not differ.   Also,  the  fuel  tank
volumes of the two vehicle types do not generally differ.

     Second,   with   respect   to   hot-soak   emissions   from
fuel-injected vehicles,  fuel cap removal  is assumed  to result
in  completely  uncontrolled  hot-soak  emissions.    A  properly
assembled  fuel  injector   should  emit little,  if  any,  during a
hot  soak,   leaving  the  fuel  tank   as   the  primary  source  of.
emissions.   Limited   data  on  three   fuel-injected   vehicles
confirm this.   Hot-soak  emissions using Indolene  with  the gas
cap   removed   and  those  with  the   canister   removed   were
essentially  identical   at  just  over   4  grams/test,   where
controlled  emissions  were  below  one gram/test.[48]   Emissions
using commercial  fuel  without  a  canister were  only  slightly
higher  than those  without  a  gas cap.   Thus,   this  assumption
appears to  be  valid for  fuel-injected  vehicles.  However,  for
carbureted vehicles, the increase in hot-soak  emissions due to
fuel  cap   removal   is   expected  to   be   less   than  totally
uncontrolled  hot-soak  emissions  because  the  carburetor  bowl
contributes to,  and  probably is  the major source of,  hot-soak
losses  from these vehicles.   Since data  are not available to
precisely predict the  degree to  which  hot-soak emissions  from
carbureted  vehicles  would  increase  with  fuel  cap  removal,  it
will  be  assumed  that  the  carburetor  bowl dominates   and  that
hot-soak emissions do not increase.   Thus, the values presented
in Table  2-17  for hot-soak  emissions  from carbureted  vehicles
with missing  fuel caps  are  the  same as those  for non-tampered
carbureted vehicles  (i.e.,  2.32  and 3.84  g/test  for  9.0- and
11.5-psi RVPs,  respectively, as shown in Table 2-13).

     As explained in Appendix  2-B,  the tampering offsets  used
in this  analysis were   calculated  by  subtracting the  average
non-tampered vehicle  emissions  shown  in  Table  2-13  from the

-------
                                             Table 2-17

             Uncontrolled Evaporative Emissions (g/test)  from Tampered Vehicles  vs.  RVP*
Canister Disconnects
Vehicle
Type
LDV
and
LOT,



Model
Year
pre-71
71
72-77
78-80
81+

Fuel
System
All
All
All
All
Garb
Finj
—9.0
H.S.
14.67
14.67
14.67
13.29
10.36
4.93
psi—
Dnl.
26.08
26.08
20.90
16.32
14.95
14.95
-11.5
H.S.
22.45
22.45
22.45
18.50
17.47
11.59
psi**-
Dnl.
47.99
47.99
35.45
25.11
25.71
25.71
—9.0
H.S.
14.67
10.91
10.91
2.32
2.32
4.93
Fuel Cap Removal
psi—
Dnl.
26.08
26.08
20.90
16.32
14:95
14.95
-11.5
H.S.
22.45
16.15
8.98
3.79
3.84
11.59
psi**-
Dnl.
47.99
47.99
35.45
25.11
25.71
25.71
LDT2         pre-79    All          18.08   42.33     27.66  77.89     18.08  42.33     27.66  77.89

              79+      Same as LDV, LDTi

                                                                                                               V
                                                                                                               CTi
HDV          pre-85    All          18.08   42.33     27.66  77.89     18.08  42.33     27.66  77.89           "*

              85+                   14.67   26.08     23.31  39.87      3.69  26.08      6.11  39.87
*    Figures presented are for  low  altitudes;  high-altitude correction factors are  as  follows:   1)
     LDV  — pre-1977  =  1.3,  1977  = 1.0,  1978-81  = 2.59,  1982-83  =1.3, 1984+  = 1.0;   2)  LOT,,
     LDT2 and HDV — all model years = 1.3.
**   Values for RVPs between 9.0 and 11.5 psi can be calculated via linear interpolation.

-------
                              2-65

uncontrolled emission  levels in Table  2-17.   These  offsets  at
various  RVPs  were  then incorporated  into  the  EF  runs  at  the
tampering  incidence  rates  developed   from   the  survey  data
previously   discussed.    These   offsets   represent   extreme
increases  in  evaporative  emissions,  reaching  levels of  10-20
grams/test for  11.5 RVP fuel.   (Tampering  offsets  are shown in
Appendix 2-B  for light-duty and heavy-duty vehicles  in  Tables
2-B-6 and 2-B-7, respectively.)

     5.    Summary

     Based on  the above discussions,  motor vehicle evaporative
emissions  can  be  divided  into several  different  categories.
The  first  consists  of emissions  from  properly-designed  and
operated vehicles  assumed  to emit  at the  standard;  therefore,
none  of the  control  strategies (to  be detailed  in the  last
section  of  this  chapter)  will  reduce  this portion.   However,
the  four probable  components  of current  excess motor  vehicle
emissions will be addressed in the remainder of this study.

     The first  — insufficient  design  of  the purge  system  —
could  be  addressed  via  changes  to  the  certification  test
procedure.    The  excess   RVP   effect   could   theoretically  be
reduced  or  eliminated through the reduction of  in-use fuel RVP
and/or the revision  of certification fuel  specifications.   The
effects  of the  remaining two  sources  of excess  evaporative
losses  (i.e.,   malmaintenance/defects   and  tampering)  probably
cannot  be  totally   eliminated,  but  could  be  significantly
reduced  if  in-use  RVP  were controlled to lower levels or  an
effective  inspection and  maintenance  program  for  evaporative
systems could be developed and implemented.

     The extent  to  which each  of these five sources contribute
to  total  motor  vehicle   evaporative   losses  —  and to  total
non-methane hydrocarbon (NMHC)  inventories  —  will  be explained
in  Chapter  5.   There, future  total NMHC  inventories will  be
broken  down  into  stationary source  emissions  (separated  into
bulk storage,  Stage I, refueling, and  other)  and motor  vehicle
losses  (divided  into  exhaust  HC and  the  five components  of
evaporative HC  losses).   Results  are  presented graphically  in
Figure 5-1 of Chapter 5.

     D.    Effect of RVP on Exhaust Emissions

     EPA's EF  program includes  tests  for  exhaust  emissions  as
well as  evaporative  emissions.   Prior to November of 1983,  when
testing was only performed using Indolene,  the effect of  RVP on
in-use  emissions  was not known.  Between October 1983 and  July
1984,   RVP   appeared   to   have  little   effect  on   exhaust
emissions.[49]   However,   since  July  1984   (when  the  test
sequence was  improved), a significant effect  has  been  seen,
particularly that  lowering RVP  lowers  exhaust  emissions of  HC
and  CO;  no significant reduction  in NOx  emissions  with  lower
volatility fuels  has been noted.   The  lack of  an  effect prior
to July 1984 is  presumed to be due to  the  extra purging  of the

-------
                              2-66

in-use canister during the  evaluation on Indolene,  in which the
HFET and various short tests were conducted.

     Figures  2-10  through  2-15  show  the  trend  toward  higher
exhaust emissions  with  higher volatility  fuel  for  each  of  the
three  pollutants.    This   effect   is   seen   with   open-loop
carbureted,    closed-loop    carbureted,    and    fuel-injected
vehicles.   The data  in these figures consist of all  those  cars
tested between July  1984  and July 1985, in which the commercial
fuel was tested first and the prep cycle was a full  LA-4.*

     Tables   2-18    through   2-22   present  the   results   of
statistical  analyses to  determine  if  the  trends noted  in  the
above  figures are significant.   Table 2-18  shows  the  results
obtained  from  assuming  a  simple   binomial  model.   If  there
exists  no  relationship  between  exhaust  emissions  and  fuel
volatility,   then   the   number   of  vehicles  showing   higher
emissions with  a  higher  RVP fuel  should  be approximately  one
half of the total number  of vehicles.  The standardized value
determined  (a)  is a measure  of the  likelihood that a  given
number of  vehicles would have higher emissions at  a  higher  RVP
if  there   is  no   relationship   between  the  two   (i.e.,   if
randomness  is assumed).   As Table  2-19  shows,  a is  less  than
0.05 for  all but  one of  the HC  and CO cases, which indicates
that  an  RVP/exhaust  emissions   relationship  probably  exists
(i.e.,  the results are not randomized).

     Tables  2-19  through 2-22  show  the  results of  performing
analyses of variance using the following model:

Exhaust Emissions (VEH,RVP) = n + AVKH + ARVp,  where

     H = overall mean for all vehicles at all RVPs
     AVEH  = average deviation from the mean for a given
              vehicle
     ARVP  = average deviation from the mean for a given RVP

Should the  effect  of RVP  not be  significant, then the value of
ARVP will  be equal  to zero for each  RVP.  This  is indicated
by the F-statistic,  which is a  measure of the relative  amount
of variance  in  the data explained by the given factor (in this
case RVP).   The vehicle-related  variability  was also included
in this analysis so  that  the effect of fuel volatility could be
more   clearly  identified    The  tables   indicate    that   the
F-statistic  is  greater  than  F-95%  in  all of  the  HC  and CO
cases,  which indicates that RVP  is  significantly   related to
exhaust HC and CO (see footnotes  on tables).
     Because  the analysis  on  the  effect  of  RVP  on  exhaust
     emissions was  conducted after the  analysis  on evaporative
     emissions,  more  vehicles were able  to  be included  (i.e.,
     the  exhaust   data  were  "frozen"   in   July  1985,   while
     evaporative data were examined only through April 1985).

-------
                       Figure 2-10
 t.5
0.5-
             AVERAGE HC EMISSIONS (G/Ml)
                            N=65
                                                            M
              9.0        10.4         11.7
            OPEN LOOP CARBURETED VEHICLES

-------
                          Figure 2-11
   20
    15-
    10-
Ul
    5-
                AVERAGE CO EMISSIONS (G/MI)
                               N=65
                                                               CTi
                                                               oo
                 9.0        10.4         11.7

               OPEN LOOP CARBURETED VEHICLES

-------
                          Figure 2-12
to
z
o
LU  0.5-
                 AVERAGE NOx EMISSIONS(G/MI)
                                                              K>
                 9.0          10.4         11.7

                    i nnp P.ARRURFTED VEHICLES

-------
                            Figure 2-13
    1.5
«M»    *
o
GO
LJ 0.5-
                  AVERAGE HC EMISSIONS (G/MI)
              CARBURETED
                 N=81
                                       FUEL-INJECTED
                                             N=61
            9.0  10.4   11.7          9.0   10.4
                     CI OSED LOOP VEHICLES
                                                  11.7
                                                                  to

-------
                            Figure 2-14
                 AVERAGE CO EMISSIONS (G/MI)
o
(/>
CO

Ul
             CARBURETED
FUEL-INJECTED

      N=61
           9.0   10.4    11.7           9.0  10.4   11.7

                     CLOSED LOOP VEHICLES
                                                                  to

-------
                       Figure 2-15
 1.5

0.5-
 0
             AVERAGE NOx EMISSIONS (G/MI)
          CARBURETED
                                   FUEL-INJECTED
              10.4   11.7          9.0   10.4
                 CLOSED LOOP VEHICLES
                                                            NJ

-------
                                      Table 2-18
                       Vehicles Showing Higher Exhaust Emissions
with Higher RVP Fuels
CARBURETED VEHICLES
RVP(psi)
High/Low
HC


CO


NOx


10.4/9.0
11.7/10.4
11.7/9.0
10.4/9.0
11.7/10.4
11.7/9.0
10.4/9.0
11.7/10.4
11.7/9.0
Open-Loop
Number
53
44
54
48
38
52
26
34
34
out of
out of
out of
out of
out of
out of
out of
out of
out of
65
65
65
65
65
65
65
65
65
FUEL INJECTED

HC


CO


NOx



10.4/9.0
11.7/10.4
11.7/9.0
10.4/9.0
11.7/10.4
11.7/9.0
10.4/9.0
11.7/10.4
11.7/9.0

42
50
54
40
40
44
37
31
38
Number
out of
out of
out of
out of
out of
out of
out of
out of
out of

61
61
61
61
61
61
61
61
61
cx*
.0000
.0022
.0000
.0000
.0869
.0000
.5537
.3557
.3557
Closed-Loop
Number O**
49
69
68
59
65
71
44
44
50
out of
out of
out of
out of
out of
out of
out of
out of
out of
81
81
81
81
81
81
81
81
81
.0294
.0000
.0000
.0000
.0000
.0000
.2177
.2177
.0174
(All Closed-Loop)
CX*
.0016
.0000
.0000
.0075
.0075
.0003
.0485
.4483
.0274








































Combined

Number cx*
102 out of 146
113 out of 146
122 out of 146
107 out of 146
103 out of 146
123 out of 146
70 out of 146
78 out of 146
84 out of 146
ALL VEHICLES
Number e
144 out of 207
163 out of 207
176 out of 207
147 out of 207
143 out of 207
167 out of 207
107 out of 207
109 out of 207
122 out of 207
.0000
.0000
.0000
.0000
.0000
.0000
.8085
.2033
.0344

a<*
.0000
.0000
.0000
.0000
.0000
.0000
.3121
.2236
.0051
=  A measure of the likelihood that this many vehicles would  show  higher exhaust emissions
at a  higher RVP  if there was no  real  relationship between the two  (i.e.,  a higher value
indicates a higher  likelihood  that this occurrence is random).  Values  above .05 indicate
that  the occurrence  can be considered random at  a  95-percent confidence  level.   Values
below  .05  indicate  that the occurrence is not  random and that  there  is  a statistically
significant relationship between exhaust emissions and fuel RVP.
                                                                                                       V
                                                                                                       ~J
                                                                                                       to

-------
                                   2-74
                                Table 2-19

                 Analysis  of Variance - Exhaust RVP Effect
                              (All Vehicles)
Source

RVP
VEH
ERR
TOTAL
 DF

  2
206
412
620
  SS

  2.0401
883.050
 10.970
896.060
Exhaust HC

MSB

1.0201
4.2866
 .0266
 F-stat*

 37.557
160.993
F 95%

3.00
1.00
F 90%

2.30
1.00
                                Exhaust CO
Source
RVP
VEH
ERR
TOTAL
DF
2
206
412
620
SS
661.020
258900.000
4828.980
264490.000
MSE
330.51
1256.8
11.964

F-stat*
27.626
105.053


Exhaust NOx
Source
RVP
VEH
ERR
TOTAL
DF
2
206
412
620
SS
MSE
.050497 .025248
257.49
5.380
262.92
1.2499
0.013

F-stat*
1.934
95.726


                                                          F 95%

                                                          3.00
                                                          1.00
                                                          F 95%

                                                          3.00
                                                          1.00
                                                         F 90%

                                                         2.30
                                                         1.00
                                                         F 90%

                                                         2.30
                                                         1.00
     The F-statistic  is a measure  of  the significance of  a given factor
     (here, RVP)  in relation to  the exhaust emissions.   A value  larger
     than  the  theoretical  value  (i.e.,  F 95%)  indicates that  the  RVP of
     the fuel  is  significant in  relation  to exhaust emissions  using the
     given level of significance (i.e., a 95% confidence interval).

-------
                                   2-75
                                Table 2-20

                Analysis  of Variance - Exhaust RVP Effect
                      (Carbureted Open-Loop Vehicles)
Source

RVP
VEH
ERR
TOTAL
 DF

  2
 64
128
194
    SS

     .62937
  187.000
    3.991
  191.620
Exhaust HC

MSB

 .31469
2.9219
0.031
 F-stat*

 10.094
 93.720
F 95%

3.07
1.43
F 90%

2.35
1.32
                                Exhaust CO
Source

RVP
VEH
ERR
TOTAL
 DF

  2
 64
128
194
    SS
MSB
  313.180   156.590
77333.000  1208.300
 1487.820    11.624
79134.000
 F-stat*

 13.472
103.952
F 95%

3.07
1.43
F 90%

2.35
1.32
Source

RVP
VEH
ERR
TOTAL
 DF

  2
 64
128
194
    SS
                               Exhaust NOx
MSB
 F-stat*
     .0051764  .0025882    .371
   59.598      .93121   133.503
     .893      .007	
   60.496
F 95%

3.07
1.43
F 90%

2.35
1.32
     The F-statistic  is  a measure  of  the significance  of  a given factor
     (here, RVP)  in relation to  the  exhaust emissions.   A  value  larger
     than  the  theoretical  value  (i.e.,  F 95%)  indicates that  the RVP of
     the fuel  is  significant  in  relation  to exhaust emissions  using the
     given level of significance (i.e., a 95% confidence interval).

-------
                              2-76
                           Table 2-21

           Analysis of Variance - Exhaust RVP Effect
                (Carbureted Closed-Loop Vehicles)

                           Exhaust  HC
Source
RVP
VEH
ERR
TOTAL
Source
RVP
VEH
ERR
TOTAL
Source
RVP
VEH
ERR
TOTAL
DF
2
80
160
242
DF
2
80
160
242
DF
2
80
160
242
SS
.86908
622.70
5.111
628.68
SS
MSB
.43454
7.7838
0.032
Exhaust
MSB
307.940 153.970
161460.000 2018.200
2552.060 15.951
164320.000
SS
.046258
111.960
2.757
114.760
Exhaust
MSB
F-stat*
13.604
243.676
CO
F-stat*
9.653
126.530
NOx
F-stat*
.023129 1.342
1.3995 81.206
.017


                                                     F 95%

                                                     3.00
                                                     1.29
                                                     F 95%

                                                     3.00
                                                     1.29
                                                     F 95%

                                                     3.00
                                                     1.29
F 90%

2.30
1.21
F 90%

2.30
1.21
F 90%

2.30
1.21
The F-statistic  is  a measure  of  the significance of  a  given factor
(here, RVP)  in relation to the  exhaust emissions.   A value  larger
than  the  theoretical  value (i.e., F  95%)  indicates that the  RVP of
the fuel  is  significant  in relation  to exhaust emissions using  the
given level of significance (i.e., a  95% confidence interval).

-------
                                   2-77
                                Table 2-22

                Analysis  of Variance - Exhaust RVP Effect
                         (Fuel-Injected Vehicles)
Source

RVP
VEH
ERR
TOTAL
 DF

  2
 60
120
182
    SS

     .59899
   30.841
    1.815
   33.255
  Exhaust HC

  MSB

   .29950
   .51401
   .015
F-stat*

19.802
33.984
F 95%

3.07
1.43
F 90%

2.35
1.32
Source

RVP
VEH
ERR
TOTAL
 DF

  2
 60
120
182
    SS

   86.789
 9470.300
  844.911
10402.000
  Exhaust CO

  MSB        F-stat*
 43.395
157.84
  7.041
 6.163
22.418
F 95%

3.07
1.43
F 90%

2.35
1.32
Source

RVP
VEH
ERR
TOTAL
 DF

  2
 60
120
182
    SS

     .010244
   77.208
    1.722
   78.940
 Exhaust NOx

  MSB

   .0051219
  1.2868
   .014
F-stat*

  .357
89.685
F 95%

3.07
1.43
F 90%

2.35
1.32
     The F-statistic  is a measure  of  the significance  of  a given factor
     (here, RVP)  in relation to  the exhaust  emissions.   A  value  larger
     than  the  theoretical  value  (i.e.,  F 95%) indicates that  the  RVP of
     the fuel  is  significant in  relation  to exhaust emissions  using  the
     given level of significance (i.e., a 95% confidence interval).

-------
                              2-78

     The  above  analyses show  that for  each technology  class,
the trends  in HC and  CO  emissions versus RVP  are significant,
whereas the trend in NOx emissions versus RVP is not.

     As   described   earlier   with   respect   to   evaporative
emissions,  these  test data  directly  apply only to  vehicles
designed  for  9-psi  RVP fuel and  operated on  fuels of  various
RVPs.   They do not  apply to vehicles  designed for and tested on
higher RVP fuels.   Thus, the data are directly  applicable  only
to the  situation where  vehicle  designs  are not  changing,  but
in-use RVP  is being  reduced  (i.e.,  pre-1990  vehicles).   The
question that remains  is what  happens to exhaust emissions  when
vehicles  are  redesigned  for some  higher  RVP and  then  operated
on that fuel.

     Two  extremes  appear possible.   One, the  exhaust  emission
effect is  completely related to  in-use  fuel  RVP  and  redesign
for that  RVP  will  not reduce  the  exhaust emission effect.  Two,
vehicles currently  exhibit  lower  emissions on  Indolene  because
they  are  designed using  Indolene and,  therefore,  optimizing
them for  any  other RVP will  result  in  the  same  low  emissions
when operated on  that fuel (i.e., the  exhaust effect  will be
eliminated if design RVP equals in-use RVP).  The  fact  that the
earlier EF testing  did not  show an RVP-related exhaust emission
effect argues for  the latter.   The only  difference between the
two  sets  of  EF  testing   was  the   evaporative  emission  test
procedure and the  sequence of  fuels.  Since  no  hysteresis is
known to  be  present with  respect to  the effect of fuel  RVP on
exhaust  emissions  outside   of  the  purging  of  the  evaporative
control  canister,  all of  the  changes between  the two  sets of
testing  appear to  be  related  to  evaporative emissions.   Since
the earlier test sequence  (which  mitigated the impact of higher
RVPs)  eliminated the  RVP effect on exhaust emissions,  it would
appear  reasonable   to  conclude that  redesigning  the  vehicle's
evaporative and  exhaust  emission  control  systems  for a  higher
RVP would eliminate the exhaust effect,  as well.

     Thus,  the  exhaust  emission  effect   is   assumed  to  be
eliminated via  any  of the long-term strategies  for  post-1989
model year  vehicles,  when  design RVP will  be equal  to in-use
RVP.   Under the  short-term strategies,  where  in-use RVP would
be less  than  certification  fuel RVP,  the exhaust effect is also
assumed  to  be eliminated (i.e.,  the  car would be designed to
handle any RVP less than or equal  to certification RVP).

     For  pre-1990  vehicles that  are  operated  on  9.0-psi fuel,
this exhaust effect is also assumed to be eliminated.   However,
when  these  Indolene-designed  vehicles   are  operated  on  RVPs
greater than  9.0 psi,  the  exhaust  effect will be  dependent on
the  in-use   RVP.    (Adjustment   of   MOBILES  exhaust  emission
factors, based on  11.5 RVP  fuel,  for  various control  scenarios
will be discussed in Chapter 5.)

-------
                              2-79

VI.   Summary of Evaporative Emissions Problem and
     Development of Possible Control Scenarios

     1.    Review

     At  this point,  it may be  helpful  to review  the  major
topics  discussed  in  this  chapter.   First,  the  current  ozone
non-attainment problem  is  quite widespread  and is expected  to
continue without further  reductions  in hydrocarbon  emissions.
(Of  the 54  current  non-attainment areas,  35  have  requested
extensions to  1987.)   The necessary HC  reductions would appear
to  be  most  valuable  in the summer months  because  roughly  90
percent  of   all  ozone  violations  occur  between   June  and
September (inclusive).

     Evaporative   HC   emissions    from   motor   vehicles   and
stationary   sources   (gasoline   storage   and   distribution)
represent a significant portion of  those emissions contributing
to  the  ozone problem.  Motor vehicle evaporative  losses — the
primary  focus of  this  study -.-  can be  affected  by  several
factors,  primarily  the vehicle's  evaporative  control  system
design  and  the  volatility  of  the  fuel  being  used  in  the
vehicle.  There  are  some  indications that  the use  of  alcohol
blends   could   be   another   factor   affecting   evaporative
emissions.    However,  based  on  the  review presented  in  Section
IV  of   this  chapter,  alcohol   blends  only  affect  evaporative
emissions during their  use  (i.e.,  alcohol blends  do  not appear
to   permanently   deactivate   the   charcoal).    At   similar
volatilities,   alcohol   blends   appear   to   yield   similar
evaporative  emissions when  compared to gasoline.   Thus,  the
analyses conducted  in the  rest  of this  study will treat alcohol
blends in the same manner as gasoline.

     Fuel  survey data  indicate  that  some  current  commercial
gasolines are significantly more volatile than that  for  which
vehicle evaporative  control  systems are designed  (i.e.,  EPA's
certification  test fuel,  as defined  in  the  Code of  Federal
Regulations).    This   trend  of   increasing   commercial   fuel
volatility has  been  occurring over  the  past  two decades  and
there  is no  evidence that  the  trend will not  continue in  the
future.  Fuel volatility  can  be  assessed  using various  fuel
parameters,  with RVP and percent  of fuel  evaporated at  160°F
chosen  (for  purposes of this analysis)   to be most pertinent  to
diurnal and hot-soak  losses  from  motor  vehicles.  Of  these two
parameters,  RVP  will  be  the primary focus due to indications of
its  greater   significance  and  the  existence   of   more   data
defining  its  relationship  to   evaporative  emission  levels.
However,   the   impact   of    %i«o   on   evaporative   losses
(particularly hot-soak)  will continue to  be examined in future
work.

-------
                              2-80

     The RVP  of current  certification test  fuel averages  9.0
psi,  which  is   representative  of  the  early  1970's  when  the
specifications were first developed.   Results of EPA's  ongoing
emission factor  test program  show that  vehicles operating  on
commercial fuels with RVPs greater than 9.0 psi  (for which they
were designed)  have evaporative losses that  greatly exceed the
current  standard of  2  grams/test,   and  that  this  excess  is
dependent upon  the  RVP of the fuel being tested.  Using in-use
test data,  the  evaporative  excess was  attributed to  the  RVP
effect,  malmaintenance  and  equipment  defects,  and  tampering
(the  latter  two also  being dependent  on RVP).   In  addition,
because  vehicles also have  difficulty meeting  the  evaporative
standard even on 9.0-psi Indolene, some of the  excess  emissions
are attributed to insufficient design of the  purge system.

     There are  several  approaches that can  be taken to reduce
or  eliminate these excess  evaporative  emissions  from  motor
vehicles.   One   is  to  control  the  volatility  of  in-use  (or
commercial)  fuel to  a  level  equal  to  that  for  which  the
vehicles'  evaporative  control  systems are  designed.    Another
option   is   to   change  new   vehicle   design   by   revising
certification  fuel   specifications  and  test  procedure;  these
revisions would force manufacturers to increase  the size of the
evaporative canister  in order  to accommodate  higher  emissions
from the more volatile  commercial fuels,  and  to  improve  the
purge  system  to  enable the vehicle to  pass  certification tests
while  starting  with a saturated  canister (to  be discussed  in
more detail in Chapter  3).   The retrofitting of in-use vehicles
with  larger  canisters or  additional smaller  ones in  parallel
with existing systems  is  another  approach.  Though the  technical
feasibility  of   this  option has  not  been  fully assessed,  it
would   most   likely  be   very  costly   and   of   questionable
effectiveness.  Therefore,  retrofit  will   not  be   considered
further  in  this  report.   Rather, the options  involving changes
to   in-use   and  certification  fuel   volatilities   and   test
procedure  will  provide  the   basis   for  development  of  the
evaporative  HC  control  strategies  to  be   examined   in  the
remainder of this report.

     2.    Development of Control Strategies

     As  certification  tests  are intended  to  represent  in-use
operating conditions, the long-term control  strategy is  to have
certification  fuel  RVP  equal  to  that   of   typical   in-use
gasoline.  This  can be  accomplished  by controlling in-use fuel
volatility, by  revising certification  fuel  specifications,  or
through  a  combination   of  the  two.   One  remaining   question
concerns   the   volatility   level  at   which   commercial   and
certification fuels  should  be matched.   The  long-term  control
options  to  be considered in this report  are  presented  in Table
2-23.  As  shown,   this   analysis   examines   RVPs  at   0.5-psi
increments between  9.0  and 11.5 psi  (inclusive).   In  addition,

-------
                              2-81


                           Table 2-23

                Lonq-Term RVP Control Scenarios

Scenario       In-Use RVP (psi)*       Certification RVP (psi)**

   1                 11.5 (baseline)            11.5
   2                 11.0                       11.0
   3                 10.5                       10.5
   4                 10.0                       10.0
   5                  9.5                        9.5
   6                  9.0                        9.0 (baseline)
*   In-use RVP control is assumed to be implemented in 1988.
**  Certification  RVP and  test  procedure are  assumed  to  be
    revised with the 1990 model year.

-------
                              2-82

all strategies that  involve  a  change  to certification  fuel  RVP
also assume a change in  certification test procedure to correct
design problems such as inadequate purge.

     As   indicated   in   Table   2-23,   a   fuel   volatility
representative  of  ASTM's  "Class C"  cities was  chosen as  the
baseline commercial (in-use)  RVP for two basic  reasons:   1)  the
conditions of  EPA's  test  procedure most  closely resemble  the
summer climate of these areas,  and 2)  a majority  of  the current
non-attainment areas  are designated as Class  C  in  the summer.
Although fuel survey data indicate that the  current  average  RVP
in  Class  C cities  is just  below 11  psi,  RVP  is  expected  to
continue its historical  upward trend  and  the  ASTM Class  C  RVP
limit  of   11.5   psi  is  assumed  to  be  representative   of
uncontrolled levels in the late 1980's and early 1990fs.

     The earliest reasonable implementation  dates estimated  for
the  vehicle-related  and  fuel-related  control  measures  differ
from each  other and are based  on the following  assumptions.
Possible  control   measures   that  affect   vehicle   design   —
revisions  to certification  fuel  and  test  procedure  —  are
assumed  to  be  first  implementable with  the  1990  model  year.
This is based on the  assumption  that  a Final  Rulemaking  (FRM)
establishing these  controls  would be published no earlier than
late  1986,   which   already  falls  into  the  1987  model  year.
Allowing  2-3  years  for  the  redesign  of  vehicles,  revised
certification  fuel   and  test  procedure   could probably   be
implemented  starting with the 1990 model  year.   On  the  other
hand,  less  leadtime  is  estimated  to  be  necessary  on  the
fuel-related side.   Modifications to  in-use  fuel  volatility can
be  accomplished  with changes  in  refinery operating parameters
as  opposed  to  changes in equipment design,  if  desired.  (These
refinery modifications are discussed  in more detail  in Chapter
4.)  Based  on  this  assumption, the implementation date assumed
for  in-use  fuel  volatility  control  is  1988.    Again,   this
assumes that the FRM would be published in late 1986.

     Because  changes  in  certification fuel or  test  procedure
affect only  the design  of  new  vehicles,  it  takes  some  time
before the  in-use  fleet  has  turned over and the  full  impact of
larger  canisters   and   improved   purge  cycle   are  realized.
However,   any modification  to in-use  fuel volatility has  an
immediate  effect  on  evaporative  emissions  from  the  entire
fleet.    In  addition  to  affecting  motor  vehicle  emissions,
in-use fuel  volatility  has   an  impact on  HC  vapors  emitted
during  gasoline  storage  and distribution  (bulk  terminals,
refueling, etc.).   Therefore,  a viable  short-term option  is  to
control   in-use   fuel   volatility   to   levels   below   the
certification specification,  and then  eventually allow in-use
RVP to  increase to the  long-term certification RVP  level  after
a  certain  period of  time.   The  various RVP scenarios examined
under  this  short-term  approach   are   shown   in  Table  2-24.
Several time periods  for this  additional  control  were evaluated

-------
                         2-83

                      Table 2-24
           Short-Term RVP Control Scenarios
                                           Long-Term
Scenario
1
2
3
4
5
6
7
. 8
9
10
11
12
13
14
15
* In-use
** Pf»r1-Tf-
In-Use RVP (psi)*
9.0
9.0
9.5
9.0
9.5
10.0
9.0
9.5
10.0
10.5
9.0
9.5
10.0
10.5
11.0
RVP control is assumed
i r> a 1- i nn Tt\7f> anri 1-PRt- r>ri
Certification RVP (psi)**
9.5
10.0
10.0
10.5
10.5
10.5
11.0
11.0
11.0
11.0
11.5
11.5
11.5
11.5
11.5
to be implemented in 1988!
nnertiirp aKsiimeH fri h>f» rtn/i Rf*A
with the 1990 model year.

-------
                              2-84

and will  be discussed  as results  are presented  later  in  the
report.  As  with the long-term  scenarios,  in-use fuel  control
is  assumed  to  be  implemented   in  1988,  and  vehicle-related
controls begin with the 1990  model year.

-------
                              2-85

                     References (Chapter 2)

     1.    "1981-1983  Standard  Metropolitan  Statistical  Area
(SMSA) Air  Quality Data Base  for Use  in  Regulatory Analysis,"
Memo from  Richard G. Rhoads,  Director of  Monitoring  and  Data
Analysis  Division,  to  Charles   Gray,  Director  of  Emission
Control Technology Division, February 25,  1985.

     2.    "Guidance Document for the Correction  of  Part D SIPS
for  Non-Attainment  Areas," Office  of  Air Quality  Planning and
Standards,   U.S.  EPA, Research  Triangle  Park,  North  Carolina,
January 27, 1984.

     3.    "Control Characteristics of  Carbon  Beds  for Gasoline
Vapor Emissions",  EPA-600/2-77-057, Michael J.  Manos and Warren
C.  Kelly,  Scott Environmental  Technology,  for EPA,  ORD,  IERL,
February 1977.

     4.    "Combustion Engine  Economy,  Emissions and  Controls,
July 9-13,   1984"  Engineering  Summer Conferences,  The University
of Michigan College of Engineering.

     5.    "Hydrocarbon  Control  for  Los  Angeles  by  Reducing
Gasoline Volatility,"  Edwin  E.  Nelson,  Engineering  Staff,  GM
Corp., SAE Paper No. 690087.

     6.    "Effect of Fuel Front-End and  Midrange Volatility on
Automobile   Emissions,"   B.   H.    Eccleston   and   R.W.   Hurn,
Bartlesville Energy Research Center, U.S.  DOI,  Bureau of Mines,
Report of Investigations 7707.

     7.    "Effect of Fuel  Composition  on Amount and Reactivity
of  Evaporative  Emissions,"  M.W.  Jackson  and  R.L.  Everett,  SAE
Paper No. 690088,  1969.

     8.    "Mathematical Models for Prediction of Fuel Tank and
Carburetor   Evaporation  Losses,"   W.J.   Koehl,   Jr.,   Research
Dept.,  Mobil  Research   and Development  Corp.,  SAE  Paper  No.
690506, May 1969.

     9.    "Mathematical   Expressions    Relating   Evaporative
Emissions from  Motor Vehicles without  Evaporative  Loss-Control
Devices  to Gasoline  Volatility,"  William F.  Biller,  Michael
Manoff,  Jyotin  Sachdev, and  William C.  Zegal,  Scott Research
Laboratories,   Inc.,   and   David  T.   Wade,   Esso   Research
Engineering Co.,  SAE Paper No. 720700, 1972.

     10.   "Clean Air  Act  Waiver Application, Section 2ll(f),
Volume 2" E.I.  du Pont  de Nemours  and Company,  Inc.,  July 11,
1984.

-------
                              2-86

                  References  (Chapter  2) Cont'd

     11.   "Environmental Impacts  of  Methanol/Gasoline Blends,"
prepared for Air  Pollution Control Association by  Tom Cackette
and Thomas Austin, February 16, 1984.

     12.   Letter  from  Dale  F.   Pollart,   Texaco,   Inc.,  to
Richard Wilson, EPA, dated May 13, 1985.

     13.   "Analysis  of  Fuel  Volatility  Characteristics  and
Evaporative Hydrocarbon  Emissions  for Alcohol/Gasoline Blends,"
PLMR-43-83, E.I. du Pont de Nemours and Company,  Inc.,  June 29,
1983.

     14.   "Standard  Specification   for   Automotive   Gasoline,
D-439-83," American Society of Tests and Measurements  (ASTM).

     15.   "MVMA  National   Gasoline   Survey,  Summer   Season,
1984,"  Motor  Vehicle Manufacturers  Association,   Inc.,  October
15, 1984.

     16.   "Motor Gasolines,  Summer 1984," Ella Mae Shelton and
Cheryl  L.  Dickson,  National  Institute for Petroleum  and Energy
Research (NIPER), for API,  February 1985.

     17.   "Fuel   Volatility   Trends,"   Southwest    Research
Institute, EPA  Contract  No.  68-03-3192,  Work Assignment 4, Task
3, Final Report dated September 28, 1984.

     18.   "Commentary  by  General  Motors to the  EPA  on  the
Appropriateness  of  Current  Emissions Certification  Test  Fuel
Specifications,"  attachment   to  internal  correspondence  from
T.M.  Fisher,  General Motors  Corporation, to Charles L.  Gray,
Jr., EPA, September 3, 1980.

     19.   Federal Register,  January 13,  1985, 50 FR 2615.

     20.   "Alcohol Outlook," May 1985.

     21.   "Methanol  Demand  and  Availability,"  Presented  to
U.S.  EPA  Region  VI  by James   L.   Snyder,  Celanese  Chemical
Company, Inc., May 21, 1985.

     22.   "Performance  Evaluation of  Alcohol-Gasoline  Blends
in   1980   Model  Automobiles,  Phase   II  -  Methanol-Gasoline
Blends," prepared for DOE by CRC,  January 1984.

     23.   "Physical  Properties  of  Gasoline/Alcohol  Blends,"
Frank N.  Cox,  U.S.  DOE, Bartlesville Energy Technology Center,
September 1979.

     24.   "Performance  Evaluation of  Alcohol-Gasoline  Blends
in  1980 Model Automobiles,  Phase  I - Ethanol-Gasoline Blends,"
prepared for DOE by CRC, July 1982.

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                              2-87

                  References  (Chapter  2)  Cont'd

     25.   "Twenty-three   Car    In-House  Oxinol   Blend   Test
Program,"  EPA Memo  from Craig  A.  Harvey to  Charles  L.  Gray,
Jr., ECTD, November 19, 1984.

     26.   "Evaporative  Emissions  of   Methanol   Blend  Fueled
Vehicles,"  EPA   Technical   Report,   EPA-AA-TSS-PA-84-5,   Craig
Harvey, Project Officer, November 1984.

     27.   "Evaporative  Emissions from  Vehicles  Operating  on
Methanol/Gasoline Blends," Ken Stamper, SAE Paper No. 801360.

     28.   "Emissions, Fuel  Economy and  Driveability Effects of
Methanol/Butanol/Gasoline  Fuel  Blends,"  Robert   L.  Furey  and
Jack B. King,  SAE Paper No. 821188.

     29.   "Impact  of  Gasohol  on Automobile  Evaporative  and
Tailpipe Emissions," Frank M. Black and  John M.  Lang,  SAE Paper
NO. 810438.

     30.   "Evaporative  and  Exhaust  Emissions from  Cars  Fueled
with Gasoline Containing  Ethanol or  MTBE," Robert L.  Furey and
Jack B. King,  SAE Paper No. 800261.

     31.   "Gasohol: Technical,  Economic or  Political Panacea?"
Thomas C. Austin and Gary Rubenstein,  SAE Paper No. 800891.

     32.   "Gasohol Test  Program," Richard Lawrence,  Director,
Engineering    Operations    Division,    QMS,     U.S.    EPA,
EPA-AA-TAEB-79-4B, February 1980.

     33.   "Exhaust and  Evaporative  Emissions from  Alcohol and
Ether Fuel Blends," T.  M. Naman and J. R. All sup, SAE Paper No.
800858.

     34.   "Testing of Three Caltrans Gasohol  Fueled Vehicles,"
California Air Resources Board, May 1980.

     35.   "Material  Compatibility and  Durability  of  Vehicles
with  Methanol/Gasoline Grade  Tertiary  Butyl  Alcohol  Gasoline
Blends," David J. Miller,  David A. Drake, et al., SAE Paper No.
841383.

     36.   "Monthly Progress Report No.  3 for the period  May 1
through  May   31,  1985;  Work   Assignment   No.   29,   Contract
68-03-3162, 'Additional Mini-Canister  Evaluation,1  SwRI Project
03-7338-029,"  from  Lawrence  R.  Smith, SwRI,  to Craig A. Harvey,
EPA, June 15,  1985.

-------
                              2-88

                 References  (Chapter 2) Cont'd

     37.   "The  Effect  of  Methanol  on  Evaporative  Canister
Charcoal  Capacity,"  Draft  Report,   EPA-460/3-84-014,  Mary  Ann
Warner-Selph  (SwRI)  for  EPA,   January 1985.   (Available  from
NTIS, No. PB-85-179-752/AS)

     38.   GM  Presentation to  EPA-MOD,  Washington, D.C.,  June
12, 1985.

     39.   "Technical  Directive  No.  4  to  EPA  Contract  No.
68-03-3230,  Effects  of  RVP  and  Temperature  on  Evaporative
Emissions  of  2-gram,  Vehicles,"  from  John  Shelton,  Project
Officer,  EPA,  to  Myron  W.  Gallogly,  President,  Automotive
Testing Laboratories, March 20, 1985.

     40.   "Amendment  No.  1  to  Technical  Directive  No.   4,
Contract  68-03-3230,"  from John Shelton,  Project  Officer,  EPA,
to   Myron   W.   Gallogly,    President,    Automotive   Testing
Laboratories, July 18,  1985.

     41.   "Factors  Influencing  Vehicle Evaporative Emissions,"
D.T. Wade, SAE Paper 670126,  1967.

     42.   "Exhaust  and  Evaporative Emissions  of  High  Mileage
Taxicabs  and Passenger  Cars,"  EPA  Technical  Report, Craig A.
Harvey, Project Officer,  February 1985.

     43.   API   presentation  to  EPA  on   "1984   Evaporative
Emissions  Research  Programs,   Gasoline  Volatility  Assessment
Task Force," contractors:  NIPER and ATL, 1985.

     44.   Letter   from   J.S.   Welstand,   Chevron   Research
Division, to Chester J. France, EPA,  April l, 1985.

     45.   "Motor Vehicle Tampering Survey  - 1982,"  EPA,  QMS,
FOSD, EPA-330/1-83-001, April 1983.

     46.   "Motor Vehicle Tampering  Survey  -  1983,"  EPA,  QMS,
FOSD, August 1984 (no report number given).

     47.   Data  in support of  "Motor Vehicle Tampering Survey -
1984," EPA, QMS, FOSD,  report not yet published.

     48.   "Report  for  Third  Quarter,  FY  85,  In-Use  Vehicle
Testing   in   Ann   Arbor,"    EPA   memorandum    from   Howard
Brasher-Frederick to Charles L.  Gray,  EPA, OMS,  ECTD, July  23,
1985.

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                              2-89

                 References  (Chapter 2) Cont'd

     49.   "Relationship  Between  Exhaust  Emissions  and  Fuel
Volatility," EPA memo from Thomas  L.  Darlington to  Charles L.
Gray, EPA, QMS, ECTD, June 24, 1985.

     50.   "Evaporative   HC   Emissions   for   MOBILE3,"   EPA
Technical Report No. EPA-AA-TEB-85-1, U.S. EPA,  OAR,  ECTD, TEB,
August 1984.

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                              2-90

                          Appendix 2-A

                  Effect  of Ambient Temperature
               Conditions on Evaporative Emissions


     As mentioned earlier in Section IV.D. of this  chapter,  the
effect  of  ambient  temperature  conditions  on  evaporative  HC
emissions is one  of  the  areas  still being investigated by EPA.
The purpose of  this  Appendix  is twofold.   First, available data
on  evaporative  emissions  vs.   temperature  are  analyzed  and
compared  to  relative emissions  predicted  via  a  theoretical
emission model.  Second,   typical  summertime  temperature  and RVP
conditions in  several  of the  current ozone non-attainment areas
are compared  to EPA's standard evaporative  test conditions  by
means of  a theoretical diurnal  emissions  model.   Estimates made
in this Appendix are offered as a preliminary assessment  of the
impact  of temperature  conditions   as  they differ  from  those
specified as  part of  the standard  evaporative   test  procedure.
These preliminary results have not  been incorporated into  the
emission  projections  made  in  this  study,  as  more  data  and
analysis are required before this can be done with confidence.

     The  first  section   below  reviews  available  data  from  a
current  EPA  test  program designed  to  evaluate  the  impact  of
temperature on  evaporative emissions.   The  next  section  relates
these   measured   emissions   to   relative   emission   indexes
calculated for  each  test condition  using  a  theoretical  diurnal
emissions model.   Finally,  theoretical  emissions  indexes  are
calculated for  several ozone non-attainment  areas using  typical
summertime (i.e.,  July)   temperature conditions; these  indexes
provide  the  basis for a  rough comparison of city conditions to
standard EPA test conditions.

A.   Temperature vs.  Emissions Test Program

     An EPA-sponsored  test program  is  currently  being conducted
at  the   Automotive  Test  Laboratory (ATL)  for   the  purpose  of
measuring diurnal  and hot-soak losses  at various  temperatures
and gasoline  RVPs.[35]   The  complete test  matrix consists  of
the following:


                Parameter                  Test  Points

              Gasoline RVP             9.0,  10.4, 11.7 psi
              Diurnal  Starting Temp.   60, 68,  75°F
              Diurnal  Temp. Change     +15,  +20,  +24,  +30 °F
              Hot Soak Temp.            70, 82,  95°F


At the  time  of this  analysis,  testing of 24 light-duty vehicles
certified to the  2-gram  standard  (i.e.,  1981 and  later  models)
—  14  carbureted, 10  fuel-injected  — had been  completed.  The
first  9  vehicles  were  tested  over  the  entire matrix  listed

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                              2-91

above;  however,  in  order  to  include  a  greater  number  of
vehicles in the  program,  the other 15 vehicles were tested over
only  a partial  matrix  (i.e., two RVPs,  two diurnal  starting
temperatures,  and two hot-soak temperatures, instead of three).

     Data  from  fuel-injected   and   carbureted   vehicles  were
analyzed separately in the following manner:

     1)    Full-matrix  data  were   separated  from  data   on
           vehicles tested over only a partial matrix;

     2)    Emission   results  (in  grams/test)   were  averaged
           within  each set   for   each  of  the  temper a ture/RVP
           combinations;

     3)    Emission averages at  each condition  within each set
           of  data   (i.e,   full  vs.   partial   matrix)   were
           "normalized" to the standard  certification test with
           9.0-psi  Indolene,  starting  diurnal  temperature  of
           60 °F,   diurnal   change  of   +24°F,   and   hot-soak
           temperature  of   82°F  (i.e.,   the   average   g/test
           measurement  under  these   standard  conditions  was
           subtracted  from  all   other   averages,   making  the
           standard value in each set zero);

     4)    After  normalization,   the  two  data  sets  (full  and
           partial) were  combined into  one  normalized  set  by
           arithmetically  weighting   the  emission   averages  in
           each  set by the  number of vehicles  tested  in each
           data set (see Table 2-A-l);

     5)    The  average emission  factor   at  9.0 RVP from  the
           in-use EF  test program was then added to  each value
           in the normalized set,  so  that the g/test associated
           with  the  9.0  RVP  (Indolene)  test  under  standard
           temperature  conditions  was   consistent   with  the
           in-use EF  results  used in the rest   of this  study
           (see Table 2-A-2).*

     Focusing  on  the diurnal  losses measured  under  standard
test temperatures, the difference between emissions at  9.0  RVP
and  11.7 RVP  was significantly  less  in the  ATL data than that
indicated by the in-use EF results (4.26 versus  7.82 g/test for
carbureted   vehicles   and   1.44  versus   5.23   g/test   for
fuel-injected  vehicles).   In  fact,   before normalization,  the
ATL  emission  levels  were lower overall than  the average in-use
results. This  is most likely due  to  the  relative  condition of
the ATL test vehicles, which were somewhat better maintained,
     A  multiplicative  approach  could  also  have  been  used,
     wherein the ATL averages would have been  normalized to 1.0
     at the  standard 9.0 RVP  test,  and then  the  EF average at
     9.0 RVP  would have been  multiplied  by each  value  in the
     normalized set.

-------
               2-92

            Table 2-A-l

ATL Diurnal Averages — Normalized
      to 9.0 RVP Standard Test
Vehicle RVP No. of
Type (psi) Vehicles
GARB
GARB
CARB
FI
FI
FI
9.0 14
5
14
10.4 10
5
10
11.7 9
5
9
9.0 10
4
10
10.4 6
4
6
11.7 8
4
8
Starting
Temp(°F)
60
68
75
60
68
75
60
68
75
60
68
75
60
68
75
60
68
75
Diurnal Emissions (g/test)
+15°F
-0.38
-0.23
-0.08
-0.14
0.14
0.92
0.39
0.84
6.46
-0.24
-0.30
-0.16
-0.20
-0.03
1.23
-0.04
0.86
3.78
+20°F
-0.20
0.11
0.65
0.58
1.11
4.30
1.74
4.41
18.48
-0.13
-0.05
0.30
0.02
1.18
5.99
0.50
4.61
11.55
+24°F
0.00
0.62
2.13
0.96
3.13
9.69
4.26
10.17
31.38
0.00
0.58
1.25
0.58
3.60
13.99
1.44
11.16
21.13
+30°F
0.60
2.57
7.55
5.03
9.44
24.21
12.29
22.94
64.29
0.44
3.38
5.17
3.18
11.71
31.39
5.69
27.30
52.45

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                         2-93

                      Table 2-A-2

      Diurnal  Emissions  —  Consistent  with In-Use
         EF  Results  at 9.0  RVP Standard  Test
Vehicle RVP No. of
Type (psi) Vehicles
CARS
CARB
CARB
FI
FI
FI
9.0 14
5
14
10.4 10
5
10
11.7 9
5
9
9.0 10
4
10
10.4 6
4
6
11.7 8
4
8
Starting
Temp(°F)
60
68
75
60
68
75
60
68
75
60
68
75
60
68
75
60
68
75
Diurnal Emissions (g/test)
+15°F
1.94
2.09
2.24
2.18
2.46
3.24
2.71
3.16
8.78
1.01
0.95
1.09
1.05
1.22
2.48
1.21
2.11
5.03
+20°F
2.12
2.43
2.97
2.90
3.43
6.62
4.06
6.73
20.80
1.12
1.20
1.55
1.27
2.43
7.24
1.75
5.86
12.80
+24°F
2.32*
2.94
4.45
3.28
5.45
12.01
6.58
12.49
33.70
1.25*
1.83
2.50
1.83
4.85
15.24
2.69
12.41
22.38
4-3 0°F
2.92
4.89
9.87
7.35
11.76
26.53
14.61
25.26
66.61
1.69
4.63
6.42
4.43
12.96
32.64
6.94
28.55
53.70
From in-use EF test results.

-------
                              2-94

on the  whole,  than the  in-use  vehicles tested.   For  instance,
any obvious  problems,  such as  the  disconnected tank  vent  line
found  in  one  vehicle,  were corrected  before  testing at  ATL.
Also,  the  leaking gas caps  in  three vehicles  were  replaced in
order  to  prevent  intermittent  leaks  from  disguising  actual
trends  in  emissions versus temperature (i.e.,  the cap may  leak
during  the  low   temperature   test   but   not  with   the   high
temperatures,  resulting  in unrealistically higher emissions at
low temperatures).  Another reason for  lower emissions  is  that
the ATL vehicles'  evaporative  control  systems  may  have  been
more adequately purged prior to testing,  as they were  driven a
minimum of 45  miles to  the ATL test  site compared to an average
of 21  miles  between the  homes  of the  in-use  vehicles'  owners
and the EPA test site in Ann Arbor.

     Because  the  in-use  program  represents  a  significantly
larger  data  base  (over  200  vehicles  versus  24  at  ATL)   and
because  the   in-use  data  provide  the   basis   for   emission
projections  made  throughout this  study,  two  more  final  steps
were  taken to  make  the ATL  data consistent  with the  in-use
program:

     6)    The  normalized  sets  shown  in  Table  2-A-l   were
           further  normalized  at each  RVP  level  (i.e.,   the
           value  shown  for the standard temperature conditions
           with 10.4  RVP was subtracted  from  all other  values
           in the 10.4 data set; the  same was done for the  11.7
           RVP results;  see Table 2-A-3);

     7)    Finally,  the  in-use EF  average at  each of  the two
           RVPs (10.4 and  11.7) under standard  temperatures was
           added  to the  normalized  values in  each of  the RVP
           sets.

     The end product  of  these various steps,  as shown  in  Table
2-A-4,  is  a  set  of  emission  results  at  various temperatures
that  is consistent  with  averages  from  in-use EF  testing  at
standard temperature  conditions,  which were  developed from the
much  larger  data  base.   But  in   addition,  the   impact  of
temperature on  evaporative emission  levels can now  begin to be
assessed.  For  example,  a change  in the  diurnal  temperature
difference  from   the  standard  24°F  to  20°F  (with  a  starting
temperature of 60°F) can  reduce fuel-injected diurnal  losses by
0.13  g/test,  or  10  percent,  with an RVP  of 9.0  psi;  however,
the impact at  11.7 psi  is somewhat greater with a reduction of
0.94  g/test,  or  15  percent.   The  potential  impact  of  other
changes,  such  as  higher  diurnal   starting  temperatures  or
greater diurnal  temperature difference,  can also be  estimated
from Table 2-A-4.

     Again,  these   are   only  initial  results   based  on  a
preliminary  analysis  of  data  from 24  vehicles.   As  more  data
become  available,  the   analytical  techniques  described  above
will  be reassessed  and  could  be modified.   In  addition,  the
magnitude  of  the  impact  of temperature  on emissions  indicated

-------
                       2-95

                   Table 2-A-3

       ATL Diurnal Averages — Normalized
to All Three Standard Tests (9.0, 10.4, 11.7 RVPs)
Vehicle RVP
No. of
Type (psi) Vehicles
GARB 9.0


GARB 10.4


GARB 11.7


FI 9.0


FI 10.4


FI 11.7


14
5
14
10
5
10
9
5
9
10
4
10
6
4
6
8
4
8
Starting Diurnal Emissions (g/test)
Temp(°F) +15°F
60
68
75
60
68
75
60
68
75
60
68
75
60
68
75
60
68
75
-0
-0
-0
-1
-0
-0
-3
-3
2
-0
-0
-0
-0
-0
0
-1
-0
2
.38
.23
.08
.10
.82
.04
.87
.42
.20
.24
.30
.16
.78
.61
.65
.48
.58
.34
+20°F
-0
0
0
-0
0
3
-2
0
14
-0
-0
0
-0
0
5
-0
3
10
.20
.11
.65
.38
.15
.34
.52
.15
.22
.13
.05
.30
.56
.60
.41
.94
.17
. 11
+24°F
0
0
2
0
2
8
0
5
27
0
0
1
0
3
13
0
9
19
.00
.62
.13
.00
.17
.73
.00
.91
.12
.00
.58
.25
.00
.02
.41
.00
.72
.69
+30°F
0
2
7
4
8
23
8
18
60
0
3
5
2
11
30
4
25
51
.60
.57
.55
.07
.48
.25
.03
.68
.03
.44
.38
.17
.60
.13
.81
.25
.86
.01

-------
                          2-96

                      Table 2-A-4

Diurnal Emissions — Consistent with In-Use EF Results
   at All Three Standard Tests (9.0, 10.4, 11.7 RVPs)
Vehicle RVP
Type (psi)
GARB 9.0


GARB 10.4


GARB 11.7


FI 9.0


FI 10.4


FI 11.7


No. of
Vehicles
14
5
14
10
5
10
9
5
9
10
4
10
6
4
6
8
4
8
Starting Diurnal Emissions (g/test)
Temp(°F) +15°F
60
68
75
60
68
75
60
68
75
60
68
75
60
68
75
60
68
75
1
2
2
3
4
4
6
6
12
1
0
1
1
1
2
5
5
8
.94
.09
.24
.82
.08
.88
.27
.72
.34
.01
.95
.09
.45
.62
.88
.00
.90
.82
+20°F
2
2
2
4
5
8
7
10
24
1
1
1
1
2
7
5
9
16
.12
.43
.97
.54
.07
.26
.62
.29
.36
.12
.20
.55
.67
.83
.64
.54
.65
.59
+24°F
2
2
4
4
7
13
10
16
37
1
1
2
2
5
15
6
16
26
.32*
.94
.45
.92*
.09
.65
.14*
.05
.26
.25*
.83
.50
.23*
.25
.64
.48*
.20
.17
+30°F
2
4
9
8
13
28
18
28
70
1
4
6
4
13
33
10
32
57
.92
.89
.87
.96
.40
.17
.17
.82
.17
.69
.63
.42
.83
.36
.04
.73
.34
.49
From  in-use EF test  results.

-------
                              2-97

by  the  raw  data   could   change  as  the  vehicle  sample  is
broadened,  which could also cause these preliminary findings to
change.

B.   Theoretical Diurnal Emissions Index vs.  Test Data

     At  this  point,  the  data  could  simply be  reduced via  a
multiple  regression  analysis.   However,  the  amount  of  data
available is not  large  and strong non-linear interrelationships
between the variables are  known to  exist  (e.g.,  the  effect of
an  increase  in  diurnal  temperature change will be  much greater
at  high  fuel  RVP than  low).   Thus,  at this point in  time, it
was deemed  more  appropriate  to utilize  an emission  model for
uncontrolled diurnal emissions to reduce  the test  variables to
a  single  evaporative  emission  potential   and  then  correlate
actual  emissions  with   this  potential.    In  this  way,  less
emphasis is placed  on any individual data point  and  the chance
of  having  outliers  that   strongly  affect  the  results  is
significantly lessened.

     A  model  of  uncontrolled  diurnal emissions developed by
D.T.  Wade  in  1967  was  chosen  for  this  purpose.[41]   (No
hot-soak emission model was  known  to  be readily  available.)
This model  relies on changes in actual fuel  vapor pressure, the
Ideal Gas  Law,  and  the readily predictable  processes ocurring
in a vehicle's fuel tank to predict  uncontrolled  diurnal losses
from  a  fuel   tank   as  a  function  of   fuel  characteristics
(including  RVP)  and   temperature   conditions.    The  concepts
involved  in   the  modeling  of   diurnal   losses  are  fairly
straightforward;  however,   minor   errors   can   exist.    For
instance, the assumption that the vapor pressure at  the midway
point between the starting and ending  diurnal temperatures is
the  same  as  the  average  of   the   initial  and  final  vapor
pressures may involve  a small amount  of  error.  Wade compared
his predicted  uncontrolled levels to  fuel  tank  running losses
measured  during  road   and   dynomometer   tests.[41]    Although
running  losses   differ  from  diurnal  emissions  as  we  have
referred to them  here,  the same  basic principles  apply because
both types  of  losses occur  in  response to  an  increase in fuel
tank  temperature.  Wade  found that his  model  was  better  at
predicting losses measured during the road  tests than with the
dynomometer tests, most  likely  because equilibrium between the
liquid  and  vapor  phases  within the  fuel  tank  was  better
maintained  during  the   road  tests.    Correlation  between  the
predicted values  and the dynomometer  measurements was rather
poor,   especially as the  losses  increased.[41]   However,  as
actual  in-use  conditions would most closely parallel  the  road
tests, the model  should be  suitable when used  to predict the
relative impacts of various field conditions.

     Wade's model can be used to predict  absolute uncontrolled
diurnal losses  (i.e., grams  of  HC emitted from  the  fuel tank)
for any  given  set of conditions;  however,  its use here was to
predict  relative   losses   and  not   absolute   values.    More
specifically,   Wade's  model  was  used   here  to  calculate  a

-------
                              2-98
relative  index of  theoretical  uncontrolled  diurnal  emissions
which  could  be related  to measurements  of controlled  diurnal
emissions  under  various   conditions   to  produce   a   diurnal
emissions model.  An  index-of  1.00  was assigned to the standard
diurnal test (i.e.,  60-84°F, 9.0 RVP Indolene).

     Wade's  equation  for   uncontrolled  diurnal  losses  is  as
follows:
     G = 454 W  (
                    520
                 690 - 4M
             (P - p )
               t   2
                              P -p
                               t
                   (P -p ) V
                     til
     where:

     G = Weight hydrocarbon lost, g
     W = Fuel density, Ib/gal
     M = Molecular weight of hydrocarbon vapor, Ib/lb mole
           at average liquid temperature
     p = Vapor pressure of gasoline, psia, at liquid temper-
           temperature corresponding to T
     P = Total pressure, psia
         p   +
          1
     P =
psia
     V = Volume of vapor space, cu ft
     T = Temperature, R

     Subscripts:

     t = Tank
     1 = Initial state
     2 = Final state

-------
                              2-99


     The   relative   emissions   index   mentioned  earlier   was
calculated   as   the   ratio   of  Gt««t   (using  various   test
temperatures  and  RVPs) to  G,t
-------
                         2-100

                      Table 2-A-5

            Calculated Emission Indexes for
            Each ATL Diurnal Test Condi t i on
Test
No.
l
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
RVP Starting
(psi) Temp (°F)
9.0 60



68



75



10.4 60



68



75



11.7 60



68



75



Diurnal
Charge (°F)
+15
+20
+24
+30
+15
+20
+24
+30
+ 15
+20
+24
+30
+ 15
+20
+24
+30
+15
+20
+24
+30
+ 15
+20
+24
+30
+ 15
+20
+24
+30
+15
+20
+24
+30
+ 15
+20
+24
+30
                                                 Emissions
                                                   Index

                                                     0.51
                                                     0.77
                                                     1.00*
                                                     1.45

                                                     0.71
                                                     1.03
                                                     1.33
                                                     2.04

                                                     0.96
                                                     1.42
                                                     1.96
                                                     2.88

                                                     0.76
                                                     1.08
                                                     1.52
                                                     2.11

                                                     1.06
                                                     1.56
                                                     2.14
                                                     3.24

                                                     1.40
                                                     2.34
                                                     3.03
                                                     4.71

                                                     0.89
                                                     1.42
                                                     2.02
                                                     2.54

                                                     1.41
                                                     2.31
                                                     2.98
                                                     4.58

                                                     1.97
                                                     3.33
                                                     4.76
                                                     7.05
Current EPA certification test conditions

-------
      Figure 2-A-l
EMISSIONS  VS  INDEX
        CARBURETED CARS




6
8
LJ
g
Ł
Q,








ou -
70 -

60 -
50 -

40 -

30 -


20 -


10 -

0 -

-t-
D




D
+
.Jj
•+
D
+
D +
i + ffl
•f- * rpj O
H dlnw "•
i i i i i i i •
0 2 4 6 E
                                            M
                                            O
            INDEX

-------
                                     Figure 2-A-2
        Ł
        6
        2
        LJ
D
O
             50 H
     30 H
             20
             10 H
              0
E
                            EMISSIONS  VS  INDEX
                                    FUEL-INJECTED CARS
                              I
                              2
                                               n
                                                n
  I
  4

INDEX
                                   D
                                        «2
                                                 I
                                                 6
                                                                D
                                                                           K)
                                                                           O
8

-------
                              2-103


C.   City Temperature Conditions vs.  EPA Test Conditions

     This  final  portion of  this Appendix  makes  a  preliminary
attempt  to  evaluate  how   representative   EPA's  current  and
proposed  certification  test  procedures  are of  conditions  in
various ozone  non-attainment areas.   The comparisons  will make
use of Wade's diurnal emissions model once  again,  and therefore
hot-soak losses will not be  discussed.   No attempt will be made
here to  predict  absolute emissions  in  any  of  the urban  areas
examined,  but   rather  relative   city  temperature   and  RVP
differences  will  be  assessed  with   respect   to  EPA's   test
conditions.  As  mentioned  earlier,  after  careful analysis  of
all data,  efforts  may be  made  in  the  future  to make MOBILE3
city-specific in its modelling  of  evaporative HC emissions.  It
is  important  to  note,   however,   that  any  methodologies  or
techniques used  in this Appendix  do not necessarily represent
the approach that will  be  taken  in  any  modification of  the
MOBILE program.

     For this  analysis,  two  basic  comparisons were  made.   The
first  evaluates  current  city-specific  conditions,   including
actual summertime  RVPs  from MVMA's  1984 Summer Gasoline Survey
[14],    against EPA's  current  certification test  for  diurnal
losses —  a  60-84°F  temperature excursion with 9.0 RVP Indolene
test  fuel.   The  second  comparison  is  more representative  of
future  conditions,  assuming  ASTM's volatility limits  will  be
reached  in  each  of  the  urban  areas  and  comparing  these
city-specific  conditions  to  a  proposed certification  test  —
using  an  RVP  of  11.5 psi  with  the  same   diurnal  temperature
excursion  of 60-84°F.   Both comparisons make  use of  the same
temperature  data  for  each  of  the  cities  —  30-year  average
minimum  and  maximum July  temperatures.*   In future  work,  one
possible refinement would be the use of temperatures  from days
on  which  ozone violations  have actually  occurred within each
area.   However,  for this  analysis,  typical July temperatures
were chosen  because  July is  one of the two months  shown  to be
most prone to ozone episodes  (the other  is  August, as indicated
earlier in this chapter in Table 2-4).

     From  the  list of 47 non-attainment areas  shown  earlier in
Table  2-1,  17  were  included  in  MVMA's  1984  Summer  Gasoline
Survey.[14]  Because current  city-specific  RVPs were needed for
the first comparison, only these 17  areas were  included in this
analysis.
     Temperatures  were  taken  from the  Climatography  of  the
     United  States,  U.S.   National   Oceanic  and  Atmospheric
     Administration,  and  The  Weather Almanac,  Gale  Research
     Company.

-------
                             2-104

     City-specific inputs for the first  comparison are shown in
Table 2-A-6.  Temperatures are shown  in  Fahrenheit degrees,  but
were converted to Rankin  for  use in Wade's equation.   City RVPs
shown are from the MVMA survey.   All other variables  (i.e.,  W,
M,  p2  and  pi)  are  a  function  of  RVP  and temperature.   Using
these inputs, .a  relative  diurnal index was calculated  for  each
of  the  cities using Wade's equation;  again,  the  standard  EPA
test with  9.0 RVP Indolene  is  given an  index  of  1.00.   Final
indexes for each city are shown in Table 2-A-7.

     For these city-specific  index calculations,  the  effect of
fuel   "weathering"   on   volatility   and,   thus,   evaporative
emissions  was also  accounted   for.   As  discussed earlier  in
Section  IV.B. of  Chapter  2,  General  Motors   estimated  that
diurnal emissions were roughly  15 percent  lower  with  weathered
fuel than  with  non-weathered  Indolene  at  the  40-percent  full
tank level  specified in EPA's  test  procedure.[16]  For purposes
of this analysis, a  constant  factor  of 0.85 was  applied  to  the
city-specific  portion , of   the  diurnal   index  (i.e.,   the
numerator)  to account for this 15-percent  decrease in  emissions
due to  fuel weathering in  the  field.  Because EPA's  test fuel
is not weathered, the 0.85 factor is  not  applied  in determining
G.td  (the  denominator of the  index).   (This weathering  effect
has already been incorporated into  the  indexes  shown  in Table
2-A-7.)

     As  indicated in  Table  2-A-7,   the current  certification
test on Indolene appears  to  significantly underestimate diurnal
emissions in the majority  of the  ozone non-attainment  cities
examined.   In only two of the 17 cities  (Boston and Atlanta) do
diurnal  losses  appear  to   be   slightly overestimated  by  the
certification test —  indicated  by an  index  of  less  than one.
These results are not  surprising as  current RVPs in most of the
cities examined are much greater  than 9.0 psi.

     The second  question to  be answered  concerns the  future:
"If RVPs in all  areas  reach the ASTM summer (July) limits, will
the certification diurnal test be representative  of these areas
if test fuel  RVP is  raised  to 11.5 psi  (instead  of the current
9.0 psi)?"   In  order  to address  this  question,  city-specific
indexes  were  recalculated  using the  inputs  shown  in  Table
2-A-8.   Temperatures are  the same   as  before   (i.e.,  30-year
average July minimums  and  maximums), but  here  the RVPs shown
are the current  ASTM July limits for  each of  the  cities.*   Of
course, the remaining variables also change because of  their
dependence  on  RVP.    Weathering  was  again  included  in  the
city-specific calculations.
     This is true  except  for three  cities—Chicago,  Cleveland,
     and St. Louis—where current RVPs are already above their
     respective ASTM  limits.   In these cases,  the MVMA  survey
     RVPs were used (i.e., same as in Table 2-A-6).

-------
                      2-105
                   Table  2-A-6
City-Specific Inputs for First Index Calculation
              (Using Survey RVPs)
T
2
MVMA
T Survey
1 RVP
W
City (°F)* (°F)* (psi)** (Ib/qal)
Chicago 83.1
Cleveland 81.6
Detroit 83.1
Boston 81.4
NYC 85.2
Wash., DC 88.2
Phila. 86.8
Miami 89.1
Kansas City 88.0
St. Louis 88.4
Dallas 95.5
San Antonio 94.0
Atlanta 86.5
New Orleans 90.4
Phoenix 104.8
Las Vegas 103.9
Denver 87.4
EPA Test 84.0
(Current)
* Temperatures
minimums (Ti )
United States,
60.7
61.2
63.4
65.1
68.0
69.1
66.7
75.5
66.9
68.8
74.0
74.0
69.4
73.3
77.5
75.3
58.6
60.0

are 30-year
for the month
U.S. National
11.8
11.7
11.4
11.0
11.3
10.6
11.0
10.5
10.0
10.5
10.0
10.0
9.7
10.5
8.4
8.3
9.2
9.0

average
of July
Oceanic
6.17
6.17
6.17
6.18
6.18
6.19
6.18
6.19
6.20
6.19
6.20
6.20
6.21
6.19
6.23
6.24
6.22
6.22

M
i. (Ib/lb
61.2
61.3
61.6
62.0
61.7
62.4
62.0
62.5
63.0
62.5
63.0
63.0
63.3
62.5
65.2
65.4
63.8
64.0

P
2
mole) (psi)
9.4
9.1
8.9
8.4
9.2
9.2
9.3
9.2
8.6
9.1
9.7
9.4
8.0
9.5
9.5
9.3
7.8
7.2

normal daily maximums (T2)
(Sources: Climatoqraphy of
and Atmospheric
Administration,
P
1
(psi)
6.4
6.3
6.3
6.3
6.8
6.5
6.5
7.3
5.9
6.4
6.7
6.7
5.9
6.9
6.0
5.6
4.6
4.6

and
the
and
The Weather Almanac, Gale Research Company)
** Average city
Season 1984.
RVPs from the

MVMA National


Gasoline

Survey -- Summer



-------
                              2-106

                          Table 2-A-7

      Current  EPA Test vs. Calculated City-Specific Diurnal
                   Indexes (Using Survey RVPs)
City
Chicago
Cleveland
Detroit
Boston
NYC
Wash. , DC
Philadelphia
Miami
Kansas City, MO
St. Louis
Dallas
San Antonio
Atlanta
New Orleans
Phoenix
Las Vegas
Denver
"Current" Diurnal Index
1.56
1.38
1.25
0.96
1.27
1.38
1.45
1.07
1.20
1.35
1.67
1.45
0.87
1.44
1.77
1.74
1.12
EPA Indolene Test                       1.00
  (Current)

-------
                                     2-107

                                  Table  2-A-8

               City-Specific  Inputs  for  Second  Index  Calculation
                         (Using ASTM's July RVP Limits)



City
Chicago
Cleveland
Detroit
Boston
NYC
Wash., DC
Phila.
Miami
Kansas City
St. Louis
Dallas
San Antonio
Atlanta
New Orleans
Phoenix
Las Vegas
Denver
EPA Test
(Future)***

T
2



T

(°F)*
83.
81.
83.
81.
85.
88.
86.
89.
88.
88.
95.
94.
86.
90.
104.
103.
87.
84.

1
6
1
4
2
2
8
1
0
4
5
0
5
4
8
9
4
0

* Temperatures
minimums (Ti)
United
States,
The Weather

/ o
60
.61
63
65
68
69
66
75
66
68
74
74
69
73
77
75
58
60

1
F)*
.7
.2
.4
.1
.0
.1
.7
.5
.9
.8
.0
.0
.4
.3
.5
.3
.6
.0

ASTM
RVP
Limit
(psi)** (
11.8
11.7
11.5
11.5
11.5
11.5
11.5
11.5
10.0
10.5
10.0
10.0
11.5
11.5
9.0
9.0
10.0
11.5

are 30-year average
for the month of July
U.S.
Almanac,
National


W
Ib/qal)
6.17
6.17
6.17
6.17
6.17
6.17
6.17
6.17
6.20
6.19
6.20
6.20
6.17
6.17
6.22
6.22
6.20
6.17






M
(Ib/lb
61
61
61
61
61
61
61
61
63
62
63
63
61
61
64
64
63
61

normal daily
(Sources:
.2
.3
.5
.5
.5
.5
.5
.5
.0
.5
.0
.0
.5
.5
.0
.0
.0
.3




mole) (p
9
9
9
8
9
9
9
10
8
9
9
9
9
10
10
10
8
9


P
2
si) J
.4
.1
.0
.7
.4
.9
.7
.0
.6
.1
.7
.4
.7
.3
.4
.3
.6
.3

maximums (T2)
Climatography of
Oceanic and Atmospheric
Administration,

P
1
(psi)
6.4
6.3
6.3
6.5
7.0
7.1
6.8
7.9
5.9
6.4
6.7
6.7
7.1
7.7
6.5
6.1
5.0
6.0

and
the
and
Gale Research Company)
**
***
ASTM's maximum RVP  specification for  the  month of  July for  each area,
except where current levels already exceed ASTM limits.
As assumed in this analysis.

-------
                             2-108
     Indexes  for  this   second  comparison  were  calculated  as
before  (i.e.,  the denominator  based  on standard  Indolene  test
conditions) and  are  shown  in Table 2-A-9.   As  indicated  there,
most  of  the  indexes have increased  in comparison to  those  in
Table 2-A-7.  This  is entirely due to  the assumed  increase  in
RVP  as  ASTM  limits  are reached.   The  exceptions occur  in six
cities where  the indexes  do not  change  because  their  current
RVPs  are  either  just at or  above  the ASTM  limits  (i.e.,  inputs
are the same  for these  particular  cities  in both Tables 2-A-6
and 2-A-8).

     In this  part of the analysis,  the city-specific  indexes
are most appropriately compared to the  index  calculated for the
future  test  conditions  implicit  in  this  study  —  a  60-84°F
diurnal temperature  excursion with an  RVP of  11.5  psi.   This
index,  also  shown  in  Table  2-A-9,  is  1.89;  because  this
involves  a test  fuel,  no  weathering effect  was  accounted for
here.  As  shown, if  certification RVP were revised  to  11.5 psi
with no change in the current test  temperatures,  the  test would
then  ensure  that vehicles'  evaporative  control  systems  were
designed  to  operate  properly in  the majority  of U.S.  cities.
As shown  in Table 2-A-9, only two of the 17 cities (Phoenix and
Las Vegas) have  indexes greater than  1.89  (that  of  the  future
test procedure),  indicating theoretically higher diurnal losses.

D.   Summary

     A  few basic  conclusions  can be  made  from the  analyses
presented  in this Appendix.  First, diurnal  and hot-soak losses
can  increase  dramatically with  higher  temperatures  as well  as
with higher RVPs.  The  effect of  higher  RVPs had already  been
fairly well-defined  via EPA's  in-use EF testing  (as  described
in  detail  earlier  in   Chapter  2).   However,   the   effect  of
temperature on   evaporative  emissions has  not been  examined  to
nearly such a great extent,  as the  ATL  testing  represents EPA's
first  significant work  in this area.   As shown  in Part  A  of
this  Appendix,   initial  ATL  test   data show emissions  to  be
somewhat  less  sensitive  to RVP  than  do  the  in-use  EF  test
results,  which   could imply  that  perhaps  the  ATL results  are
also  underestimating the  effect  of  temperature.  However,  as
more  vehicles are   added  to  the   ATL  sample,  trends   in  the
results could change and become more consistent with the in-use
EF data.

     Some     preliminary     conclusions     regarding     the
representativeness of EPA's  current  certification procedure can
be made  based  on the  analysis  in Part  C  of this  Appendix.
Using the  diurnal emissions index based on Wade's equation,  it
was  shown  that   the variety  of  summer  temperature  and  RVP
conditions typical of several of the ozone non-attainment areas
could theoretically  result  in  a  rather  wide range  of diurnal

-------
                              2-109

                           Table  2-A-9

          Future*  EPA Test  vs.  Calculated  City-Specific
         Diurnal Indexes (Using ASTM's July RVP Limits)
City
Chicago
Cleveland
Detroit
Boston
NYC
Wash. , DC
Philadelphia
Miami
Kansas City, MO
St. Louis
Dallas
San Antonio
Atlanta
New Orleans
Phoenix
Las Vegas
Denver
"Future" Diurnal Index
1.56
1.38
1.31
1.06
1.34
1.67
1.63
1.40
1.20
1.35
1.67
1.45
1.51
1.76
2.32
2.34
1.44
EPA 11.5-RVP Test                         1.89
(Future)*
     As assumed in this analysis

-------
                             2-110

losses.   However,   the majority  of  these  predicted  relative
levels are greater  than that predicted for the current standard
diurnal   test   conditions  (i.e.,   60-84°F,   9.0   psi   RVP) .
Therefore,  the premise  made  in  Chapter  2  that EPA's  current
certification test  is  underestimating  summertime diurnal losses
in  the majority of the  urban areas  appears  to be  confirmed.
Results of this initial analysis  support the position that  the
current test  conditions need  to be modified — either  in terms
of  RVP  or  temperatures,  or  both  —  in  order  to  be  more
representative of conditions in the  field.  The change examined
here — raising certification  fuel RVP to 11.5 psi without  any
other modifications — would appear  to result in vehicles being
properly designed for typical  summer  days  in most of  the cities
examined.   However,  an   examination  of  days  on which  actual
ozone violations have occurred may show  more severe temperature
conditions than the 30-year July averages,  and could result in
higher city-specific indexes.

     As  alluded  to earlier,  one of  EPA's  future  goals  is to
incorporate city-specific information on  diurnal  and  hot-soak
temperatures,  RVP,  and perhaps weathering  into  the  modelling of
evaporative  HC emissions.   Additional  information  is  needed
before   this   task   can   be   accomplished   with   confidence.
Following completion  of  the  ATL testing,  the objective  is to
develop  two  models — one for  diurnal  and  one  for  hot-soak
losses — that can  be used to  predict emissions from controlled
vehicles (i.e., equipped with a canister)  as a  function  of both
RVP   and   temperature  conditions.    Then,    as   city-specific
conditions  are  defined,   the  appropriate  diurnal  and  hot-soak
losses  could  be   determined   and   input  into MOBILES.    In
addition, more information on  the  effect of fuel weathering in
the  field  is  needed  before   it  can  be incorporated into  the
emissions  modelling.   The   effect    of  weathering  on   fuel
volatility  —  as  opposed to  the  effect  on emissions  —  will
most  likely be the focus here.   The weathering  effect  could
then  enter  into the  analysis  as  a  direct  adjustment  of  each
city-specific  RVP   before it  is  read  into  the  diurnal  and
hot-soak models.

-------
                              2-111


                          Appendix 2-B

             Breakdown of Motor Vehicle Evaporative
             Emission Factors into Their Components


I.   Introduction

     The  evaporative  emission factors  used  in this  analysis
were derived  from the results  of EPA's in-use  emission factor
(EF)  test  program.   From  July  1984 until  April  1985,  164
vehicles were  tested under this  program.   These vehicles  were
tested on   1)  commercial fuel with a  nominal  RVP  of  11.7 psi,
2)  a blended  fuel with  an RVP of  10.4 psi,  and  3)  Indolene
fuel,  with an  RVP  of  roughly  9.0  psi,  in  that order.   The
complete test procedure has been  summarized  in Table  2-11 under
the heading of Post-July 1984.

     The vehicles  in  the EF testing program have been separated
by the condition  of  the  vehicle,  and  by  type of  fuel  metering
system.   Those vehicles  having  evaporative  emission  control
malfunctions  considered  to  be tampering  were  placed  in  the
category of  "tampered"  vehicles.   The remaining  vehicles  were
categorized as  "non-tampered" vehicles.   As  a  subset  of  this
group,   those  vehicles  which  exhibited  no  evaporative  control
system ,  malfunctions   were   categorized   as   "problem-free"
vehicles.  Table  2-14 listed the potential  malfunctions in the
evaporative  control   systems,   and   noted   those   that   were
considered tampering.  Within each  of the  above categories, the
vehicles   have   also  been   separated  into    carbureted   and
fuel-injected vehicles.

     Through   consideration   of    the  different   evaporative
emission rates  for  each  of  these  categories,  the  individual
components  of  the  final  evaporative  emission  factors  were
determined.  These components are:   1) the  standard  level,   2)
the  insufficient   design  effect,    3) the  malmaintenance  and
defect  effect,  4) the excess RVP effect,  and 5)  the tampering
effect.  The  magnitude  of the first  four  of  these  components
were determined  directly  from  the  EF  data.   The  in-use  EF
sample  is  not  thought   to  have  a  representative  number  of
tampered vehicles,  however,  so the  magnitude  of the tampering
effect   has not  been developed  from this testing, and  will
therefore be discussed separately.   These components  are later
used to determine  the  evaporative  emission  factors   for  the
various control scenarios in Chapter V.

-------
                              2-112
II.  Non-Tampered Vehicle Evaporative Emission Rates

     The  average  measured   emission   rates  for  non-tampered
vehicles for each  of  the three fuels tested is shown in the top
portion of  Table 2-B-l.   However,  this analysis  requires  that
the  emission  rates be known  for  in-use RVPs  other than  just
these  three levels.    Therefore,  curves  were  fit through  the
data for  both  diurnal and  hot-soak emissions  for  each type of
fuel metering system.   The emission rates from  these  curves are
summarized  in  the bottom part of  Table 2-B-l.  Note  that the
rates  from  the curves   at  9.0,  10.4,  and  11.7  psi  differ
slightly from the actual test data.

     These  emission   rates  have been   separated  into  the  four
non-tampered components   listed  previously.  The  remainder  of
this section will  describe the  process by  which the magnitude
of   each   component   was  determined,   and   how   they   were
extrapolated from  light-duty vehicles  to  light-duty  trucks and
heavy-duty vehicles.

     A.    Standard Levels

     The  standard  levels  represent  the  emission  rates  that
would  be  seen  if  the  vehicles  emitted  just  at the current
2-gram/test LDV  standard  on 9.0 RVP fuel.   As it  is necessary
to  break  this  level down  into  diurnal  and  hot-soak  losses
(which vary from vehicle to  vehicle),  it  is  assumed  that  the
ratio  of   hot-soak   to   diurnal   emissions  from  problem-free
vehicles is the  same  that would be  seen if the  standard  level
were met.   Therefore, all  that needs  to  be done  to determine
the  standard levels   is  to  normalize the  hot-soak and diurnal
emissions  on   9.0  RVP fuel  from the  problem-free sample  such
that  their  sum  equals  2   grams/test.    The   emission  rates
observed  from  the problem-free  vehicles   and   the  calculated
standard levels are presented in the first parts of Table 2-B-2.

     B.    Insufficient Purge Design Effect

     The  differences  between  the  standard   levels  and  the
problem-free  emission  rates  on 9.0   RVP   fuel  represent  the
effect of insufficient purge system design.  This is  based upon
the  assumption  that   an  operating  evaporative  control  system
with  no  malfunctions should  meet  the  2-gram/test  standard.
This effect  is determined by  simply subtracting  the  calculated
standard  levels  from  the   emission   rates  for  problem-free
vehicles  on 9-psi RVP fuel,  as  shown  at  the bottom  of  Table
2-B-2.   Note  that for fuel-injected  vehicles this  effect  is
non-existent,   as their problem-free average emissions  on  9-psi
RVP fuel are under 2 grams/test.

-------
                  2-113
               Table  2-B-l

Non-Tampered 81+ LDV and LDT Evaporative
       Emission Rates  (q/test)
EF Test Data
Fuel Metering System RVP(psi)
CARS 9.0
10.4
11.7
FI 9.0
10.4
11.7
Fitted Curves
Fuel Metering System - RVP(psi)
GARB 9.0
9.5
10.0
10.5
11.0
11.5
FI 9.0
9.5
10.0
10.5
11.0
11.5
Hot-Soak
2.33
2.93
4.05
0.93
1.38
1.92
Hot-Soak
2.32
2.46
2.68
2.98
3.37
3.84
0.90
1.08
1.27
1.46
1.65
1.83
                                             Diurnal

                                               2.36
                                               4.92
                                              10.14

                                               1.21
                                               2.23
                                               6.48
                                             Diurnal
                                               2.32
                                               3.04
                                                 06
                                                 ,40
                                                 05
4
5
7
9.01
                                               1
                                               1
                                               1
  25
  59
  93
2.34
3.68
5.51

-------
                             2-114
                          Table 2-B-2

         Estimation of Standard Level and Insufficient
          Purge Effect for 81+ LDVs  and  LDTs  (q/test)
Problem-Free Vehicle
Average with 9.0 RVP

         CARB
         FI
                              Hot Soak

                                 1.50
                                 0.64
Diurnal

  1.25
  0.87
Standard Level*

         CARB
         FI
                                 1.09
                                 0.85
  0.91
  1.15
Insufficient Design/Capacity
    Purge Effect**	
         CARB-Straight
             -Adjusted
         FI
                                 0.41
                                 0.30
                                 0.00
  0.34
  0.30
  0.00
**
Problem-free average normalized to 2-gram standard.
Problem-free average minus  standard  level;  if negative, as
for FI vehicles, considered zero.

-------
                              2-115
                                          l

     These  insufficient  design  effect  values  for  carbureted
vehicles,  require  an additional,  very slight adjustment  due to
the fact  that  the  curve fits described in the  previous  section
do  not  exactly match  the EF  data.   These adjusted  values  are
also  shown  in  Table  2-B-2.    The   differences   between  the
straight  and  adjusted  values  are equivalent  to the differences
at  9.0  RVP between the EF data  for  non-tampered  vehicles  and
those given by the  fitted curves.  Without this adjustment,  the
component  values would not  sum to the  average emission level
for non-tampered vehicles in the EF sample.

     C.     Malmaintenance and Defect Effect

     Non-tampered vehicles,  on  the  whole,   show  significantly
higher average  evaporative  emission rates than  do problem-free
vehicles  (a  subset of  non-tampered vehicles).   This  effect is
assumed to be due to improper  maintenance  and equipment defects
in  the   evaporative   emission   control   system,   but  not   to
deliberate     tampering.        (The     distinction     between
malmaintenance/defects  and  tampering  was  made  earlier in Table
2-14 of Chapter 2.)

     The magnitude of  the effect of malmaintenance and defects
upon evaporative emission rates  was found to increase with fuel
RVP.   The  determination  of   this   relationship   for  diurnal
emissions  from  carbureted  vehicles   is  shown  graphically  in
Figure 2-B-l.   The top line shows the  average emission rates at
the 3 fuel RVPs for all  non-tampered  vehicles;  the middle line
shows  these  rates  for   only  problem-free  vehicles;  and  the
bottom line shows  the  difference between the top  two lines.  A
simple linear  regression  passing through  the value  at  9.0  RVP
has been  fitted to  the values at 10.4 and 11.7 RVP to arrive at
this "difference" curve.   This same method was  used  to develop
the   relationships   for   carbureted  hot-soak,   fuel-injected
diurnal,   and  fuel-injected hot-soak emissions.*   The resulting
malmaintenance and defect effects are summarized in Table 2-B-3.
     Two  carbureted  1983  Nissan  Stanzas  in the  problem-free
     sample  had unexplainably  high  (>23 grams/test)  hot-soak
     emissions   that   skewed  the   results   such  that   the
     malmaintenance and defect  effect  decreased with increasing
     RVP.  The  removal of  the hot-soak  results for  these two
     vehicles  from  the  problem-free  sample  corrected  this
     problem.   Therefore,   this  approach was taken  for  this
     portion of the analysis.

-------

      12.0
                            FIGURE  2-B-1
                          CARBURETED DIURNAL EMISSIONS
                                                                        CTi
                                                                 1 1.8
O NON-TAMPERED
     FUEL RVP
PROB.-FREE
MAINTENANCEXDEFECT

-------
              2-117


           Table 2-B-3

Malmaintenance and Defect Effect
for 81+ LDVs and LDTS
Fuel Meter inq System RVP (psi)
GARB 9.0
9.5
10.0
10.5
11.0
11.5
FI 9.0
9.5
10.0
10.5
11.0
11.5
(grams/test)
Hot Soak
0.83
0.91
0.99
1.07
1.15
1.24
0.29
0.42
0.55
0.67
0.81
0.93
                                         Diurnal

                                           1.11
                                           1.21
                                           1.31
                                           1.41
                                           1.51
                                           1.61

                                           0.34
                                           0.44
                                           0.54
                                           0.64
                                           0.74
                                           0.84

-------
                             2-118


     D.    Excess RVP Effect

     The RVP effect  represents  the  excess evaporative emissions
that  arise from  operating  vehicles  on  a  fuel  of  a  higher
volatility  that   for  which   they  were   designed.    Current
evaporative   control  systems   are   designed   to   meet   the
2-gram/test standard when operated  on Indolene,  with an average
RVP of 9.0 psi.   Current  in-use gasolines in many areas  of  the
country,  however, have average volatilities well  above 9.0 psi.

     The magnitude of the RVP  effect will of course depend upon
the  actual  volatility  of  the  in-use   fuel.    Herein,  this
magnitude  is  generally  defined   as  the  difference  between
non-tampered  evaporative  emissions   on   commercial   fuel  and
Indolene,  adjusted  to reflect  the  effect that  fuel  volatility
has upon the malmaintenance  and defect  effect.  Without  this
latter correction a situation  of  double counting would  arise.
As an  example, calculation  of  the  excess RVP effect  on diurnal
emissions  from  carbureted vehicles  operating on  11.5-psi  fuel
is reviewed below.

     Using the fitted curve values  listed in Table  2-B-l,  the
total  difference  between  the carbureted  diurnal  losses at 11.5
RVP (9.01  g/test) and 9.0  RVP  (2.32  g/test)  is  calculated  as
6.69  g/test.   However,  part   of   this  total   difference  in
non-tampered  emissions  has already  been  accounted  for  in  the
RVP-dependent  malmaintenance/defect  effect.   As  Table  2-B-3
shows, the difference between the  11.5 RVP and 9.0 RVP diurnal
effects  for   carbureted  vehicles  is  0.50  g/test (i.e.,  1.61
minus  1.11).   Therefore,  the  net  effect to be  attributed  to
excess RVP  is simply the difference between 6.69  and 0.50,  or
6.19 g/test.  This  value,  along with the estimated  excess  RVP
effect for each of the other cases,  is shown in Table 2-B-4.

     E.    Extrapolation of LDV Data to LDTs and HDGVs

     The  extrapolation  of  the  light-duty vehicle  evaporative
emission rates to light-duty  trucks  and  heavy-duty vehicles  is
done  here exactly  as  it  was  done  for MOBILES.*   Basically,
since  little or  no  in-use test  data exist for  these vehicles,
the emission  rates  are extrapolated based upon  their relative
standard  levels.    For  LDTs,   this  means  that  evaporative
emission rates will  be  exactly  the  same as for LDTs,  as both of
these vehicle classes must meet  the  same 2.0-gram/test standard
under identical test procedures.

     Beginning with  the 1985 model  year, HDGVs must meet either
a 3,0-gram/test or 4.0-gram/test standard,  depending  upon their
gross  vehicle  weight.    Therefore,  the  evaporative  emission
rates for HDGVs under the 3.0- and  4.0-gram standards are those
     See Reference 50 of Chapter 2.

-------
                      2-119



                   Table  2-B-4

Excess RVP Effect for 81+ LDVs and LDTs (q/test)

                                                 Diurnal

                                                   0.00
                                                   0.62
                                                   1.54
                                                   2.78
                                                   4.33
                                                   6.19

                                                   0.00
                                                   0.24
                                                   0.48
                                                   0.79
                                                 .  2.03
                                                   3.76
Fuel Metering System RVP (psi)
GARB 9.0
9.5
10.0
10.5
11.0
11.5
FI 9.0
9.5
10.0
10.5
11.0
11.5
Hot-Soak
0.00
0.06
0.20
0.42
0.73
1.11
0.00
0.05
0.11
0.18
0.24
0.29

-------
                              2-120


for   light-duty   vehicles   multiplied   by   1.5   and   2.0,
respectively,  weighted  by  their  respective  sales  fractions
projected for  1987  — 81.5 percent for 3-gram and  18.5  percent
for    4-gram     vehicles.     This    yields     an    overall
heavy-duty/light-duty    multiplicative   factor    of    1.5925.
Heavy-duty vehicles  are  assumed to  be completely carbureted, so
the  evaporative  emission  factors  from  only  the  carbureted
vehicles are  used.   The resulting  evaporative  emission  factors
and the magnitude  of each of  the various components  are shown
in Table 2-B-5.

Ill.  Tampering Effect

     The emission rates  for  tampered vehicles have been derived
from SHED testing on  light-duty vehicles  with removed canisters
and/or fuel  caps.   The results of this SHED  testing,  which was
performed using  9.0 and 11.5  RVP fuels,  are  shown in  the top
portion of  Table 2-B-6.   The  values  for fuels  of other  RVPs
were   determined   through   linear   interpolation.    Certain
assumptions  were   made   as  part   of this   testing.   First,
uncontrolled  diurnal emissions were  assumed to   be  the  same
regardless of  either the  type  of disablement or  the  vehicle's
fuel   metering system.   Secondly,  for fuel-injected  vehicles,
uncontrolled hot-soak  emissions are assumed to be  the same for
either canister  or  fuel cap  removal.   Finally,  for carbureted
vehicles,   fuel  cap  removal  is  assumed  not  to   lead   to  any
increases in hot-soak  emissions (i.e., the uncontrolled values
are  the  same  as the non-tampered  hot-soak  averages shown in
Table 2-B-l).

     The differences between these  uncontrolled emissions  and
those of  non-tampered vehicles are defined  as the "tampering
offsets"   to  be  used   in  the  MOBILE3  program,   along  with
tampering frequency  estimates.   These offsets are  given in the
bottom half of Table 2-B-6.

     Again,  LDV data  on  uncontrolled evaporative emissions  were
used  to  develop  the LDT  and  HDGV  estimates,  due to  lack of
evaporative testing on these classes.  As before,  the tampering
offsets for  LDTs were  assumed to  be  equal  to those  developed
from  the   LDV  data,   as   indicated   in  Table   2-B-6.    The
methodology used to  develop  uncontrolled  estimates for HDGVs is
similar  to  that  mentioned  previously  with  respect  to  the
non-tampered  averages (i.e.,  as  outlined  in  Reference 50 of
Chapter  2).   Variations  from  the  basic  MOBILES  method  of
extrapolating LDV evaporative data  to  "HDGVs  will  be detailed in
an upcoming EPA  technical  report,  entitled "The Effect  of  Fuel
Volatility   on   Controlled    and   Uncontrolled    Evaporative
Emissions," which is  expected  to be released by the end of the
year.  Uncontrolled  estimates and tampering  offsets (calculated
as before  —  i.e.,  uncontrolled minus  non-tampered  averages)
for HDGVs are presented in Table 2-B-7.

-------
                           2-121
                        Table 2-B-5
Evaporative Emission Rates for Non-Tampered 85+ HDGVs(g/test)
Component
Standard Level
Insufficient Design
Capac i ty/Pur ge
Malmaintenance/Defect




-
Excess RVP





Total Non-Tampered
Average




RVP (psi)
-
-
9.0
9.5
10.0
10.5
11.0
11.5
9.0
9.5
10.0
10.5
11.0
11.5
9.0
9.5
10.0
10.5
11.0
11.5
Hot-Soak
1.73
0.64
1.32
1.45
1.58
1.71
1.84
1.97
0.00
0.09
0.31
0.67
1.15
1.77
3.69
3.91
4.26
4.75
5.36
6.11
Diurnal
1.44
0.48
1.77
1.93
2.09
2.25
2.41
2.57
0.00
0.98
2.46
4.43
6.90
9.85
3.69
4.83
6.47
8.60
11.23
14.34

-------
                             2-122
                          Table 2-B-6

                   81+ LDV and LPT Tampering*

              Uncontrolled Emission Rates (g/test)
Fuel Metering
    System

    GARB
    FI
 RVP
(psi)

 9.0
 9.5
10.0
10.5
11.0
11.5

 9.0
 9.5
10.0
10.5
11.0
11.5
Canister Removal
Hot-Soak  Diurnal
  10.36
  11.79
  13.21
  14.63
  16.05
  17.47

   4.93
   6.26
   7.59
   8.93
  10.26
  11.59
14.95
17.10
19.25
21.41
23.56
25.71

14.95
17.10
19.25
21.41
23.56
25.71
           Gas Cap Removal
          Hot-Soak  Diurnal
 2.32
 2.46
 2.68
 2.98
 3.37
 3.84

 4.93
 6.26
 7.59
 8.93
10.26
11.59
14.95
17.10
19.25
21.41
23.56
25.71

14.95
17.10
19.25
21.41
23.56
25.71
Fuel Metering
    System

    GARB
    FI
 Tampering Offsets (g/test)

 RVP    Canister Removal
        Hot-Soak  Diurnal
                  11.5
           8.04
           9.33
          10.53
          11.65
          12.68
          13.63

           4.03
           5.18
           6.32
           7.47
           8.61
           9.76
           12.63
           14.06
           15.19
           16.01
           16.51
           16.70

           13.70
           15.51
           17.32
           19.07
           19.88
           20.20
                      Gas Cap Removal
                     Hot-Soak  Diurnal
             0.00
             0.00
             0.00
             0.00
             0.00
             0.00
             4
             5
   03
   18
 6.32
 7.47
 8.61
 9.76
12.63
14.06
15.19
16.01
16.51
16.70

13.70
15.51
17.32
19.07
19.88
20.20
     To be  included in an  upcoming  EPA Technical  Report,  "The
     Effect of  Fuel Volatility  on Controlled  and  Uncontrolled
     Evaporative Emissions," by  Celia  Shin and  Tom Darlington,
     TEB,  ECTD,  QMS, currently under  development.

-------
                             2-123



                          Table 2-B-7

                      85+ HDGV Tampering*

              Uncontrolled Emission Rates (g/test)

 RVP             Canister Removal                 Cap Removal
(psi)

  9.0
  9.5
 10.0
 10.5
 11.0
 11.5
 RVP
(psi)

  9.0
  9.5
 10.0
 10.5
 11.0
 11.5
Hot-Soak Diurnal
14.67 26.08
16.40 28.83
18.12 31.59
19.86 34.35
21.58 37.11
23.31 39.87
Tampering Offsets
Canister Removal
Hot-Soak Diurnal
10.98 22.39
12.49 24.00
13.86 25.12
15.11 25.75
16.22 25.88
17.20 25.53
Hot-Soak
3.69
3.91
4.26
4.75
5.36
6.11
(g/test)
Diurnal
26.08
28.83
31.59
34.35
37.11
39.87

Cap Removal
Hot-Soak
0.00
0.00
0.00
0.00
0.00
0.00
Diurnal
22.39
24.00
25.12
25.75
25.88
25.53
     To be  included  in an upcoming  EPA Technical  Report,  "The
     Effect of  Fuel  Volatility  on Controlled  and  Uncontrolled
     Evaporative Emissions,"  by  Celia  Shin and  Tom Darlington,
     TEB,  ECTD,  QMS,  currently under  development.

-------
                            CHAPTER  3

         Vehicle-Oriented Excess Evaporative HC Control

I.    Introduction

     This chapter will  focus  upon the modifications  to  current
vehicular evaporative  emissions  control  systems  (ECSs)  needed
in  order  to  improve  their  ability  to  control  evaporative
emissions.   The  need  for  such  improvement  stems  from  the
proposed  changes  in the certification  test  procedure  to:  1)
eliminate the discrepancy between certification and in-use fuel
volatility,   and  2)  begin  the  test with a  fully  saturated
canister.   These  changes   will   necessarily  require  increased
storage capacity and purge capacity in evaporative ECSs.

     The  key   issues   surrounding  improvements   of   current
evaporative  ECSs   involve  the   technological  feasibility  of
potential modifications,  and  the  costs  associated  with  such
modifications.   These  two  issues are addressed  in  Sections  II
and  III  below,  respectively.   The  overall  conclusions  are
presented in Section IV.

     Two effects that  arise from improved evaporative ECSs that
will affect the overall costs will  be addressed separately from
the generalized  cost  determination,  as their  costs  are  more of
an  indirect nature.   These  are:   1)  an  improvement  in  gas
mileage  due  to   increased  fuel  vapor   recovery  (i.e.,  the
evaporative recovery/prevention credit),  and   2)  a reduction in
gas mileage  due  to the extra weight  involved  in  using a larger
evaporative  canister  (i.e.,  the  excess  weight  penalty).   The
former  is  addressed in Section  VI  of Chapter  4  and the latter
in  Appendix  6-B  of  Chapter  6.    This  chapter  will  focus
primarily upon the initial price  increase to the consumer.

II.  Technology

     As  has been   indicated,  vehicular  evaporative  emissions
control  systems require modification  in  order  to  meet  the
stricter  requirements  imposed by the proposed changes in  the
certification  test  procedure.    These  changes   will   center
around:   1)  increasing the capacity  of  the canister  to adsorb
and desorb  hydrocarbon vapors, and  2)  increasing  the  ability
of   the  control  system  to  purge  the  evaporative  canister.
Before discussing the technological  feasibility of making  these
improvements, however,  it  is  necessary  to understand what  the
system  working  capacity is,  how  it  is  determined,  and  to
estimate how much more capacity is needed.

-------
                              3-2
     A.    System Working Capacity

     In Chapter 2 of this report, a brief description  of  system
working capacity was presented.   Therein;  it  was defined  as the
actual  mass  of  gasoline vapors that  an  evaporative control
system  will  adsorb  and  desorb  during   operation,   and  was
described  as  being  dependent  upon  factors  both  internal  and
external  to  the  control  system.   That  description  will  be
expanded at this point.

     The  internal  factors cited as determining,  in part,  the
system  working  capacity are:   1) the physical  characteristics
of the  charcoal,   2)  the volume  of  charcoal  in the  canister,
3) the configuration of  the canister,  and  4)  the volume  of
purge air drawn through by the control  system.

     Vapor  adsorption  and  desorption  is  a  purely  physical
process,  with  Van  der  Wall's   bonding  acting  as  the   force
holding the  vapor  to  the  charcoal.[1]   The effectiveness  of
this bonding  will  depend  upon  the  average particle  size,  the
ratio  of  surface area to  volume of  the individual  particles,
and  the  size  of  the  pores  in  which the  vapor molecules  are
adsorbed.   These various elements  determine  what  is  defined as
the  charcoal  "working  capacity"   (measured  as grams HC per  100
cubic centimeters (cc)  of charcoal).

     In a  given volume of charcoal,  smaller  particles*  can be
compacted more tightly, thus  increasing  the likelihood that the
vapors will come  in contact  with the surface of the  particles.
The  tighter  compaction  of particles also  allows for  a greater
mass  of  charcoal  in a  given  volume,  resulting  in  increased
volumetric working  capacity.   This  increase in charcoal working
capacity has been  seen  in  a  designed exper iment. 12]   This same
compaction,  however,  decreases   permeability and  reduces  the
flow rate through the canister at a specific  pressure  drop.   It
is  for this  reason  that,  in  current  practice,  the maximum
pressure drop across the  canister at  a  specified flow rate is
usually the  determining  factor   in  the  selection of  particle
size.[3]
     Particle  size   of   a  given  charcoal   type   is  usually
     expressed in terms   of  mesh size  and  is expressed  in the
     form A x  B.  A and  B are divisions per inch and A x B size
     particles are  able   to  pass through  (I/A)   inch by  (1/B)
     inch openings.    Thus, larger values of A and B represent a
     smaller mesh size and therefore smaller particles.

-------
                              3-3


     A greater  surface area for  a  given particle  implies  more
sites  to which  vapor  molecules  can  be bonded.   Therefore  a
particle  with  a  highly  convoluted  surface  having  a  large
surface  area to  volume  ratio  will  necessarily  be  a  better
adsorber than a particle  of similar size with a smaller surface
area to  volume  ratio.   Increasing this  ratio by disturbing the
surface  of  a particle  is  the  process that  is  referred to  when
carbon is defined as being activated.[4]

     Finally,  pore  size   can   affect  the   charcoal   working
capacity, although  the effect  is  not as clear  as  with  particle
size or  the  surface  area-to-volume ratio.   In general,  vapor
molecules will  adsorb  into pores  of a size  comparable  to their
own.  It is possible,  however,  that larger particles  can become
lodged  in  pores  in such  a manner  as to  block access  to  more
pore space  that  smaller  particles  could  occupy.   Since these
larger  particles   are  heavier   and   the  bonding  forces  are
stronger, they may not be removed during the purge  cycle, and a
portion of the carbon's adsorptivity will be lost.tl]

     A  charcoal's working  capacity  is  measured as its ability
to adsorb and desorb HC vapor,  on  a  volumetric basis,  under a
relatively  standardized  test  procedure.  Working  capacity  is
usually measured  as grams  of butane per 100 cc of  charcoal,  as
butane is  easy  to work with,  yields consistent results and is
the  dominant  compound   in vehicular   evaporative  emissions.
Typical  levels   of  "butane  working   capacity"   for   various
charcoals are presented in  Table  3-1.   These  values  will not
necessarily translate directly into  charcoal working  capacities
for vehicular evaporative emissions, as  these  HC vapor  mixtures
are more  complex  than  simple butane.   Since HC species differ
in  their  physical  characteristics,  they   will   be  adsorbed
preferentially  and  the  degree of  preference  may depend  upon
carbon type.   Thus, equal  butane working  capacities  will not
always result in equal gasoline working capacities.[2,4]

     Assuming that  the characteristics  of the charcoal remain
the same,  there  should be  a  direct  relationship between the
volume of  charcoal  used and the  system  working capacity.  This
should be  clear  from  the  definition  of the charcoal  working
capacity.

     Canister configuration may  play a  role in determining the
system working capacity,  although this  fact  is disputed.   In a
study  by Scott Environmental  Technology, the  working  capacity
of  a  canister was  increased by  12.3 percent  by  doubling the
length of  a  cylindrical  canister while holding  the  diameter,
and  therefore  the  cross  sectional  area,   constant.[2]   The
theoretical  explanation for this  increase  in  working  capacity

-------
                                            3-4


                                         Table 3-1

                                   Charcoal Properties*

Charcoal
BPL-3
WV-A
WV-A
Extruded***

Manufacturer
Calgon
Westvaco
Westvaco
West-varo

Base
Coal
Wood
Wood
Wnnri

Mesh Size
6 X 14
10 X 25
14 X 35
****
Surface
2
Area (m /q)
800-1000
1500-1700
1600-1800
Apparent
Density
3
(Ib/ft )
23-24
15-18
16-19
?n_7i
Capacity
Test I*
6.8
8.5
9.0
in. >;
(q/100 cc)
Test II**
8.08
8.31
8.89
*    Specified  by   charcoal  manufacturer   in   "Westvaco's  Wood-Base   Carbons  Improve
     Evaporative Emission Control,"  Billy Kornegay,  Ph.D., P.E.,  September 1980.
**   From a test performed by Westvaco.
***  Data from phone  conversation with Bill Kornegay of  Westvaco Corporation  on November
     5, 1984.
**** Not specified,  but equivalent pressure drop of mesh size 6 x  14.

-------
                               3-5


 centers on the  concept  of a  "mass  transfer zone" (MTZ).  This
 theory states that when the  carbon bed is  charged,  there will
 exist a zone  which  is fully  saturated  with hydrocarbons and a
 zone where the  saturation  decreases from  fully  saturated  to
 completely devoid of  hydrocarbons.   This  MTZ will only  operate
 at half of its  theoretical capacity when  breakthrough  occurs,
 and  its  length will  not  vary  with the  length of  the carbon
 bed.   A carbon bed whose  length  is  twice  that  of  the MTZ will
 have a capacity at breakthrough  of  75  percent of maximum.*  By
 doubling  the  length of the carbon  bed,  with the  length of the
 MTZ remaining constant,  there will be less  under-utilization of
 capacity,  and the  capacity at breakthrough will be 87.5  percent
 of maximum.**   This   theoretical  increase  of   12.5  percent  is
 quite close to that observed  in the testing.[2]

      Other reports, though, have indicated  that system  working
 capacity    is   not    significantly    related    to    canister
 configuration.   The  first of these provides   no  experimental
 results to support its  conclusion,  however.  In the other, the
 only experimental  results provided involved canisters that had
 been loaded beyond breakthrough,  which  is relevant with respect
 to total  capacity, but not  working capacity.[5]   Thus, since
 the  argument  that there   is  no  relationship  between  canister
 configuration and  system working  capacity appears quite  flawed,
 whereas the argument  for  a relationship appears reasonable and
 consistent, working capacity  must be considered to be  sensitive
 to canister configuration.

      The  final factor that can be controlled by the  evaporative
 emission  control  system designer  is the volume  of  purge air
 drawn though  the  system.   Without  adequate purge,  the carbon
 will  saturate quickly  and  lose even more capacity that  it would
.naturally.   It  has been  shown  that the total  volume of purge
 air,  rather than the velocity of  the air,  determines the amount
 of  adsorbed   hydrocarbon  that   will   be  desorbed.tS]   When
 sufficient purge air  is available, the  system working  capacity
 is the same  as  the  "canister working capacity."  Otherwise, it
 is less than  the canister  working capacity.


 *Figured  as:   [0.5 (length) x 1.0 (capacity  utilized)] +
                   [0.5 (length) x 0.5 (capacity  utilized)].

 **   Figured  as:   [0.75  (length)  x  1.0 (capacity utilized)] +
                   [0.25  (length)  x  0.5 (capacity utilized)].

-------
                              3-6


     Chapter 2  also described several  factors  external to  the
control  system that  may  affect  the  system working  capacity.
These include the humidity of the purge air,  the  temperature of
the purge  air,  and the  vapor  concentration of the  evaporative
emissions.    Working  capacity  will   decrease  with  increased
humidity,  but  this is not a lasting  effect  as charcoal has  a
higher  affinity  for  hydrocarbons  than  for  water  vapor.[2]
Working  capacity will  increase with  higher temperature  purge
air as  more HC can  be  desorbed  at  higher  temperatures. [2,4]
Working  capacity will  also  increase  when  there is  a  larger
concentration  of  HC  vapors.[2]   This  latter  effect  is  worth
quantifying as  it will become significant when in-use RVP  and,
therefore,  HC vapor concentration,  are changed.

     The   adsorptivity  of  charcoal   has   been  found  to   be
dependent  upon  the  vapor  concentration  of  the  evaporative
emissions.[2]    This  is  illustrated in  Figure 3-1,   showing  the
average  charcoal  working   capacities   for  two   coal-based
charcoals  tested  on  8.7  and 13.8  RVP  (psi)  fuels.  The  higher
RVP fuel will  necessarily produce a higher  vapor concentration
(due to  its higher volatility) than  the  lower  RVP  fuel.   The
figure clearly shows an  increase  in charcoal  working capacity
with increasing RVP,  which will  translate into a higher  system
working capacity.

     B.     Extra Control  Needed

     The increase  in  system working capacity necessary to  meet
the requirements  of the  changes in  the test  procedure can be
estimated  by considering the  resulting increase in uncontrolled
emissions  (i.e.,  HC vapors to  the canister)  that  result  from
these changes.   These must be  adjusted, however,  to  reflect the
changes  in  working  capacity  that   will  occur   automatically
without  any modifications  to the  evaporative control  system.
The difference  between  these two  will  represent  the  amount of
extra control that the ECS designer will have to develop.

     Figure 3-2 shows graphically how the  required  amount of
extra system working capacity is determined.  Curve  1  shows the
relationship  between  uncontrolled  evaporative  emissions  and
fuel volatility.  Therefore, this  curve represents the increase
in  system   working  capacity  required  with  various  RVP  fuels.
For present purposes, this curve has  been normalized  such  that
emissions  from  a  9.0  RVP fuel,  typical of current certification
fuel,  equal 1.0.   Curve  2  is  a  reproduction of   Figure  3-1,
showing the relationship between charcoal working capacity and
fuel volatility.  This curve has also been normalized  such that
the value  for  9.0 RVP fuel equals  1.0.  Curve 3 is the ratio of
Curves  1   to  2,  and  indicates  the  additional  system  working
capacity,  relative  to the 9.0 RVP baseline, that is  needed in

-------
      FIGURE  3-1
CHARCOAL WORKING CAPACITY vs. RVP





_J
<
0
u
A**
u_
<
V
w
o
8
\
o
x
l/>
IF r
o







/ .u -
6.9 -
6.8 -
6.7 -
6.6 -
6.5 -
6.4 -
6.3 -
6.2 -
6.1 -
6.0 -
5.9 -
5.8 -
5.7 -

5.6 -
5.5 -

5.4 -
5.3 -
5.2 -

5.1 -
5 0 -
** m\f





n
.-•'"
.--"
x"
./'
/•'
/
._^~
./
..-•"
s~'
..'""
..'-"
X
X
..--'
--p""
_.-""
-/
....
,.-•""
.-""
j-^"
/
.,- .-*
B

l I I 1 i
8.0 10.0 12.0 14
                                               i
                                               vj
           RVP
    CHAR. WORKING CAP.

-------
UJ
E
O.
UJ
     1 .7
     1 .6 -
mmm


uj    1 .3 -
     1.2-
     1.1  -
     1 .0
                               FIGURE  3-2
                          EFFECTS RELATIVE TO 9.0 RVP FUEL





9.0
  a   EMISSIONS
                  9.4
9.8
10.2
         RVP  (psf)
  CHAR.  WC
10.6      11.0      '11.4


  *    DESIGN  CAPACITY
                                                                               U)
                                                                                I
                                                                               00

-------
                               3-9


addition  to  that  naturally  occurring within  the system.   For
example,  a  change in  the  certification  fuel  to  11.5-psi  RVP,
while  generating  64 percent  more  emissions,  will only require
the  development  of  a  45-percent   increase  in  system  working
capacity,  as  a  13-percent  increase  in  the  system  working
capacity  will  be  realized   from  the   increase   in  specific
charcoal working capacity.

     Because  of  the   increase in  the  amount  of  uncontrolled
emissions generated by a higher RVP  fuel and  loaded  onto  the
larger capacity canister, a  greater volume of purge air will be
necessary to unload the canister during the purge cycle.   With
a higher  RVP fuel, the HC  concentration obtained  in the vapor
above  the liquid fuel  is  greater  than  the  HC  concentration
obtained  with  a lower  RVP  fuel.   However, since  the HC vapors
are  loaded  at a higher  HC  concentration,   and  subsequently
desorbed  during   the  purge   cycle   at  the   same   increased
concentration, the purge volume only has  to  be increased  by a
degree   that   is  less than  the  increase   in   uncontrolled
emissions.  Assuming the HC  concentration is  a  linear function
of  RVP,   the  HC  concentration to  and  from  the  canister  with
11.5-psi  RVP   fuel   is  28   percent   greater   than   the   HC
concentration  with  9.0-psi  RVP  fuel.   Therefore,  the  purge
volume  only  has  to  be  increased  by  28  percent  (1.64/1.28  =
1.28)  to  purge an equal percentage of the adsorbed HC from the
larger canister.

     C.    Potential Modifications

     As discussed previously,  to increase the  system's capacity
to  control   emissions,  both   canister  capacity  and  purge  air
volume must be  increased.  Changing the  canister configuration,
increasing  the desorption-adsorption  temperature  differential
and  changing  the particle  size  are  also options,  but  their
effects  are  less pronounced  and  too  vehicle-model specific to
be  considered  here.    The  remainder  of  the  discussion,  then,
will be limited to canister and purge  capacity.

     1.    Canister Capacity

     In order  to  increase the canister working capacity, either
canister  volume can  be increased or  specific charcoal working
capacity  can be increased.   Though  increasing the canister size
will  increase the  cost of   the  evaporative  emission  control
systems,   it   will    require  no   significant   technological
innovation.    The  option  of  using  a  charcoal  with   a  higher
specific  working  capacity than that  presently used  has become
technologically feasible for  some systems with  the introduction
to  the  market  in  1984  of  a  new  type  of  charcoal.   The
properties of this "extruded" charcoal were shown  in  Table 3-1,
along with the properties of other  charcoals.

     Because  of  the greater  specific working  capacity  of  the
extruded  charcoal  (10.5  vs.  6.8-9.0   g/100   ml),   canisters

-------
                              3-10


with  an equal  volume of  the extruded  charcoal would  have  a
higher working  capacity  and,  thus,  be able to support emissions
from  a  higher RVP  fuel.   This  is  shown  in  Table 3-2,  taking
into  account  the current  carbon type of  various  manufacturers
and curves 1 and 2 of Figure 3-2.  By switching  to  this  type of
charcoal,  then,  present systems could  support  9.7 - 11.7  RVP
fuels  without  requiring  an   increase  in  canister  size.    An
increase  in  pressure  drop  with  the  extruded  charcoal   may
occur.   However,  the charcoal manufacturer expects to be  able
to accommodate  these concerns by manufacturing various particle
sizes.[6]

     The option of  switching  to  this extruded charcoal  to  meet
an  11.0-11.5  RVP certification  fuel standard is  feasible  for
some  vehicle  manufacturers (i.e.,  those  using  large  particle,
coal-based  charcoal).   However, since  it is not  necessarily
feasible  industry-wide,  the  remainder  of  this  report  will
consider only the  alternative option to  increase  the canister
capacity — increasing the canister size.  This  is  not meant to
imply that  charcoals with specific working  capacities  greater
than  those  traditionally used could  not  be  developed.   It  is
more  an indication of  a  decision  not to  make  any assumptions
about their development  at this  time.   Also,   in the  absence of
regulatory  actions,  improved charcoal  could  be used  to reduce
the  volume  of  current  canisters,   thus  still  requiring  an
increase due to certification fuel and test procedure changes.

     The  increase  in designed  canister  capacity  required  to
meet a new RVP standard is shown in Table  3-3.   For an 11.5 RVP
certification  fuel,  this   would be  a  45-percent  increase  in
carbon corresponding to: 580  ml  for LDVs,  760 ml  for LDTs  and
1800  ml for  HDVs.    To estimate  this  for LDVs  and LDTs,  an
average  industry-wide canister  size  was  determined   from  1985
certification records by  assuming  an equal  sales  distribution
between  evaporative  families  for  a  given  manufacturer   and
averaging  corporate-average  canister  sizes  by  projected  1990
sales for  each  corporation.   Only  dominant manufacturers  were
included:  General  Motors, Ford, Chrysler, Toyota, and  Nissan.
For HDVs, an average canister size of 4000 ml  is used, as it is
expected that General  Motors will use  two canisters totaling
4000  ml  of charcoal  on  all of  its  HDVs. [7]   Details of  these
calculations are shown in Appendix 3-A.

     It  was  assumed  that  all   canisters  would  have  to  be
proportionally  increased  in size to  accommodate the  increased
emissions.     Many   manufacturers   presently   use   identical
canisters on  vehicles with differing  fuel tank sizes and  fuel
metering systems.   The  result is that many  vehicles  currently
have oversized  canisters.   Presumably,  it  is  more  economically
advantageous  to  overdesign  some  systems  than  to manufacture
more  than  a  few   different-sizes   of   canisters.   With   the
increasing  use  of   fuel injection,  though, there  may  be  more

-------
                              3-11
                           Table 3-2

          Canister  Equivalents With Extruded Charcoal
Canister

Ford
Chrysler
GM
Toyota**
Nissan**
           Present
           Carbon
            Type

        Calgon BPL-3
        Westvaco WV-A
        Westvaco WV-A
        Calgon BPL-3
        Calgon BPL-3



Mesh
Size
6 x 14
14 x 35
10 x 25
6 X 14
6 x 14
Ratio of
Increased
Working
Capacity
to Present
Working
Capacity
1.54
1.17
1.24
1.54
1.54
Equivalent
  RVP
Control*

 11.65
  9.85
 10.20
 11.65
 11.65
**
From Curve 3 of Figure 3-2.
Estimated on the basis of charcoal type.

-------
Vehicle Class


LDV
LOT
HDV
                                                Table 3-3


                                    Average Canister Volume Increase*
Certification
9.5
ml
129
169
400

%
10
10
10
10.0
ml
245
321
760

%
19
19
19

ml
361
473
1120
Fuel RVP (psi)
10.5
%
28
28
28

ml
477
625
1480
11.0
%
37
37
37

ml
581
761
1800
11.5
%
45
45
45
     From curves 1 and 3 of Figure 3-2,
                                                                                                              u>
                                                                                                              i
                                                                                                              M
                                                                                                              10

-------
                              3-13


incentive  to manufacture  additional  smaller  canisters  because
of the  lower emissions  of fuel-injected vehicles.  Thus,  it  is
possible  that  the  actual  average  canister  volume  increase
required will be less than has been determined here.

     It  is  also  possible  that some  vehicle  redesign  may  be
required  to  physically  accommodate  a  larger canister.   Most
canisters are presently installed  in  or adjacent to  the engine
compartment.   It   is  assumed  that there  should be  sufficient
space to  accommodate the larger canister,  though it may  not  be
as simple  as replacing  the existing canister.  As was indicated
earlier, switching to an  improved  charcoal  is a possibility and
this   could  be   used   to  mitigate   particularly   difficult
installations.  Thus,  no  cost will  be  allocated  for  vehicle
redesign in  section III of this chapter.

     2.    Purge Capacity

     Along  with  an increase   in  storage  capacity,  a  similar
increase   in  the   ability   to   purge   (e.g.,    desorb)   the
hydrocarbons  from  the  canister will  be required to  handle the
more volatile fuel.  In addition, purge  air  may need to  be
increased to address the change in certification test procedure
to begin  with a saturated  canister.   This  additional  increase
is   likely  for   carbureted   vehicles,  since  their   current
problem-free  emissions  on 9-psi RVP  fuel  are  above  the 2-gram
standard  (see  Appendix  2-B).    However,   it  should  not  be
necessary  for  fuel-injected   vehicles,  since  their  analogous
emissions are below the 2-gram standard.

     Increasing the  amount of  purge  can be accomplished either
by increasing  the  duration of  the purge or by  increasing the
rate  of  purge.    The  duration  of purge  can  be  increased  by
reducing  the time  during engine  operation  when purge does not
occur  in  current  systems.  Currently, the  first  2-3  minutes  of
engine  operation   and/or during  minor  deceleration  are  times
during  which many systems shut  off  the  purge.   The  rate  of
purge,   on  the other hand,  can be  increased by  increasing the
size of  the controlling  orifice,  thus allowing more  air to  be
drawn through the canister in a given amount of time.

     The primary concerns that arise  with an  increase  in purge
center  upon  vehicle performance.   Increasing  the purge  will
have  an  effect  upon   the  engine's   fuel-air  ratio  (absent
feedback  control),  which  in  turn  may have an  effect  upon
exhaust  emissions   and  engine  performance.    There exists  the
potential  for  increased  HC  and  CO  exhaust  emissions,  and
negative   effects    upon   driveability  from  rich   misfire.

-------
                              3-14


     These concerns have been raised by  engine  manufacturers as
they relate to  the desired improvements  in evaporative emission
control,  and  also as they relate to the  control of  refueling
emissions.[8,9]   What  little testing  has been  done  addressing
these  concerns,  however,  has  tended  to  indicate  that  these
problems are not major and can be overcome fairly easily.

     In  1978,  the American Petroleum  Institute (API)  performed
a  series of  tests  on  a  carbureted  closed-loop 1978  Pontiac
Sunbird,  modified  to  support   a refueling  emissions  onboard
control  system.  Though the  amount of  HC purged  over an  FTP
increased  by  65-86   percent,   no  significant   increase   in
engine-out or  post-catalyst emissions occurred,  except in  the
extreme  case  where  77-91  grams of HC were  purged in  a  single
FTP.  [10]  This is  well above  that needed  for  evaporative HC
control  even  at  11.5-psi   RVP   (i.e.,  35-45 grams  (see  Table
2-B-6 in  Appendix 2-B)).   API's test results are  summarized in
Table 3-4.   Driveability  was evaluated  in both  cold-start  and
hot-start tests and  was deemed  excellent in both cases for  the
modified vehicle.[10]

     Recently,  API  performed  a  series  of  FTP  exhaust  and
evaporative emission tests on a  multi-point  fuel-injected 1985
Buick  Century  with a  9.0-psi   RVP  fuel  and  an 11.7-psi  RVP
fuel. [II]  The results  of  the  API  testing show only  slight
increases in  exhaust emissions  because of the higher volatility
of  the  test  fuel.   The comparison  of  results  is made   for  a
vehicle with  a 400-ml  carbon canister on  the 9.0-psi  RVP  fuel,
and  the  same  vehicle  with  an  8-1  onboard  refueling  carbon
canister  on  the  11.7-psi  RVP  fuel.   The amount of HC  purged
during  the exhaust test portion on the enlarged canister  was
between  20-50  grams more than on  the  small  canister,  even
though  the purge  rate was  not  changed.   The  HC  emissions
increased from  0.14  to 0.21 g/mi,  the CO  emissions  increased
from  1.81  to  2.30 g/mi, and the NOx  emissions  increased from
0.32  to  0.38  g/mi.   However,  these  increases  may  not  be
statistically  significant   because   of   the  limited  number  of
tests performed on each fuel.

     General  Motors  has done some  testing  on  a 1981 4.3L V8
engine  to determine the effects on exhaust  emissions from an
increase  in  the  purge  rate. [12]   Only when  the  purge  was
increased to  its  maximum level   (i.e.,  no  restricting  orifice),
and  then  primarily when there  was  no delay  before  purge  began
(i.e.,  purge  during cold  operation when feedback  system  is
inoperative),   was  there  a  significant  increase  in  exhaust
emissions to  the  point where  current  standards  could not  be
met.  (It is  assumed that  no delay  indicates that  for  a period
of time just after ignition the  engine operated in an open-loop
fashion.)  GM's test are   summarized in  Table 3-5.  There  is no
indication as to  the effect  that the  increased  purge  rate  had
upon driveability.

-------
                                                  Table  3-4

                                  Effect  of  Purge on Exhaust Emissions  [10]
test No. Canister
Canister HC
Loading, g*
	 Production 50
Canister
1
2
3
4
5
6
7
8
9
10
11
12
4
4
5
5
5
5
6
6
6
6
6
6
160
160
160
150
160
160
160
160
160
160
160
0
Purge
Orifice, in,
0.100
0.180
0.180
0.125
0.125
0.125
0.125
0.100
0.100
0.090
0.090
0.110
0.110
HC
Delay Purged, g
-
3 min.
3 min.
3 min.
3 min.
No
No
30 sec.
30 sec.
No
No
No
No
26
77
91
41
56
67
74
23
18
22
19
25.9
1.0
Exhaust Emissions, g/mi
HC
CO
NOx
0.39+0.03 6.41+0.91 0.98+0.07
0.53
0.49
0.35
0.38
0.41
0.42
0.33
0.41
0.36
0.35
0.39
0.37
6.24
6.43
4.95
5.45
6.28
7.34
5.88
6.85
6.02
5.63
5.91
6.35
0.98
0.84
1.09
0.99
0.96
0.93
0.93
1.01
1.04
0.99
1.01 V
1.03 Ł
*    Refueling system canister.
**   Average Emission Test Results

NOTE:  Tests  1-6  used a purge valve  drilled  out to the orifice
size specified.  Tests 7-12 used a purge valve  drilled to 0.180
in. with the specified orifice in-line.

-------
                              3-16
                            Table  3-5
             General Motors' Study of the Effect of
      Canister  Purge Rate  on Emissions  -  1981  4.3L  V8  [12]*
                       Exhaust (g/mi)
Production
Max.  Purge
No Delay
Max.  Purge
0.020
Constant Purge
Orifice

0.040
Constant Purge
Orifice

0.050
Constant Purge
Orifice
0.060
Constant Purge
Orifice
0.070
Constant Purge
Orifice
 HC

0.40
0.41
0.36

0.66
0.63
0.53

0.39
0.38
0.44
0.44
0.37
0.40
0.38
0.38
0.35
0.45
0.43
0.40
0.40
0.37
 CO

2.1
2.5
2.2

8.1
8.1
5.9

3.5
4.7
3.4

2.1
2.0
2.5
0.33   2.0
2.2
1.9
1.77
2.25
  98
  05
0.97
1.01
1
1
0.40
0.37
0.36
0.38
0.34
0.35
1.18
1.53
1.65
1.40
0.67
1.96
        NOx

        0.78
        0.78
        0.79

        0.66
        0.69
        0.73

        0.74
        0.71
        0.72

        0.76
        0.76
        0.73

        0.78
        0.78
        0.77
          Evap. HC (q/test)
        DIU     HS     Total
0.81
0.88
0.87
0.90
0.87
0.91

0.93
0.88
0.89
0.91
0.86
0.89
4.62
3.53
1.97

0.59
0.65
0.52

0.97
0.86
0.76

2.04
2.31
2.00

2.30
2.82
2.57

2.54
2.03
2.14
0.98
2.27

0.79
1.62
1.42
2.45
1.05
0.47
0.86
0.82
0.89

0.72
0.73
0.67

0.76
0.81
0.76

0.93
0.85
0.79

0.87
0.81
0.87

0.86
0.86
0.78
0.94
0.88

0.69
0.88
0.68
0.89
0.77
0.83
1.36
1.36
0.88
1.91
1.08
1.30
0.82
0.89
0.87
0.77
0.78
0.92
                        5.48
                        4.35
                        2.86
                        1
                        1
                        1

                        1
                        1
                        1
 ,32
 ,38
  18

 ,73
 ,66
 .52
                        1.97
                        3.16
                        2.79
3.17
3.63
3.44

3.40
2.89
2.92
1.91
5.15

1.48
2.50
2.11
3.34
1.82
1.30

2.18
2.26
1.76
2.69
1.87
2.22
     Prior  to  a 30-min.  road prep  (round-trip  between Pontiac
     and  Lake  Orion,  Michigan),  the vehicle  received  a  new
     carburetor, ECM, EGR, distributor, canister and converter.

-------
                              3-17
     Thus,   it   would  appear  that   the  problems   posed   by
increasing  the  purge  rate  can be  solved without  significant
effects  upon vehicle  performance.   Closed-loop fuel  metering
control  is  expected to be  present in 99  percent of light-duty
vehicles  sold   in  model  years  1987  and  beyond.[13]   Also,
naturally cleaner  fuel-injected engines  are projected  to make
up 89 percent  of the light-duty gas vehicle and the light-duty
gas truck market by model year 1990.[14]  The presence of these
two technologies will  require that only small changes  and some
additional  system  calibration  need  be  made  to eliminate  any
measurable effects of increased purge upon vehicle performance.

     Little  information  is  currently available  on  evaporative
ECSs  for heavy-duty  gas  vehicles as  they are  just  now being
introduced.   The systems used,  however,  are  quite  similar  to
those   used   in  light-duty   vehicles,   with   the  necessary
modifications in size.  Thus, it is  probable  that the increased
purge requirement  can be met with fairly simple refinements to
the control system.

III.  Costs


     This  section  will  describe  the  method by which  EPA  has
estimated  the   costs  associated   with   the  improvements   in
evaporative  control  technology discussed previously.   Only  the
initial price  increase to the consumer will be  developed here.
Operating  costs,   such   as  the   weight-related  fuel  economy
penalty and the credit due  to  recovered  evaporative losses,  are
discussed  in  Appendix   6-B  and   Section  VI  of  Chapter  4,
respectively.

     The costs of  control are  developed  as they pass  from  the
vendor to the  vehicle manufacturer to the dealer and ultimately
to the consumer.   The ultimate cost  to the  consumer is referred
to as  the Retail  Price  Equivalent (RPE),  and will include  all
of the increases seen along the way.   It  is this price increase
which may potentially affect vehicle  sales,  which  is addressed
at the end  of  this section.  All  prices  are presented  in 1984
dollars,  with  adjustments  from  other   years   based  upon  the
Bureau of Labor Statistics new consumer price index.*
*    The 1984 new  car  CPI  was estimated as 4 percent.  This has
     now  been  determined   by BLS  to  be  2.9  percent.   This
     difference  is  not expected  to  significantly  alter  the
     conclusions of this analysis.

-------
                              3-18
     A.    Vendor Level

     In this  particular  case,  "vendor"  refers  to the  canister
manufacturer, which may  actually be  the vehicle manufacturer in
some  cases.   The  need  to  build  a  larger  canister  and  make
adjustments  to  the purge  system  will  lead  to certain  cost
increases.   These   costs  can  be  divided  into:   1)  a  larger
amount of  carbon,  2)  larger canister  components,  3)  retooling,
and  4)  the  recalibration of  the  evaporative  control  system.
The  vendor  will  also  include  overhead (20 percent)  and  profit
(20  percent)  in the  price that  is passed  on  to the  vehicle
manufacturer.[15]

     As  the  canister  size  increases,  the  amount  of  carbon
required will  increase with  the volume of  the  canister.   The
increase  required  for  a given   certification  fuel  RVP  was
developed in  the previous section and was summarized  in Table
3-3.  The  carbon cost used is a vehicle-sales  weighted average
of  the  cost of  the  various  types  of  carbon  currently used  by
vehicle manufacturers.   Table  3-6  shows  the  calculated costs
for  the  increased  carbon  for  each  certification  fuel  RVP.
These  costs  include the  vendor  overhead  and  profit  mentioned
previously.   The details of these cost calculations,  except for
the  markups  for  overhead and profit,  are  given in Appendix 3-A
at the end of this chapter.

     The canister components  are assumed to increase  in size in
proportion to  the  increase in the  total  area  of the canister.
Therefore,  they  are treated  separately from  the carbon.   The
prices  for  the  relevant  components:   the body,  the  grid,  the
filters, the  caps,  and the  connectors have been taken  from  a
1983  draft  report entitled,  "Manufacturing Costs  and  Retail
Price  Equivalent   of   Onboard  Vapor  Recovery  System   for
Gasoline-Filling  Vapors," prepared  by  LeRoy  Lindgren  under
contract to the  American  Petroleum  Institute.*[16]  This  report
has  been  reviewed  in  a previous document,  and  the  costs  have
been  modified slightly  to correct  for  some arithmetic  errors
and  discrepancies  in markups for overhead and  profit.[17]   The
calculations   to  determine   the   increased   cost   for   each
certification  fuel  RVP  are  detailed  in Appendix 3-A, and the
results are presented  in Table  3-6.   These include  labor costs
and  markups for  vendor overhead and profit.  The latter were not
included in the cost calculations  in Appendix 3-A.
     This report  has since been updated  as  the "Revised Report
     of API/LHI Cost  Estimate  of  Onboard Vapor  Recovery System
     and  Review  of  EPA Technical  Report EPA-AA-SDSB-84-01  on
     Feasibility,  Cost, and Cost Effectiveness  of  Onboard Vapor
     Control,"  September  28,   1984.   The costs  cited  here have
     not  changed  significantly,  so this  analysis  has not been
     altered.

-------
                                   3-19
                                Table  3-6

             Vendor  Cost, Manufacturer  Costs and Retail Price
                     Equivalent Increases (1984 Dollars)
Vehicle Class
LDV Vendor Level Costs:
Carbon*
Canister*
Tooling
ECU
Total Vendor Level Costs
Manufacturer Level Costs:
RD&T
Certification
Total Manuf. Level Cost
Manuf. Overhead/Profit**
Total Dealer Cost
Dealer Profit***
Retail Price Equivalent
LOT Vendor Level Costs:
Carbon*
Canister*
Tooling
ECU
Total Vendor Level Costs
Manufacturer Level Costs:
RD&T
Certification
Total Manuf. Level Cost
Manuf. Overhead/Profit**
Total Dealer Cost
Dealer Profit***
Retail Price Equivalent
HDV Vendor Level Costs:
Carbon*
Canister*
Tooling
ECU
Total Vendor Level Costs
Manufacturer Level Costs:
RD&T
Certification
Total Manuf. Level Cost
Manuf. Overhead/Profit**
Total Dealer Cost
Dealer Profit***
Retail Price Equivalent
Certification
9.5
.20
.15
.08
.07
.50
.07
.60
1.17
.28
1.45
.05
1.50
.27
.16
.08
.07
.58
.13
.76
1.47
.35
1.82
.06
1.88
.34
.28
.08
.07
.77
.32
1.09
.26
1.35
.05
1.40
10.0
.40
.20
.08
.07
.75
.09
.60
1.44
.35
1.79
.05
1.84
.55
.25
.08
.07
.95
.16
.76
1.87
.45
2.32
.07
2.39
.69
.45
.08
.07
1.29
.38
1.67
.40
2.07
.07
2.14
10.5
.59
.27
.08
.07
1.01
.10
.60
1.71
.41
2.12
.07
2.19
.83
.33
.08
.07
1.31
.18
.76
2.25
.54
2.79
.09
2.88
1.03
.60
.08
.07
1.78
.45
2.23
.54
2.77
.08
2.85
Fuel RVP
11.0
.79
.32
.08
.07
1.26
.12
.60
1.98
.48
2.46
.07
2.53
1.10
.40
.08
.07
1.65
.20
.76
2.61
.63
3.24
.10
3.34
1.39
.73
.08
.07
2.27
.52
2.79
.67
3.46
.09
3.57
11.5
.99
.38
.08
.07
1.52
.13
.60
2.25
.54
2.79
.09
2.88
1.38
.46
.08
.07
1.99
.23
.76
2.98
.72
3.70
.10
3.80
1.71
.84
.08
.07
2.70
.58
3.28
.79
4.07
.13
4.20
*    Prices include 40 percent vendor mark-up for overhead and profit.
**   A mark-up of 24 percent was used for corporate overhead and profit.
***  A mark-up of 3 percent was used for dealer profit.

-------
                              3-20


     Retooling  costs  will   also  be  incurred  by the  canister
manufacturer.  Total tooling costs are  specified  by  Lindgreh as
$0.16  per   canister.[16]    Complete   retooling  will   not  be
required, though,  since current  canister  sizes  will  still  be
appropriate  for  many  vehicles.   Thus,  it  is  assumed  that the
tooling cost  associated with an increase in canister size  will
be  approximately half  of  this cost,  or  $0.08  per  canister.
This  is  also  summarized  in  Table  3-6.   For  an 11.5-psi  RVP
certification fuel,  the total  per-vehicle component  cost to the
vehicle  manufacturer  is  $1.52  for  LDVs,  $1.99  for  LDTs  and
$2.70 for HDVs.

     As  it  was previously determined  that  increasing the purge
rate would  only require recalibration  of existing   systems,  no
new hardware  need be  costed out.   However, a  $.07  per-vehicle
cost  is  allocated to  modify existing  electronic  control  units
(ECUs).   This cost  is the  same  as that assumed necessary  to
modify existing ECUs to  accommodate  an  onboard refueling vapor
control system.[18]

     The  sum  of  the  above costs  represent  the total  vendor
level  costs,   which  are   then  passed  on   to  the   vehicle
manufacturer.  However, where the canister  manufacturer is the
same as  the  vehicle  manufacturer,  as it  is  in  many  cases here,
this is primarily a  transfer cost.

     B.    Manufacturers Level

     The  vehicle  manufacturer  must  purchase  (or transfer) the
canister and  control technology at  the vendor  level  cost rate.
The manufacturer will  also  face research, development,  testing,
and certification  costs  associated with the  implementation  of
the improved  technology.  There are  also corporate  overhead and
profit that  are  incorporated into the  price that is passed  on
to the dealer.

     Research, development,  and testing  costs  will  be  incurred
by  the  manufacturer  to  recalibrate  the  fuel  metering  and
emission control systems.  As  it  was determined that this would
require no additional  hardware (the only hardware  modification
—  the  ECU  —  being addressed  previously), this cost  will
include only design modification and testing costs.

     Estimates for these costs  are  difficult to  determine.   It
will  be   assumed  here that, on  average,  for  an 11.5-psi  RVP
certification  fuel   standard,  25 vehicle  tests,  2  months  of
technician time  and  1 month of engineering will be sufficient
to  recalibrate  each  engine-evaporative  family  combination.
Testing  costs  for  LDVs and  LDTs were  obtained  from  earlier EPA
work on light-duty certification costs.[19]  For  HDVs,  the  cost
used  here was that  determined  in  the  previous  HDE rulemaking
which  instituted  HDV  evaporative  HC  controls.[20]    It  is
further  assumed  that this cost  is  proportional to  the control
required.  A vehicle  acquisition  cost,  held  constant   for  all
levels of  control,  is also included.[17]  This  methodology  is
detailed more in Appendix 3-A.

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                              3-21


     The  research,   development  and  testing  costs (RD&T)  are
summarized  in Table  3-6.   These  have  been  amortized over  5
years at  10 percent  to  reflect the spreading out of payments by
the manufacturer.  For an 11.5-psi RVP  certification fuel,  this
yields  $.13/vehicle  for  LDVs,  $.23/vehicle   for  LDTs   and
$.58/vehicle for HDVs.

     Manufacturers  of   LDVs   and LDTs  will  incur  a  cost  to
certify  their   fleets  with  a   new  certification  fuel.    No
recertification  cost will  be incurred by  HDV  manufacturers,
because no  formal evaporative testing  is  required  by  EPA  (the
development    testing     previously    discussed     should    be
sufficient).  The LDV/LDT costs  were obtained from the EPA work
previously cited.[17]  Because year to year  carryover  of engine
families  is  not  100  percent, only  90 percent  of  the LDV/LDT
recertification  costs  would be  attributable to  this  change.
Amortization  over   5   years  at   10  percent  results  in  a
$.60/vehicle LDV and $.76/vehicle LDT cost  impact  (see Appendix
3-A for details).

     Before passing on  the  cost  to  the  dealer,   the vehicle
manufacturer  will  add  markups  for   corporate  overhead   and
profit.  These were  determined to  be 10 percent and 14 percent,
respectively,   in  an  earlier  EPA  cost  analysis.[21]   These
markups are applied  to  the  sum of the total vendor  level costs,
the  research  and  development  costs,   and  the  certification
costs.  This value is shown in Table 3-6.

     The total cost  at  the  manufacturer level, then, is the sum
of the hardware,  development,  certification,  and  markup costs.
It is  assumed that  no  significant  retooling will be required at
the assembly level — only at the canister manufacturing level.

     C.    Dealer Level

     The total increase in  cost  seen by the  dealer  is  shown in
Table  3-6.  The dealer  is expected to make  a reasonable profit
from the sale of a vehicle.   Therefore, a markup which recovers
incremental  costs  and yields  a  fair  return  on  incremental
investment must be included in the total cost.   This markup was
determined to  be 3 percent  in the same EPA cost  analysis  used
to determine  corporate overhead and profit.  [15]  The dealer
markups in each situation are shown in Table 3-6.

     D.    Consumer Level  (Retail Price Equivalent)

     The bottom  line of Table 3-6 shows the increase in initial
cost  expected  to be seen by the consumer.   The  resulting RPE
increase   associated  with   a  change  to   an   11.5-psi   RVP
certification fuel is $2.88/vehicle  for LDVs, $3.80/vehicle for
LDTs, and $4.20/vehicle for  HDVs.

-------
                              3-22
     E.    Impact on Vehicle Sales

     The  impact  on vehicle  sales  due  to  the  retail  price
equivalent  increase is determined  by the  price elasticity  of
demand.    For   light-duty   vehicles  and   trucks,   this   is
approximately -1.0  and  for  heavy-duty trucks it is in the range
of -0.9 to  -0.5. [17,22]  For the purposes  of this  analysis,  a
-0.7 price  elasticity  will  be assumed  for HDVs.   This means,
for the HDV  case,  that  a 1-percent  increase in the  RPE should
result in a 0.7-percent decrease in demand.

     Prices   for   light-   and    heavy-duty   vehicles   vary
considerably.   Using  an  average  light-duty  vehicle and  truck
cost  of  $10,000   and   a  heavy-duty  vehicle  cost  range  of
$11,000-57,000  results  in the vehicle demand decrease  shown  in
Table 3-7  for an  11.5  RVP  certification fuel  (2250-2790  LDVs,
940-1110 LDTs and  140-170 HDVs).  With price decreases  of this
small magnitude,  though, the  use  of  this  price/demand impact
model is  questionable.   This price  increase would  probably  be
of  little consequence  in  relation to  annual  price increases
occurring at  the time  of new model year introduction.   In any
event,  the sales impacts estimated by the model are negligible.

IV.  Conclusions

     The improvements required  to increase  storage capacity and
purge  capacity  in  vehicular  ECUs  appear  to  be feasible  with
current  technology.    No  significant  effects   upon   vehicle
performance   other   than  reduced  evaporative   emissions  are
expected from these changes.  The  final  cost to the consumer at
the  time   of   vehicle  purchase    has   been   estimated   as
$2.88/vehicle,  $3.80/vehicle, and $4.20/vehicle  for LDVs,  LDTs,
and HDVs,  respectively,  in the most extreme  case of an ll.5-psi
RVP certification  fuel.  These cost  increases  are not expected
to impact upon vehicle sales to any significant degree.

-------
                         3-23
                       Table  3-7

              Vehicle Demand Impact with
            an 11.5 RVP Certification Fuel
Vehicle
Class
LDV
LDT
HDV
Percent
Price Increase
0.021-0.026
0.032-0.038
0.045-0.053
Percent
Demand Decrease
0.021-0.026
0.032-0.038
0.032-0.037
                                              Number Demand
                                                Decrease*

                                                2254-2791

                                                 938-1114

                                                 145-167
Uses 1990 vehicle sales projections.

-------
                              3-24
                     References (Chapter 3)

     1.    "Basic Concepts  of  Adsorption on Activated  Carbon,"
Activated Carbon Division, Calgon Corporation.

     2.    "Control Characteristics of  Carbon  Beds  for  Gasoline
Vapor Emissions," EPA-600/2-77-057, Michael J. Manos  and Warren
C.  Kelly,  Scott  Environmental  Technology, Inc.  for  EPA,  ORD,
IERL, February 1977.

     3.    "Activated   Carbon   for    Effective    Control    of
Evaporative Losses," Ronald S.  Joyce,  Paul.  D. Langston, George
R.  Stoneburner,  Charles  B.  Stunkarol,  and George S.  Tobias,
Pittsburgh Activated  Carbon Division,  Calgon Corp., SAE Paper
#690086, January 1969.

     4.    Meeting  with  Howard Shrut,   Calgon  Corporation,  July
18, 1984.

     5.    "Combustion  Engine   Economy, Emissions  and  Control
July  18-12,   1985," The  University  of  Michigan,   College  of
Engineering,  Ann Arbor, MI.

     6.    Conversation  with   Bill  Kornegay,  Ph.D.,  Technical
Director, Chemical  Division,  Westvaco  Corporation, November  5,
1984.

     7.    "Characterization of  Fuel/Vapor Handling  Systems  of
Heavy-Duty Gasoline Vehicles  over  10,000 Pounds  GVW,"  Draft
Report,  prepared  by  Jack  Faucett  Associates  for  EPA,  QMS,
Contract No.  68-03-3244, September 27,   1985.

     8.    Comments   of   the   Motor   Vehicle   Manufacturers
Association   of   the  United   States,   Inc.,   on  EPA  Report
450/3/84-012a, "Evaluation of  Air  Pollution  Regulatory Strategy
for Gasoline Marketing  Industry,"  November 8,  1984.  (Available
in Public Docket No. A-84-07.)

     9.    Comments on EPA Report  450/3/84-012a,  "Evaluation of
Air  Pollution   Regulatory   Strategy   for  Gasoline   Marketing
Industry,"  submitted  by  Chrysler  Corporation  to  U.S.  EPA,
November 5, 1984. (Available in Public Docket No.  A-84-07.)

     10.   "Onboard  Control  of  Vehicle  Refueling  Emissions:
Demonstration  of   Feasibility,"   API  Publication  No.   4306,
October 1978.

     11.   "API  Onboard  Refueling Emission   Control  Project,"
work   by   Mobil   Research    and   Development    Corporation,
presentation to EPA-ECTD, August 7, 1985.

-------
                              3-25


                  References  (Chapter  3)  Cont'd

     12.   General  Motors  Submittal   to EPA,  March  11,  1985
(letter from Eric  0.  Stork,  Deputy Assistant Administrator  for
Mobile  Source  Air Pollution Control,  EPA,  to Thomas M.  Fisher,
General Motors, dated September 3, 1976).

     13.   "Emission   Control   Technology   and  Strategy   for
Light-Duty  Vehicles  1982-1990.   Final  Report,"  prepared  by
Energy and Environmental Analysis, Inc.

     14.   "Automotive  Technological  Projections Based  on  USA
Energy  Conservation Policies," Dana  Jones  and  LeRoy Lindgren,
December 17, 1983.

     15.   "Cost   Estimations   for  Emission   Control   Related
Components/Systems    and    Cost    Methodology    Description,"
EPA-460/3-78-002, U.S. EPA, March 1978.

     16.   "Manufacturing  Costs  and Retail  Price Equivalent of
Onboard  Vapor  Recovery System  for  Gasoline  Filling  Vapors,"
LeRoy Lindgren  under  contract to  API,  June 1983.   (Attachment
to  MVMA  Comments,  Reference  8,   available in  Public  Docket
A-84-07.)

     17.   "The  Feasibility,  Cost,  and  Cost  Effectiveness  of
Onboard Vapor  Control," EPA-AA-SDSB-84-01,  Glenn W. Passavant,
U.S. EPA, March 1984.

     18.   "Costs  of  Onboard Vapor Recovery Hardware,"  Mueller
Associates under  sub-contract  to  Jack Faucett  under contract to
EPA, February 14,  1985.

     19.   "Light-Duty  Vehicle  Certification  Cost,"  memo  to
Edmund  J.  Brune,  Director,   Certification  and  Surveillance
Division  from   Daniel  P.  Hardin,   Jr.,  Certification   and
Surveillance Division Staff, U.S.  EPA, March 13, 1975.

     20.   "Regulatory  Analysis  and  Environmental  Impact  of
Final  Emission  Regulations  for  1984  and  Later  Model  Year
Heavy-Duty Engines,"  EPA,  OMSAPC,  December 1979.   (Available in
Public Docket No. OMSAPC-78-4.)

     21.   See for  example the Regulatory  Analysis  and  Summary
and Analysis  of Comments  prepared  in  support of  the light-duty
diesel  particulate regulations for 1982  and  later  model  year
light-duty  diesel  vehicles.    (Both   are  available in  Public
Docket No. OMSAPC78-3.)

     22.   "Regulatory   Support    Document  for    the    Final
Evaporative Emission  Regulation and Test Procedure for 1984 and
Later   Model   Year   Gasoline-Fueled   Heavy-Duty   Vehicles,"
EPA/OAR/OMS,  January  1983.    (Available in Public  Docket  No.
OMSAPC-79-1.)

-------
                              3-26


                          Appendix 3-A

               Detailed Derivation of Evaporative
                       ECS  Component  Costs

     This appendix details  the  calculations used to  derive the
evaporative  emission  control  system  (ECS)  costs discussed  in
Chapter  3.   The  first section will describe  how  the  average
canister  sizes  for   current  evaporative  control systems  were
determined.  This will be  followed by sections  discussing:   1)
canister material  costs,   2) research,  development  and testing
costs, and   3)  certification costs associated with  the changes
in the certification test procedure.

Average Canister Sizes in Current Vehicles

     The  average  canister  sizes  for  current  vehicles  were
calculated  by  using  a sales-weighted average  of the  canister
sizes  currently in  use.   Only the  major manufacturers  — GM,
Ford,  Chrysler,  Toyota,  and Nissan  — were considered  in this
calculation.

     Table   3-A-l   shows   the  canister   sizes   used  by  each
.manufacturer for various engine families.   Table 3-A-2 combines
these  values into a  single value for  light-duty vehicles and
light-duty  trucks  for each  manufacturer,  assuming  egual  sales
per engine  family.   Using  the  forecasted 1990 normalized market
share  shown in Table  3-A-3 for  these  five  manufacturers,  a
sales-weighted  average canister size  for  each  vehicle class is
determined.   These  industry-wide  average  canister   sizes   are
summarized  in  Table  3-A-4.  As   indicated  in  the   table,  the
average  canister  size for  heavy-duty  gas  vehicles  is  taken as
the current size for  GM  vehicles, as GM  dominates  this market
(i.e., two-thirds of sales).

Canister Material Costs

     This section details the methodology  used  to determine the
costs  associated  with  improving  canister  working  capacity.
These costs will be  determined  for each  potential certification
fuel RVP.
                                                   /
     Table  3-A-5  shows the canister material costs  to vendors
taken  from  a draft  report prepared for API by  LeRoy Lindgren.*
The  costs  presented  are  for an  850  ml GM canister,  which is
smaller  than the average  canister sizes  for  current  LDV,  LDT
and HDV classes shown  in Table 3-A-4.
*Reference 16  in  Chapter  3.   A final version  of  the report has
since become available, but  the changes were not significant so
the calculations were not redone.

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                         3-27





                     Table 3-A-l



                Canister Distribution

Manufacturer
GM
GM
GM
GM
Ford
Ford
Ford
Chrysler
Chrysler
Chrysler
Toyota
Toyota
Toyota
Toyota
Nissan
Nissan

Canister Size (ml)
1500
2500
2500 + 300
2500 -1- 1500
925
1400
1400 + 1400
1320
1790
1320 -1- 1320
835
845
1400
1400 + 645
580
1230
Number of
LDV*
29
—
—
—
7
3
1
4
3
—
2
1
1
—
6
2
Families
LDT*
2
5
1
0
8
7
—
1
6
4
1
—
1
1
3

1983 Model Year

-------
                              3-28
                           Table  3-A-2

              Average Canister  Size by Manufacturer
Vehicle Class

     LDV
     LDV
     LDV
     LDV
     LDV

     LDT
     LDT
     LDT
     LDT
     LDT
Manufacturer

  GM
  Ford
  Chrysler
  Toyota
  Nissan

  GM
  Ford
  Chrysler
  Toyota
  Nissan
 Avg. Canister Size
for 9.0 RVP Fuel (ml)*

        1500
        1225
        1521
         979
         743

        2288
        1147
        2059
        1427
         580
     Average of  1983 MY  canisters  assuming equal sales of evap.
     families.

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                               3-29


                           Table 3-A-3

                  Market Shares by Manufacturer

                             1983  Normalized*   1990 Normalized**
Vehicle Class  Manufacturer  Market Share (%)   Market Share (%)

     LDV         GM               45.74               46.81
     LDV         Ford             17.78               18.20
     LDV         Chrysler          9.56                9.78
     LDV         Toyota           13.89               13.00
     LDV         Nissan           13.03               12.21

     LDT         GM               41.98               40.86
     LOT         Ford             34.76               33.84
     LDT         Chrysler         10.12                9.85
     LDT         Toyota            7.29                8.57
     LDT         Nissan            5.85                6.88
 *   Normalized on the basis of 100 percent of  the  domestic  LDV
     and LDT market is shared  by  GM,  Ford and Chrysler,  and 100
     percent of the  imported LDV  and LDT market  is shared  by
     Toyota and Nissan.

**   Normalized as for 1983.   Manufacturers'  shares of  domestic
     or imported market is  assumed to be the same  as for  1983,
     but  the  ratio  of  imported to  domestic  registrations
     changed in accordance  with projections  made  in Reference
     13 of Chapter 3.

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                   3-30


               Table 3-A-4

   Industry-wide Average Canister Size*

                       Avg.  Canister Size
Vehicle Class         for 9.0 RVP Fuel (ml)

     LDV                      1292
     LDT                      1688
     HDG                      4000**
 *    Uses 1989 Market Shares.
**    Average canister size used by GM.

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                              3-31


                           Table  3-A-5

           Canister Material Cost to Vendor  (Dollars)*

 Component                           Weight           Material
Description          Material        (Ibs.)          Costs ($)**

Body                  DB437            .30
Grid                  G7               .10
Int. Filter           AY332            .10
Ext. Filter           KZI-4            .20
Charcoal              54448            .50
Cap                   DB437            .10
Connectors            DB437            .05

TOTAL                                                   1.22
 *   Taken from Reference 16 of Chapter 3.
 **  Material  costs are  those  for  an  850-ml  GM  canister  and
     were converted to 1984 dollars from 1983 dollars.

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                              3-32
     Table  3-A-6  shows  these  material  costs  after  they  have
been scaled up to the  average  canister sizes  for LDV,  LDT and
HDV families.  The charcoal  costs, were increased  in  proportion
to  the  increase  in  volume of the  canisters.  The body,  grid,
filter  and  cap   costs  were  increased  in  proportion  to  the
increase in surface  area  of  the  canister.   (For cylinders which
have the  same length-to-diameter  ratio,  the ratio  of  surface
areas  is   equal   to  the  ratio  of  volumes   to the  two-thirds
power.)   The connector cost is independent of the  canister size
and therefore remains constant.

     The charcoal costs  per  unit volume  were calculated  on  a
1990 vehicle sales-weighted basis  (See Table  3-A-3).   GM and
Chrysler use wood-based  charcoals  (price  =  $l/lb,  density  =
.26-.30  g/ml)  whereas  Ford,  Nissan,  and  Toyota use  coal-based
charcoals  (price  =  $2/lb.,  density =  .37-.38 g/ml).   Tables
3-A-7,   3-A-8,  and  3-A-9  contain the  canister  material  cost
increases to meet a  higher RVP certification  fuel for  LDV, LDT
and  HDV  classes,   respectively.    The  increases   in  volume
required .for each higher RVP certification  fuel are  listed in
Table 3-3 of Chapter  3 and the increases in surface area can be
determined  from   the  volume  ratios   (as  stated earlier).   The
increases in costs  were  calculated  by  exactly the same method
as was  used to scale  up the 850-ml GM canister to the average
canister sizes for each class of vehicle.


Research,  Development and Testing Costs

     Table   3-A-10   contains   a  summary   of  the   research,
development   and   testing   (RD&T)   costs  for  a  change  in
certification fuel to  an  RVP of  11.5 psi.   The various costs of
RD&T per  engine  family are broken  down  in  Table  3-A-10  and
costs  for  each  component  were  estimated  using  engineering
judgment.   The total  cost was calculated using the total number
of engine  families  from  1984 certification  records.   The total
cost was amortized at 10 percent for  five years and this amount
was  used  to determine  the  cost  per vehicle based upon 1989
sales projections.

     To  obtain the costs for a change in  the  certification fuel
to  an  RVP  between   9.0   psi   and  11.5   psi,  the  vehicle
modification  costs  were  held  constant  and  the  salary  and
testing costs were  varied  linearly.   The RD&T  costs  for the
different  certification  fuels  are  listed  in  Table  3-6  of
Chapter  3.

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                              3-33
                           Table  3-A-6

   Baseline* Canister Material Costs to Vendor (1984 Dollars)
 Component
Description

Body
Grid
Int. Filter
Ext. Filter
Charcoal**
Cap
Connectors

TOTAL
                  LDV

                 .33
                 .05
                 .13
                 .28
                1.39
                 .11
                 .04

                2.33
                            Vehicle Class
  LPT

 .39
 .06
 .16
 .33
1.92
 .13
 .04

3.03
  HDV

 .70
 .11
 .28
 .59
2.40
 .22
 .04

4.34
**
Baseline  refers  to  the  average  canister  sizes  for  9.0
RVP fuel shown in Table 3-A-4.
Charcoal cost  is  the 1990  sales-weighted average cost of
the  different  types  of  charcoals  (in  1984  dollars).
Wood-based  charcoal  ($l/lb) is  used by GM  and Chrysler
and coal-based charcoal ($2/lb)  is used by Ford,  Nissan,
and Toyota.
NOTE:  Body, filter, grid, and cap  costs  increase in proportion
       to  the  surface  area  and  charcoal  cost  increases  in
       proportion to  the volume.   (Canister  length-to-diameter
       ratio is assumed  to  remain constant.)   Connector cost is
       independent  of  the  canister volume,  thus  there  is  no
       increase in  material cost  to the vendor  for connectors
       for larger canisters.

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                                 3-34


                             Table 3-A-7

  LDV  Canister Material Cost  Increase at Vendor Level*  (1984 Dollars)

 Component      	Certification Fuel RVP (psi)
Description

Body
Grid
Int. Filter
Ext. Filter
Charcoal
Cap	

TOTAL              .20       .41       .59       .78       .99
     Does not  include  40-percent  vendor mark-up for  overhead
     and profit.
9






.5
.02
.00
.01
.02
.14
.01
10.0
.04
.01
.02
.04
.28
.01
10.5
.06
.01
.03
.05
.42
.02
11.0
.08
.01
.03
.07
.56
.03
11.5
.10
.02
.04
.09
.71
.03

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                                 3-35


                             Table 3-A-8

  LPT  Canister Material Cost  Increase at Vendor Level*  (1984 Dollars)

 Component      	Certification Fuel RVP (psi)
Description

Body
Grid
Int. Filter
Ext. Filter
Charcoal
Cap	

TOTAL              .26       .53       .80      1.06      1.31
9.5
.03
.00
.01
.02
.19
.01
10.0
.05
.01
.02
.04
.39
.02
10.5
.08
.01
.03
.06
.59
.03
11.0
.10
.01
.04
.08
.79
.03
11.5
.12
.02
.05
.10
.98
.04
     Does  not  include  40-percent vendor  mark-up  for  overhead
     and profit.

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                                 3-36


                             Table 3-A-9

  HDV Canister Material Cost  Increase at Vendor Level*  (1984 Dollars)

 Component      	Certification Fuel RVP (psi)
Description

Body
Grid
Int. Filter
Ext. Filter
Charcoal
Cap	

TOTAL              .37       .74      1.10      1.48      1.82
9.5
.05
.01
.02
.04
.24
.01
10.0
.09
.01
.04
.08
.49
.03
10.5
.14
.02
.05
.11
.74
.04
11.0
.18
.03
.07
.15
.99
.06
11.5
.22
.03
.09
.19
1.22
.07
     Does not  include  40-percent  vendor  mark-up for  overhead
     and profit.

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                               3-37
                           Table 3-A-10

      Research, Development and Testing (RD&T) Costs Summary
      	(1984 Dollars)	


LDV/LDT:   ($/family)

    Vehicle Modification                              16,000l
    Engineer Salary (1 mo. @ $50K/yr)                  4,170*
    Technician Salary (2 mo. @ $35K/yr)                2,9202
    25 Tests (@ $610/test)1                           15,250
                                                      38,340

HDV: ($/family)

    Vehicle Modification                              20,0002
    Engineer Salary (1 mo. @ $50K/yr)                  4,1702
    Technician Salary (2 mo. @ $35K/yr)                2,9202
    25 Tests (@ $2000/test)J                          50,000
                                                      77,090
                           LDT            LDT           HDV
Cost/Family                $38,340        $38,340     $77,090

Number of Families         1374            814          11*

Total Cost              $5,252,580     $3,105,540    $847,990

5 years @ 10%           $1,385,629/yr    $819,24l/yr $223,700/yr

1989 Sales              11,000,000s    3,640,000s     386,000*

RD&T Cost/Vehicle ($)     0.13           0.23          0.58
1    Inflation-adjusted  values   from  EPA   memo,   "Light-Duty
     Vehicle Certification  Cost," from Daniel  P.  Hardin, March
     13, 1975.   [Reference 19 of Chapter 3.]
2    Estimated.  ;
3    "Regulatory Impact  Analysis, Oxides of  Nitrogen Pollutant
     Specific Study and  Summary  and Analysis of Comments," EPA,
     March 1985.
4    EPA's  "Control  of  Air  Pollution  from New Motor  Vehicles
     and New Motor Vehicle  Engines;  Federal  Certification Test
     Results for 1984 Model Year."
5    Based  on  DRI "trendlong"  projections  from the Fall 1984
     Lonq-Term Review, Data Resources Inc., 1984.

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                              3-38


Certification Costs

     Table 3-A-ll contains a  summary  of the certification costs
associated  with  a  new  certification  fuel.    The  costs  per
vehicle  tested  are  summarized  for  both  emissions  data  and
durability vehicles.   The  total costs  are  based on  the  number
of LDVs and  LDTs  certified in 1984.   However,  only those engine
families  which are  carried  over  from  the previous year  are
relevant,   since   those   which   are  recertified   anew   would
experience   certification   costs   with  or   without   a   new
certification  fuel.   Carryover is estimated  to be  90  percent;
therefore, the total  cost was reduced to  90  percent  of  its
original value.   The reduced total was  amortized  at 10  percent
for five years  and  this amount was used to determine the cost
per vehicle  based upon 1989  sales  projections.  It should be
noted   that   formal   certification   testing  for   evaporative
emissions  is   not   required   for   HDVs.   Thus,  there  is  no
certification   cost  associated  with  a  change  in  the  HDV
certification fuel.

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                              3-39


                          Table 3-A-ll

           Certification Costs Summary (1984 Dollars)


Emission Data Vehicle Costs:1 ($/Vehicle Tested)

    Vehicle Modification                               16,000
    Mileage and Maintenance                            10,400
      (<§ $2.60/mile, 4000 miles)
    Testing Cost                                        1,220
      (2 Tests/Vehicle, $610/test)                    	
                                                       27,620

Durability Vehicle Costs:1 ($/Vehicle Tested)

    Vehicle Modification                               16,000
    Mileage and Maintenance                           154,500
      (<§ $3.09/mile, 50,000 miles)
    Testing Cost                                        7,930
      (13 Tests/Vehicle, $6lO/test)                   	
                                                      178,430

Total Vehicles Tested and Costs: ($)
                                         LDV              LDT
Emission Data (307 LDV, 133 LDT)2      8,479,340       3,673,460
Durability (109 LDV, 45 LDT)2         19,448,870       8,029,350

Total Cost                            27,928,210      11,702,810

90% Carryover                        $25,135,389     $10,532,529

5 yrs. <§ 10%                          $6,631,200      $2,779,000

1989 Sales3                           11,000,000       3,640,000

Certification Cost/Vehicle ($)          0.60             0.76
     Inflation-adjusted  values   from   EPA  memo,  "Light  Duty
     Vehicle Certification Cost,"  from Daniel  P.  Hardin,  March
     13, 1975.  [Reference 19 of Chapter 3.]
     EPA's  "Control  of  Air  Pollution  from New  Motor  Vehicles
     and New  Motor Vehicle Engines;  Federal Certification Test
     Results for 1984 Model Year."
     Based  on DRI  "trendlong"  projections  from the Fall  1984
     Lonq-Term Review, Data Resources Inc., 1984.

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                            CHAPTER  4

          Technological Feasibility and Cost of In-Use
          	Gasoline Volatility Control	


I.    Introduction

     As described in Chapter 2, one of the  two possible methods
of  eliminating  the  current evaporative  emission  excess  is  to
control  the  volatility  of  commercial gasoline.   Estimates  of
refinery  costs  and  fuel  economy benefits  of reducing in-use
gasoline  volatility  are  presented  in  this  chapter.    As  also
described in  Chapter 2,  the  two  fuel parameters  most relevant
to  evaporative  emissions are RVP and %ieo.   In-use  control  of
both  of  these  parameters  is being  considered.   However,  the
great majority of the refinery modelling  performed thus far has
focused  on the  control  of RVP, as the effect  of  this parameter
on  evaporative  emissions is  most  well known.   Studies  of  the
cost  of  controlling   %t6o  are   still   underway,  though  the
results available to date are presented in Section III.C below.

     This chapter begins  with a  general   discussion  of gasoline
volatility and  the  types of  HC  compounds which most affect  it
(Section  II).   The  next  section  (Section  III)  presents  a
general  description  of  the main  source  of  information for  the
cost of  in-use  gasoline RVP  control  and  %iso control,  a study
conducted by  Bonner and  Moore Management Science for EPA.[1]
This  study  uses their  proprietary Refinery  and  Petrochemical
Modeling  System  (RPMS),  which  is  a linear  programming  (LP)
computer model.   This section also  presents the results of  the
Bonner and Moore study,  primarily the refinery cost  of reducing
gasoline  RVP  one to two psi below ASTM limits  under various
situations,  but  also includes the  cost  of  reducing  %iso to  25
or 30 percent.   Section IV examines  the  effect of  RVP control
(and  the likely butane excess generated by  it)  on  the wider
butane market.  Section V examines the effect  of RVP control  on
the  energy  content  of  gasoline  and estimates   the  resultant
effect  on vehicular  fuel  economy.   Section  VI  examines  the
additional  economic  benefit  of   recovering  or   preventing
evaporative   emissions   (via   both  fuel-  and  vehicle-related
controls)  from  both  vehicles  and  the  distribution  system.
Section  VII combines the results  of  the previous  sections  to
evaluate  the   overall  cost  of  volatility  control  of  in-use
gasoline.

II.  Refinery Control of Gasoline Volatility

     Oil  refineries  currently  refine   crude oil   to  supply
several  petroleum products, one of which is gasoline for motor
vehicle  consumption.  The volatility of  the  gasoline produced

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                              4-2

depends on the properties  of  the crude oil and the  natural  gas
liquids  (NGLs),   which include  butanes  and  natural  gasoline,
used  in  the  refining  process  and  on  the  actual  refining
processes  themselves.   There   are  ASTM  specifications   for
gasoline volatility  characteristics which  serve as  guidelines
for  the  refineries to  follow.   These ASTM gasoline volatility
specifications  and   in-use   volatility  trends  were  already
described in Chapter 2, Section IV.

     As  already  mentioned,   RVP  and  %iso   are  the  two  most
important gasoline volatility properties affecting  evaporative
HC emissions.  The major HC compounds contributing  to high RVP
are n-butane and  iso-butane,  although  n-pentane  and  iso-pentane
also  affect  RVP.   The RVP blending  values  for  these parafins
are given in  Table 4-1.  Generally,  the easiest way  to  reduce
gasoline RVP  is  to reduce the blending  of  straight  butane into
gasoline.   The  next  easiest  approach  is  to  remove  butane
presently contained   in  other gasoline  stocks.   This requires
modification  of  existing  separation  facilities   and/or  the
installation of new facilities to  remove contained butanes.   In
addition,  butane  can  be  converted,  via  processes  such  as
alkylation,   in  higher  boiling  compounds.  As  a further  step,
extreme  RVP   limits   could   require   removal  of  some   Cs
components which,  in most cases,  would  require  new separation
facilities.   The  approach that  is  actually used depends  on  the
economics involved, which are complex and highly interactive.

     Both butanes and  pentanes strongly affect  %iSo,  but  so
do   many  other   gasoline   components,   and   the   specific
relationship  between  each  of   these components  and %iso  is
beyond the scope  of  this  study.   Suffice  it to  say that  the
more  short-chain  hydrocarbons (with four to  five carbon  atoms)
in gasoline,  the higher the RVP and %i6o-

     Butane has a high-octane quality.   Thus, RVP control which
reduced  the  use  of  butane  would  also  require  additional
refinery processing to  compensate  for  the octane quality which
the butane would otherwise provide.

     The use of alcohols  in  gasoline complicates matters, since
both  methanol  and   ethanol  affect   RVP  as  well   as   other
volatility parameters  and  octane.   Their  RVP  blending  values
are  also  shown  in Table  4-1.   Adding 5%/2.5%  methanol/TBA to
11.0-psi  RVP gasoline  increases RVP by 2.2 psi.    Adding  10
percent ethanol to 11.0-psi RVP  gasoline increases RVP by 0.40
psi.   Thus,  their addition to gasoline  must be  accompanied .by
an even greater reduction in  butane/pentane content,  though the
alcohols' high-octane compensates   for  that  of  butane in  this
case.

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                              4-3


                           Table 4-1

    Blending Values for Selected Hydrocarbons and Alcohols*

Hydrocarbons                         RVP Blending Value (psi)

n-Pentane                                       15.6
Iso-Pentane                                     20.4
n-Butane                                        65
Iso-Butane                                      92.8

Alcohols

                             10%   2.5% Methanol  5% Methanol
     Property             Ethanol  2.5% T-butanol 2.5% T-butanol

Reid Vapor Pressure, psia   15.0        54.0           40.0

Percent Distilled at -
        160°F               220        115            175
        210°F               137        110            105
        230°F               108        100            100
        330°F               100        100            100

Research Octane             133.6      120.7          124.7

Motor Octane                101.8       96.5           97.3

(R+M)/2                     117.6      108.6          111.0
     The  contribution   to  the  finished   fuel   parameter  is
     determined by multiplying  the  blending value by the volume
     percent of  the  compound  in the  fuel.   The  net  effect of
     adding a  compound  is  the  volume  percent of  the compound
     times  the difference  between  the blending  value  of  the
     compound and that for the compound being replaced.

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                              4-4

III. The Bonner and Moore Study

     Bonner and  Moore Management Science  conducted a  study  on
the  refinery  cost  impact  of  vapor  pressure  control  under  a
number of subcontracts with Southwest  Research  Institute (SwRI)
and  Jack   Faucett   Associates  (JFA)  as   contracted   by  the
Environmental  Protection Agency.  The  results  of the study are
contained  in  a  fully documented  final  report by Bonner  and
Moore  entitled  Estimated  Refinery   Cost   Impact   of   Reduced
Gasoline Vapor  Pressure.[1]   The general  methodology and major
assumptions of Bonner  and Moore's  study are presented  below  in
Section  III.A.    The  results  of  the  study are  presented  in
Sections III.B and III.e.  The reader  is referred to the Bonner
and Moore report  for  more  specific  details of the refinery cost
study.   No  attempt  is made  here to  explain the  B&M  study  in
detail  because  of  its complexity and the availability  of the
final  report,  which  is  an  independent  document  that  fully
details the study and results.

     A  draft  of this  study (dated March  1,  1985)  was  sent  to
the  American   Petroleum  Institute  (API),  the  Motor   Vehicle
Manufacturers   Association  (MVMA),  and   the   Motor Equipment
Manufacturers  Association  (MEMA) for  peer  review.   A  copy  of
this draft  and  all  comments received are contained in  Docket
A-85-21 in  the  West Tower  Lobby at EPA  Headquarters,  401  "M"
Street, S.W.,  Washington, D.C.,  20460, where they can be viewed
or  copied  (for  a  reasonable fee)  during  working  hours.   The
comments received from  these organizations  were  addressed  to
the fullest extent possible in the final report  (dated  July 10,
1985).   However,  some of  the comments  could not  be  addressed
without  further  modelling  and  most  of  the   ongoing    work
described below is intended to address such comments.

     A.    Bonner & Moore's Refinery  and  Petrochemical  Modeling
           System

     EPA contracted  Bonner  and Moore  to  use their  proprietary
linearly  programming   (LP)   computer  model,   designated  the
Refinery and Petrochemical Modelling System (RPMS),  to  estimate
the refinery  costs  of reducing  RVP  and %iso.   One and two-psi
RVP reductions below the maximum specified  ASTM(D439) RVP and 5
and  10 percent  reductions in  maximum allowed  %iso (from the
35 percent allowed  in  the  base  case)  were  analyzed  for  each  of
three  geographic  gasoline-refinery   regions   referred  to  as
Petroleum Administration for Defense Districts  (PADDS I,  II and
III).    It  was  assumed that the other two districts,  PADDs  IV
and V   (excluding  California),   could  be   approximated  by  the
average of  PADDs II  and III.   California  gasoline consumption
(roughly 11 percent  of the national  consumption)  was  excluded
since  California already restricts  gasoline RVP  to 9.0  psi.

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                               4-5

The national  average costs for RVP reduction  were estimated by
consumption weighting the PADD-specific costs  obtained from the
RPMS.    The   costs   of  controlling  the   volatility  of  both
alcohol-free  gasoline  and  methanol  and  ethanol  blends  were
examined.    Volatility controls  were applied  uniformly  to  all
three grades  of  gasoline;  unleaded  regular,  unleaded premium,
and leaded  regular.   The volume fractions  of  national gasoline
production contributed  by  each of  the grades were  65  percent
unleaded  regular,  18 percent  unleaded  premium, and  17  percent
leaded regular.  Leaded gasoline is allowed  to contain only 0.1
gram  per  leaded gallon  of  lead,  so the  effects  of  EPA's  lead
phasedown program are fully factored in.

     There are also  some additional  assumptions that  had to be
made  in  modelling   the  alcohol-fuel blends.   First,  gasoline
production was set  at the same level  used  in the alcohol-free
cases.    No   fuel   economy   changes   that   might   apply   to
alcohol-containing fuels were  taken  into  account.   Furthermore,
100  percent  of  each  grade  of   gasoline,  unleaded  premium,
unleaded regular and leaded regular, was assumed to contain the
specified   concentration  of  alcohol.    While   this  is   not
realistic,  it  was  the most  convenient  way  to include alcohols
in the  RPMS  and  the results appear to  be  reasonable.   (As  will
be  discussed  below, this  same  approach  was  used  to  model
ethanol   blends   and the  results  were clearly  unreasonable).
Also,  a lower  RVP case  study of 3 psi  below the baseline vapor
pressure  was  evaluated  for  the methanol  blend because  of  the
possibility  that commingling  of  the  blend  with  alcohol-free
gasoline  would  increase RVP beyond that  of either  fuel  due to
the azeotropic  behavior  of  alcohol  and  hydrocarbon mixtures
(discussed further  in Section IV.C. of Chapter 2).   The 1-psi
further reduction  in vapor  pressure  would tend  to  partially
offset  any  increase in vapor  pressure  due  to such commingling
effects,  resulting  in•evaporative emissions egual  to  those  for
alcohol-free fuels.

     The  estimated  costs   in  all  cases   for each   PADD  were
developed  by  the   RPMS  using  a  single  "super  refinery"  to
represent all  of the refining capabilities  of that PADD (i.e.,
the average  refinery).   This  super  refinery  was required  to
produce all  of the  gasoline projected to be produced  by  all of
the individual refineries in  that PADD  in the  timeframe  of  the
study, which was 1990.   Individual  refineries  would be expected
to experience costs  both above and  below that  estimated  by  the
RPMS,  but on average,  the  actual  costs should be  close  to  that
projected  by  the   model.    The   complexities  involved  with
modeling   individual   refineries    make   such   an   approach
economically infeasible and make the use of  a  single  refinery a
necessary limitation of this study.

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                              4-6

     The gasoline  costs  estimated by  the  RPMS are,  by design,
incremental in  nature and do not attempt to  represent the full
cost  of  refining  gasoline.   This avoids  a  number of  complex
issues  associated  with  valuing  capital equipment already  in
place.  As the  desired output  is  the effect of RVP on refining
costs,  a  difference between  an  uncontrolled  and  controlled
scenario, this is fully satisfactory for this study.

     To accomplish  this,  a base 1990  case  is run  to  determine
optimal process requirements and  refinery costs  associated with
producing   the   1990  product   slate,   considering   process
capacities  known  to  be  available   in 1984,  and,  thus,  not
requiring capital investment.  The controlled case  is  run in an
analogous  fashion   (i.e.,   a  fresh   optimization  from  1984
capacities),    only  with   a  lower   RVP   or   %iso   product.
Conceptually,   this  approach assumes  that  investment  occurring
between now and 1990 in the uncontrolled case can  be redirected
toward more  productive use,  if  economically desirable,  in the
controlled case.  This may or may not be the  case,  depending on
the   timing   of   any  volatility   controls,   and   is   being
investigated   more   fully   via   further   modelling  runs.[2]
However,   information that  is available on  some  of  the  past
model runs shows  that very  little  of the  investment  occurring
in  the  base  case  does  not  also  occur   in  the  controlled
case.[2]    Thus,  little  redirection  of  1984-1990  investment
appears to be  occurring  and the effect of  allowing this  in the
modelling runs appears to be small.

     For  those readers investigating such details,  it  should be
noted  that  the  RPMS  runs tend to  project  sizable  capital
investments between  1984  and  1990   for  the  base cases  even
though the refinery industry as  a  whole is  expected  to  invest
little for gasoline capacity aside  from environmental  control
(i.e.,  lead   phasedown).[3]   This  occurs  because   the  current
capacity of many peripheral processes  (e.g.,  cooling towers)  is
not  known  and  was  presumed to  be zero  in 1984  for  modelling
purposes.  Thus,  the  required 1990  base  capacity for  these
processes  is  considered to  be  entirely incremental,  though  in
all  likelihood, the vast  majority of  it is currently  in  place.
These sizable  capital investments have no  direct  effect  on the
estimated  RVP   control   costs,   nor   the   estimated  capital
investment   required  for  RVP   control,    since   these   are
incremental costs  involving  the subtraction of base case costs
from  the controlled case  costs,  both  of  which contain these
costs.   It simply means  that the  capital  investment  shown for
either the base or controlled cases cannot be used to estimate
the  total capital  investment  required  by the refining industry
between  1984  and  1990.   However, as  the current  capacities  of
some  of  these  peripheral  processes  may  be  in  excess of  that
needed in  1990, the model may be overestimating  the additional

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                               4-7

capacity needed  for RVP control.  The degree  to  which this may
be occurring is unknown.and is not easily estimated.

     Present RPMS runs  also  assume that all  capital investment
is  amortized  over  year-round  production.   This  is appropriate
in the base case,  since most of this  equipment is  of  the kind
that   is   used  year   round.    However,   equipment  purchased
expressly  for  RVP  control  might  only  be  used  during  the
specified RVP control  season.   As  discussed in Chapter 2, ozone
violations are prevalent in the  summer  months, so  RVP control
might  only be required  during  part  of the year.   For purposes
of  this  analysis,  a  4-month  summer  control  period  (i.e.,
June-September) was  chosen.   However, a summer period of 3,  5,
or  6  months  could  also  have been examined.   This  RVP control
equipment may  also  be useful during  the non-summer period, but
to what  degree is  not  known.   Additional work is  underway  to
estimate  the  non-summer  benefit.[2]   Thus,   the   current  RVP
control  costs   may   underestimate   the   impact    of   capital
investment  on a  per-gallon  basis  for  a summer-only control
strategy.

     In the extreme case that the  capital  investment associated
with  RVP  control has  no value outside of  the control  period
(i.e., the effect of capital on the cost of gasoline per gallon
was 3  times higher,  based on a 4-month summer  period) and this
caused the  model to  avoid  all incremental capital investment
(i.e., opt  for operating  modifications),  the RVP  control  cost
would be no  greater than  that  estimated under a  no-investment
scenario.   This scenario was modelled primarily to simulate the
situation where the leadtime granted  to  refiners prior  to RVP
controls was  insufficient  to design and build  new capital, but
it applies as well  to  the extreme situation in which  the model
itself  avoids  all  incremental  capital  investment  because
capital investment  associated  with  RVP  control   has   no  value
outside of the  RVP control  period.   While in  theory  the cases
were to be strictly no new investment, this stipulation  had  to
be  relaxed  in  practice,   again  due to  the  unknown  current
capacities  of many peripheral processes.   It  did  not  seem
reasonable to  limit such  capacities  to  those required  in the
base  case, because  historic gasoline  production  has  been  much
higher  than   projected  1990  levels  and  much excess  capacity
could exist.  At  the same time,  the degree of this  excess  is
unknown.   Thus, the no-investment costs may  be underestimated,
since the benefit  of some capital  investment may  be  included.
The extent to which this is  true is  not  known and is not easily
estimated.   Thus,   these costs represent  the  best  estimates
available under such conditions.

     Another  important aspect of modelling refinery RVP control
is  the treatment   of  natural  gas  liquid  (primarily  butane)
supply  and   demand.    Currently  the  butane  market  varies
dramatically  between  summer  and  winter.   With  gasoline  RVP
levels 2  psi  higher  in the winter  (corresponding  to  a  butane
composition increase of  4  percent by  volume),  butane  supplies
tend  to be short  and prices  high.   In the summer,  the opposite
is true.   With RVP  control,  even more butane  will  be  available

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                              4-8

in  the  summer   and   prices   could  decrease   further.    This
potential   price   decrease  is   dependent   on   the   entire
butane/petrochemical market and not  just on  petroleum refinery
operations.    Thus,  a  model  such  as  RPMS,  which  only  models
petroleum refining,  cannot project  the price  drop.    In  fact,
the price of  butane must  be  input to  the  model.   However,  two
types of situations were  modelled  using RPMS  to  simulate  the
effect of the potential price drop.

     The first situation assumed that  butane could be purchased
or not purchased  at its  current  price, which varies  with  PADD,
depending  on  its  economic  usefulness.    This  situation  is
referred  to  as  the  "open"  N6L  purchase  scenario.   Butane
availability  was  limited  to that  purchased  by refineries  in
recent  times.   The second  situation   forced the  refinery  to
purchase all  of  the  available  butane  at  the  current  summer
price.   This   situation  is  referred  to  as  the  "fixed"  NGL
purchase scenario.  The first situation was intended to place a
lower limit  on RVP control  costs by allowing  refineries to sell
any excess  butane  generated  by RVP  control at  current  market
prices.   In reality, lower butane  prices would  probably  occur,
thereby  reducing  the  profitability   of doing  this  and  also
increasing the  cost of RVP  control.   The  second situation  was
designed  to  place  an upper  limit  on  RVP control costs  by
requiring the refinery segment of  the  butane market  to use  all
of  the  excess  butane at  current market  prices.  In reality,
prices  would   drop  and  other  segments  at  the  market  would
utilize at  least  part  of  the butane excess  and  result in  lower
RVP control  costs.

     Practically,  there are a number of  potential problems even
with  this bracketing  analysis.   One,  when  the RPMS was used to
model the first  situation, refineries  could not actually sell
butane generated  within  the plant at the  current market  price.
They  could  only avoid purchases.  Thus,  RVP control  costs  are
not as  low  as they might  have been.    Two, butane  availability
was  limited to  historical  refinery  purchases.    This  is  not
necessarily consistent with  the conclusion of  Section  IV  in
Chapter 2,  where it  was  concluded that  RVP nationwide  could
increase by  1990  to ASTM  limits.  This  conclusion  implies that
butane usage would increase by 1990 without RVP  controls.   Lead
phasedown  may  actually cause  this  additional  butane  to  be
produced within the refinery.   However,  if it  does  not,   more
butane could be purchased,  as butane  supplies were exhausted in
many  of the  base  scenarios.   This  would  lower   the  cost  of
producing  gasoline  in   the  uncontrolled  cases   and,   thus,
increase the cost of RVP control.   The effect of both of  these
potential  problems   is   now  being   analyzed   via  additional
modelling runs.[2]  In addition,  analysis  of the impact of  RVP
control  on  the   entire  butane  market  was performed.[4]   Its

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                               4-9

results are  described in Section IV, below,  and are being used
in  the additional  modelling  runs  to  more  accurately  model
butane price effects.

     Until   more  detailed   information   is   available   from
additional RPMS  cases currently being  evaluated,  the  midpoint
between  costs   under  the   "fixed"   and  "open"  NGL  purchase
scenarios   will   be  used  for the  cost  of  RVP  control.   This
decision is  subject  to change based on new  data  on the effect
of RVP control on butane  value,  but is the best estimate  based
on data currently available.

     The final aspect of the RPMS deserving  discussion here is
the way the  model simulates  ASTM gasoline  specifications.   RVP
levels for  the  uncontrolled RVP base  case were set at maximum
ASTM D-439 RVP specifications.  PADD average maximum RVPs  were
estimated   by  volumetrically  weighting the  RVPs  of  all  the
gasoline produced by refineries in a particular  PADD.   National
average maximum  RVPs  were estimated  by volumetrically weighting
the PADD-specific RVPs  by the  volume  of  gasoline  produced in
each PADD.   RVP  of PADDs  4  and 5 was assumed to be the average
of the  RVPs for PADDs 2 and 3.   The  PADD-specif ic   RVPs  and
national  RVPs  are  presented  in  Table  4-2.   The  volumetric
production  weighting  factors  are  presented   in  Table  4-3.
Current (1984)   national  average  gasoline RVP,  as  determined
from the MVMA  fuels   survey,  is 10.89  psi,  which is  near  the
maximum ASTM RVP  specification of  11.27  psi.    It is assumed
that,  by 1990, the national  average  RVP will equal  the maximum
ASTM  RVP   specification.    This  was  discussed   in  detail  in
Chapter 2,  Section IV.

     Besides RVP, ASTM addresses  fuel volatility  by specifying
minimum and  maximum  temperatures  at which specified  fractions
of the  fuel  are evaporated via  distillation  (i.e.,  T10  and
Tso)    as    discussed   in   Chapter   2,   Section  IV.    Such
specifications do not lend  themselves  to   linear  programming
since temperatures at which  certain  fuel volumes  are evaporated
cannot be  easily manipulated when  two  fuel streams  are merged.
It is much easier to  work in the reverse mode,  the percent fuel
evaporated at specific  temperatures  (i.e.,  %iso),  since  these
can be  volumetrically  averaged when  two  streams  are blended
together.   This  is  the  mode  in  which the  RPMS  works.  It  is
possible  to convert  from   one  mode  to  the other,   but  only
approximately.    Thus,  at  the present  time,  it  is not  clear
precisely   how the  RPMS  limits  (other than RVP)  approximate
those of ASTM.   However,  the RPMS requirements specified  by B&M
for  maximum  percent  of   gasoline  evaporated   at   a   given
temperature  appear   to   be  within   the   ASTM   requirements
specifying minimum and  maximum temperatures  corresponding  to a
given percent of gasoline evaporated.   ASTM  D-439 requirements

-------
4-10
Table 4-2
National and PADD-Specific RVPs and %igos
Resulting from Bonner & MDore RPMS Cases
Level of RVP
NGL Purchase Baseline (B)
PADD Scenario
I
I
II
II
III
III
Nat. Avg
Nat. Avg
Open
Fixed
Open
Fixed
Open
Fixed
Open
Fixed
RVP
11.5
11.5
11.46
11.46
11.12
11.12
11.27
11.27
%158
34.978
34.978
33.028
35.0
33.144
33.144
33.27
33.92
Control
B-l psi
RVP
10.5
10.5*
10.46
10.46
10.12
10.12*
10.27
10.27*
*158
33.7
33.778*
.32.487
33.284
30.753
31.184*
31.59
32.11*

B-2
RVP
9.5
9.5
9.46
9.46
9.12
9.12
9.27
9.27

psi
*158
32.1
32.0
31 .808
30.739
28.325
28.28
29.82
29.42
4. V^UA »^-* *^fj  * * * w^.*. K-fS^^lA t, .LV^ri l k^s^> v,r*\_.\^A A \ t-f /  UJ
RVP = midpoint between (B)  and (B-2)
%158 =

-------
                                   4-11

                                Table 4-3

                           Cost of RVP Control
                        ($  per  Barrel  of  Gasoline)


                 	PADD	
     RVP                                   4 + 5         Total U. S.
Reduction, psi      1	2	3	(ex. CA)1      (ex. CA)j.

Alcohol-Free Gasoline
     With Investment, Open Butane Purchases
     10.1840.3650.2110.288           0.259
     2          0.547   0.748    0.501      0.625           0.587

     With Investment, Fixed Butane Purchases

     1          0.1893  0.396    0.2123     0.304           0.271
     2          0.561   0.857    0.504      0.681           0.626
     With Investment, Average of Fixed and Open Butane Purchases

     1          0.186   0.380    0.212      0.296           0.265
     2          0.554   0.802    0.502      0.653           0.606

     No Investment, Fixed Butane Purchases

     1          0.2144  0.5014   0.3004     0.401           0.358
     2          0.641   1.084    0.713      0.899           0.826

     No  Investment,   Estimated Average  of  Fixed  and  Open  Butane
     Purchase

     1          0.211   0.480    0.300      0.390           0.3505
     2          0.6335  1.0145   0.7105     0.8625          0.8005

2.5% MeOH + 2.5% TEA Blend, with Investment, Open Butane Purchases

     1          0.3696  0.4076   0.314      0.360           0.35
     2          0.815   0.898    0.692      0.795           0.77
     3          1.3707  1.5097   1.163      1.336           1.29

5.0% MeOH + 2.5% TEA Blend, with Investment, Open Butane Purchases

     1          0.1958  0.3878   Q.2248     0.298           0.27
     2          0.5818  0.7948   0.532      0.676           0.62

PADD-Specific Fraction of Total Gasoline Volume (%)

                8.83   29.25    53.99       7.93          100.00
Footnotes on following page.

-------
                                4-12

                         Table  4-3  (cont'd)
1    Estimated as average of cost for PADDs 2 and 3.
2    Total  U.S.   (ex.  CA)  costs were  estimated by  volumetrically
     weighting of  PADD-speci f ic  costs  for PADDs 1, 2,  3,  and 4 and
     5   (excluding   California)   using   PADD-specific   gasoline
     production.
3    Actual case  not  run, cost  estimated  from  open butane purchase
     for  1-psi   RVP  reduction  using  the percentage  increase  for
     2-psia reduction costs between open and fixed NGL purchases.
4    Actual case  not run,  cost  estimated from fixed butane purchase
     costs  with  investment  for  1-psi  RVP  reduction  using  the
     percentage  increase  between  2-psia  reduction  costs with  and
     without investment.
5    These  costs  were  estimated from  the No-Investment  costs  for
     fixed butane  purchases  presented  in the previous  row using the
     ratio  of  midpoint  (open-fixed)/2  vs.  fixed  butane purchases
     costs for the cases with investment.
6    Actual case  not run,  cost  estimated by  applying ratio of 1-psi
     reduction cost  to 2-psi reduction  cost for PADD  3  control to
     the 2-psi reduction cost for PADD in question.
7    Actual case  not run,  cost  estimated by  applying ratio of 3-psi
     reduction cost  to 2-psi reduction  cost for PADD  3  control to
     the 2-psi reduction cost for PADD in question.
8    Actual  case  not  run,  cost  estimated  using  the  ratio  of
     corresponding  costs   from   open   butane  purchase  cases  for
     alcohol-free  gasoline  with  investment  applied to PADD  3 cost
     for 5%/2.5% MeOH/TBA from B&M.

-------
                              4-13

for minimum  and maximum  temperatures  corresponding to  a  given
percent of  gasoline evaporated  are not  tight  specifications,
and   current   fuels   are   not   being   restricted  by  these
requirements.

     The point  of major  concern on  the gasoline  distillation
curve  is  the  %iso,  as  discussed  in  Chapter  2,  Section  IV.
Bonner  and  Moore limited the maximum  %iso to  35 percent  for
the RPMS cases  in their  original  study.   This  resulted in the
values of %i*o presented  in Table  4-3,  for the  specific  PADDs
and  for the  volumetric  weighted  national  average.   Current
(1984)  national  average  gasoline  volatility  properties  are
10.89-psi   RVP  and  32.6  %ieo.   These  values  are  those  for
volumetrically  weighting  all   gasoline  grades   (65   percent
unleaded regular,  18 percent unleaded  premium,  and  17  percent
leaded  regular),  but  are also the  same as  those  for  unleaded
regular  gasoline  as  presented  in Table  2—7  of  Chapter  2,
Section  IV.   The   average  %iso   of   current  gasolines   is
approaching 35 percent,  indicating that the B&M restriction of
35  %iso  is not  too  lax.   Therefore,  the  B&M  costs   for  RVP
control with  %1So restricted  to 35  percent  appear  reasonable
from this  point  of view.

     B&M modelled some additional cases to  evaluate the  cost of
further controlling  %J6o/  both independently and in  addition
to RVP control.   The cases evaluated and the results  of  running
these  cases  with the  RPMS  are  presented  in  Section  11 I.e.  of
this chapter.

     B.    Refinery Costs of RVP Control

     The projected costs  of 1-  and 2-psi  RVP reductions  below
the maximum  ASTM-specified  RVP  for various gasoline  types  and
other scenarios  are shown in Table  4-3.   Before  discussing  the
results of  Table  4-3,   it   should  be noted   that  the  %lSo  of
these  fuels  are  indirectly  reduced through  this  RVP  control,
because removing  compounds  which  contribute  to  high RVP  also
lowers  %i6o,  to  a  certain  extent.   The  reductions   in  %iso
associated   with  these  1-   and  2-psi  RVP  reductions   for  the
"open" NGL purchase  scenario are  1.7  percent  and  3.5  percent,
respectively,  as  indicated  by the  national average  levels  for
%ieo  presented  in Table  4-3.    %ieo  is  reduced  1.8  and  4.5%
for the corresponding "fixed" NGL purchase  scenario.

     The cost of controlling the  RVP of alcohol-free  gasoline
is of primary concern,  since it  represents  nearly  89  percent of
all gasoline sold in the  U.S.  (with methanol blends making up 4
percent and ethanol blends  the  other 7  percent of the  nations
gasoline  sales.)    As   can  be   seen  in   Table  4-3,   the
nationwide-average cost of  reducing .RVP by 1  psi  is  0.62-0.95

-------
                              4-14

cents per gallon   ($0.259-0.358  per bbl), while  the cost  of  a
2-psi  reduction  is greater  than two  times  that,  or  1.40-1.97
cents  per  gallon  ($0.587-0.826  per  bbl),   depending  on  how
capital investment and the butane market are  treated.

     The  least expensive  RVP control  scenarios  are those  in
which  the  refineries  have  the  ability  to   invest in  capital
equipment to optimize their  refinery  processes.   This situation
occurs when the  controls  are to  be  in  place long enough  to
justify  the  capital  investment  and  after   refiners  have  had
sufficient  time  to design  and implement  new equipment.   This
definitely  applies to  the  long-term  control  scenario  (i.e.,
2010)  and may apply  to short-term controls if  the above  two
conditions are met.

     In  addition,  two  extreme  scenarios were  evaluated  with
capital investment permitted, one with  "open" NGL  purchases and
one  with  "fixed"  NGL  purchases,  as  described  earlier.   RVP
control for the "open"  NGL  purchase scenario was  slightly less
expensive than for  the  "fixed" case ($0.587  vs.  0.626 $/bbl for
a  2-psi  RVP  reduction,  respectively).    As  also  described
earlier,  the  current  best estimate of  the RVP control  cost is
halfway between these  two values.

     For the no investment situation,  only fixed NGL cases were
modelled.   Open  NGL costs  were  estimated  from the  runs "with
investment"   to    determine   the    best    estimate   midpoint
"no-investment"  cost,  as   shown   in  Table  4-3.   These  "no
investment" costs  may  be appropriate  under   short-term  control
if  refineries  are  not  given sufficient   time  to  invest  in
capital prior  to  control or  if  the  period   of control  is  too
short  to  justify  capital  investment  (generally  thought  to  be
2-4 years).

     Thus,  the "with investment"  costs are  used  to  represent
long-term   control  costs   and   both   "with"   and   "without
investment" costs  are used to  represent the  range  of  potential
short-term  control  costs.   These costs are  used  in determining
the overall costs  of RVP  control   presented  at the  end  of this
chapter and  also  the  cost-effectiveness of  RVP control  ($/ton)
presented in Chapter 6.

     The  cost  of  controlling the  RVP  of  alcohol-blends  follows
the  same  general   PADD-to-PADD trend  as  that for  alcohol-free
gasoline.   Overall, the  cost  of  vapor  pressure  control  is
greater   for   gasoline   containing   the    2.5/2.5    percent
methanol/TBA blend, than  for alcohol-free gasoline.  The  cost
of  a 3-psi reduction for  PADD 3  (the  only  PADD  evaluated)  is
increased 68 percent over that of just  a  2-psi  reduction.  This
increase  may  differ slightly between  PADDs,  but was assumed in
Table 4-2 to be relatively constant.

-------
                              4-15

     The  cost   of  reducing   RVP   for  the   5.0/2.5   percent
methanol/TBA  blend,  in  contrast,  is  less  than  that  for  the
2.5/2.5 percent  methanol/TBA blend  and  is 6-7  percent  greater
than that  for alcohol-free  gasoline,  on  average.  Bonner  and
Moore credits the  smaller  cost  to the non-linear vapor pressure
blending behavior  of  the additional methanol,  as  indicated  by
the  blending values  shown  in  Table 4-1.   The  additional  2.5
percent of  methanol incurs  a  small  additional  vapor  pressure
penalty but  contributes a  larger  octane  benefit.  As  this  is
expected  to  be  more   popular   than   the   2.5/2.5   percent
methanol/TBA blend in the  future,  and its RVP control costs are
so close to  that for alcohol-free  gasoline,  only  the cost  for
alcohol-free gasoline will be used hereafter.

     As indicated  above, attempts were  made to model 10 percent
ethanol  blends,    in  the  same  manner  as   methanol   blends.
However, in  all  cases,  the base  (uncontrolled)  RVP was  already
very near  or below  the  2-psi  reduction  level.   This  was  an
artificial result  of  restricting %18o to  35 percent.   This  is
unrealistic for current ethanol blends,  as  ethanol dramatically
affects %l6o and  current levels of  %iso for  ethanol  blends
at  11.5-psi   RVP  are  around  42  percent.    Thus,  the  forced
lowering of  %iso  likely  forced most of the  butane out  of  the
fuel  and   lowered  RVP  dramatically  prior  to  control.   This
situation  is  being corrected in  additional modelling currently
being  conducted  by B&M.   Results  are  not available  yet,  but
will be incorporated in  the study of  controlling evaporative
emissions  as soon as the RPMS case studies are complete.

     Thus,  little  can presently  be  said   quantitatively  about
the   cost    of   controlling   the   RVP   of    ethanol   blends.
Qualitatively, ethanol  has  a  smaller  RVP effect  and  greater
octane effect than methanol/TBA mixture  (see  Table 4-1).  Thus,
one would expect its presence to  impact RVP control  costs less
than  the  methanol/TBA  mixture  when  %iso  is  not controlled.
This is being further investigated  via  further  RPMS  modelling
runs.[2]  The  economic  impact on the  ethanol  blending industry
of  controlling  the  quality  of   the   finished  blend  (i.e.,
eliminating splash blending  and requiring  coordinated blending)
is  also being investigated.[5]   This is  discussed further  in
Section III.D.

     C.    Refinery Cost of Controlling  the Percent of Gasoline
           Evaporated at 160°F

     The  significance   of  controlling   %iso  has   already  been
discussed  in  detail  in Chapter 2,  Section IV.   In review,  the
representative volatility  measure with  respect to  the  portion
of  hot-soak  emissions occurring  from  the  fuel  metering system
appears  to  be  %i6o,   because   160°F   is  a   typical  maximum

-------
                              4-16

carburetor  bowl  temperature   during   a  hot-soak.    B&M  was
instructed  to evaluate  the  cost of  controlling  %iso  through
running  additional  RPMS  cases  with  restrictions  on %i8o,  as
it may  be valuable to  control  %iso  in  addition  to controlling
RVP.   This  section discusses the RPMS  cases  evaluated by  B&M
and the sensitivity of refinery costs to controlling %i«0.[l]

     Two  sets of cases  have been run  to  date to  evaluate  the
effect  of  controlling %iso  on  refinery costs.   They were  run
for  PADD  2  under  the  fixed  NGL   purchase  scenario.   This
situation was believed  to  result in  the worst-case cost  for
%ieo  control  since it showed the highest RVP  control  cost  and
the greatest  sensitivity to fixing  NGL purchases.  The  first
set of  cases  was  conducted  for  alcohol-free gasoline, while the
second was  run for  5/2.5 percent methanol/TBA blends.   A  third
set of  cases  is  currently being run using the  RPMS to evaluate
refinery cost  of  controlling %iso  at  different  RVPs  for  PADD
3, because  54 percent of national gasoline production occurs in
PADD 3  and these results  will  represent  more  of  a  national
average than  those for  PADD  2.[2]   The results  of running  the
third set of  cases  are not  available at this time,  but will be
incorporated into the analysis as they become available.

     The results  for  the first  two  sets of  cases  are detailed
in B&M's  supplement   to their  earlier  report.[1]   They  are
summarized in the following paragraphs.

     1.     Alcohol-Free Gasoline

     Results  of  evaluating  the  first  set  of  cases  run  to
determine   the   refinery   cost   of   controlling   %iso   of
alcohol-free  gasoline indicate  that  RVP  control  cost decreases
as  %IBO   restrictions  for  the baseline  uncontrolled   RVP
scenario and  for  controlled RVP  scenarios are  limited  below 35
percent.   Results of running  6 cases  were used   to,  evaluate
refinery    control    costs    at   different    RVP    and   %1So
restrictions.   These  6 cases run  for  PADD 2  are  described in
Table 4-4.  The  resulting  costs  and actual RVPs and %ls<>s  are
presented in Table 4-5.

     It  is  difficult  to  separate  the  costs of controlling  RVP
and  %iso,  because  refinery  operations  necessary  for  RVP
control,  as  discussed  in  Section   II,  may  also  result  in
controlling %iso-   The $0.857 per barrel  cost for  a 2-psi  RVP
reduction for PADD 2 under the  fixed NGL purchase scenario also
includes  (unavoidably)  a 4.26  percent decrease  in  %i6<>.   This
is because  controlling gasoline  RVP  involves  removing  butane,
which   affects   %iso.   A   2-psi  reduction   in  RVP   may   be
accomplished  by   an  estimated  4 percent  reduction in  butane
content,  which,   absent  other   changes,  also  reduces  %iso  4
percent because of butane's low boiling point.

-------
                              4-17

                           Table 4-4

                 RVP and %igo Restrictions for
               RPMS Cases Evaluated to Determine
         Refinery Costs of Gasoline Volatility Control


                Max. RVP = 11.46 psi     Max. RVP = 9.46 psi

Max %ieo ~ 35%              x                       x

Max %!6o = 30%              X                       X

Max %160 = 25%              X                       X
X    Indicates that RPMS  case  was run for specified maximum RVP
     and

-------
                            4-18

                         Table 4-5

      PADD 2 Refinery Costs and Actual RVPs and %i60s
     	for  RPMS Cases  Described  in  Table  5-4

All gasoline grades are alcohol-free.
1.  RVP = 11.46           Cost =           2.  RVP =9.46
    %16Q = 35%          $.857/bbl           %i6Q = 30.74


Cost = $0.485/bbl                      Cost = $0.045/bbl
3.  RVP = 10.53           Cost =           4.  RVP = 9.46
         = 30%          $.417/bbl           %160 = 30%
Cost = $.841/bbl                       Cost = $.500/bbl
5.  RVP =9.86            Cost =           6.  RVP =9.11
    %160 = 25%          $.075/bbl

-------
                              4-19

     Controlling RVP  2 psi  below the  ASTM maximum for  PADD 2
with %ieo restricted  to 30  percent,  is  less costly than  at 35
percent, partially  because the  30  percent  restriction  for  the
uncontrolled RVP  scenario limits  RVP  to  10.53  psi.   This  is
nearly  l  psi  below  the  11.46-psi maximum ASTM  specified  RVP
level.   Therefore  this $0.417/bbl  cost of controlling RVP to
9.46 psi does not assess  the cost of controlling RVP 2 psi,  but
rather  only assesses  the cost  of  controlling  RVP  1.07  psi.
Likewise the  cost of  controlling  RVP to  2 psi below the ASTM
maximum  specified  RVP   level   with   %iso  restricted   to   25
percent  is  only  $.075/bbl,  because  there  is  actually only a
0.75-psi  reduction   in   RVP  due  to   the  25   percent   %i«0
restriction.

     The costs  illustrated  in  the  matrix of  Table  4-5  also
indicate the cost  for controlling  %iso at constant  RVP.   The
costs  are   $0.45/bbl  for  %iso  between  30.74  and  30.0  percent
and  $0.50/bbl  for  %i6o   between 30  and  25 percent,  both  at
9.46-psi RVP.  Other  costs included  in the matrix are costs for
controlling both RVP and %iso simultaneously.

     It is  clear from this  matrix  that  the  refinery  cost of
gasoline volatility  control  is a  function  of  the   level  of
control of  both RVP  and %iso.   The  costs presented  for  RVP
reduction  in the  previous  section  (at %i«0  restricted  to 35
percent) are the most representative RVP control  costs,  but  may
be  reduced  by  as  much  as  a  factor  of  2  if  baseline  %iso
levels were  lower.   MVMA survey data  for   fuels  sampled during
July of  1984  indicates   that  the  average  %is«   (which  can be
used to  approximate  %iso)   for  volatility Class C  gasolines
was  32.6   percent   (discussed  in  Chapter  2,   Section  IV).
Assuming no  change  in future  %iso levels (there  is  currently
an upward trend), the RVP control cost  in  PADD  2 may currently
be  overestimated slightly  since  its  %i6o  is  being  reduced
from  -a  greater  value,   35  percent,   to   30.74   percent.   The
sensitivity of  overall costs and cost-effectiveness of gasoline
volatility  control  to   restricting   the   %i6o    are  addressed
further in Chapter 6,  Section III.

     2.    Methanol/T3A Blends

     The second  set  of   cases   evaluated   by  B&M using  their
proprietary  RPMS.  were  run  to  study  the  refinery  cost  of
controlling  %iso   for   gasoline  containing   5/2.5  percent
MeOH/TBA.    These cases   are  the  same  as  those  run  for  the
alcohol-free study  on refinery  cost  of  controlling  %i60,  as
illustrated in Table  4-4.  The  results of  running  these cases
are presented in Table 4-6.   They may be analyzed as were those
of  the  alcohol-free   %i6o  control  study.  These  results  are
summarized below.

-------
                            4-20

                         Table 4-6

      PADD 2 Refinery Costs and Actual RVPs and %igos
     	for RPMS Cases Described in Table 5-4	,

All gasoline grades contain 5/2.5% MeOH/TBA.
1.  RVP = 11.20           Cost =           2.  RVP =9.46
    %160 = 35%          $0.491/bbl          %160 = 35%


Cost = $1.039/bbl                      Cost = $0.620/bbl


3.  RVP =9.89           Cost =           4.  RVP =9.46
    %160 = 30%          $.072/bbl           %160 = 30%


Cost = $1.296/bbl                       Cost = $1.224/bbl
5.  RVP =8.10            Cost =           6.  RVP =8.10
    %160 = 25%          $.000/bbl

-------
                              4-21

     Cost of RVP control  to  9.46 psi  (2  psi below  the maximum
ASTM  specified  RVP  of  11.46  psi)  is  lower  for  low  %iso
restrictions  than   for  high   %1So   restrictions.     This   is
because  actual  RVP  reduction  is  less as  %iso  restriction  is
lowered.  The  cost  differences are  $0.491/bbl  for RVPs  from
11.2  to 9.46 psi  (a  1.74-psi  RVP  reduction)  at a  35 percent
%ieo   restriction,   and  no   cost  at   a   25  percent   %iso
restriction  because  this %ieo  restriction  limits  RVP  to  8.10
psi for even the  uncontrolled RVP  case,  which is already  less
than  9.46  psi.   The  cost  of  a 5  percent  difference  in  %iSo
may be  estimated from  the cost of reducing  %iso  from  35 to  30
percent at RVP equal to 9.46 psi.  This cost is $0.620/bbl.

     The $0.491/bbl  cost  for  RVP control in PADD 2  to  9.46 psi
at  %ieo  restricted   to  35   percent   is  probably   a  slight
underestimation  of    the   cost   of  reducing   %iso   RVP   of
methanol/TBA blends 2 psi, because RVP is only  reduced  1.74 psi
at  constant   %i60.    The  %iso  of  methanol  blends   is,   as
discussed  in Chapter  2,  Section  IV.C.,  higher  than   that  of
alcohol-free gasoline and likely exceeds 35 percent,  on average.

IV.  Effect of  RVP Control on the Butane Market

     The major  method  of RVP  control  is to  remove  butane  from
gasoline, as described in Section II, and to  replace the butane
with heavier components.   The butane that is no  longer used in
gasoline is made available to the market and  this excess supply
could  and  likely  will decrease  the  market price of butane and
economically   impact  suppliers   and  purchases.    While   in
aggregate,   this  economic  impact   should  be  zero  (i.e.,   the
benefits to  purchasers  of cheaper  butane  should equal  the  cost
to  suppliers),   there  may  be  economic  impacts  on  isolated
segments of  the butane market.  Thus,  Jack Faucett  Associates
(JFA) was contracted to evaluate the effect of reducing the RVP
of gasoline  on  butane  prices and  usage.   The results  of  their
study   are   presented  in   a  report   entitled,  "The  Butane
Industry:  An Overview and Analysis  of  the Effects  of  Gasoline
Volatility Control  on  Prices  and Demand".[4]   The   results  of
this study are  summarized below.

     JFA concluded that excess  butane  supply from any  level  of
RVP  reduction   evaluated would be  large  compared  to  actual
butane  demand  as  a fuel  or  a  feedstock  priced  at  $23.08/bbl,
the baseline annual  average national price  of  butane.   Because
of  the  limited  demand  for  butane   as  a  unique   fuel   or
petrochemical feedstock, a small  level  of  RVP reduction results
in enough excess butane to  cause butane prices  to fall to  the
level  of the petrochemical  floor price, estimated to be $20.26
per barrel  in   1990.   Here butane  is  used  in place  of  other
feedstocks   primarily  in the  production  of  acetic  acid  and

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                              4-22

ethylene.   The  demand  for  these  other  feedstocks  is  large
enough that even  extreme reduction of RVP  would not  result  in
providing enough  additional butane to  drive the price below the
petrochemical  floor  price.    JFA  estimates  that,  at  any  price
above  the  $20.26/bbl petrochemical  floor price,  no  more  than
850,000 bbls of butane  per  year could be  absorbed by the  fuel
and petrochemical feedstock sectors of the  butane market.   This
volume is  significantly less  than  the 8.6  million barrels  of
excess butane  estimated to  result from  a  1-psi RVP  reduction
for  a  4-month control  period.    On  the  other  hand,  the  42.9
million  barrels   of  excess  butane  estimated to  result  from  a
2-psi reduction in gasoline RVP over  a  6 month  control  period
would  all   be  used  at  the  petrochemical   floor   price  at
$20.26/bbl.

     These prices  for  butane estimated  by JFA are similar  in
magnitude  to  those  presented  in the B&M  study.[1]   The  raw
material costs for both normal  and iso-butane  for PADD 3  were
estimated  at  $23.30/bbl in  the B&M study.   The PADD 3  prices
are the best choice  for comparison with  JFA's  national  average
price  because  PADD  3  produces  over 50  percent of  the  nations
gasoline.  Under  the "open"  NGL situation,  these prices  were
assumed   to    remain   constant    and   refineries  could   avoid
purchasing butane,  if  desired.   However,  they could not  sell
butane produced  within  the  refinery.   Under  the  "fixed"  NGL
situation, refineries  were  forced to  purchase  all  the  NGLs
projected to be  available at these  same prices,  regardless  of
its value  to the refinery.    It is very useful to compare  the
incremental  refinery   values  for   butane  under  these   two
conditions with  the  petrochemical floor  price  of  $20.26/bbl
determined by JFA.

     The   incremental   refining  values   of  butanes  for  ' all
scenarios, as  estimated by  B&M,  are  presented  in  Table  4-7.
Incremental  refining values  (value  to  refinery of  the  last
barrel used) of  normal  butanes under  the "fixed" NGL purchase
scenario are $21.04/bbl, $16.44/bbl, and  $21.30/bbl  for  a 2-psi
RVP  reduction  for  PADDs  1,  2,  and  3   respectively.    The
incremental  values  of   iso-butane  are   much  higher;  $27.05,
$21.69,  and  $26.86  per barrel  for  PADDs  1-3,  respectively.
Where these  figures  are below  the  $23.30/bbl price of  butane,
this  means that  butane prices would have  to drop  to  these
levels for refineries  to purchase and utilize all  of the  NGLs
projected to  be available.

     As can be seen,  the incremental  values for  iso-butane are
all above  the  floor  price  of $20.26/bbl floor  price  estimated
by JFA.  As  the  sales-weighted  value  is  well above  $23.00/bbl,
iso-butane prices  should not  drop and  no  excess should  reach
the market.

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                                 4-23

                              Table 4-7

            Incremental  Refining  Values  of  Butanes  ($/bbl)

                     PADD-1             PADD-2             PADD-3
                  Open    Fixed**    Open    Fixed**    Open   Fixed**
RVP: Base
  Normal Butane   35.27*  35.24      24.77*  20.98      29.80*  29.80
  Iso-Butane      32.03*  32.05      24.75*  23.30      31.16*  31.16

RVP: -1-psi
  Normal Butane   28.75*    na***    23.20   18.37      26.22*    na
  Iso-Butane      30.51     na       25.83*  23.46      31.14*    na

RVP: -2-psi
  Normal Butane   21.97   21.04      22.39   16.44      23.30   21.30
  Iso-Butane      28.15   27.05      24.89*  21.69      29.04*  26.86
*    Butane purchases limited by maximum availability.
**   Butane purchases required to equal maximum available.
***  na = Case not modelled by Bonner and Moore.

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                              4-24

     The  situation for  n-butane  is  slightly  different.   The
sales-weighted  value  in the  three PADDs  is  very near  the JFA
estimated floor price of $20.26/bbl.  Thus, the market  price of
n-butane  would  likely drop  to  this  level  with  a 2-psi  RVP
reduction.   However,   little  n-butane may actually  switch  to
petrochemicals  since  refineries  can  apparently utilize  all of
the excess  at  this price.   Of  course,  even less  effects would
be seen with a 1-psi RVP reduction.

     In the  "open"  NGL situation,  the incremental butane values
are nearly  always  above  the current market price  of $23.30/bbl
and  purchases  are  often   limited by  projected  availability.
This has  raised  some  concerns that  the  model  may be  valuing
butane-utilizing   processes  too   highly,  since  such  high
incremental values  would argue  for equally high  market  prices.
To  further  investigate this  possibility,  Bonner  and Moore is
evaluating the sensitivity of its model to a number  of  factors,
including base  alkylation capacity (a  butane  consumer)  and 1990
butane  availability.[5]   These  results  will  be  incorporated
into the study as soon as they are available.

V.   Fuel Economy Credit

     This  section  presents  an   analysis of   the  effect  of
reducing  the volatility of gasoline on  fuel  economy.    It  is
hypothesized  that,   if   gasoline  volatility   is  reduced  by
removing butane  from gasoline  and replacing it  with  other fuel
components,   the energy density of the gasoline  will  increase.
Furthermore,  vehicular fuel  economy  should  increase  with  an
increase  in  fuel energy density.   Thus,  there should be a fuel
economy  benefit  resulting  from  reducing  the  volatility  of
in-use gasoline.   As  a result of  the analysis,  it is estimated
that reducing RVP  by  1 and  2 psi  will increase  fuel economy by
0.25  and 0.56  percent for feedback and  non-feedback-eguipped
vehicles.

     The remainder of this  section explains how  these estimated
increases in  fuel economy were determined.  It  is divided into
three parts:   1) the  relationship between gasoline  volatility
and energy  density, 2) the relationship between  energy density
and  fuel economy,  and  3)  the  overall  relationship  between
gasoline volatility and fuel economy.

     A.     Volatility and Energy Density

     Quantifying  the   relationship  between   RVP   and   energy
density  is  difficult  because  of   1)   the   complex  refinery
operations  involved in lowering RVP and maintaining octane and
other  requirements  and  2)  the  relatively  wide  range  of
commercial  fuel  energy contents  occurring at  any  given RVP.

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                              4-25

Relevant  information  from two  different sources  was  available
to derive independent estimates  of  the effect of RVP  on energy
density.  Also,  both  API  and MVMA were  requested  to submit any
relevant  information  they might  have.   The  two  independent
analyses  and  the two  submittals are described  in  the following
paragraphs.    Table  4-8  details  the quantitative  results  from
each for direct comparison.

     The  first  independent analysis used  the output  of Bonner
and Moore's  linear  programming  model,  which is  being  used  to
estimate  the  cost  of  controlling RVP.[1]   In addition to RVP
and  octane,  the  model  generates  estimates  of  other  fuel
properties,    including  API   gravity,    aromatic   content,   and
50-percent distillation temperature, which  can  then be  used  to
estimate fuel energy density  using  a well-accepted relationship
defined in ASTM D3338-74.   There was significant variation from
region  to  region  in  the effect  of  RVP  reduction  on energy
density,  resulting  from  the varying  regional  composition  of
gasoline  at   different   RVPs.    Energy   densities  increased
0.22-0.30 percent  for  a  1-psi  RVP  reduction  and  0.33-0.69
percent  for  a   2-psi  RVP  reduction.    Weighting  the regional
effects  by   gasoline  production volume resulted  in  weighted
energy-density increases of 0.25 percent and 0.56 percent for a
1- and 2-psi RVP reduction, respectively.

     The second  independent analysis  examined MVMA  fuel survey
data from January and July gasoline samples  taken from 1979-83
(these were available on  tape and could be accessed en masse).
The energy content  of each fuel  sample in the surveys was again
estimated   from   the   properties   of   the  fuels  using   the
relationship  from ASTM  D3338-74, as described  above.   A linear
regression  was   then  applied  to relate the RVPs  and  energy
densities  (BTUs/gallon)  for  the  nearly   2,000   summer  fuel
samples and also  for the  4,400  summer and winter  fuel samples.
For the summer gasolines,  a  1-psi  reduction in RVP from 11.5 to
10.5 psi resulted in a 0.25 percent increase  in energy density,
with a  range  of  0.22  to 0.28 percent  at 90 percent  confidence.
For summer and winter fuels  combined,  a 1-psi reduction in RVP
from 11.5  to 10.5  psi  resulted in  a  0.33 percent  increase  in
energy  density,  with  a  range of  0.32  to  0.34 percent at  90
percent  confidence.   The  R  was  only  0.09 for  summer  fuels
and 0.30 for  summer and  winter  fuels  combined,  but due to the
large number  of  samples,  the relationship  is quite  certain,  as
evidenced  by  the  tight   90-percent  confidence  limits.   The
regression  of summer  fuels  is  probably the  most  appropriate
for use here.   The winter fuels  were  included  to  provide  a
wider range of RVPs and to test the sensitivity of  the results
to range of  RVP.

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                              4-26

                           Table  4-8

      Effect of Change  in RVP on  Change  In Energy Density
   Source of Information

1. Bonner & Moore

   PADD 1
   PADD 2
   PADD 3

   Volumetric Wtd. Average

2. MVMA Fuel Sampling Data

   Sxommer Fuels
   Summer & Winter Fuels

3. MVMA Submittal

   Calculated Effect

4. API Submittal
 Percent of Increase in Heat
  Of Combustion (Btu/qal)
RVP 1-psi          RVP 2-psi
     ,30
     22
     ,26

     25
   0.25
   0.33
 .54
 .33
 .69

 .56
0.50
0.66
   0.32               0.64

    No calculated results

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                              4-27

     The MVMA  submittal  in this  area  outlined a  first-order
analysis  of   the  effect  of   reduced  RVP  on   fuel   energy
density. [6]   They stated  that  they were  not aware of any test
data  that  would  provide  a  direct  relationship  between  RVP
reduction through  butane  control  and  vehicle  fuel  economy;
however, they did make  some calculations to estimate the effect
of butane  content  on  energy density.   They too  used  the  the
method  described  in ASTM  D3338-74  to estimate  gasoline energy
content  from  predicted  average  properties  of  the  gasoline.
They  estimated the percent  decrease  in  fuel  butane  content
associated with a 1- and  2-psi  change in RVP to be  1.8  and 3.7
percent, respectively.  Then,  assuming that  the composition of
the non-butane portion  of  the  fuel  would remain  constant,  they
estimated the  change  in the energy density using  the relative
energy  densities  of gasoline,  and while MVMA  did this  using
three baseline gasolines  of various RVP,  their analysis  ignores
the fact that  reduced butane content will reduce  octane.   This
octane  can  be replaced by further  processing of  the gasoline
feed  stocks,  which will  likely reduce  energy  density, or  by
increasing aromatic content, which will  likely  increase energy
density.  MVMA estimated  that  1-psi and  2-psi reductions  would
increase   energy   density  by    0.32    and   0.64   percent,
respectively.   As these figures  are somewhat larger  than  those
estimated using the Bonner and Moore model and  the  regression
of summer fuel  RVPs,  it  appears that  increased processing  to
replace  lost   butane  dominates  somewhat  and reduces  the  net
energy increase by about 0.07 percent per psi RVP.

     API,   in  their   submittal,   stated   that   there  is   no
predictable  relationship  between  gasoline  vapor  pressure  and
gasoline density.[7]  They  state that a number of compositional
changes  occur  in  reducing  RVP   to  ensure  that  the  other
properties  of  the  gasoline   remain   in   accord  with   ASTM
specifications and  that  production  volume  is maintained.   As
evidence,  they  cite the  fact  that  the  scatter  in the energy
densities of  surveyed  fuels at a specified  RVP  is  greater than
the difference  in  energy  density between  RVPs,  and  make  the
determination  that  any  relationship between  RVP  and  energy
density  impossible  to  ascertain.    Therefore,   they  did  not
submit  any  conclusions on  the net  effect  of  all the  factors
affecting energy density accompanying a reduction  in  RVP,  other
than to state that the relationship is unpredictable.

     As  our   own  assessment  of   the  energy   densities   of
MVMA-surveyed fuels  indicated,  there is  a wide  variation  in
energy  density  at  any  given RVP and this variation  is larger
than  the  effect  of  RVP.    However,  the  90  percent  confidence
limits  on the  predicted slope  take this  variation  into  account
and still predict  a range  of only 0.25+0.03  percent per  psi  for
summer  fuel.   Thus,  while  other factors  can overwhelm  the  RVP

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                              4-28

effect for  any given fuel,  on average the RVP  effect is quite
certain and  quantifiable.   The fact  that the Bonner  and Moore
estimates  fall within  this  small  range,  and  yet  were  quite
independent, is further support for their accuracy.

     Given  that  the  analysis  of the survey  data and the  B&M
study  yield essentially  the  same  results,  the  B&M  estimates
will be used here as it is a forward  looking  study of  lower  RVP
fuels  across  the  board  rather  than  backward  looking  survey
results.    The  result  is  that energy density is  projected  to
increase  0.25  percent with a 1-psi  reduction in RVP  and 0.56
percent with a 2-psi reduction.

     B.    Energy Density and Fuel Economy

     Much  data on  the  fuel economy  of  all  types  of  vehicles
exist  in  the  literature.   However,  few  studies  relate  fuel
economy  to  fuel  energy  density.   Thus,  while the effect  of
energy density on  fuel  economy  should be more consistent  and
discernible  than  the  effect  of  RVP  on  energy  density  (once
measurement variation is  eliminated),  few data exist from which
to determine accurate estimates.  Compounding this  is  the fact
that the  random variation in fuel economy measurements is large
(e.g., 3-5  percent)  relative  to the expected  change in  fuel
economy (less  than  one percent).  Three  sources of  information
were  used  in  analyzing   this   relationship:    1)   test  data
supplied  by General Motors and Ford  with respect  to  the CAFE
adjustment  rulemaking*   (use  of  this  information  was  also
recommended  by MVMA in their  submittal in this area),  2) fuel
economy  data  from  EPA's  in-house  emission  factors  testing
program,   and  3)   a   discussion   submitted  by  API  reviewing
different  factors  that   affect  fuel  economy.   A  theoretical
analysis  of  the  vehicle  design optimization  and performance on
the  different  gasoline  types was  then  used to  arrive  at  a
conclusion.  These are discussed in order below.

     In a letter dated  August 15,  1984, General Motors cited
data  on  the relationship between gasoline  energy  density  and
fuel economy which  was presented in  a  Chevron Research Co.  SAE
paper in 1974,  and added that GM testing  on more recent systems
supported  the  results  presented  in  the  SAE paper.[8,9]   The
vehicles  tested by  Chevron were  from the  1970  and 1972  model
years, and  the SAE paper  points  out that these tests can only
give  an  indication  of  1970  and   1972   car  performance   in
general.   Their results were based  on testing six vehicles with
six  fuels,  repeating  each  vehicle/fuel-specific  test  at  least
eight  times.   Fuel economy was measured by weighing  the fuel
     See 49 FR 48024, December 7, 1984.

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                              4-29

consumed and measuring the  distance  travelled during  each  test
cycle.  Heat (energy) content  of  the fuels was calculated using
a widely  accepted correlation involving  API  gravity,  percent
aromatics,  and  volatility of  the gasoline from  ASTM-3338.   The
average value of  the ratio of  the  percent change  in  vehicular
fuel  economy to the percent change  in gasoline  energy density
(defined as R)  was  0.57.   The GM submittal did not  supply  or
refer  to  any  data supporting  their  average  value  for  R
resulting from  testing  on  more  recent  systems,  but  they  did
state  that  the testing  yielded  R  values ranging from  0.1  to
0.9 with an average  of  0.5.  In their submittal  they  suggested
an overall  average R of  0.6.

     This value of 0.6 for  R was  later recommended by GM, Ford,
and MVMA in response to  questions asked by EPA's Certification
Division in  the EPA memorandum referenced in the supplemental
NPRM   on    the   CAFE    adjustment   rulemaking   referenced
earlier.[10,11,12]   This  ratio of  increased fuel economy  to
increased  energy  content  of  0.6  was   recommended   for   all
vehicles   (without   differentiating   between   feedback   and
non-feedback equipped  vehicles).    This  ratio  is  not  heavily
supported by a  large data base, but likewise  is  not  refuted by
the data sets  used  by GM and  Ford.   The major   conclusions  of
these manufacturers  as stated  in  their January 22, 1985 letters
to EPA are  discussed below.

     In their   letter  to  EPA, GM   summarizes  data  from  five
vehicles  (two   with  throttle-body   injection  (TBI)  and  three
carbureted)  of  model years 1981  and 1984, which  are  presented
in Table 4-9.[10]   They  include  R  factors for  FTP and highway
tests.  The  method  which  General  Motors  used  to measure  or
calculate the  fuel  economizes of these  five vehicles  was  not
stated in the GM  letter.   The  results  for FTP testing  were  an
average  R  of   0.62  for  five  vehicles,  with  a   range  of
0.34-0.89.   For  the highway  test procedure  the  average ratio
was  0.53,  with  a range of  0.41-0.72.   The  0.89  and  0.72  R
values were both for  a  1984 Pontiac  J2000 with TBI.

     GM did not explain why R is greater for the  FTP  tests  than
for the highway tests.   This is not the expected result for two
reasons.   One,  there is  more  stopping  and starting on  the  FTP
than  on  the  highway test  (e.g.,  more  accelerations where  a
carburetor  could be  operating  rich  and not able  to utilize  the
extra energy).   Two, the  FTP contains  cold operation,  where the
highway  test  does   not.   Again,   the  engine  will  likely  be
operating rich  and the feedback loop will be inoperative during
this time.   This anomaly in the data is unexplained.

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                              4-30

                           Table  4-9

             GM Data on Ratio of  Percent Change in
      Fuel Economy to Percent Change in Energy Density[10]

                                                R Factor
Test Vehicle                              FTP              HWY
Carbureted Vehicles
  1984 Olds Delta                         0.35             0.51
  (5.0L, 4bbl.)
  1981 Olds Cutlass                       0.39             0.41
  (4.3L, 2bbl.)
  1981 Chevette                           0.80             0.62
  (1.6L, 2bbl.)
  Average                                 0.51             0.51

TBI Vehicles
  1984 Chevrolet Citation                 0.65             0.41
  (2.5L, TBI)
  1984 Pontiac J2000 (1.8L TBI)           0.89             0.72
  Average                                 0.77             0.56

Composite Average                         0.62             0.53
(Carbureted and TBI)

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                              4-31

     If the  data from the  five vehicles are  divided  into  two
groups, as  illustrated in Table  4-9,  the TBI-equipped vehicles
show higher  R values  (0.77  vs.  0.51  for the  FTP and  0.56  vs.
0.51 for  the highway  test)  than the  carbureted  vehicles.   The
composite data have  an average R of 0.58, which  may  be rounded
off  to  0.6.   However,  the  fact that  the TBI  vehicles  show
higher R values  than the  carbureted vehicles and  the statement
that R can  approach 1.0 for  some operating  conditions  (i.e.,
steady state) indicate that  it may be appropriate to  assume an
R higher than 0.6 for fuel-injected vehicles.

     Both  the TBI  vehicles  and the  carbureted vehicles  were
probably  equipped   with   electronic  feedback   control   (EFC)
operating  over  most of the  test cycle,  as  all  GM vehicles of
model years  1981  and later  used EFC.   Therefore, one  can still
distinguish  between  TBI and  carbureted  vehicles here, but  the
results (i.e., R values)  should  be the  same  for both sets of
vehicles,   since  the  real technological  difference  is between
feedback and non-feedback equipped vehicles.

     In a direct response to EPA's  question, "Is  it appropriate
and/or  possible  to  account  for  the  effect  of  fuel  energy
content on the vehicle's  energy efficiency?   If  so,  how  should
this be  done?"   GM  supplied no  other data  than that  in Table
4-9 and a  reference  to SAE  paper no.  740522 and  recommended an
R of 0.6.

     Ford  also   recommends   that  an  R  =   0.6   be  adopted  to
represent the 1980-85 model year  vehicles.[11]   The Ford  letter
of  1/22/85  goes  on  to state  that future  model year  vehicles
could  respond  differently  and,   thus,  should   be  evaluated
separately  if warranted by  future fuel  specification changes.
Ford based their  conclusion  on repeated test results  from  four
different vehicles  with different  engines   and  control systems
using two different fuels.   Twelve CVS-H  and twelve HWFET tests
were conducted on each vehicle  and with each  fuel  for a total
of 192 tests.  The method used to determine the  fuel economies
of  these  vehicles   (volumetric  measurement or  carbon balance
calculation) was not  stated  in the Ford  letter.   These results
are presented in Table 4-10.

     One  of  these four  vehicles was  equipped with  electronic
fuel injection (EFI),  always  accompanied by  electronic feedback
control,  while  the  rest  were  designated NFB   for  non-feedback
vehicles.   The R value for  the EFI vehicle for the hot-start
test was  0.75.   For  the hot-start portion of  the urban driving
cycle (CVS-H) fuel evaluation and the  highway  fuel  economy  test
(HWFET) fuel  evaluation analyses,  the  R values were  0.71  and
0.84, respectively.   The other  three vehicles  were non-feedback
controlled vehicles  (NFB) with average R values of 0.35 for the

-------
                                   4-32

                                •Bible 4-10

                  Ford Data on Ratio of Percent Change in
           Fuel Economy  to Percent Change in Energy DensityCll]

Test Vehicle             M-HHS*         CVS-H*       HWFET*      CVS-C/H*
w/o Feedback Controls
3.8-216 NFB
1.6-602 NFB
5.0-807 NFB
Average
W/Feedback Controls
1.6-343 EFI
Composite Average
0.5974
0.6178
0.2095
0.4749
0.7502
0.5437
0.2168
0.5574
0.2687
0.3476
0.7082
0.4378
1.1837
0.7173
0.1161
0.6724
0.8403
0.7143
0.846
0.846
1.065
0.955
(Feedback and Non-Feedback)
     M-H  Hot-Start  =  city  and  HWFET  combined  to  yield  a
     metro/highway value.
     CVS-H = city test cycle - hot-start.
     HWFET = highway test cycle.
     CVS-CH = City cycle test - cold-start.

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                              4-33

CVS-H  analysis,  and   0.67   for   the  HWFET   fuel   evaluation
analysis.   These  R values  are significantly  lower than  those
resulting from  testing the  EFI  vehicle.   MOBILES  projections
predict  that  by  1990 nearly 90  percent  of  gasoline-fueled
vehicles  in-use will  have  EFI  or  will  be  feedback-equipped
carbureted vehicles.    Thus,   based  on  the  Ford data,  it  is
reasonable to assume an R value higher than 0.6  for  vehicles in
use in 1990,  the majority of which will use EFI.

     It should  also be noted  that  this Ford  data supports the
theory  presented  earlier;  that  vehicles  tested  on  fuels  of
different energy content would provide higher  R values over the
HWFET than over the CVS-H  test cycle.   It also  contradicts the
results of the  GM analysis,  in which R from the FTP was greater
than  R  from  the  HWFET.    This   contradiction  indicates  the
variability  in  measuring  R  over  different  test cycles,  and
lends some doubt to  the accuracy of this method of analyzing R.

     Ford states  in the January  22,  1985  letter that,  though
fuel economy  should increase  due to an increase  in the energy
content of  the  fuel  the vehicle is  operated on,  the  vehicle
cannot utilize  100  percent of  the  increased  energy  content of
the fuel  because  there are  penalties  that are  associated with
greater fuel  density.[11]   These penalties  are:    1)  air/fuel
ratio  shifts  slightly richer,   2)  cylinder  to  cylinder  A/F
distribution   becomes   worse,   and 3)  A/F  ratio  excursions  on
transients increase.    Ford   states  that  these  variations  in
air-fuel ratio  due  to changes  in fuel properties will  prevent
the R value from ever  reaching 1.0,  and thus they  recommend R =
0.6.  Again,   no differentiation was made  between R  values for
carbureted and  fuel-injected  feedback  and  non-feedback equipped
vehicles,  even  though  the  data  supports  a  higher R  value for
EFI vehicles  than for  NFB vehicles.

     The  MVMA  letter  of January 22,  1985 analyzes  the  data
submitted by  GM and Ford and reaches the  same conclusion; 0.6
is  a  reasonable value for   R.[12]   The  MVMA  letter  does  not
propose a higher  R value  for feedback  equipped vehicles vs.
non-feedback  equipped vehicles.

     The  second  source  of   information  was  EPA's  in-house
emission factors testing  program.  No major conclusions  on the
relationship  between lower RVP fuel  and vehicular  fuel  economy
can  be drawn  from these  data  due  to  the   large  degree  of
variability in the  R  values calculated  from  the  EPA  test  data
for vehicles  operating on different fuels  (R = -4  to R  = +5).
It   appears   that   the   variability   associated   with   the
measurement  of  both fuel properties and fuel  economy is larger
than the  actual changes in  energy  density (only  -0.4 to  +1.0
percent).   Because  of  this,  the  results from  this test  program
could not  be  used to evaluate R.

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                              4-34

     Finally, API,  in their  submittal, stated  that there  are
many variables that can combine with  fuel  volatility parameters
to  affect   energy  density  and   fuel  economy.[3]   However,
although  they mention  data  reported  in  CRC  Report  No.  527
showing the  effect of ethanol blends on fuel economy,  they did
not submit  any  data  relating  energy density  and fuel  economy
for   alcohol-free   gasoline.    Since   ethanol   lowers   energy
content,  rather  than  raising  it  as  does  lower   RVP,  this
severely limits the value of their submittal here.

     General  Motors  also  submitted   a   theoretical  argument
defending an  R  valve significantly less than  1.0,  in  the form
of  a  letter  from  Chemical  Engineering Professor  John  Longwell
of MIT.  GM  submitted the data from  references  [4]   and  [6]  to
Professor John  Longwell  of MIT for his analysis  and comments.
Professor Longwell concluded that  the GM suggested value  of  R =
0.6 is  reasonable.[13]  Professor  Longwell's conclusion was not
based on any data other  than that already  discussed;  but  he did
perform  a  theoretical  analysis  of  the  effects  of  different
gasoline  properties  (including   energy   density)  on   fuel
economy.  He  explains that high density,  low H/C  fuels may run
at higher equivalence ratios  resulting  in lower efficiency and
lower  R.   This  effect   is  greater  for volumetrically metered
fuels than  for  fuel  metering  controlled  by an oxygen sensor.
This  implies that  volumetrically  metered fuel systems  (i.e.,
open-loop carbureted vehicles) may yield  lower  R  values  than
fuel  metering  controlled  by  an  oxygen  sensor,  referring  to
feedback equipped fuel systems.

     Longwell  goes  on  to  discuss  the  effect  of   increasing
aromatic  content,  which   increases   fuel  viscosity,   surface
tension, and  latent heat of vaporization.  He writes that these
changes decrease evaporation ratio  which  decreases fuel mixture
homogeneity  and  quality  of cylinder  to cylinder  distribution,
both  of which  lower the  fraction  of the volumetric  heating
value  that   is  captured  in miles  per gallon.   Longwell  also
explains  that  higher  aromatic  content   also  increases  flame
temperature, which increases heat losses to  the  cylinder walls,
thus, decreasing efficiency, and R.

     Longwell  concludes   that  the  major  changes in the  fuel
system  have  not improved the  engine's ability  to  capture  the
high  heating value  of  higher  density fuels.   Because  he  was
unable  to  identify  factors  that  would  tend  to  appreciably
increase  R  above   1.0,  he concluded  that  a  multiplicity  of
effects  caused  by   increased  density  and  aromatic   content
combine  to   reduce  R.  Longwell  states that  the GM suggested
value of R  = 0.6 is reasonable,  but  he does not  suggest using
different R values for vehicles with different fuel systems.

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                              4-35

     Because of the inconsistencies in the R  values  provided by
GM and  Ford that were  discussed  previously,  and  also  those in
the R  values  resulting from  EPA's  in-house emission  factors
test program,  a theoretical  analysis of  R  is  necessary.   Two
arguments may be presented  to support an  R value greater  than
0.6.    The   first  argument addresses  the  implications  of  an  R
value  significantly less  than 1.    The  second  evaluates  the
vehicle design optimization procedure and  its effect on vehicle
operation on  different fuels.   These arguments are  discussed
below.

     An R of ,0.6,  as  estimated by MVMA,  GN,  and Ford, indicates
that 40  percent of  the excess  energy available  in lower RVP
fuels  will  not  contribute to an  increase  in vehicular  fuel
economy.  Possible sources  of  the  energy  losses  have  been
proposed by Ford,  GM, and  Professor Longwell  of  MIT.   These
losses  resulting from lower RVP gasoline include increased heat
losses    to   cylinder   walls,    decreased    thermogravimetric
efficiency,    lower   efficiency   due  to   higher   equivalence
operating  conditions,   and  higher  fuel  surface  tension  and
viscosity (creating pumping losses).

     Ford's   explanations  for  less   complete  fuel  utilization
when  fuel   density  increases  (due  to  reduced  RVP)   include
air/fuel    ratio    shift    to    slightly    richer,     worse
cylinder-to-cylinder  A/F  distribution,   and  increase  of  A/F
excursions   on  transients.   No quantitative  estimates  for the
effect  of these  contributing  factors  is  supplied by Ford, GM,
or Professor  Longwell.  However,  losing  forty  percent  of the
net energy  increase seems an  excessive amount  for  the  combined
effect  of these  losses.  Thus, an R  value of 0.6 would  appear
to be  more  appropriately used as a  lower bound rather  than  a
best estimate.   However,  a  more  appropriate figure cannot be
identified   in  this  approach.   Therefore,  another  approach must
be taken to  determine the effect of  increased energy content on
vehicular  fuel  economy.   This  second  approach  is  described
below.

     In determining the effect of  a reduction  in gasoline RVP
on vehicular  fuel  economy,   it  is  necessary  to  evaluate the
vehicle that will be operating on this lower RVP  fuel,  and the
design optimization of that vehicle.  Automobile  manufacturers
are concerned with  obtaining  the  highest fuel  economy  possible
to meet  CAFE  requirements and advertise high fuel  economies to
attract  consumers.   Vehicular fuel  economy  figures  are  the
result   of  testing over the  EPA FTP  and  HFET cycles,  in which
the vehicles  are operated on  Indolene,  a  9-psi RVP  gasoline.
Therefore,   the  manufacturers  presumedly  optimize  the  vehicle
fuel systems  to  operate  on   Indolene,  to  maximize  the  fuel
economy  figures  resulting  from  the FTP test cycle.    As  a

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                              4-36

result, vehicles  probably  are not optimized to operate  in the
field on commercial (in-use) gasoline with  significantly higher
vapor pressure  and lower energy  density.   Operating on  a  fuel
more like  Indolene would,  presumedly, be  more efficient,  than
on  a  different fuel  for which the  vehicle was not  optimized.
This would argue  that  "R" may  actually be greater than  1.0,
though to what extent is unknown.

     While  Longwell  states  than  an  "ideal"  engine  would  be
expected  to  have  an  R  value  slightly  less  than  1.0,   the
situation Longwell  refers to  is not  the same situation which is
being  evaluated here.   Longwell's  letter   addresses  more  the
issue of  a vehicle optimized  to  run on a given fuel,  and  then
run instead  on a  denser  fuel; resulting  in  lower  efficiency.
In-use RVP  reduction  creates a circumstance in which  an engine
that is  operating at less than  maximum efficiency  on  gasoline
other  than  what  it  was   specifically  designed   for  is   now
operated  on  a gasoline  for  which  it  was  designed.   Thus,
Longwell's   analysis  does   not   apply  specifically   to  this
scenario,  and  the  theoretical   "R"  value  of   1.0   or  more
suggested  above still appears the most  reasonable.   Thus,  it
will  be  used  below  to  estimate  the  fuel  economy  credit
associated  with in-use  volatility control.   However,   a lower
bound  R  of   0.6   will  also be  examined   to   estimate   the
sensitivity of the study's  results to this  parameter.

     C.    Overall Relationship Between Gasoline Volatility and
           Fuel Economy

     Combining  the  relationship  between  fuel  volatility  and
energy density  (from  the Bonner  and Moore study)  with  our  best
estimate for  the  relationship between energy density  and  fuel
economy yields  the  overall relationship between fuel volatility
and fuel economy.   Energy density is projected to  increase  0.25
percent with  a 1-psi reduction in  RVP and  0.56 percent with a
2-psi reduction in RVP.   Vehicles should take  full advantage of
this increase  in  energy  density to  achieve a resultant increase
in  fuel  economy.   Thus,  for  both  feedback  and  non-feedback
equipped  vehicles,  the  increase  in  fuel  economy  for  1-  and
2-psi  reductions  in  RVP   would  be  0.25  and  0.56  percent,
respectively.   The  fuel   economy  effects   for  other   RVP
reductions were derived, by  fitting  a  curve through these  fuel
economy increase values  for  1- and 2-psi  RVP reductions and are
shown in Table  4-11.  The  lower  bound estimates  using  an  R of
0.6 are also shown in Table 4-11.

     These  fuel  economy  increases  were  used to  evaluate  a
dollar credit resulting from gasoline RVP control.   This credit
was  determined by multiplying  the  percent  increase   in  fuel
economy by the  total  number  of gallons of gasoline  consumed by

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                              4-37

                           Table  4-11

               Fuel  Economy Effect  of  RVP  Control

RVP Reduction                              Percent Increase in
   (psi )	                           	Fuel Economy	
                                      Best Estimate  Lower Bound
                                        R = 1.0          R = 0.6

     0.5                                   0.11             0.066

     1.0                                   0.25             0.150

     1.5                                   0.40             0.240

     2.0                                   0.56             0.336

     2.5                                   0.73             0.438

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                              4-38

motor  vehicles,  and then  valuing that  gasoline, at  $0.98 per
gallon.    This   value   was   determined  by   subtracting   a
'consumption-weighted  state  fuel tax of $0.13 per gallon and the
Federal  tax  of  $0.09 per gallon from  the 1984 national-average
retail gasoline price of $1.20 per gallon.[14]  In other words,
the  consumer would be  able to travel  additional  miles  on the
high  energy, low RVP gasoline,  and  is thus  credited the dollar
value of the gasoline he would otherwise have had  to purchase
in  order  to travel  those  extra  miles  made available  by the
resulting high  vehicular fuel economy.

VI.  Economic Credit From Evaporative HC Recovery/Prevention

     There  are  three major  sources of  evaporative  hydrocarbon
emissions  that  are  associated with  gasoline  RVP.    They are
stationary   source  emissions  (such as  bulk  storage  terminal
breathing  losses,  bulk  transfer  losses,  and service station
losses from  transfer  and underground tank breathing),  refueling
emissions,   and  motor  vehicle   evaporative   emissions.    The
emission reductions for each  of these sources  associated with
RVP  control  are detailed in Chapter 5 of this study.  However,
in  addition  to representing  an  environmental  benefit,  these
emission reductions also represent  an economic  benefit in that
these HC emissions  are now available to be consumed  as fuel by
the   motor   vehicle  (i.e.,   current   emissions   due  to  high
volatility fuel represent  a cost to the economy).  The same is
true  for certification  fuel RVP control, although only emission
reductions   from motor   vehicles  are   relevant   there.    The
methodology  used to  evaluate   this  cost credit  resulting from
the  recovery and  prevention  of evaporative  HC emissions  via
both fuel and vehicle control is outlined below.

     The reductions in  evaporative HC emissions from stationary
sources, refueling, and  motor  vehicles (as described in Chapter
5)  are   used directly to  determine the  mass  of HC  now usable
that  would  otherwise  be lost  if  excess  evaporative  emissions
were not controlled.   This  tonnage of hydrocarbons is  converted
to  an equivalent   volume  using  the  density  (Ib/gal) of  the
hydrocarbons.    Because  the   lighter  hydrocarbons   evaporate
first, the specific gravity and energy densities  (Btu/gal)  of
those    hydrocarbons   no   longer   lost   to  evaporation  are
significantly  less  than  those of  gasoline.   As  a  first-order
estimate,  the  evaporative  hydrocarbons  were all assumed  to be
butanes.   The  equivalent  volume (gallons)  of  butane  saved by
RVP  reduction  is  converted  to energy  using butane's  energy
content.   This  energy is then converted to  equivalent gallons
of  gasoline,  using  a   representative  gasoline energy content
figure (Btu/gallon).  This  volume  of gasoline is then  converted
to  a  dollar  amount  using a  value  of  $0.98  per   gallon  of
gasoline.  Overall, the value  of a  ton of evaporative  emissions
(butane)  controlled or  prevented is $335.26.   The estimates for
densities, energy densities,  and gasoline value  are summarized
in Table 4-12.

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                              4-39
                           Table 4-12
       Estimates for Evaluating the Evaporative Recovery/
          Prevention Credit Resulting from RVP Control

    Description                       Units	       Estimate
Composition of Evap. Emissions                       100% Butane
Density of Butane[15]              Ib/gal            4.77
Energy Density of Butane[15]       Btu/lb             19,500
                                   Btu/gal            93,100
Energy Density of Gasoline[15]     Btu/lb             18,500
                                   Btu/gal           114,000
Value of Gasoline                  $/gal             0.98
Value of Controlled/Prevented
Evap. Emissions (Butane)           $/ton             335.26

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                              4-40

VII. Overall Cost of In-Use Gasoline RVP Control

     The overall  cost  of volatility control  of in-use gasoline
is  the  difference  between  the refinery  cost  of  gasoline  RVP
control  (Section   III)   and  the  credits   due  to  increased
vehicular fuel economy from    1)  greater  energy content  of  low
RVP  gasoline   and   2)   internal  engine  combustion  of  HCs
otherwise  lost  to  evaporation  if  RVP  were  not  controlled
(Sections V and VI).   Subtracting these credits from Bonner and
Moore's refinery cost  of RVP control  results in the  net costs
discussed below.

     The aggregate  costs of RVP  control  of  in-use  gasoline in
1988  (when only  fuel control  is  relevant)   are  presented  in
Table  4-13,   for   both   12-month  and  4-month  control  periods.
Costs for  RVP control during  a  4-month period are simply  one
third  those  of  12-month  control  period.   This  ignores  any
shifts  in  wintertime butane  supply which  might  be  caused  by
shifts  in  summertime butane usage  (e.g.,  storage of  butane in
the  summer  would  increase  winter  supplies,  while  the  use  of
butane  as  a   petrochemical   feedstock  in  the  summer  could
increase such demand for  butane in  the winter).  The short-term
costs  shown  assume  that  there   is   not  sufficient  time  for
refineries to  invest in  new  equipment for more economic means
of controlling RVP.  These  costs,  as  well as those for the long
term, are used in determining the cost effectiveness figures of
Chapter 6.

     These costs are dependent on several assumptions described
earlier  in this  chapter.   Should  further   analysis  currently
being conducted prove any  of these assumptions  incorrect,  the
results of the recent analysis will be incorporated  in the cost
calculations,   and  the costs  will be  revised accordingly.   The
major areas being further investigated  are:   1) the  effect on
refining   costs   of   controlling  "the   percent  of   gasoline
evaporated  at  160°F,   2)  the  value  of  refinery  equipment
purchased  specifically  for gasoline  volatility control  during
periods  of  the year  without volatility  restrictions,   3)  the
sensitivity of gasoline  refinery costs to the availability of
butane  and  alkylation  capacity,   4)  the  cost  of  refinery
gasoline specifically  to be blended with ethanol,  and   5)  the
effect  on  the ethanol  industry  of  no  longer permitting  the
"splash"  blending  of  ethanol  and gasoline.   The  results  of
studies  in these  areas  will  be  used  to   revise  these  cost
estimates as necessary as soon as they are available.

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                              4-41

                           Table 4-13

          Net Costs of Short-Term In-Use RVP Control:
   1988 No Investment Case  (millions  of 1984 dollars per year)


                  	12-Month Control	
Level of RVP      Refinery  Fuel Economy  Evap.  Recovery
Control (psi)      Costs        Credit         Credit

    0.5             286         79            96
    1.0             624        180           182
    1.5            1028        287           256
    2.0            1439        402           321
    2.5            1880        523           379


                  	4-Month Control	
Level of RVP      Refinery  Fuel Economy  Evap.  Recovery   Net
Control (psi)      Costs        Credit         Credit       Cost

    0.5              95         26            32            37
    1.0             208         60            60            88
    1.5             343         96            85           162
    2.0             480        134           107           239
    2.5             627        175           127           325

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                              4-42

                     References  (Chapter  4)

     1.    "Estimated  Refining  Cost Impact  of  Reduced Gasoline
Vapor  Pressure,"  Final  Report,   Bonner and  Moore  Management
Science  under  SwRI  Work  Assignment  #28  of  EPA  Contract  No.
68-03-3162, July 1985.

     2.    Memorandum,  "Transmittal of  Draft  Work  Assignment
#13  Contract  68-03-3192," Craig  Harvey, Project  Officer,  TSS,
ECTD,  QMS,  EPA,  and Cooper  Smith,  Technical  Project Monitor,
SDSB,   ECTD,   QMS,  EPA,   to  Albert   W.   Ahlquist,   Contract
Specialist, NCB, CMD, EPA, July 15, 1985.

     3.    Draft  Supplemental  Report  to   "Estimated  Refining
Cost  Impact   of  Reduced  Gasoline  Vapor  Pressure," Bonner  and
Moore, October 4, 1985.

     4.    "The  Butane Industry:   An  Overview and  Analysis of
the  Effects  of  Gasoline  Volatility  Control  on  Prices  and
Demand," Draft  Report,  Jack  Faucett Associates, Work Assignment
#5, EPA Contract No. 68-03-3244, May 30,  1985.

     5.    Memorandum,   "Transmittal   of   Change  1   to  Work
Assignment #6  Contract 68-03-3244," Robert  J.  Johnson, Project
Officer, SDSB,  ECTD,  QMS, EPA,  to  Paul  S.  Eninger, Contracting
Officer, NCB,  CMD, EPA, July 15, 1985.

     6.    Harry  Weaver,  Director,  Environmental  Department,
Motor  Vehicle  Manufacturers  Association,  letter  to  Charles
Gray, Director, ECTD, QMS, EPA,  December 4,  1984.

     7.    Ronald   L.   Jones,   American   Petroleum  Institute,
letter  to  Charles  L.  Gray,   Jr.,  Director   ECTD,   QMS,  EPA,
December 17,  1984.

     8.    W.S.  Freas,   Manager,   Emission  and  Fuel  Economy
Operations, General  Motors,   letter  to  R.E.  Maxwell,  Director,
Cert. Division, QMS, EPA, August 15, 1984.

     9.    J.C.  Ingomells,  Chevron   Research  Company,  "Fuel
Economy  and  Cold-Start  Driveability  with Same  Recent  Model
Cars", SAE Paper No. 740522.

     10.   T.M  Fisher, Director,  Automotive  Emission Control,
General  Motors  Corporation,  letter  to  EPA,  Central  Docket
Section (LE-131), Docket A-83-44, January 22, 1985.

     11.   D.R.  Buist,  Director,  Automotive Emissions and Fuel
Economy  Office,  Environmental   and Safety Engineering  Staff,
Ford,  letter  to Richard D. Wilson,  Director,  QMS, EPA, January
22, 1984.

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                              4-43

                 References (Chapter 4) cont'd

     12.   Fred   W.   Bowditch,   Motor  Vehicle   Manufacturers
Association,  letter to  Richard D.  Wilson,  QMS,  EPA, January 22,
1985.

     13.   John P. Longwell,  Professor of  Chemical Engineering,
Massachusetts  Institute  of  Technology,   letter   to  Marvin  W.
Jackson,   Environmental   Activities   Staff,   General   Motors
Technical Center,  January 16,   1985.

     14.   From Department of Energy,  Monthly  Energy  Review,
March  1985,  as published  in  the  National Petroleum  News  1985
Factbook, p.  101.

     15.   Technical Data Book, API, Volume 4, 1983.

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                           CHAPTER  5

                      Environmental Impact

I.    Introduction

     This chapter  examines  the environmental  impact  associated
with each of  the  evaporative hydrocarbon (HC) control scenarios
described in  Chapter  2:   1)  long-term  control  of   in-use  and
certification fuel volatilities to  equal levels (via changes to
one or  both);  and, 2)  additional  short-term control  of in-use
RVP to  levels lower than the  long-term  specifications for both
fuels under 1) above.

     The first section following this  introduction (Section II)
presents motor  vehicle evaporative emission factors,  by model
year,  for each of the RVP scenarios.   Next,  Section  III reviews
the effect  of RVP control on exhaust emissions,  while Section
IV deals with  the effect of  in-use RVP control  on  evaporative
losses from gasoline storage and  distribution sources.  Section
V  presents  projected  non-methane  hydrocarbon  (NMHC)  emissions
inventories  under  the various  long-  and  short-term  control
scenarios,   evaluating  future  nationwide  inventories  and  also
emissions  in  the  47  non-California   urban  areas currently in
violation  of   the  NAAQS  for  ozone  (0.125  ppm).*   This  is
followed (in  Section  VI)  by  an ozone air  quality  analysis of
these  same  urban  areas,  comparing relative  ozone  violations
under the  various NMHC control  strategies.   Finally,  the last
section (VII)  examines  the  effect  of  RVP  control on  levels of
toxic emissions (i.e.,  benzene and gasoline vapors).

II.  Motor  Vehicle Evaporative HC Emission Factors

     As described in  Chapter  2,  evaporative HC  emissions from
motor  vehicles  originate  from  two  basic  components  of  the
vehicle's fuel system  — the fuel  tank and the carburetor.  The
"diurnal"  portion  of   the  certification  test  simulates  the
vehicle's exposure to  daily  cyclic  temperature variations which
cause evaporative losses from the fuel tank  to  occur  as  the
gasoline  vapors  expand  in  response  to  ambient  temperature
increases.   The  "hot-soak"   portion of  the  certification  test
simulates emissions which  occur just  after  the engine has been
turned off,  when residual engine and exhaust system  heat causes
the evaporation  of fuel  remaining in the  carburetor  bowl,  as
well as from  the fuel  tank  and  fuel  lines.   Total  per-vehicle
evaporative  HC  losses  are  represented  by  the  sum  of  the
hot-soak and  diurnal  emissions,  and  are expressed in  terms of
     As  the California  Air  Resources  Board  (CARS)  currently
     regulates  in-use  RVP  in California, the  seven California
     cities currently in  non-attainment  of  the ozone  NAAQS are
     not included in the city-specific analysis.

-------
                               5-2


grams/test.*  However, for  air quality modelling  purposes,  the
hot-soak  and diurnal  emissions are  treated  separately,  since
diurnal  emissions  occur  once  per  day,  but hot-soak  emissions
occur once  per  vehicle trip.  Thus, the  hot-soak  emissions  are
multiplied by the number of trips per day and  then added  to  the
diurnal  emissions.   The  sum is then  divided  by  the  number  of
vehicle miles travelled per  day to yield an emission  factor  in
terms of grams per mile (g/mi).

     For  the evaporative  emission control  scenarios  described
in  Section  VI   of  Chapter  2,  the  derivation  of  light-duty
vehicle  (LDV)  evaporative emission  factors can most  easily  be
separated  into  four  parts,  differentiating  between  certain
model year groups.  The  first  section of Part A below addresses
post-1989  LDVs  in  the  case  where   in-use   RVP  equals  the
certification fuel  RVP (long-term control  scenarios);  the 1990
model year is assumed to be the first to  be affected by changes
to  certification   fuel   and/or  test   procedure.    The  second
section  addresses  these  same  model  years  where  in-use  RVP  is
below the certification fuel RVP (short-term,  additional in-use
RVP control).  The third  section addresses  1981-1989 model year
LDVs  operating   on  various  in-use RVP  fuels  (both  long-  and
short-term scenarios); these vehicles  will  be designed  for  9.0
psi,  so  their  emission  rates  will  only be affected  by in-use
RVP control.  The  fourth  section addresses  pre-1981  model year
LDVs  under  various in-use  RVP levels  (same scenarios);  again,
these vehicles   are  designed  for  9.0-psi  fuel,   but would  be
operating on various in-use RVPs.

     The  derivation of  light-duty truck  (LDT) and heavy-duty
vehicle  (HDV) emission factors is  based almost entirely  on  the
LDV data.[l]  This  derivation  is briefly discussed in Section B
following the development of the LDV rates.

     A.     Light-Duty Vehicles

     1.     Post-1989 LDVs: In-Use RVP = Certification RVP

     Both  vehicle-  and  fuel-related  control  strategies  can
apply  to  1990  and  later  model   year  vehicles.   Under  the
long-term strategy, commercial  fuel  RVP  and certification fuel
RVP will  be made equal  at some level  between 9  and  11.5 psi,
inclusive.

     As  discussed  in  more  detail in  Chapter  2   (Section  V),
motor  vehicle   evaporative  emissions   can,  conceptually,   be
attributed to five  sources:  1)  properly designed and operated
     Specific  test  procedures  are  outlined  in  Part 86  of the
     Code of Federal Regulations, and are  reviewed  in Section V
     of Chapter 2.

-------
                               5-3


systems;   2)  insufficient  design  of  the  purge  system;   3)
itialmaintenance  and equipment  defects;   4) commercial  fuel RVP
in  excess  of  certification  fuel  RVP;  and   5)  evaporative
control  system  tampering.   Below, the effect of RVP  on each of
these  sources will be considered.  The quantitative  inputs and
results  for post-1989 vehicles are summarized in Tables 5-1 and
5-2, which draw upon  the emission levels  categorized  in Section
V   of   Chapter   2  (Table   2-15).    As   explained  there,  the
derivation of these emission rates are based on  data generated
as  part  of  EPA's ongoing in-use  emission  factor   (EF)  test
program.

     Vehicles with properly designed  and operated systems are
assumed  to  emit  at  the standard level,  which is  2  grams/test
for  LDVs  and  LDTs,   3  grams/test  for  lighter  HDVs,  and  4
grams/test  for   heavier  HDVs.   This  portion  of  the  emission
factor   would   not   be    affected  by   either   fuel-   or
vehicle-oriented  control,   as  indicated  in Tables 5-1  and 5-2.
These  assumed  standard   levels   were  split  into  diurnal  and
hot-soak  portions  using  the  ratios  of  diurnal  and  hot-soak
emissions to total emissions from problem-free EF LDVs.

     The  effect  of  improper  design  of  the purge  system  is
estimated as  the  difference  between  the average emissions  of
problem-free  EF  LDVs  and the  standard levels  described above.
This  effect  is  assumed to  disappear  with  a revised (i.e.,
improved) evaporative emission test  procedure that could likely
include,  at  a minimum, the  saturation of  the canister prior to
testing.  Thus,  emissions   due to improper design are  shown as
zero under the control scenarios  in Tables 5-1 and 5-2.

     The  effect  of  malmaintenance   and  defects  was  shown  in
Chapter  2  to  be  dependent  only  upon  in-use  RVP.   It  was
estimated as  the  difference between emissions from non-tampered
EF  vehicles  and  problem-free  EF  vehicles operated  on various
RVPs.   Since  this  effect  represents  an in-use  problem not
likely  to be eliminated  by  changing the  certification  test
procedure (barring design  standards or  an  improved  durability
test),  it remains.  This effect's  dependence on  in-use RVP is
indicated in Tables 5-1 and  5-2.

     The  RVP  effect  was shown  in Chapter 2  to  be  due to the
differences  between  certification  and   in-use  RVPs,  and  was
calculated  by  subtracting  non-tampered vehicle  emissions  on
Indolene  from emissions  of  non-tampered vehicles operating  on

-------
                               5-4


commercial (11.5-psi) fuel.*   As  certification and  in-use  RVPs
are  assumed  to  be equal  under  the long-term  strategies,  this
RVP  effect  disappears in  new  vehicles,  as indicated  in  Tables
5-1 and 5-2.

     Finally, the  tampering effect is much like the  effect  of
malmaintenance   and   defect  in   that   it  remains   after   the
long-term strategy is imposed, but its magnitude  is reduced  by
lowering  in-use   RVP.   However,  unlike   the   other  effects,
tampering rates  are dependent upon vehicle mileage  and are not
constant with model  year  (i.e.,  there  is a zero-mile  rate  plus
a  deterioration  factor  per  every  10,000  miles).   Therefore,
MOBILE3 handles  tampering  separately  and the tampering portion
of emissions  is  not  shown in Tables 5-1 through 5-4.  Tampering
offsets, calculated  by subtracting total  non-tampered emissions
from  uncontrolled emissions  measured with disabled  vehicles,
were presented for various RVPs in Appendix  2-B of  Chapter  2,
along with details on the methodology used.

     Also  shown   in  Tables  5-1  and  5-2 are  the breakdown  of
baseline   emissions  from  these  post-1989   vehicles;   they
represent levels  estimated for the case where in-use RVP =11.5
psi  and certification  RVP  =  9.0 psi.   The  overall  control
efficiencies  of  the  various  RVP   scenarios  (expressed  as
percent-reductions  from  baseline  emission  levels)  are  also
shown in the tables.

     2.    Post-1989  LDVs:  Additional  Short-Term   In-Use  RVP
           Control

     As  in  the   previous   section,  this  control  strategy  is
examined  with respect  to  the five  components of  evaporative
emissions  from  motor vehicles.    Controlling  in-use  RVP to  a
level  lower  than  the long-term certification RVP  is assumed  to
have  no effect  on  properly  designed  and  operating  vehicles
since  these  vehicles are already  assumed to be emitting  at the
standard.  The  improper  design/purge and RVP  sources  are  also
not  affected  since  they  are  already  assumed  to  be  zero.
However, the  malmaintenance/defect and tampering  sources would
be  affected,  since  these  are dependent  only  on  in-use  RVP.
Thus,  the  total  non-tampered diurnal  and  hot-soak  emission
rates  for  these  vehicles,  respectively, can be determined from
Tables  5-1 and 5-2 by choosing the RVP column  corresponding  to
the  short-term in-use RVP  level.   In other words,  the long-term
     However,  as  part  of  the  RVP  impact  has  already  been
     accounted  for  in  the malmaintenance/defect  effect  (shown
     to  be dependent  upon in-use RVP),  this RVP effect  is  an
     adjusted    figure    (i.e.,     the    difference    between
     malmaintenance/defect  at  Indolene and  11.5-psi  commercial
     fuel has been subtracted from the total  difference between
     non-tampered emissions at  Indolene  and 11.5-psi  commercial
     fuel).  (See Appendix 2-B in Chapter 2 for more details.)

-------
                               5-5
                            Table 5-1

       Diurnal Emissions from Non-Tampered Post-1989 LDVs
           Under Lonq-Term Control Scenarios (q/test)

                              Certification = In Use RVP (psi)
                 Baseline*    9.0    9.5  10.0  10.5  11.0  11.5
Carbureted Vehicles
Properly Designed
and Operated**
Improper Design**
Malmaintenance
and Defect**
Excess RVP**

0
0

1
6

.91
.30

.61
.19

0
0

1
0

.91
.00

.11
.00

0
0

1
0

.91
.00

.21
.00

0
0

1
0

.91
.00

.31
.00

0.91
0.00

1.41
0.00

0.91
0.00

1.51
0.00

0.91
0.00

1.61
0.00
Total               9.01      2.02  2.12  2.22  2.32  2.42  2.52

Reduction from
  Baseline (%)       -        78   76    75    74    73    72
Fuel-Injected Vehicles

Properly Designed
and Operated**      0.91      0.91  0.91  0.91  0.91  0.91  0.91

Improper Design**   0.0       0.00  0.00  0.00  0.00  0.00  0.00

.Malmaintenance
 and Defect**       0.84      0.34  0.44  0.54  0.64  0.74  0.84

RVP**	   3.76      0.00  0.00  0.00  0.00  0.00  0.00

Total               5.51      1.25  1.35  1.45  1.55  1.65  1.75

Reduction from
  Baseline (%)       -        77   76    74     72    70    68
*    "Baseline"  indicates  in-use RVP =  11.5  psi, certification
     RVP = 9.0 ps i.
**   From Table 2-15 in Chapter  2.

-------
                                 5-6
                             Table 5-2

         Hot-Soak  Emissions  from Non-Tampered Post-1989 LDVs
             Under Long-Term Control  Scenarios (q/test)

                            Certification = In-Use RVP (psi)
                 Baseline*  9.0   9.5  10.0  10.5  11.0  11.5

Carbureted Vehicles

Properly Designed
and Operated**       1.09   1.09  1.09  1.09  1.09  1.09  1.09

Improper Design**    0.40   0.00  0.00  0.00  0.00  0.00  0.00

Malmaintenance
 and Defect**        1.24   0.83  0.91  0.99  1.07  1.15  1.24

Excess RVP**	    1.11   0.00  0.00  0.00  0.00  0.00  0.00

Total                3.84   1.92  2.00  2.08  2.16  2.24  2.33

Reduction from        -     50    48    46    44    42    39
  Baseline (%)
Fuel-Injected Vehicles

Properly Designed
and Operated**       0.61   0.61  0.61  0.61  0.61  0.61  0.61

Improper Design**    0.00   0.00  0.00  0.00  0.00  0.00  0.00

Malmaintenance
 and Defect**        0.93   0.29  0.42  0.55  0.67  0.80  0.93

Excess RVP**         0.29   0.00  0.00  O.OQ  0.00  0.00  0.00

Total                1.83   0.90  1.03  1.16  1.28  1.41  1.54

Reduction from
  Baseline (%)   .     -     51   44    37    30    23    16
*    "Baseline" indicates in-use  RVP  = 11.5  psi,  certification
     RVP =9.0 psi.
**   From Table 2-15 in Chapter 2.

-------
                               5-7


certification   RVP  level   is   irrelevant  here   because  the
remaining  effects  are  dependent  on  in-use  RVP  alone.   The
tampering  offsets  under these  short-term  control  scenarios are
again  the  same as  those used  in  the  long-term analysis under
the appropriate in-use RVP level.

     3.    1981-1989 LDVs:  In-Use RVP Control

     These  vehicles  are  all  certified  to  meet  the  2-gram
standard on Indolene regardless of  the control scenario.   Thus,
their  emissions depend  only  on in-use RVP.  Derivation of their
emissions is separated  from  pre-1981 models since  significantly
more data  exists  for these  later models.  (Emission factors for
the older models are derived in the next section using the more
recent-model data.)

     As  these  pre-1990  vehicles  will   not  be  affected  by
certification  fuel  or   test   procedure   modifications,   their
emissions  can be  estimated  using current  test  results.   For
non-tampered vehicles,  the average emission  levels of the EPA
EF program  can be used  directly.   Implicit  in these totals are
the  various   effects   of   improper   purge    system   design,
malmaintenance/defects   and   RVP.   Tampering   is,   as  usual,
considered  separately.   The non-tampered  diurnal   and hot-soak
emission  rates  for  1981-89  models,  respectively,  and  their
reduction from baseline  levels  are shown in Tables  5-3 and 5-4.

     4.    Pre-1981 LDVs:  In-Use RVP Control

     Evaporative   emissions    estimates   for   pre-1981   LDVs
operating on  ll.5-psi  fuel were  derived  for  MOBILES,  based on
limited test  data,  in  mid-1984.[1]   Since  that time, API  has
tested  14  1978-80  vehicles   (certified  to  the  6-gram  SHED
standard)  on  both  Indolene   and  commercial  fuels.[2]    In
general,  API's results  on  both Indolene  and the  commercial
fuels show higher  emissions than  those of  EPA's  EF program (see
Table  5-5), but the API vehicle mileage is over 3  times higher,
possibly explaining the  difference.   For  MOBILES,  the  6-gram
SHED emissions  were assumed to equal  the  2-gram SHED emissions
because Indolene data  on both  sets of cars showed  very similar
results.  While the API  sample included only  14 vehicles, these
results  represent  actual test  data  at  reasonable  mileages.
Thus,   the  API   data   for   1978-80   vehicles   appear  more
representative  and  have  been  substituted   for  the  original
MOBILES estimates.

     API's  tests  were  conducted only on  models  from 1978-80.
Given  the   lack  of  any  new  data on pre-1978  vehicles,  the
MOBILES estimates  for these  earlier  models have  been retained
for this analysis.

-------
                               5-8
                           Table  5-3

          Diurnal  Emissions from Non-Tampered  1981-1989
        LDVs Under In-Use RVP Control Scenarios (g/test)

                           	In-Use RVP (psi)
                Baseline*  9.0   9.5  10.0  10.5  11.0  11.5

Carbureted Vehicles

Non-Tampered
  Vehicle Total     9.01   2.32  3.04  4.06  5.40  7.05  9.01

Reduction from
 Baseline (%)        -     74    66     55    40    22      0


Fuel-Injected Vehicles

Non-Tampered
  Vehicles Total    5.51   1.25  1.59  1.93  2.34  3.68  5.51

Reduction from
 Baseline (%)        -     77    71     65    58    33      0


*"Baseline"  indicates  in-use RVP =  11.5 psi, certification
     RVP =9.0 psi.

-------
                               5-9
                            Table  5-4

         Hot-Soak Emissions from Non-Tampered 1981-1989
        LDVs Under In-Use RVP Control Scenarios (g/test)

                           	In-Use RVP (psi)
                Baseline*  9.0   9.5  10.0  10.5  11.0  11.5

Carbureted Vehicles

Non-Tampered
  Vehicle Total    3.84    2.32  2.46  2.68  2.98  3.37  3.84

Reduction from
 Baseline (%)       -      40   36     30    22    12      0


Fuel-Injected Vehicles

Non-Tampered
  Vehicle Total    1.83    0.90  1.08  1.27  1.46  1.65  1.83

Reduction from
 Baseline (%)       -      51   41     31    20    10      0
*    "Baseline" indicates  in-use RVP =  11.5  psi, certification
     RVP =9.0 psi.

-------
                            5-10

                         Table  5-5
Evaporative Emissions Testing on Non-Tampered 1978-1980 LDVs

Fuel
RVP
9.0
9.0
10.5
10.5
11.5
11.5


Test Program
EF
API
EF
API
EF*
API**
* Original MOBILES
** Rovi R»H MnRTT.F"* i
No. of
Vehicles
Tested
124
14
__
14
— — -
14
figures.
:i cmr«ie ( APT '
Mean
Odometer
(Miles)
14,100
49,040
—
49,040
__
49,040
R 1-e»fi1- Hal-;

Emissions
Hot Soak
2.27
2.44
—
2.81
3.98
3.29
^

(q/test)
Diurnal
3.08
5.16
—
9.77
9.31
15.12


-------
                              5-11


     5.    Summary of LDV Emission Factors

     The resulting non-tampered  LDV  evaporative emission rates,
in terms of  g/test,  under the various RVP control scenarios are
shown in Table 5-6.  Here, the carbureted and fuel-injected LDV
emission  rates  shown  in  Tables 5-1  through 5-5  are  weighted
together based on MOBILES  model-year  sales projections.[1]  For
both  the  long-term  and  short-term  control  strategies,  the
emission rates can  be  determined by choosing  the appropriate
in-use RVP scenario.

     B.    Light-Duty Trucks and Heavy-Duty Vehicles

     The  MOBILES  evaporative   emission   estimates  for  LDTiS
(6000 Ibs.  GVW* and less) are essentially  the same  as those for
LDVs.[l]   This  is based  on:  1)  the fact  that  the  emission
standards —  6 and  2  grams  in  1978  and  1981,  respectively  —
are  the same  for  both  LDVs  and  LDTiS,  and  2)  that early  EF
testing  of   LDVs   and   LDTiS  on    Indolene   showed   similar
results.  However, pre-1979  LDTs having  a GVW  over  6,000 Ibs,
now   designated   LDT2s,   were  previously   classified   as
heavy-duty vehicles  (HDVs); their  MOBILES emission factors are,
thus,  the  same  as  the  HDV  rates described  below.   Post-1978
emission  factors for  LDT2s  are the same  as those for  LDTiS
and LDVs in MOBILES.

     Because no new LDT data were  available  for this  study, the
MOBILES methodology  was  retained.   The changes  made  to  the LDV
data   (discussed  earlier)  are   also  reflected   in the  LDT
estimates  used.   These  LDTi  and  LDT2   emission  factors  are
summarized in  Tables  5-7 and  5-8,  respectively.   The post-1980
figures  in  the  tables differ from the LDV  rates  in Table 5-6
only   because   of   different   carbureted/fuel-injected   sales
weightingstl];  the  individual  rates,  if shown,  would be the
same  as  the   individual  carbureted  and   fuel-injected  LDV
estimates.

     The situation  is entirely  analogous  for HDVs.   No  new HDV
data are currently available  and the MOBILES  estimates  were  in
part based  on LDV emissions.[1]   Thus, the MOBILES methodology
is again used here,  but with the revised LDV  estimates.   The
HDV  emission  rates used  in this study are  summarized  in Table
5-9.
     Rated "gross vehicle weight".

-------
                                                   Table  5-6

                                 Non-Tampered LDV Evaporative HC Emission Rates
                                Under Various RVP Control  Scenarios (grams/test)
In-use Fuel
Model
Year
Low Altitude
pre-1971
1971
1972-77
1978-80
1981
1982
1983
1984
1985-86
1987-89
1990+
High Altitude
pre-1971
1971
1972-76
1977
1978-80
1981
1982
1983
1984+
9.0
H.S.

14.67
10.91
8.27
2.44
2.18
2.06
1.93
1.75
1.45
1.19
1.01

19.07
14.18
14.07
8.27
6.32
5.66
2.68
2.50
(Same

Dnl.

26.08
16.28
8.98
5.16
2.21
2.12
2.02
1.89
1.66
1.47
1.34

33.90
21.16
17.15
8.98
13.36
5.74
2.76
2.63
as Low
9.
H.S.

16.22
11.38
8.63
2.52
2.33
2.20
2.08
1.91
1.62
1.36
1.14

21.09
14.79
14.69
8.63
6.52
6.03
2.87
2.70
Altitude)
5
Dnl.

30.46
18.69
10.55
6.24
2.90
2.77
2.64
2.46
2.15
1.89
1.44

39.60
24.30
20.15
10.55
16.15
7.51
3.60
3.43

10.
H.S.

17.78
12.13
9.22
2.64
2.54
2.42
2.29
2.11
1.82
1.56
1.26

23.11
15.77
15.68
9.22
6.84
6.59
3.14
2.97

RVP (psi)*
0
Dnl.

34.84
22.13
12.80
7.77
3.86
3.68
3.48
3.21
2.77
2.37
1.54

45.30
28.77
24.44
12.80
20.13
10.01
4.78
4.52

10.
H.S.

19.34
13.17
10.02
2.81
2.84
2.70
2.56
2.37
2.05
1.77
1.38

25.14
17.13
17.05
10.02
7.28
7.35
3.51
3.33

5
Dnl.

39.22
26.61
15.72
9.77
5.12
4.84
4.56
4.18
3.54
2.97
1.64

50.99
34.59
30.02
15.72
25.31
13.25
6.30
5.93

11
H.S.

20.89
14.50
11.05
3.03
3.21
3.05
2.89
2.68
2.32
2.00
1.51

27.16
18.85
18.80
11.05
7.84
8.30
3.97
3.76

.0
Dnl.

43.61
32.12
19.31
12.23
6.73
6.43
6.12
5.70
5.00
4.37
1.74

56.69
41.75
36.88
19.31
31.68
17.44
8.36
7.96

11
H.S.

22.45
16.15
12.32
3.29
3.65
3.47
3.29
3.04
2.62
2.24
1.63

29.18
20.99
20.96
12.32
8.53
9.46
4.51
4.27

.5
Dnl.

47.99
38.58
23.53
15.12
8.68
8.37
8.04
7.61
6.87
6.22
1.84

62.38
50.16
44.93
23.53
39.16
24.47
10.88
10.45

Certification fuel RVP  is  assumed to be 9.0 psi  for all pre-1990 model years;  1990 and later vehicles are assumed to
be designed for an RVP equal to the in-use level (i.e., certification RVP = in-use RVP beginning in 1990).

-------
                                                    Table  5-7

                                 Non-Tampered LDTi  Evaporative  HC Emission  Rates
                                Under Various RVP Control Scenarios (grams/test)
In-use Fuel
Model
Year
Low Altitude
pre-1971
1971
1972-77
1978-80
1981-83
1984
1985
1986
1987
1988-89
1990+
High Altitude
pre-1971
1971
1972-76
1977
1978-81
1982-83
1984
1985
1986
1987
1988-89
1990+
9.
H.S.

14.67
10.91
8.27
2.44
2.32
2.09
1.86
1.64
1.44
1.19
1.01

19.07
14.18
14.07
8.27
6.32
3.01
2.72
2.42
2.13
1.87
1.54
1.31
0
Dnl.

26.08
16.28
8.98
5.16
2.32
2.14
1.97
1.80
1.65
1.47
1.34

33.90
21.16
17.15
8.98
13.36
3.01
2.79
2.57
2.34
2.15
1.91
1.74
9.
H.S.

16.22
11.38
8.63
2.52
2.46
2.24
2.02
1.80
1.60
1.36
1.14

21.09
14.79
14.69
8.63
6.52
3.19
2.91
2.62
2.34
2.09
1.77
1.48
5
Dnl.

30.46
18.69
10.55
6.24
3.04
2.80
2.57
2.34
2.14
1.89
1.44

39.60
24.30
20.15
10.55
16.15
3.95
3.65
3.35
3.04
2.78
2.45
1.87
10.
H.S.

17.78
12.13
9.22
2.64
2.68
2.45
2.23
2.00
1.80
1.56
1.26

23.11
15.77
15.68
9.22
6.84
3.48
3.19
2.89
2.60
2.35
2.03
1.64
RVP (psi)*
0
Dnl.

34.84
22.13
12.80
7.77
4.06
3.72
3.38
3.04
2.74
2.37
1.54

45.30
28.77
24.44
12.80
20.13
5.28
4.84
4.40
3.96
3.57
3.08
2.00
10.
H.S.

19.34
13.17
10.02
2.81
2.98
2.74
2.49
2.25
2.04
1.77
1.38

25.14
17.13
17.05
10.02
7.28
3.87
3.56
3.24
2.92
2.65
2.30
1.79
5
Dnl.

39.22
26.61
15.72
9.77
5.40
4.91
4.42
3.93
3.51
2.97
1.64

50.99
34.59
30.02
15.72
25.31
7.02
6.39
5.75
5.11
4.56
3.86
2.13
11.
H.S.

20.89
14.50
11.05
3.03
3.37
3.09
2.82
2.54
2.30
2.00
1.51

27.16
18.85
18.80
11.05
7.84
4.38
4.02
3.66
3.30
2.99
2.60
1.96
0
Dnl.

43.61
32.12
19.31
12.23
7.05
6.51
5.97
5.43
4.96
4.37
1.74

56.69
41.75
36.88
19.31
31.68
9.17
8.47
7.77
7.07
6.45
5.69
2.26
11
H.S.

22.45
16.15
12.32
3.29
3.84
3.52
3.20
2.88
2.60
2.24
1.63

29.18
20.99
20.96
12.32
8.53
4.99
4.57
4.16
3.74
3.37
2.92
2.12
.5
Dnl.

47.99
38.58
23.53
15.12
9.01
8.45
7.89
7.33
6.84
6.22
1.84

62.38
50.16
44.93
23.53
39.16
11.71
10.98
10.25
9.52
8.89
8.09
2.39
Certification fuel RVP  is assumed to be  9.0  psi for all pre-1990 model years; 1990 and later vehicles are assumed to
be designed for an RVP equal to the in-use level (i.e., certification RVP = in-use RVP beginning in 1990).

-------
                                                    Table  5-8

                                 Non-Tampered LDT2  Evaporative HC Emission Rates
                                Under Various RVP Control Scenarios (grams/test)
In-use Fuel
Model
Year
Low Altitude
pre-1979
1979-80
1981-83
1984
1985
1986
1987
1988-89
1990+
High Altitude
pre-1979
1979-81
1982-83
1984
1985
1986
1987
1988-89
1990+
9.
H.S.

18.08
2.44
2.32
2.09
1.86
1.64
1.44
1.19
1.01

23.50
6.32
3.01
2.72
2.42
2.13
1.87
1.54
1.31
0
Dnl.

42.33
5.16
2.32
2.14
1.97
1.80
1.65
1.47
1.34

55.03
13.36
3.01
2.79
2.57
2.34
2.15
1.91
1.74
9.
H.S.

20.00
2.52
2.46
2.24
1.02
1.80
1.60
1.36
1.14

26.00
6.52
3.19
2.91
2.62
2.34
2.09
1.77
1.48
5
Dnl.

49.44
6.24
3.04
2.80
2.57
2.34
2.14
1.89
1.44

64.27
16.15
3.95
3.65
3.35
3.04
2.78
2.45
1.87
10.
H.S.

21.91
2.64
2.68
2.45
2.23
2.00
1.80
1.56
1.26

28.49
6.84
3.48
3.19
2.89
2.60
2.35
2.03
1.64
RVP (psi)*
0
Dnl.

56.55
7.77
4.06
3.72
3.38
3.04
2.74
2.37
1.54

73.52
20.13
5.28
4.84
4.40
3.96
3.57
3.08
2.00
10
H.S.

23.83
2.81
2.98
2.74
2.49
2.25
2.04
1.77
1.38

30.98
7.28
3.87
3.56
3.24
2.92
2.65
2.30
1.79
.5
Dnl.

63.66
9.77
5.40
4.91
4.42
3.93
3.51
2.97
1.64

82.76
25.31
7.02
6.39
5.75
5.11
4.56
3.86
2.13
11.
H.S.

25.75
3.03
3.37
3.09
2.82
2.54
2.30
2.00
1.51

33.47
7.84
4.38
4.02
3.66
3.30
2.99
2.60
1.96
0
Dnl.

70.78
12.23
7.05
6.51
5.97
5.43
4.96
4.37
1.74

92.01
31.68
9.17
8.47
7.77
7.07
6.45
5.69
2.26
11
H.S.

27.66
3.29
3.84
3.52
3.20
2.88
2.60
2.24
1.63

35.96
8.53
4.99
4.57
4.16
3.74
3.37
2.92
2.12
.5
Dnl.

77.89
15.12
9.01
8.45
7.89
7.33
6.84
6.22
1.84

101.25 ^
39.16 *
11.71
10.98
10.25
9.52
8.89
8.09
2.39
Certification fuel RVP is assumed to be 9.0 psi for all pre-1990 model years;  1990 and later vehicles are  assumed to
be designed for an RVP equal to the in-use level (i.e., certification RVP = in-use RVP beginning in 1990).

-------
                                                    Table  5-9

                                 Non-Tampered HDV Evaporative HC Emission Rates
                                Under Various RVP Control Scenarios (grams/test)
In-use Fuel
Model 9.
Year H.S.
Low Altitude
pre-1985 18.08
1985-1989 3.69
1990+ 3.06
High Altitude
pre-1985 23.50
1985-1989 4.80
1990+ 3.98
0
Dnl.

42.33
3.69
3.22

55.03
4.79
4.19
9.
H.S.

20.00
3.91
3.19

26.00
5.08
4.15
5
Dnl.

49.44
4.83
3.38

64.28
6.28
4.39
10.
H.S.

21.91
4.26
3.32

28.49
5.54
4.32
RVP (psi)*
0
Dnl.

56.55
6.47
3.54

73.52
8.42
4.60
10
H.S.

23.83
4.75
3.45

30.98
6.17
4.49
.5
Dnl.

63.66
8.60
3.70

82.76
11.19
4.81
11.
H.S.

25.75
5.36
3.57

33.47
6.97
4.64
0
Dnl.

70.78
11.23
3.86

92.01
14.60
5.02
11.
H.S.

27.66
6.11
3.70

35.96
7.95
4.81
5
Dnl.

77.89
14.34
4.02

101.25
18.65
5.23
Certification fuel RVP is assumed to be 9.0 psi for all pre-1990 model  years;  1990 and later vehicles are  assumed  to
be designed for an RVP equal to the in-use level (i.e., certification RVP = in-use RVP beginning in 1990).

-------
                              5-16
III.  Motor Vehicle Exhaust Emission Factors

     As  discussed  in  detail  in  Chapter  2,  EPA's  in-use  EF
testing  indicates that  fuel  RVP  has an effect on exhaust HC and
CO emissions from current  vehicles;  no effect on NOx  emissions
was shown to be present. [3]   This effect on HC and CO emissions
appears  to be  basically linear with  RVP and was accounted for
in this  analysis by applying multiplicative  factors for  each
RVP scenario  to the original  MOBILES exhaust emission  factors
published  in   June  1984.   These   multiplicative   adjustment
factors  are  shown  in  Tables 5-10  and  5-11  for  HC  and  CO,
respectively.*   The  "base"  case  in the  tables,  as  before,
refers to  an in-use RVP  of  11.5 psi  and  a certification  fuel
RVP of 9.0 psi  (current);  the other RVP scenarios (11.5 down to
9.0 psi) indicate  the  long-term  control  options where  in-use
RVP is  assumed to equal certification fuel  RVP  (beginning with
the 1990 model year).

     Original  MOBILES   exhaust  emission  factors  (published  in
June 1984) were based on an in-use RVP  of roughly  11.5  psi and
a  certification fuel  RVP  of 9.0 psi,  which  represents  the
baseline  RVP  scenario.   Therefore,  no  exhaust  adjustment  is
necessary under  the  base case, as  indicated by the  factors  of
1.00 in  Tables  5-10  and 5-11.  Also, no adjustment is necessary
for those model  year  vehicles   that were  not  equipped  with
evaporative  control  systems  (i.e.,  pre-1971 LDGVs  and  LDG^s,
pre-1979  LDGT2s,  and pre-1985  HDGVs).  This  is based  on  the
conclusion made in  Chapter 2 that the RVP effect on exhaust HC
and CO  is related to the purging  of the evaporative  canister
and not  to  the combustion of fuel  inducted  via  the carburetor;
therefore,  no  adjustment  is  made   for  these   model   years,
regardless of  RVP  level  (i.e.,  the  original MOBILES  estimates
are used).

     As  is  the  case with all  in-use EF  testing,   the  exhaust
emissions  effect   was  measured  only  for  vehicles   whose
evaporative  control systems  were  designed  for  Indolene  (9.0
psi)  and operated  on  fuels  of  various  RVPs.   These  data were
used to  develop the exhaust adjustment  factors  at  each  RVP
level  shown  in  Tables  5-10  and  5-11 for the pre-1990  models.
As shown,  no adjustment  is  necessary for these  vehicles  under
the ll.5-psi  RVP scenario, as these  pre-1990 model  years  still
     Although  adjustment  factors  for  both  HC   and  CO  are
     presented,  the  remainder  of  the  study focuses only  on
     non-methane   hydrocarbons.    The   possible   CO   benefits
     achievable  with in-use RVP  control were not  incorporated
     into this  study,  but could  enter  into cost  effectiveness
     calculations in future analyses.

-------
                                   5-17
                                Table 5-10

                      Exhaust HC Adjustment Factors*
Model Years

LDGV
  pre-1971
  1971-80
  1981-89
  1990 +

LDGT,
  pre-1971
  1971-83
  1984-89
  1990+

LDGT 2
  pre-1979
  1979-83
  1984-89
  1990+

HDGV
  pre-1985
  1985-89
  1990+
RVP Scenarios
Base
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
11
1.
1.
1.
0.
1.
1.
1.
0.
1.
1.
1.
0.
1.
1.
0.
.5
000
000
000
846
000
000
000
846
000
000
000
846
000
000
956
11
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
.0
000
991
969
846
000
991
969
846
000
991
969
846
000
991
956
10
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
.5
000
982
938
846
000
982
938
846
000
982
938
846
000
982
956
(psi)
10
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
.0
000
973
907
846
000
973
907
846
000
973
907
846
000
973
956
9
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
.5
000
965
877
846
000
965
877
846
000
965
877
846
000
965
956
9.0
1.000
0.956
0.846
0.846
1.000
0.956
0.846
0.846
1.000
0.956
0.846
0.846
1.000
0.956
0.956
     To be multiplied by June 1984 MOBILES exhaust HC factors.

-------
                                   5-18
                                Table 5-11

                      Exhaust CO Adjustment Factors*
Model Years

LDGV
  pre-1971
  1971-80
  1981-89
  1990+

LDGTi
  pre-1971
  1971-83
  1984-89
  1990+

LDGT2
  pre-1979
  1979-83
  1984-89
  1990+
HDGV
  pre-1985
  1985-89
  1990+
RVP Scenarios
Base
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
11
1.
1.
1.
0.
1.
1.
1.
0.
1.
1.
1.
0.
1.
1.
0.
.5
000
000
000
809
000
000
000
809
000
000
000
809
000
000
924
11
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
.0
000
985
962
809
000
985
962
809
000
985
962
809
000
985
924
10
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
.5
000
970
924
809
000
970
924
809
000
970
924
809
000
970
924
(psi)
10
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
.0
000
955
886
809
000
955
886
809
000
955
886
809
000
955
924
9
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
0.
1.
0.
0.
.5
000
939
848
809
000
939
848
809
000
939
848
809
000
939
924
9.0
1.000
0.924
0.809
0.809
1.000
0.924
0.809
0.809
1.000
0.924
0.809
0.809
1.000
0.924
0.924
     To be multiplied by June 1984 MOBILES exhaust CO factors.

-------
                              5-19


represent  the baseline  case (designed  for  9.0  psi);  however,
this  is not  the  case for  1990  and later vehicles  which,  under
the  long-term  control  scenarios,  would  be  designed for  the
in-use fuel RVP.

     As concluded in  Chapter  2,  the  effect  of  in-use RVP  on
exhaust emissions is assumed to  be eliminated if  vehicles  are
operated  on  the  same  RVP  fuel  for  which  they  were  designed
(i.e.,  in-use RVP equal  to certification RVP).   Therefore,  in
all  of the   long-term  strategies  examined  in  this  chapter,
original   MOBILES  exhaust  emission   factors   estimated   for
post-1989  vehicles  are  adjusted  by the  same factor as  that
calculated for the 9.0-psi RVP  scenario for the preceding model
year  group,  which was designed  for 9.0 psi.   In  other  words,
the  level of  in-use fuel  RVP  is  irrelevant  as  long as  it  is
equal to  certification fuel RVP.   The  adjustment  factor  shown
in  Tables 5-10  and  5-11  for  1989 vehicles  (designed for  9.0
psi) under the 9.0-psi in-use RVP scenario  is  representative of
this  situation  and is, therefore,  assumed to  apply to all 1990
and  later models  as well,  except of  course  for  the baseline
case where no change in certification fuel is made.

IV.  Effect of In-Use RVP Control on Gasoline Storage
     and Distribution Losses

     While this  study  focuses  primarily on the  non-compliance
of   in-use  motor   vehicles   with  the  current   evaporative
standards, one  of the strategies  being considered  to  control
this  evaporative  excess  would also have an  impact on emissions
from  stationary   sources.   As  the  levels  of  evaporative  HCs
emitted  during  the  storage and handling  of gasoline  are  a
function  of  true  vapor pressure (which is dependent  upon  RVP),
the  control   of   in-use  gasoline volatility  would  affect  the
level of  emissions from these  sources.  Of  course,  the  other
strategies being examined  (changes to certification fuel  and
test  procedure)   would  have  no  impact  on  these  stationary
sources as  they  involve  only  a  change in the  design of  new
vehicles.

     The  following sections  deal  with  the effect of  in-use  RVP
control on each  of  three  basic categories of  gasoline  storage
and  distribution  losses:   1)  bulk storage  and  bulk  transfer
losses, 2) service station  (Stage  I) emissions,  and 3)  vehicle
refueling  losses.  Evaporative emission rates  for these  sources
are  commonly expressed in terms  of grams of  HC  vapor lost  per
gallon of gasoline stored or transferred.

-------
                              5-20
     A.    Bulk Storage and Transfer Losses

     This  first  category  consists  mainly  of  breathing  and
working (i.e., loading and unloading)  losses  resulting from the
storage  of  gasoline  in  bulk  terminals  and  the transfer  of
gasoline  to  tankers,  ships,  and  barges  used  for  transport.
Emission  rates  associated with bulk  storage  are dependent upon
various factors  such as  tank  configuration  (fixed or floating
roof),    tank   dimensions,    ambient   and    liquid   storage
temperatures,  and   vapor molecular   weight  and  true  vapor
pressure   (both  dependent   upon   the  RVP  of  the  gasoline).
Emissions  incurred  during the loading  of  cargo  carriers  are
dependent  upon the  method  of filling  (submerged or splash),
bulk  temperature  of  liquid,  and  the RVP-dependent  parameters
mentioned   above.     Equations   defining  specific    types   of
evaporative  losses (e.g., breathing,  loading)  as a function of
these  and other  parameters were developed for  various types of
storage and transport mediums and were published in EPA's AP-42
Document.[4]

     The   impact  of  controlling   in-use   fuel  volatility  on
evaporative  emissions from  the bulk  storage  and transfer  of
gasoline  was  determined  using the  various  AP-42  equations.
Holding   the  non-fuel-related  parameters  in   the   equations
constant,   it was  estimated that a  reduction  in  in-use RVP from
11.5  to  9.0 psi would result  in  a  20-28  percent decrease in
evaporative   losses   from bulk  storage  terminals   (magnitude
dependent  upon   tank  configuration  and   type  of    loss   —
breathing,  working,   or   standing).[4]   With  respect  to  cargo
loading,  the same decrease  in  RVP  should  reduce  evaporative
losses  by  approximately  20  percent.[4]  Inventories  for  the
various  types  of  losses in  the  bulk  storage  and  transfer
category  were  adjusted   by  the  appropriate  factors  and  were
incorporated  into  this analysis  under  all  control  strategies
involving  the regulation  of  in-use fuel volatility.   Estimates
for  the  intermediate  in-use RVP  scenarios   (e.g.,   10.0,  11.0
psi)  were  derived  through  linear   interpolation  between  the
inventories associated with the 9.0- and 11.5-psi options.

     B.    Service Station (Stage I) Losses

     This second stationary category  includes  the  breathing and
loading losses  associated with underground storage  facilities
at  service stations.  Losses   in  this  category are  sometimes
referred  to  as  "Stage I,"  designating emissions between  the
tank truck and the service station.   Emission rates  from these
sources  are  primarily based  on  the  same parameters as  the
breathing and loading losses  described in the previous section.

-------
                              5-21


     As  before,  the  estimated  reduction  in  Stage  I  losses
resulting from a 2.5-psi decrease in in-use fuel  RVP  is between
20 and 28 percent. [4]   In this analysis, Stage I emissions were
handled  as   one broad  category  and  an  estimated  23-percent
reduction was  assumed  for the  9.0-psi  in-use RVP  scenario;  as
before,  emissions  for  the  intermediate in-use  RVP  scenarios
were developed using linear interpolation.

     C.    Refueling Losses

     Refueling  losses  refer  to the vapors that  escape into the
atmosphere  while dispensing  gasoline  from  a  service  station
pump into a vehicle's fuel  tank.   The  refueling  emission rate
is  dependent   upon   the  RVP   of   the  fuel,   the   dispensed
temperature  of  the  fuel,  and  the  temperature  differential
between the dispensed fuel and the  liquid already  in  the tank.
In  support  of  pending  EPA  actions  regarding  the control  of
refueling  emissions   (the onboard  versus  "Stage  II"  issue),
extensive tests were  conducted  to  determine the  relationship
between refueling emission levels (in terms of grams  per gallon
of fuel dispensed) and  the above parameters.   The derivation of
an equation  relating these parameters  is documented  in  an EPA
technical report.[5]

     In  order  to  determine  (for this  analysis) the  effect  of
in-use RVP reductions  on uncontrolled  refueling  emissions,  the
equation  developed  from  the  refueling test  data  was  used.
Assuming nationwide  average  summertime  conditions  — dispensed
temperature  9.4°F  less  than  fuel  tank temperature,  with  a
dispensed temperature  of  78.8°F — the impact  of  in-use  RVP
control was determined.   In  addition to the displacement losses
calculated with the refueling equation, a  spillage  factor  of
0.3 g/gal  (5-6 percent of the total refueling  loss), which is
unaffected by  RVP,  was  also  included  in the overall emission
factors.   With  a reduction in RVP from 11.5 psi to 9.0 psi, the
uncontrolled   refueling   emission   rate   under   the   above
temperature conditions is  estimated  to  decrease from 6.0 to 4.8
grams/gallon,  or  by 20  percent.   As  the  equation  used  to
calculate these refueling rates  is  linear,  values for  each  of
the intermediate RVP  control scenarios  were  determined through
interpolation.

     D.    Non-RVP-Related Controls

     Regardless  of  whether  in-use  RVP  control  is implemented,
EPA, states and local  areas have established equipment-related
controls for  stationary sources that must  be accounted  for  in
modelling future hydrocarbon emissions.  The  Clean Air  Act  as
amended  in  1977 requires  that hydrocarbon emissions  from both
new  and  existing  stationary  sources   in ozone  non-attainment
areas  be controlled to  the  lowest  achievable  levels;  EPA has
interpreted  this as those levels  achievable with "reasonably

-------
                              5-22


available control technology"  (RACT),  which varies  from  source
to  source.    To  assist  the  states   in   developing  control
regulations consistent  with RACT  levels,  EPA's  Office of  Air
Quality  Planning  and  Standards  (OAQPS)  issued,  in  the  late
1970's,  several  control technique  guideline  (CTG)  documents
relevant  to  various   sources  associated   with  the   gasoline
marketing  industry.[6-11]   These  CTGs  assessed  the technology
available to  control  HC emissions from various  sources  such as
bulk   storage   terminals,   gasoline   tank   trucks,    loading
operations, etc.,  and provided estimates of the emission  rates
achievable with the RACT level of  control.

     The Clean Air  Act  Amendments  of  1977  also stated that  all
areas  were  to be  in  compliance with the  ozone NAAQS by  1982;
therefore, this  date  was originally  projected  as  the year  by
which  RACT  levels of  control would  be fully  implemented  on HC
sources  in the  non-attainment areas  of  the  late 1970's  and
1980's.  In  anticipation of  full  implementation  by 1982,  RACT
began  being  applied  to some  sources  (primarily new  sources)
following publication  of the CTGs in  1977 and  1978.   However,
RACT was not  fully  implemented  by 1982 and indeed  is  not  fully
in place  at the time  of this analysis; as  outlined earlier,  an
estimated 54 urban areas are currently out of  compliance  and 35
have  requested  an  extension of  the attainment  date  to  1987.
For purposes  of  this  analysis,  it was  assumed that RACT  would
be fully  implemented  by 1988, which is  the  earliest projection
year examined in this  report.

     The emissions  control  efficiencies and  source growth  and
retirement  (or  replacement) rates to be  assumed  in  modelling
future  HC  emissions  from  these   stationary  sources   were
evaluated  in  a  1980  EPA   report.[12]   Using  the RACT-based
emission rates outlined  in  the  CTGs,  it was estimated that  the
HC emissions  reduction  achievable with full  implementation of
RACT was  roughly 80 percent  in both the bulk storage/transfer
and  Stage I  categories.[12]   The  net  growth  and replacement
rates  (respectively)  for both  of these categories,  based  on
projections of  future earnings in the petroleum industry,  were
estimated  at   1.9   and  4.5   percent   per   year,  compounded
annually.[12]

     The  control efficiencies  estimated above  are applicable
only  to base  emissions  at   the pre-RACT level  typical of  the
late  1970's  (when the CTGs  were  published).  The  HC  emissions
projections made for  this   analysis  were  based on the  NEDS*
     NEDS  is the  National  Emissions  Data  System, from  which
     emissions inventories  are  compiled by  EPA's  National  Air
     Data  Branch  within   OAQPS;  the   most  recent  inventory
     available at  the time  of  this  analysis  was  for  calendar
     year 1982.

-------
                              5-23


inventory  for  1982,  a year  by which some  sources  had already
been  controlled to  the  RACT level.   Between  1978 and  1982,
limited  implementation  of  RACT  resulted  in  a  reduction  of
approximately 14-15 percent  in average  emission rates from bulk
storage and transfer sources and an  almost  negligible 4 percent
in  Stage  I  losses  (measured  from  1978  levels).[13]   This
partial  implementation  of  RACT  was  accounted  for  in  this
analysis  by  modifying  the  control  efficiencies  used in  the
model.  Instead of  applying the 80-percent control recommended
for  both  categories,  a  76-percent  reduction from  average 1982
bulk  storage/transfer  emission  rates  was  estimated  to  be
achievable with full   implementation of RACT;  for  the  Stage I
category,  the recommended  control efficiency  was reduced  to 79
percent to account  for  the slight  implementation of  RACT in
this area.

V.   Hydrocarbon Emissions Inventory Analysis

     MOBILES    is   EPA's   current   model    for    estimating
calendar-year   fleet-average  emission   factors   for   various
gaseous pollutants.    In  calculating evaporative   HC  emission
factors (included  in  total  non-methane  hydrocarbons,  or NMHCs)
for  this  analysis,  the model-year  hot-soak and  diurnal  losses
estimated  earlier  for each  of the  various control strategies
serve   as   inputs  to   MOBILES.     Within   the  model,   these
evaporative losses  (in  terms  of grams/test)  are  converted to
grams/mile  using  estimates  of  average trips  made and  miles
driven each day.  The  June 1984  version of MOBILES  assumed that
these values  were constant  over all model years, but  recent
work  supports the  theory  that older vehicles make fewer  trips
and  travel  less miles than  new  vehicles.[14]   Because  this is
probably  more  realistic  than  the  assumptions   within  the
originally  published   MOBILES,   inputs   for   miles/day   and
trips/day  have  been  revised  and  were  used to  calculate  the
evaporative emission factors used in this analysis.

     Emissions  inventories for various  source categories  were
then  calculated for the  nation  (excluding California)  and for
the  47  non-California  urban  areas that  are   currently  in
non-attainment  of the  ozone NAAQS.*  (The  specific cities were
*    Nationwide  inventories  were  converted  to  non-California
     inventories   assuming   that   California   accounts   for
     approximately  11  percent  of total  nationwide  emissions.
     This   figure   is   fuel-consumption   based,  so   may  not
     necessarily  apply  to  all  stationary  sources.   However,
     because   the    control   programs   will    affect    only
     gasoline-related  sources,   the   11-percent  figure   was
     applied  to  all  entire  inventories  to  put  the  emissions
     reductions in the proper perspective.

-------
                              5-24


listed  earlier  in  Table  2-1   of   Chapter  2.)   All  future
projections are  based  on the  1982 NEDS inventory  for  volatile
organic  carbons  (VOCs),  or  NMHCs.    To   the  motor   vehicle
portions  of  this  inventory  are  applied  annual  compound  VMT
growth rates (calculated for  each vehicle  class via the MOBILES
Fuel  Consumption Model,  or  FCM)  and  emission  factor  ratios
(future to  base year)  from  the  M05ILE3 runs.   Projections  of
stationary source emissions are based  on the annual growth  and
retirement  rates,   along with  emission  control  efficiencies,
discussed in the previous section.   Of  course,  the  stationary
sources that  contribute to  evaporative HC  emissions  (gasoline
storage and distribution) have been the  focus  above,  since they
are  affected  by fuel  RVP,  but  all  sources  of  NMHC  emissions
have  been  included  in  the  modeling  with  their  respective
growth, retirement,  and control estimates.t12]

     Baseline   NMHC  emissions   inventories   were   calculated
assuming  that  an in-use  RVP of  11.5 psi  and a certification
fuel RVP of 9.0  psi would continue through the year 2010;  these
inventories will be  presented along  with those for the control
cases  in  the tables discussed in the following sections.   To
put  the various sources of NMHC  emissions into  perspective,  a
breakdown  of  future  total  baseline  emissions  is  presented
graphically in  Figures  5-la  and  5-lb for  calendar years  1988
and  2010.   In Figure 5-la,  the inventories are broken down into
six  categories:    motor   vehicle  evaporative   losses,   motor
vehicle exhaust emissions,  refueling,  Stage  I,   bulk  storage,
and  others  (consisting  of off-highway and  non-gasoline-related
stationary sources).   As shown,  the  "others"  category is  the
largest in both years,  representing  approximately 61-72 percent
of total NMHC emissions.  Motor vehicle  emissions (evaporative,
exhaust, and refueling losses) make up roughly  24-36  percent  of
the  total.   The lower  end of  the  range  is representative  of
2010,  as  motor vehicle emissions will  decrease  with  time  in
response  to  evaporative and  exhaust  HC standards  and  improved
fuel economies  (used to convert refueling  losses  from  g/gal  to
g/mi).

     Figure  5-lb breaks  motor  vehicle  evaporative  emissions
down further  into  the  five  components  discussed in detail  in
Chapter 2 (Section  V).  These  sources of evaporative  losses
are:   properly  designed  vehicles   (meeting   the  standards),
improper design of  purge  system,  malmaintenance/defects,  excess
in-use RVP, and  evaporative system tampering.   As  indicated  in
Figure  5-lb,   the  RVP  effect is   the  largest   of  the  five,
contributing to  approximately 35  percent  of total  evaporative
losses.

     The  following   inventory discussion begins  with  estimates
of future NMHC  emissions  under  the  long-term  control  scenarios
—  in-use RVP   equal   to  certification  fuel  RVP,  at  various

-------
                         5-25
                      Figure  5-la
  Non-Calif. NMHC Inventory—Baseline (11.5-psi RVP)
    laoeo
    13000-

    14000-

    15

    12

    11

    1
          1988
                                    2010
   1771
  Bulk
Storage
Stage    Re-    MV
  I    fueling  Exh
                                      MV
                                      Evap.
Others
                       Figure 5-lb
Non-Calif. MV Evap.  Inventory—Baseline (11.5-psi RVF)
    11
    170O-
    1
 «  isoo
 8
 o
 =   TOO-
 4J
 i
     100 -
      c
                        1988
                     .  2010
          Prop.
       Designed
     Imp.  Malm./   RVF     Tampering
    Purge   Def.  Excess

-------
                              5-26


volatility levels.  The  next  section focuses on  the  short-term
additional control  of  in-use RVP,  where  in-use volatility  is
temporarily  controlled  to  a  level   lower  than  the  long-term
certification fuel RVP  specification.   (For  a review of the two
control  scenarios  and the RVP  options under each, see Section
VI  of  Chapter  2.)   It  should  be  noted  that  this  chapter
incorporates  a  year-round   analysis;  in  other  words,   the
emissions  results presented  in  Tables 5-12  through  5-15  are
based  on year-round  control  of  in-use and certification  fuel
RVPs.   (Both 4-month  and  12-month  analyses  will be  presented
later  in Chapter 6.)   Also,  an  inspection/maintenance program
for  exhaust  emissions is assumed  to be in effect  in  all areas
through 2010.

     A.    Long-Term Analysis

     Long-term   control   involves  changes  to   in-use  and/or
certification  fuel  RVPs to  make  the  two  equal to each other.
For this  analysis,  in-use  fuel  control was assumed to  begin  in
1988,  and certification fuel  and test procedure changes would
start  with  the  1990   model  year.   Six   long-term  control
scenarios were examined, with RVPs ranging between 9.0 and 11.5
psi.

     Table 5-12  presents future non-California  NMHC inventories
estimated  for  the baseline  case  (shown  previously in Figures
5-la and 5-lb)   and the six  long-term control strategies.   As
shown,  the control  of  in-use  RVP to  a level of  9.0  psi, while
holding  certification fuel RVP  at its current 9.0  psi, results
in the  largest change — almost a 7-percent  reduction in total
annual non-California NMHC emissions in the year 2010.

     The  tonnage reductions estimated  to  be achievable in  1988
and  2010 with  this 9.0-psi control  case are  shown graphically
in Figures  5-2a  and  5-2b.   As  indicated  in  the  top figure,
in-use RVP control  (along with revised test  procedure) reduces
emissions  from  the following five  categories:   motor  vehicle
evaporative  losses, motor vehicle  exhaust  emissions,  refueling,
Stage I,  and bulk storage.  As  evaporative emissions  from motor
vehicles  are the focus  of the  control programs  being examined
in  this  analysis,  it  is  not  surprising  that  the  largest
reductions are  predicted  for  this  category;  as  indicated  in
Figure 5-2a,  72  and  62 percent of the  total NMHC reductions  in
1988  and 2010,  respectively,  are  projected  to occur  in  the
motor vehicle evaporative category.

-------
                              5-27
                           Table 5-12

           Non-California NMHC Emissions  Inventories
                Under Long-Term Control Options*
Scenario    RVP (psi)
B

1

2

3

4

5

6
    Baseline case **

    11.5

    11.0

    10.5

    10.0

     9.5

     9.0
   NMHC,  1000 tons/year(% Reduction)
   1988        1995         2010

14,307(0)   13,350(0)    15,298(0)

14,307(0)   13,125(1.7)  14,714(3.8)

14,024(2.0) 12,958(2.9)  14,629(4.4)

13,769(3.8) 12,807(4.1)  14,543(4.9)

13,553(5.3) 12,676(5.1)  14,458(5.5)

13,360(6.6) 12,553(6.0)  14,374(6.0)

13,191(7.8) 12,439(6.8)  14,288(6.6)
**
California  emissions,  roughly  11  percent  of  nationwide
total,  were excluded.   Long-term  control  assumes  in-use
RVP and certification fuel  RVP will be equal, beginning in
1990;  in-use fuel changes would  occur  in  1988,  followed by
certification fuel changes  in  1990;  year-round RVP control
is assumed.
Baseline  case  refers  to  the  uncontrolled situation  in
ASTM's  "Class-C"  areas:   in-use  RVP  at  11.5  psi  and
certification fuel RVP equal to 9.0 psi.

-------
                          5-28
                      Figure 5-2a
   Non-Calif. NMHC Reductions—RVP Control  to 9..0 psi
   1300
   1100 H
I
8
r
                      1988         2010

          1771     re"^i     c^>    (S3
         Bulk    Stage    Re-    MV      MV
       Storage     I    fueling  Exh.    Evap.

                       Figure 5-2b
 Non-Calif.  MV Evap. Reductions—RVP Control  to  9.0  psi
    TOO -\
o
s
    400 -\
 I  „
                      1988
2010
                                          BED
                   Imp.   Malm./   RVP   Tampering
                  Purge    Def.   Excess

-------
                              5-29
     In   Figure   5-2b,  these   reductions  in   motor   vehicle
evaporative emissions  are broken  down further into  the various
components  shown  earlier   (in   Figure   5-lb).    Of  the  five
original  sources,  reductions occur  in  only three  in  1988  and
four  in 2010.  Emissions from  properly designed vehicles  will
not  be reduced,  as  these  vehicles  are  assumed to  meet  the
evaporative standards; therefore,  this category  does not appear
in Figure 5-2b.  A second category — improper purge design —
is not included in  the 1988  emissions  reductions  because  the
change  in test procedure that would address this problem would
not  be implemented until 1990;  therefore, this  component  does
contribute to the reductions in the year 2010.   As  indicated in
the  figure, the  largest reductions are  achievable in the excess
RVP  category  —  61-77 percent of motor  vehicle  evaporative HC
reductions    are   predicted   to   occur   here.    This    is
understandable,  in part, because  excess  RVP   is  the  largest
source  of  total  motor vehicle evaporative losses (as indicated
previously in Figure 5-lb).

     Combined inventories  for the  47  ozone non-attainment areas
examined  are  presented  in  Table  5-13.   These  non-California
urban  areas  (listed  in Chapter  2)  consist  of  45  low-altitude
and  2  high-altitude SMSAs.   Similar to  the nationwide analysis,
a 2.5-psi reduction in in-use RVP  (from the current 11.5  down
to 9.0  psi)  would  reduce  year 2010 emissions  in these  47 urban
areas by an estimated 7-8  percent.

     B.    Short-Term Analysis

     Tables  5-14  and  5-15  show  future  non-California   and
47-city NMHC  emissions inventories,  respectively,  estimated for
the  various short-term RVP  scenarios.   As the RVP  combinations
listed  in  these  tables   indicate,  this  short-term  strategy
involves temporary additional control of in-use  RVP to  a level
lower  than  the long-term certification  specification.   As  with
the  long-term scenario,  in-use  and  certification  changes  are
assumed to  take  place, respectively, in 1988 and  1990.   While
the    certification    fuel    specification    would    continue
indefinitely,  the  in-use  control  would  be  relaxed  after  a
specified  period of  time  and  in-use   and  certification  RVPs
would  become  egual.   Several time periods for  this short-term
control were evaluated;  scenarios  of   2,  4,  7,  and  9  years
(represented  by  1990, 1992,  1995, and  1997)  are shown  in  the
tables.   Of  course,   the  inventories presented  are  applicable
only  if  additional  in-use  control is  in  place  during  the
calendar  years  shown;  following   the  relaxation   of  in-use
control  to  the  long-term   certification  fuel   level,  annual
inventories would be those estimated  for the  long-term  strategy
under the appropriate  RVP  scenario (in Tables 5-12 and 5-13).

-------
                              5-30
                           Table 5-13

  Combined NMHC Emissions Inventories for 47 Urban Areas Under
Scenario
B
1
2
3
4
5
6
Lonq-Term
RVP (psi)
Baseline case **
11.5
11.0
10.5
10.0
9.5
9.0
Control Options*
NMHC, 1000 tons/year(%
1988 1995
5077(0) 4693(0)
5077(0) 4601(2.0)
4960(2.3) 4534(3.4)
4855(4.4) 4472(4.7)
4767(6.1) 4418(5.9)
4688(7.7) 4368(6.9)
4620(9.0) 4322(7.9)
Reduction)
2010
5465(0)
5229(4.3)
5193(5.0)
5158(5.6)
5122(6.3)
5087(6.9)
5051(7.6)
**
Long-term  control  assumes   in-use  RVP  and  certification
fuel  RVP will  be equal, beginning  in  1990;  in-use  fuel
changes  would  occur  in  1988,  followed by  certification
fuel changes in 1990;  year-round RVP control is assumed.
Baseline  case  refers  to the uncontrolled  situation  in
ASTM's  "Class-C"  areas:   in-use  RVP  at  11.5  psi  and
certification fuel RVP equal to 9.0 psi.

-------
                              5-31


                           Table 5-14

   Non-California* NMHC Emissions Inventories With Short-Term
Additional
Scenario
B
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Short-Term
In-Use RVP
(psi)
Baseline (11.5)
9.
9.
9.
9.
9.
10.
9.
9.
10.
10.
9.
9.
10.
10.
11.
0
0
5
0
5
0
0
5
0
5
0
5
0
5
0
In-Use
Long-Term
Cert . Fuel RVP
(psi)
i Basel
9
10
10
10
10
10
11
11
Jl
11
11
11
11
11
11
ine (9.
.5
.0
.0
.5
.5
.5
.0
.0
.0
.0
.5
.5
.5
.5
.5
RVP Control
NMHC (
1990
0) 13,
12,
12,
12,
12,
12,
13,
12,
12,
13,
13,
12,
12,
13,
13,
13,
821
795
795
950
795
950
124
795
950
124
320
795
950
124
320
553
1000
1992
13,
12,
12,
12,
12,
12,
12,
12,
12,
12,
13,
12,
12,
12,
13,
13,
513
550
550
687
550
687
838
550
687
838
004
550
687
838
004
200
tons/year)
1995
13,350
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
,439
,439
,553
,439
,553
,676
,439
,553
,676
,807
,439
,553
,676
,807
,958
1997
13,397
12,504
12,504
12,608
12,504
12,608
12,715
12,504
12,608
12,715
12,828
12,504
12,608
12,715
12,828
12,957
California  emissions,   roughly  11  percent  of  nationwide
total, are excluded.

-------
                           5-32



                        Table 5-15



Combined NMHC Emissions Inventories for 47 Urban Areas With
Additional Short-Term In-Use RVP Control
Scenario
B
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Short-Term
In-Use RVP
(psi)
Long-Term
Cert. Fuel RVP
(psi)
NMHC (1000
1990
Baseline (11.5) Baseline (9.0) 4877
9
9
9
9
9
10
9
9
10
10
9
9
10
10
11
.0
.0
.5
.0
.5
.0
.0
.5
.0
.5
.0
.5
.0
.5
.0
9
10
10
10
10
10
11
11
11
11
11
11
11
11
11
.5
.0
.0
.5
.5
.5
.0
.0
.0
.0
.5
.5
.5
.5
.5
4459
4459
4522
4459
4522
4593
4459
4522
4593
4671
4459
4522
4593
4671
4767
1992
4754
4362
4362
4417
4362
4417
4478
4362
4417
4478
4545
4362
4417
4478
4545
4625
tons/year )
1995
4693
4322
4322
4368
4322
4368
4418
4322
4368
4418
4472
4322
4368
4418
4472
4534
1997
4716
4351
4351
4394
4351
4394
4438
4351
4394
4438
4484
4351
4394
4438
4484
4537

-------
                              5-33


     In  comparing  the  inventories shown  in short-term  Tables
5-14 and  5-15  under different RVP strategies,  it  is  important
to note that the emissions  totals shown are dependent only upon
the  short-term  in-use RVP  listed.  In  other words,  the  1995
inventories shown  in Table  5-14  for scenario tt7  (in-use  = 9.0,
certification = 11.0) are the same as the 1995 figures  shown in
long-term Table 5-12 under  scenario 86  (in-use  = certification
= 9.0).   Inherent  in this is the assumption that  no  emissions
benefit will be  derived from the "overdesign"  of  the  canister
for  a  higher  RVP fuel  (i.e.,  a   vehicle  designed  for  ll.O-psi
fuel and  operated on  Indolene will emit the same amount  as  a
vehicle  both  designed  for   and   operated  on  Indolene).    This
assumption  is   best  explained   by   referring  to  the  five
components  of  motor vehicle  evaporative  emissions  discussed
earlier  in  Section  II  of this  chapter  (and in more detail in
Chapter 2) .

     As the source breakdowns in  Tables 5-1  and  5-2  indicated,
the  RVP   effect  and  the effect  of improper design/purge  are
assumed   to  be   totally  eliminated   if   certification  test
procedure is  revised and  if certification  RVP  is raised  to  a
level equal to in-use RVP; because  these  categories are totally
eliminated when  certification and  in-use RVPs are made  equal,
no emissions benefit can be derived from  designing the  canister
for  an  even  higher  RVP fuel.   Of  course, the emissions  of
properly designed and operated vehicles  will not  change  (i.e.,
they will continue  to emit  at the  evaporative  standard level).
The    two     remaining     effects     —     tampering     and
malmaintenance/defect  — are  dependent  only upon in-use  RVP
(i.e.,  the  fact  that certification RVP  is  higher than  in-use
RVP  will  have no  impact  on  these  essentially  uncontrolled
emissions).    Therefore,  short-term   additional  in-use   RVP
control  provides   the  same  emissions  benefits  as  with  the
long-term scenario at that particular  in-use RVP;  the advantage
is  that  the  fleet  is  allowed   to   begin   turning  over  with
vehicles  designed  for  the higher RVP to  which  in-use  control
will be relaxed after a specified  period.

VI.  Ozone Air Quality Analysis

     Because of the  complex relationship between ambient ozone
concentrations and hydrocarbon emissions, the rollback  approach
used by  EPA to  model other  pollutants  (i.e.,  NOx and  CO) is
inappropriate for  ozone.   Instead, EPA  makes use of the  EKMA
(Empirical  Kinetic   Modelling  Approach)   to   predict   future
ambient ozone concentrations in specific urban areas.   The EKMA
utilizes  a series   of  ozone  isopleths  which  depict  downwind
ozone  concentrations as  a   function  of  initial  NMHC  and  NOx
concentrations,     subsequent   NMHC     and    NOx    emissions,
meteorological conditions, reactivity of the precursor  mix,  and
concentrations of  ozone  and precursors  transported from  upwind
areas.  It should  be noted  that the EKMA as used  by  EPA  is  a

-------
                              5-34


nationwide-average  model.  In  other  words,  no  city-specific
information  is  input  into  the model  except for  the  base-year
ozone  concentrations,  or -"design  values,"  from  which  future
concentrations are  projected*;  meteorological  conditions,  etc.,
are held  constant for all  the urban  areas modelled.   (Design
values for  the 47  cities  in this  analysis  were  shown in Table
2-1  of Chapter   2. [15]   For  more  details  on  the  EKMA,  see
References 16 and 17.)

     Using EKMA and the  NMHC emissions inventories presented in
Tables 5-13 and 5-15, projections of future  ozone conditions in
the  47 current non-California non-attainment areas were  made.
The first  section below  focuses  on future  air  quality in  the
long term,  followed by  a  similar presentation with respect to
short-term control alternatives.

     A.    Long-Term Analysis

     Tables 5-16  through  5-18  present  EKMA-based predictions of
future  ambient ozone  conditions  in 47  current  non-attainment
areas  under the  six  long-term  RVP  scenarios.    The  first  of
these  tables   shows  the   average change   in   ambient  ozone
concentration  with  respect  to  the base  level  in 1982.   The
reductions  expected to  occur  under the  baseline  RVP scenario
are, of  course,  in response  to  programs  other  than gasoline
volatility control,  such as  equipment-related  stationary source
HC  controls  and motor vehicle exhaust HC emissions  standards.
However,  the additional  ozone reductions shown under  the  six
RVP scenarios  in  Table 5-16 are  due solely to  NMHC  reductions
through in-use  and/or certification RVP  control.   For example,
if  in-use   RVP   was  controlled  to  10.0  psi   in   1988  and
certification RVP was  raised to 10.0 psi in 1990, ambient ozone
concentrations by the year  1995  would be expected to decrease
an  additional  5 percent  beyond the baseline RVP scenario (i.e.,
33 percent vs. 28 percent lower than 1982 levels).

     Estimates  of total  annual violations  of  the ozone  NAAQS
are  presented  in  Table 5-17  for  each  of the  long-term  RVP
scenarios.  The NAAQS  for ozone sets  a  limit  of  0.125  ppm  for
the fourth  highest daily maximum 1-hour  ozone concentration in
any  three-year  period;   the  violations  listed  in  the  table
represent  the  total  number  of days this maximum hourly ozone
concentration  is  expected to  exceed 0.125  ppm.    Only the peak
     An  area's  "design  value"  is  its  fourth  highest  daily
     maximum  one-hour ozone  concentration  recorded  (for  this
     analysis) during 1981, 1982, and 1983.

-------
                           5-35





                        Table 5-16



Average Percentage Change* in Ambient Ozone Concentrations
in 47 Urban Areas
Scenario
B
1
2
3
4
5
6
RVP (psi)
Baseline
11.5
ll.O
10.5
10.0
9.5
9.0
Under Lonq-Term
Control
1988 1995
-23
-23
-24
-26
-27
-28
-29
-28
-30
-31
-32
-33
-34
-34
Options
2010
-18
-21
-22
-22
-23
-23
-24
  With respect to base-year (1982) levels.

-------
                      5-36
                   Table 5-17
Number of Total Annual Violations of Ozone NAAQS
in
Scenario
B
1
2
3
4
5
6
47 Urban Areas
RVP (psi)
Baseline
11.5
11.0
10.5
10.0
9.5
9.0
Under Long-Term
1988
67
67
60
55
51
48
39
Control
1995
46
35
34
31
29
26
25
Options
2010
96
76
76
74
70
67
66

-------
                              5-37


monitoring site  in  each of the 47 areas was  considered,  so the
maximum possible  number of annual violations per area  is  365.
As Table  5-16 shows, for  example,  long-term scenario  #6 (both
RVPs equal to  9.0)  is  estimated to  reduce  the total number  of
ozone violations  in the 47 cities combined by  approximately 46
percent from the baseline RVP scenario in 1995  (i.e., 25 vs.  46
violations).

     Finally,  Table  5-18  estimates   the  total   number  of
non-California urban areas expected to  be  in violation  of the
ozone NAAQS  under  the  various long-term  control options.   As
shown, scenario tt6 is projected to enable roughly 6  more cities
to  come  into  attainment  in  1988.   One limitation associated
with  evaluating   control  options  on the  basis  of  number  of
non-attainment areas is that only those areas that  fall below
the NAAQS as  a  result  of the action  are distinguishable;  in
other words,  the  value  of  bringing an area closer to attainment
is not  recognized  unless  attainment is achieved.   Therefore,
estimated  overall  emissions  reductions or  changes  in average
ambient concentrations  as  a result  of  a particular  action are
probably  more indicative  of  the environmental  impact  of the
action than is the projected number of non-attainment areas.

     B.     Short-Term Analysis

     Using EKMA  and the NMHC  emissions inventories  presented
earlier in Table 5-15,  air quality  projections  were made under
the  various   short-term RVP  control  scenarios.   Results  are
presented  (in  the same  form as for  the  long-term scenarios) in
Tables  5-19   through  5-21.   As  before  with  the  emissions
inventories,  the  short-term air quality results presented here
are basically dependent  on  in-use  RVP;  in  other  words,  the
short-term results  at  a particular  in-use RVP  level agree with
the long-term projections at that same RVP.

VII.  Effect of RVP Control on Toxic Emission Levels

     This  section analyzes how  RVP control  may  influence the
content of certain  components in liquid gasoline and how these
changes  may  affect  emissions  of  benzene   and  other  toxic
compounds.   The  primary compounds of  concern here  are benzene
and whole gasoline vapor, due to their known  or suspected human
carcinogenicity.    Benzene  has  been   listed  as  a  hazardous
pollutant under Section 112 of the Clean Air  Act.  The evidence
of carcinogenicity  of  gasoline vapors comes  primarily from the
American  Petroleum  Institute's (API)  chronic  inhalation study
in  rats  and  mice. [18]   The  effect  of  vehicle-oriented  RVP
control   will   be   addressed   first,    followed  by   that  of
fuel-oriented RVP control.

-------
                         5-38

                      Table 5-18
      Number of Ozone Non-Attainment  Areas* Under
Lonq-Term Control Options
Scenario
B
1
2
3
4
5
6
RVP (psi)
Baseline
11
11
10
10
9
9
.5
.0
.5
.0
.5
.0
1982
47
47
47
47
47
47
47
1988
14
14
13
13
11
10
8
1995
8
6
6
6
6
6
6
2010
16
12
12
12
12
11
11
Non-California areas only.

-------
                                5-39
                             Table 5-19

     Average Percentage Change* in Ambient Ozone Concentrations
   In 47 Urban Areas With Additional Short-Term  In-Use RVP Control
         Short-Term
         In-Use RVP
Scenario    (psi)
B
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Baseline
9.
9.
9.
9.
9.
10.
9.
9.
10.
10.
9.
9.
10.
10.
11.
(11
0
0
5
0
5
0
0
5
0
5
0
5
0
5
0
  Long-Term
Cert. Fuel RVP
    (psi)
                           9.5

                          10.0
                          10.0
                          10
                          10
                          10
                          11.0
                          11.0
                          11.0
                          11.0

                          11.5
                          11.5
                          11.5
                          11.5
                          11.5
1990
-25
-32
-32
-31
-32
-31
-30
-32
-31
-30
-28
-32
-31
-30
-28
-27
1992
-27
-34
-34
-33
-34
-33
-32
-34
-33
-32
-31
-34
-33
-32
-31
-29
1995
-28
-34
-34
-34
-34
-34
-33
-34
-34
-33
-32
-34
-34
-33
-32
-31
1997
-28
-34
-34
-33
-34
-33
-33
-34
-33
-33
-32
-34
-33
-33
-32
-31
     With respect to base year (1982) levels.

-------
                                5-40
                             Table 5-20

          Number of Total Annual Violations of Ozone NAAQS
   in  47 Urban Areas With Additional Short-Term In-Use RVP Control
         Short-Term
         In-Use RVP
Scenario    (psi)
B
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Baseline (
9.0
9.0
9.5
9.0
9.5
10.0
9.0
9.5
10.0
10.5
9.0
9.5
10.0
10.5
11.0
  Long-Term
Cert.  Fuel RVP
    (psi)	
      	     1990

seline (9.0)   58

9.5            29
                          10.0
                          10.0
                          10
                          10
                          10
                          11.0
                          11.0
                          11.0
                          11.0

                          11.5
                          11.5
                          11.5
                          11.5
                          11.5
                    29
                    31

                    29
                    31
                    37

                    29
                    31
                    37
                    45

                    29
                    31
                    37
                    45
                    52
1992  1995  1997
  48

  26

  26
  29

  26
  29
  30

  26
  29
  30
  33

  26
  29
  30
  33
  39
42

25

25
26

25
26
29

25
26
29
31

25
26
29
31
34
43

26

26
27

26
27
30

26
27
30
32

26
27
30
32
33

-------
                                5-41
                             Table 5-21

               Number of Ozone Non-Attainment Areas*
           With Additional Short-Term  In-Use RVP Control
Scenario
Short-Term
In-Use RVP
   (psi)
B
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Baseline (1
9
9
9
9
9
10
9
9
10
10
9
9
10
10
11
.0
.0
.5
.0
.5
.0
.0
.5
.0
.5
.0
.5
.0
.5
.0
  Long-Term
Cert. Fuel RVP
    (psi)
Baseline (9.0
9.
10.
10.
10.
10.
10.
11.
11.
11.
11.
11.
11.
11.
11.
11.
5
0
0
5
5
5
0
0
0
0
5
5
5
5
5
1990
13
6
~~6
6
6
6
6
6
6
6
8
6
6
6
8
11
1992
10
6
fr
6
6
6
6
6
6
6
6
6
6
6
6
7
1995
8
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
1997
9
6
: 6
6
6
6
6
6
6
6
6
6
6
6
6
6
     Non-California areas only.

-------
                              5-42


     A.    Vehicle-Related RVP Control

     Overall,  the  effect  of  vehicle-oriented RVP  control  on
toxic emissions will be positive.  Vehicle-oriented  RVP control
reduces  evaporative HC emissions directly  and does not  affect
the amount of vapors, toxic or benign, generated by  the vehicle
since  the fuel  is  not  affected.   Since  improvements in  the
capture   and  recycling   of  these   vapors  can  only  reduce
emissions, and not  increase them, the effect on toxic  emissions
can  only be  positive.   For  example, a  saturated  evaporative
cannister  will  not  efficiently  capture   any  additional  HC
compounds  sent  to  it.   An increase  in   its  size and  improved
purging  will provide additional capacity to  absorb  both butane
and  higher compounds,  such as  benzene.   No data  are  currently
available  showing  the  benzene content of evaporative  emissions
from current vehicles operating on commercial  fuel both failing
and  meeting  the evaporative  emission standard, so  this  effect
cannot be quantified.  However,  it  definitely will  reduce  such
emissions.

     The  effect  of vehicle-oriented RVP  control  on  exhaust
emissions is only slightly more complex.   The  primary  effect of
vehicle  improvements  will be  to improve the combustion of HC
vapors  recycled  from  the  charcoal  cannister.    This  should
reduce the emissions of all  HC compounds.   A  secondary effect
will be  that those toxic  compounds  now   being  emitted will be
recycled  to  the   engine,  so   their emissions  may  increase
somewhat.   However,  the  former  effect  should  override  the
latter,   since   the  amount  of   higher   compounds,   such  as
aromatics, being introduced to the engine via cannister purging
will be  very  small compared to  that introduced  via  the  main
fuel metering system.  For example,   even if  purged fuel is 10
percent  of  total  fuel  consumption, which   it   can  be  under
certain  circumstances, the aromatic  content of the  purged  fuel
will be  a  small  fraction  of  that of the  liquid fuel, due to the
low relative volatility of such compounds in the  fuel  tank  (the
primary  source  of  evaporative  emimissions  on  the  dominant
post-1990 vehicle technoloty,  fuel-injection).

     B.    Fuel-Related RVP Control

     The  effect  of fuel-oriented RVP control  is  more  complex,
because  the  composition of  the fuel itself is  changing.   Few
data are available with  which to  analyze this   effect,  which
overall  should  be quite  small  since the fuel  compositional
changes are expected to be quite small.   However,  what  data are
available  are used below to  quantify this  efect.   The  first
section  below estimates the  effect  of  in-use RVP  control  on
benzene  emissions.   The  second  section   extrapolates  these
conclusions  in  order to  estimate the effect  on emissions  of
whole gasoline vapors.

-------
                              5-43


     1.    Benzene Emissions

     As already  mentioned in Chapter  4,  in-use control  of  RVP
will be  achieved primarily by  reducing  the quantity  of  butane
in the gasoline  pool  by up to 5 percent  (roughly  2  percent  per
1.0 psi RVP  reduction).   If the quantity of butane  in the fuel
is  reduced  without   any  other  compositional   changes,   the
percentage of all other  fuel  constituents,  including aromatics,
would be expected to increase proportionately (i.e., by up to a
factor  of  1.05).   However,  other  compositional  changes  are
expected  which  will  either  heighten  or  mitigate this  general
increase.   No data  are  available  concerning  the effect  of  RVP
control on benzene  levels, in  particular,  but projections  are
available  from  the  Bonner  and  Moore  model  of  total  fuel
aromatic  content for   the baseline  and  control cases allowing
investment and  open NGL purchases (see Table 5-22).   As  can be
seen,   the   nationwide  average  aromatic  content   increases,
additively,  by  0.6  percent and  2.8  percent for RVP reductions
of l  psi  and 2  psi,  respectively, over  the  baseline  level  of
32.5   volume  percent.    Assuming  benzene    levels   increase
proportionately,  then  current  benzene  levels  (roughly  1.34
percent based  on  the  1984  NIPER survey [19]) would increase
0.01 volume percent with a 1  psi RVP  reduction and  0.04  volume
percent with a 2 psi reduction.

     Very limited data are also  available  which  detail vehicle
evaporative and exhaust benzene emissions as a  function of fuel
composition.   The  data  available are from a  study by EPA  and
are shown in Table 5-23.[20]   The original data  set  consisted
of 4  vehicles.   However, two of the vehicles were omitted from
this  analysis  since   they  were  pre-1978  models   and   their
evaporative  control  systems,  by design, are  quite  inefficient
and unrepresentative  of current  vehicle  technology.   Even  the
remaining two  vehicles  were  certified to  the 1978-1980 model
year  6-gram  evaporative HC  standard  and,  therefore,   do  not
fully represent  more  recent technology.   However,  their  systems
are conceptually very close  to  current  technology  and  can  be
used here.   With respect  to  exhaust  emissions controls, these
two  vehicles  were   equipped  with  oxidation   catalysts,  air
injection,  and  exhaust  gas  recirculation.  Again,  while  not
entirely  representative of the  feedback-controlled,  three-way
catalyst  vehicles of  today, the  control  systems  were generally
quite efficient  (1.5  g/mi HC versus uncontrolled emissions  of
roughly  4 g/mi)  and   represent  the best data available.   The
hot-soak  and  diurnal   emissions  shown  in   Table   5-23  were
converted  from  gram  per  test  to gram per  mile  using  the
original MOBILES equation shown below:


            Pi + (3.05 trips/day)(Hs)
     Evap =
                31.1 miles/day

-------
                              5-44
                           Table 5-22

              Changes  in Aromatic Content (Vol %)
                  Resulting from RVP Control*

                   With Investment,  Open NGLs

                        	PADD	
                                          4  + 5
                          123    (ex. CA)**
Baseline
Unleaded Regular
Unleaded Premium
Leaded Regular
  Weigted Average

1 PSI RVP Reduction
Unleaded Regular
Unleaded Premium
Leaded Regular
  Weighted Average

2 PSI RVP Reduction
Unleaded Regular
Unleaded Premium
Leaded Regular
  Weighted Average
                   38.8  32.0  31.3   31.7
                   31.6  37.9  31.0   34.5
                   30.8  31.2  34.6   32.9
                   36.1  32.9  31.8   32.4
                   37.9  33.1  31.2   32.2
                   35.8  36.9  31.3   34.1
                   31.0  31.3  33.6   32.5
                   36.3  33.5  31.6   32.6
                   38.3  33.6  32.4   33.0
                   36.0  35.6  34.5   35.1
                   31.1  31.5  32.2   31.9
                   36.7  33.6  32.7   33.2
                                                Total U.S.
                                                (ex.  CA)***
32.2
33.3
33.1
32.5
32.4
33.6
32.6
32.7
33.3
35.0
31.9
33.4
**
***
As predicted by Bonner and Moore RPMS model.
Estimated as an average of PADDs 2 and 3.
Total U.S.  (ex.  CA)  estimated by  volumetrically  weighting
of  PADD  aromatic  content for  PADDs  1,2,3,4  and 5  using
PADD specific gasoline production.
Average  estimated  by weighting  the three gasoline  grades
by % of sales by volume.

-------
                              5-45
                           Table 5-23

      Effect of Fuel Composition on Benzene Emissions [20]

Test Vehicle: 1979 LTD
Test
Code

B
B-l
C
  Fuel
Aromatic
 Vol %

  43.4
  46.6
  25.7
 Fuel
Benzene
 Vol %

  1.5
  7.1
  2.0
 RVP
 psi

 9.8
 9.8
12.3
Tailpipe
 Benzene
  cr/mi

  .025
  .035
  .014
Evaporative
  Benzene
    q/mi

    .007
    .020
    .011
Test Vehicle:1978 Monarch

Test
Code
Fuel
Aromatic
Vol %
Fuel
Benzene
Vol %
A
A-l
B
C
  27.4
  32.4
  43.4
  25.7
  0.3
  7.1
  1.5
  2.0
 RVP
 psi

 8.4
 8.4
 9.8
12.3
Tailpipe
 Benzene
  q/mi

  .030
  .058
  .030
  .033
Evaporative
  Benzene
    q/mi

    .001
    .010
    .009
    .005

-------
                              5-46


     Eyap = total evaporative emissions,  grams/mile
     Di   = diurnal emissions, grams/test (one per day)
     Hs   = hot-soak emissions, grams/test (one per trip)

     Ongoing research  to  determine the  effect  of fuel  benzene
concentration on exhaust and evaporative benzene emissions  is
currently being  conducted by the Coordinating  Research  Council
and  should  be published  by  the  end of  1985.   The  results  of
this study (and any other data which becomes  available)  will  be
incorporated  into this  analysis  as  soon  as  the results  are
published.

     The data of  Table 5-23  show evaporative benzene emissions
to  primarily be  dependent   upon  two variables;  fuel  benzene
content and RVP.   As would  be expected,  total  aromatic  content
is not  a  factor,  since the  temperatures in both  the fuel tank
and  fuel  metering system are too low to  produce benzene from
other aromatics.   Overall,  as the benzene  content of the fuel
increases,  evaporative  benzene  emissions  increase.   As  RVP
decreases,  evaporative benzene  emissions -decrease.   Estimates
of  the  effect   of  unit  changes  in each  of  these  two  fuel
properties  on  evaporative  benzene emissions  are presented  in
Table 5-24.  The  effect of  fuel benzene content  was  determined
for  each  vehicle separately  (tests  B  and B-l  for the  1979 LTD
and  tests A and  A-l for  the  1978 Monarch)  and then averaged.
The  effect  of  RVP was  determined for  each of  four pairs  of
tests (tests B and C  for  the  LTD  and  tests A  and B, A  and  C,
and  B  and C for  the  Monarch) and then  averaged.  Many  of the
changes in RVP were also accompanied by  changes  in fuel  benzene
content.  To  account  for  this,  the  benzene effect  determined
for  each  vehicle was   subtracted from  the  overall  change  in
benzene emissions  before determining the RVP effect.   While the
benzene effect  was fairly  similar for  the  two  vehicles,  the
effect of RVP varied considerably.   Thus,  additional  data would
be particularly useful  in improving this latter estimate.

     The effect of fuel benzene content  on  exhaust emissions  of
benzene was  determined in a  similar  fashion using tests B and
B-l  for the LTD  and tests  A  and A-l for  the Monarch.   These
tests represented the  largest change in  fuel benzene  content
and  RVP and  fuel aromatic  content were  relatively constant.
The  effects  of   both RVP   and  fuel   aromatic  content  were
impossible  to  estimate,  however,  as  they  tended  to  change
together  inversely.  Thus,  estimates of their  effect will have
to await the development of additional data.

     The effect  of these changes  in benzene emissions per mile
on nationwide emissions (non-California)  are  presented in Table
5-25.  An estimate  of  total  nationwide  VMT was taken from EPA
fuel consumption  model and California was  assumed to represent

-------
                              5-47
                           Table 5-24
                Effect of RVP Control on Benzene
            Evaporative and Exhaust Emission Factors
Evaporative Emissions
     RVP             -.0013(g/mi)/l psi RVP reduction
     Benzene Effect   .0019(g/mi)/l vol % Benzene Increase

Exhaust Emissions
     Benzene Effect   .0030(g/mi)/l vol % Benzene Increase

-------
                              5-48
                           Table 5-25

              Change in 1988Non-California Benzene
              Emissions Due to RVP Control (Tons)


                          	Degree of RVP Control	
Source                    1 psi reduction        2 psi reduction
M.V. Evap.
    RVP Effect                  -631                   -1261
    Benzene Effect                10                      41

M.V. Exhaust
    Benzene Effect                17                      69

    Total                       -604                   -1151

-------
                              5-49


11  percent  of  nationwide  VMT,  as  discussed  earlier  in  the
chapter.[21]  No  attempt was  made to  estimate the  difference
between LDV, LDT and HDV emissions.

     These  results  show that the RVP effect  dominates  the fuel
benzene effect and  an  overall  reduction in benzene evaporative
emissions would be  projected for in-use RVP  control.   Overall,
these decreases represent 2 and 5 percent  of  current  nationwide
(non-California)  benzene  emissions of  roughly  250,000  tons,
respectively.[22,23].

     Increased fuel benzene content occuring  while  reducing RVP
may also  affect  refueling, Stage I, and bulk storage emissions
of  benzene.  Lower  total  HC  emissions   should  lower  benzene
emissions  which  are  carried off  by the  evaporation of  other
compounds,  while  a higher  fuel benzene  content  is  likely  to
increase  benzene  concentration in  the vapor that is  emitted.
No  data  showing  which of  these  two  effects  dominates  are
available.   Given  the  very  slight  projected   increase  in
aromatic   content   (and  presumedly,   benzene  content),   any
increase  in benzene emissions  due to  increased benzene  vapor
concentration  should   be very  small  and  the  net  change  in
benzene emissions  even smaller.

     B•     Toxic Gasoline Vapors

     The  second toxic  pollutant to be considered  here  is  whole
gasoline  vapor.   The  API   animal  experiments  used an  aerosol
formed from  completely  vaporized  liquid  gasoline.[18]   However,
the precise compounds  producing the  carcinogenic  effects have
yet to  be identified.   Therefore,  all that can  be  said at this
time is that, based on  the  small  compositional changes  expected
to occur  with in-use RVP control,  the effect of such control on
the emissions of these toxic compounds should be quite small.

-------
                              5-50
                     References (Chapter 5)

     1.    "Evaporative  HO  Emissions   for  MOBILES,"  Test  and
Evaluation Branch, U.S. EPA, EPA-AA-TEB-85-1,  August 1984.

     2.    Data   submitted   in  a  formal   letter  from   J.S.
Welstand, Chevron Research  Division, to Chester J. France, EPA,
QMS, ECTD, April 1,  1985.

     3.    "Relationship  Between  Exhaust  Emissions  and  Fuel
Volatility," EPA  memo from Thomas  L.  Darlington to Charles  L.
Gray, EPA, QMS, ECTD, June 24, 1985.

     4.    "Compilation  of  Air  Pollution   Emission   Factors:
Highway Mobile Sources," U.S. EPA, EPA-460/3-81-005, March 1981.

     5.    "Refueling  Emissions  from  Uncontrolled  Vehicles,"
Dale    S.    Rothman    and    Robert    Johnson,    QMS,    ECTD,
EPA-AA-SDSB-85-6,  July 1985.

     6.    "Bulk  Plants   —   Control   of   Volatile   Organic
Emissions from Bulk  Gasoline  Plants   (CTG),"  U.S. EPA,  OAQPS,
EPA-450/2-77-035,  December 1977.

     7.    "Service  Stations  — Design  Criteria  for  Stage  I
Vapor Control Systems — Gasoline Service Stations (CTG)," U.S.
EPA, OAQPS,  EPA Internal Document, November 1975.

     8.    "Gasoline Tank Trucks  — Control  of Volatile Organic
Compound Leaks  from Gasoline Tank  Trucks and Vapor  Collection
Systems  (CTG),"  U.S.   EPA,  OAQPS,  EPA-450/2-78-051,  December
1978.

     9.    "Fixed-Roof  Tanks  — Control of  Volatile  Organic
Emissions from  Storage  of Petroleum Liquids  in Fixed-Roof Tanks
(CTG)," U.S. EPA,  OAQPS, EPA-450/2-77-036, December 1977.

     10.   "Floating-Roof Tanks  —  Control of  Volatile Organic
Emissions   from    Petroleum    Liquid    Storage   in   External
Floating-Roof  Tanks (CTG)," U.S. EPA,  OAQPS,  EPA-450/2-78-047,
December 1978.

     11.   "Bulk Terminals  —  Control  of Hydrocarbons from Tank
Truck  Gasoline  Loading  Terminals  (CTG),"  U.S.  EPA,  OAQPS,
EPA-450/2-77-026,  October 1977.

-------
                              5-51


                 References  (Chapter  5) Cont'd

     12.   "Methodology to . Conduct Air  Quality Assessments  of
National  Mobile  Source  Emission  Control   Strategies;   Final
Report," U.S. EPA,  OAQPS,  EPA-450/4-80-026, October 1980.

     13.   Computerized data files  in support of  "National  Air
Pollutant  Emissions  Estimates,   1940-1983,"  U.S.  EPA,  OAQPS,
MDAD, EPA-450/4-84-028, December 1984.

     14.   "Updated Trips-  and  Miles-per-Day Information,"  EPA
Memo  from Thomas  Darlington,   Test  and  Evaluation Branch,  to
Charles  L.  Gray,   Director  of  Emission  Control  Technology
Division, January 30,  1985.

     15.   "1981-1983   Standard  Metropolitan  Statistical  Area
(SMSA) Air Quality  Data Base for Use in  Regulatory Analysis,"
Memo  from Richard   G.  Rhoads,  Director  of Monitoring  and Data
Analysis  Division,  to  Charles  L.  Gray,   Director of  Emission
Control Technology  Division, February 25,  1985.

     16.   "Uses, Limitations and Technical  Basis  of Procedures
for  Quantifying  Relationships  Between  Photochemical  Oxidants
and  Precursors,"  U.S.  EPA,   OAQPS,  RTP,   EPA-450/2-77-021a,
November 1977.

     17.   "Guidelines  for   Use   of  City-Specific   EKMA   in
Preparing Ozone  SIPs,"  U.S. EPA, OAQPS,  RTP, EPA-450/4-80-027,
March 1981.

     18.   "Evaluation  of  Air  Pollution  Regulatory  Strategies
for   Gasoline   Marketing    Industry,"   U.S.    EPA,    OAQPS,
EPA-450/3-84-012a,  July 1984.

     19.   "Motor Gasolines, Summer 1984," Ella  Mae Shelton and
Cheryl L.  Dickson,  National Institute for Petroleum and  Energy
Research (NIPER), for  API,  February 1985.

     20.   "Composition of  Automobile Evaporative  and  Tailpipe
Hydrocarbon  Emissions," F.M.  Black  and  L.E.  High, U.S.  EPA,
J.M. Lang, Northrop Services, Inc., APCA  Journal,   Vol. 30,  No.
11, November  1980.

     21.   "MOBILES  Fuel  Consumption Model,"  Mark A.  Wolcott,
EPA, and Dennis F.  Kahlbaum, CSC,  February 1985.

     22.   "Transmittal of  Emissions  Inventory  and RVP  Data,"
EPA  memo  from Glenn  W. Passavant, EPA  to Jeff Clark, General
Accounting Office,  March 22, 1985.

     23.   "GAO Request for  Background  Information on Benzene,"
EPA  memo  from Robert  G.  Kellam, EPA to  Joseph L. Turlington,
General Accounting  Office,  May 21, 1985.

-------
                           CHAPTER  6

                    Analysis of Alternatives

I.   Introduction

     This final chapter draws on the  findings  presented earlier
in the  report and provides  a direct comparison  of  the various
HC control strategies being examined.  This  comparison is based
on the  estimated  costs  of motor  vehicle-related controls  and
in-use  fuel  controls  (presented,  respectively,  in  Chapters  3
and  4)   and  on  projected  emissions  benefits  (discussed  in
Chapter   5)  associated with  each of  the  long-  and  short-term
control   scenarios.   Using this information, cost effectiveness
($/ton)   figures  were  developed  as  a  basis  for  evaluating
appropriate   control   measures.     The   emission   reductions
associated  with   each   control   scenario,  along   with  their
relative cost effectiveness,  will be the focus  of this chapter.

     Both  long-term  control  strategies,  where in-use  RVP  and
certification fuel RVP are made equal,  and short-term control
strategies, where  in-use  fuel  is   temporarily controlled to  a
lower RVP  level  than  certification fuel, will be  examined  in
terms   of   cost,  emission   reductions,  and  resulting  cost
effectiveness.  The  long-term analysis will focus  on  the  year
2010 as  a  "steady-state" point at  which  essentially the entire
motor vehicle  fleet  will  have  turned  over  (i.e.,  revised
certification fuel and  test  procedure will  have affected  the
design  of  almost  all  of  the vehicles   in   the  field) .   The
short-term discussion  will examine the years  1988,  1990, 1992,
1995, 1997,  and 2000,  and will  focus  on benefits  achievable
with  additional   in-use   RVP control   over  and  above  those
benefits   resulting   from  the   long-term  strategies  (i.e.,
certification RVP equal to in-use RVP).

     As   discussed   earlier   in  Chapter   2,   ozone-related  HC
control   appears  to be most valuable  during the  summer months,
as  over  90   percent of  all  ozone  violations  tend  to  occur
between  June  and September  (inclusive).   Because of  this,  both
12-month  (year-round)  and 4-month  (summer only)  analyses  will
be performed  below.*  In both cases,  the  period  of  analysis
represents  both   the  control  period   for   in-use  volatility
control  and the period of consideration  of  emission benefits.
     Summer periods other than  four  months could also have been
     evaluated.  Cost-per-ton estimates  for  3-, 5-,  or  6-month
     control  periods  could  be  determined in  a  fairly linear
     fashion.   For example,  6-month  benefits would  be one-half
     of  annual  tons,  costs  would  be roughly  three-quarters of
     annual dollars,  so cost per ton would be  approximately 1.5
     times higher than the annual figure.

-------
                               6-2
Due to  the uncertainty  associated  with  the  relative  value  of
ozone benefits  in the summer and winter, the  discussion of the
results  in  this chapter will  focus primarily, on the  12-month
figures.

     Section   II   below   outlines   the   methodologies   and
assumptions used  to  calculate  cost effectiveness  estimates for
both  the   long-  and   short-term  control   strategies.    (The
discussions   on  the   development   of   costs  and   emissions
reductions  are  merely  reviews,  as  the  details on  both are
presented in  Chapters  3 through  5.)  Following  the  methodology
descriptions, Section  III presents  the results of the analyses,
first for the long-term and then for the short-term strategies.

     An  analysis  of  alternatives  based  on  best  estimates and
current  conditions  will be  presented  first.   This  "base"  case
includes  no  control   of  vehicle   refueling   losses   and  no
inspection  and   maintenance  (I/M)  programs   for  evaporative
emissions,  as  these  have not  been  implemented  to  date.   As
discussed  in  Chapter 4, the ratio of  percentage change in fuel
economy  to  percentage  change  in fuel  energy  content   (due  to
butane  removal),  designated  "R",  should  theoretically  be  1.00.
However,  limited  available  data  indicate a  lower boundary  of
0.6 for  this  ratio.   Therefore,  base  case costs and credits are
evaluated  for both  R = 1.0  and R =  0.6,  but  a  100-percent
efficiency  still  represents  the best estimate  at  this  time,  as
the theory is sound (see Chapter 4).

     In  addition  to  the base  case analysis.  Section  III  will
also present  the results of various sensitivity analyses.   The
first sensitivity analysis  will examine  the  effect  of average
in-use  gasoline  RVP  staying fairly constant at  the  current 0.5
psi (on average)  below ASTM limits  rather  than  reaching these
limits  (e.g.,  average Class  C RVP  would  stay  at  11.0  psi,
instead  of  reaching  the baseline value of  11.5  psi by  1988).
Because  RVPs  are not expected to decrease below current levels
without   further    regulation,   this    sensitivity    analysis
represents  a  worst-case impact  on the RVP control  scenarios.
As with the base case,  this sensitivity analysis is performed
for both R = 1.0 and R = 0.6.

     The second sensitivity  analysis will examine the effect of
implementing  onboard  vehicle refueling loss  controls  in  1989,
an issue now under  study within  EPA.   If onboard controls are
required,   that  rulemaking  could   include   a  revision  of
certification  fuel  RVP  to  11.5  psi  and  a  change  in  the
evaporative test  procedure  to  require  a  saturated canister  at
the start of  the  certification  test.   However, the revisions to
the  test fuel  and  evaporative  test  procedure  could  be  made
without  implementing  onboard  refueling  controls.    Thus  these
revisions and their resulting emission  reductions  should not  be
unequivocally associated  with  onboard  refueling  controls.   On

-------
                              6-3
the   increment,   when  considering   both  RVP   and  refueling
controls,  it seems  most  proper  to  associate  the control  of
excess evaporative and  exhaust HC emissions  due to high in-use
RVP  to  RVP  control  (vehicle or  in-use  fuel) and  to  associate
the  control  of  refueling  emissions  with  onboard  refueling
controls.  Thus, the  majority  of  the refueling emission control
previously   associated   with   in-use  RVP   control   must   be
subtracted  out  for  the  onboard  sensitivity  analysis; a  very
small amount of refueling  loss control  is still  achievable with
RVP  control  due   to tampering  with onboard   systems.   (More
detail  is  given in  Section II.)   As before, this sensitivity
analysis is performed at both "R"  values — 1.0 and 0.6.

     The third  sensitivity analysis  will  examine the  effect of
eliminating  the exhaust HC  emission  reductions  associated with
RVP  control.   As  discussed  in Chapter 2,  in-use  EF  test  data
indicate  that  exhaust   emissions  decrease  with  lower  RVPs.
While there  is  no reason  to question these technical results, a
sensitivity  analysis   without  these  RVP-related   exhaust  HC
reductions  has  been  performed to examine  the  significance of
these   exhaust   benefits   with  respect    to   the  base   case
costs/ton.   This  case  is  evaluated  with an  "R"  value of  1.0
only.

     The fourth sensitivity  analysis  will examine the  effect of
implementing  an   inspection   and   maintenance   program   for
evaporative  control  systems.  By  identifying  and theoretically
preventing vehicle problems,  this type of  program  would reduce
tampering and malmaintenance/defect  losses, which  are now only
affected  by in-use  RVP control.   To date,  I/M programs  have
been  implemented  only  for  exhaust  emission  control equipment,
so  only  exhaust  I/M  was   included  in  the  base  case.   A
sensitivity  analysis   with  an  evaporative  I/M  program  was
performed because of the  possibility  of  such a program coming
into  place  in  the   late  1980's.    As   with  the   "no  exhaust
benefits" case,  only R = 1.0 was evaluated.

II.  Methodology

     A.     Long-Term Analysis

     The   methodology   used   to    estimate   the   long-term
(steady-state)  costs,  emission reductions,  and  resulting  cost
effectiveness of  controlling  evaporative HC  emissions through
equating  in-use  and certification   gasoline  RVPs  along  with
revisions to certification  test  procedure is detailed  in  this
section.  '  The   methodology   for  the   year-round   (12-month)
analysis  will  be   presented  first,   followed   by   that  of
summer-only  (4-month)  analyses.   The  year  2010  was  used  to
represent  the   long  term,   as  the vehicle  fleet would consist
entirely of post-1990 (i.e., controlled) vehicles by this time.

-------
                               6-4
     Estimation of  the  2010 non-California  emission  reductions
associated with  the base  case  (including exhaust  HC  benefits,
without onboard refueling  loss  control  and with  no evaporative
I/M program) were simply taken  from total inventory projections
of the previous chapter  (see  Table 5-12).  Net  and incremental
emission  reductions  were  estimated  for  each  long-term control
scenario   (11.5-psi  RVP   down  to   9.0-psi   RVP  in   0.5-psi
increments).*  The  sources of NMHC  emission reductions include
motor vehicle  evaporative  and  exhaust  emissions,  and  gasoline
storage and  distribution  sources  (i.e.,  bulk  storage,  Stage I,
and refueling).

     The   emission   reductions   estimated  for   the   long-term
control scenarios are presented in Table 6-1  for  the  base case
and  the   four  sensitivity  analyses.   Emission  reductions  are
detailed here  in order to  provide  a perspective on the relative
contribution  of  various  sources  —  motor  vehicle  evaporative
losses,  motor  vehicle   exhaust  emissions,   refueling,   bulk
storage,   and Stage  I.   As  shown,  motor  vehicle  evaporative
emissions  make  up the  largest controlled category,  accounting
for 61 to 63 percent of  total NMHC reductions  in 2010  (assuming
the base case).

     Estimation of  the  emission reductions  associated with the
various sensitivity  analyses vary in complexity.   Elimination
of  the  RVP-related exhaust  emission  effect  simply  involves
removing the portion of the emission reduction  attributable to
motor vehicle  exhaust  emission  control  (i.e., 215,000  tons in
2010) shown  in Table 6-1.   For  the  "lower baseline RVP"  case,
emission  reductions  are  simply  calculated  from a  new baseline
— in-use  RVP  =  11.0 psi  and certification  fuel  RVP =  9.0 psi
— instead of  the  11.5/9.0 RVP baseline  used  in  the base case.
In other   words,  in Table 6-1,  emission reductions  for  this
sensitivity  case   are   262,000  tons  lower   than base  case
reductions  under  all  RVP   scenarios,   which  represents  the
difference  between  the   11.5/9.0   and  the  11.0/9.0   baseline
inventories.

     Consideration of  the  presence  of onboard refueling  loss
controls   is  only  slightly  more  complex.    Since  in-use  RVP
control affects even controlled refueling losses  (by the  same
proportion  as  uncontrolled  emissions)   and  onboard  controls
would be  subject to  some  degree of  tampering, some control of
refueling   loss   persists  even   if  onboard  controls   are
implemented.   Based  on  previous EPA  studies,   onboard  controls
are at least  97 percent  effective; accounting .for the projected
tampering  incidence  (the  same  as  the then-current  evaporative
control tampering rate),  refueling emissions  are expected to be
     The  uncontrolled  baseline assumes  an  in-use  fuel RVP  of
     11.5 psi and a certification fuel RVP of 9.0 psi.

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                                 6-5



                              Table 6-1

                  Annual  Emission  Reductions  Under
           Long-Term Control Scenarios in 2010 (10^ Tons)*

                                   In-Use = Cert. RVP (psi)
Case/Category

"Base Case":
   - Evap.HC
   - Exhaust HC
   - Refueling
   - Bulk Storage
   - Stage I
   - Total

"Lower Baseline" Case:**
   - Evap. HC
   - Exhaust HC
   - Refueling
   - Bulk Storage
   - Stage I
   - Total

"Onboard" Case:
   - Evap. HC
   - Exhaust HC
   - Refueling
   - Bulk Storage
   - Stage I
   - Total

"No Exhaust" Case
   - Evap. HC
   - Exhaust HC
   - Refueling
   - Bulk Storage
   - Stage I
   - Total

"Evap. I/M" Case:
   - Evap. HC
   - Exhaust HC
   - Refueling
   - Bulk Storage
   - Stage I
   - Total


*Non-Calitornia emission reductions only.
**   Assumes baseline in-use RVP of 11.0 psi, instead of 11.5 psi
11.5
369
215
0
0
0
584
, . **
—
—
—
—
_
—
369
215
0
0
0
584
369
0
0
0
0
369
284
215
0
0
0
499
11.0
419
215
17
12
6
669

230
177
0
0
0
407
419
215
1
12
6
65T
419
0
17
12
6
454
305
215
17
12
6
555
10.5
468
215
34
25
13
75^

279
177
17
13
7
49T
468
215
2
25
13
723
468
0
34
25
13
540
324
215
34
25
13
611
10.0
516
215
51
38
20
840

327
177
34
26
14
578
516
215
3
38
20
792"
516
0
51
38
20
625
344
215
51
38
20
668
9.5
564
215
68
51
27
925

375
177
51
39
21
663
564
215
4
51
27
F6T
564
0
68
51
27
710
361
215
68
51
27
111
9.0
613
215
85
64
33
1010

424
177
68
52
27
T48
613
215
5
64
33
930
613
0
85
64
33
"795
378
215
85
64
33
775

-------
                              6-6


controlled by  94  percent in 2010  (i.e.,  essentially  all  models
in the fleet will be equipped with onboard  controls).[1]   Thus,
the  2010  emission  reductions  attributable  to  refueling  loss
control are reduced by 94 percent,  as  indicated in  Table  6-1.
As  mentioned  earlier,  implementation of  an onboard  refueling
loss  control  program  could  also   involve   a  revision  of  the
certification fuel  RVP specification to  11.5  psi and  a  change
in evaporative test procedure (i.e., beginning with  a saturated
canister).  However,  as  mentioned  before,  these test procedure
revisions  could  be  implemented  without  implementing  onboard
refueling  controls  and,  therefore,  should  not be  inherently
associated with onboard refueling  controls.   Thus, the emission
reductions associated  with changing the RVP  of the  test  fuel
and  the  evaporative  test  procedure (the   control  of  vehicle
evaporative and  exhaust  HC emissions at  11.5 psi RVP)  will be
retained for this onboard sensitivity analysis.   The 94-percent
reduction in refueling loss control due  to implementation of an
onboard program reduces the overall effect of RVP control  by up
to 8 percent in comparison to the base case.

       Consideration of the presence of  an effective inspection
and maintenance  (I/M)  program  for evaporative  control  systems
is  also  somewhat  complex.   Evaporative  I/M  programs  could
affect  both  the  malmaintenance  and  defect  effect  and  the
tampering  effect  associated  with  motor  vehicle  evaporative
emissions.   In  Chapter   2  of  this  study,  specific  vehicle
problems  were  classified  as malmaintenance/defect or tampering
(see  Table 2-14).   By detecting   and  forcing  repair of  such
problems   as   a  broken   canister  or   damaged  vacuum   line
(malmaintenance/defect)  or  a  missing  canister  or  fuel  cap
(tampering),  an  evaporative  I/M program could  reduce portions
of  these excess  evaporative  emissions.   It was  assumed  that
such   a  program  could  potentially   address  all   types   of
tampering,  but   only  certain   types  of   malmaintenance   and
defects.   (Appendix 6-A  contains  the analysis of  the potential
for I/M to address the various  specific types  of malmaintenance
and defects) .   An evaporative I/M  program was assumed to  be 70
percent effective in  eliminating both tampering and  applicable
malmaintenance and  defects.[3]   The estimated maximum portions
of  hot-soak   and  diurnal   emissions   from   carbureted   and
fuel-injected  vehicles that  would  potentially  be affected by
I/M are  shown  in Table 6-2.  The  resulting 2010 motor vehicle
evaporative emission  reductions associated  with RVP  control in
conjunction with  an evaporative I/M program are shown  in  Table
6-1.   In order to compare this case with the other  sensitivity
cases  shown  in  the  table,   a  nationwide   analysis  (excluding
California)  was  performed,  even   though  an  evaporative  I/M
program  would  most  likely be  implemented  only  in urban  ozone
non-attainment  areas.   However, the  relative impact  of  such a
program  on  emissions  in just these urban areas would parallel
that  indicated  in the nationwide  analysis.   As shown  in  Table
6-1,  overall  emission reductions  due to  RVP control  are  14-23
percent  lower  under this evaporative I/M sensitivity case than
for the base case.

-------
                              6-7
                           Table 6-2

   Effect of Evaporative I/M on Malmaintenance/Defect Effect
   and Tampering Rates for 1981+ Model Years (Baseline Case)
w/o Evaporative I/M (g/test)
w/  Evaporative I/M (g/test)*

      % reduction in M&D
                                  M&D Emission Rates (LDV & LDT)
                                      FI
                                  DI
  .84
  .39

54.0
          HS
     .93
     .34

   63.7
                       Garb.
               DI
         1.61
         1.02

        36.6
                  HS
          1.24
           .84

         32.0
w/o Evaporative I/M
w/  Evaporative I/M*
                                      Tampering Rates (%)
                                  LDV Mileage
                    LDT Mileage
                                 0
     50K  100K
0
0
3.9
1.2
7.8
2.3
 0

3.6
1.1
                  50K  100K
7.6
2.3
11.6
 3.5
     Assumes  an  evaporative  I/M  program  efficiency  of  70%
     (i.e.,  70%  of  tampering  is  caught,  and  70%  of  each
     addressable M&D problem is caught).

-------
                              6-8
     Moving  to  the  estimation  of  costs,  the  net  cost  of
commercial  gasoline and  motor vehicle-related  controls  are  a
function  of  several individual components.   These  include:   1)
the  refinery cost  of  reducing gasoline  RVP,   2)  the  cost  of
motor vehicle  redesign,   3) the  value of  the  increased energy
content of  commercial  gasoline,  4)  the  value of  recovered  or
prevented evaporative HC  losses,  and  5)  the cost  of increased
vehicle weight  due to  the enlarged canister.   The combination
of   these  individual   components  is  described   below.    The
detailed  derivation of  the individual  vehicle- and fuel-related
control costs  are provided in  Chapters  3  and  4,  respectively.
The only  exception  is the evaluation  of  the weight-related fuel
economy penalty,  which  is described in Appendix 6-B  at  the end
of  this  chapter.   Like   emission  reductions,  all  costs  are
determined on an annual  basis.

     The  refinery costs  of  reducing  RVP  are taken  from  Table
4-3  of   Chapter   4.   For  this  2010   scenario,   the  "with
investment"  costs  are  most  applicable  and,  as   described  in
Chapter 4,  the  average  of the   "open"  and  "fixed"  NGL cases was
used.   Nationwide  (non-California)  annual  costs  are  simply
calculated  by  multiplying  these  refinery costs by  nationwide
gasoline  consumption   (excluding  California  and  off-highway
gasoline  consumption) from EPA's  MOBILES  Fuel Consumption Model
(FCM)  for  the  year  2010. [4]   This  annual  consumption  is  75
billion gallons  (1.79 million  barrels).    These refinery  costs
are  summarized  in Table  6-3  and do  not   vary  with any of  the
sensitivity  cases  except   where the RVP of commercial  gasoline
only rises  to  11  psi.   In this case,  the  cost  of  the first 0.5
psi of RVP control is avoided.

     The  costs of  vehicle  redesign,  on   a  dollar-per-vehicle
basis,  are  taken  from   Table  3-6  in Chapter 3.  These  are
multiplied  by  Energy and Environmental  Analysis  (EEA)  vehicle
sales  projections   for   the   year   2010   to  determine  annual
costs.[5]    The   resulting annual   vehicle  design  costs  are
summarized in Table 6-3 and do  not vary with sensitivity case.

     Reducing  in-use gasoline RVP  also  increases  the  energy
density of  the gasoline,   which,  in turn,  results  in increased
fuel economy in  motor vehicles.  The  effects are  summarized in
Table  4-11  of Chapter  4.  The annual credit  is   estimated  by
multiplying  the  increases  in  vehicular  fuel economy of  Table
4-11   by    the   non-California   nationwide   fuel   consumption
described above and  an  estimated  value of  gasoline of $0.98 per
gallon.   The resulting  credits are shown  in  Table  6-3  for both
the  base  case, where  R  (the  fraction of  the  increased energy
that  is  fully utilized by the engine) equals  1.0, and  for the
sensitivity  case  assuming  an  R-value of  0.6.  The  credit  for
the latter is simply 60 percent of the former.

-------
                                  6-9
                               Table 6-3
                     Annual Costs Under Long-Term
Control Scenarios in 2010 (10°$/yr)
In-Use = Cert. RVP
Case /Category
"Base Case":
- Refinery Cost
- Vehicle Cost
- Fuel Econ. Credit*
- Evap. Recov. Credit
- Weight Penalty
- Total Cost
"Lower Baseline" Case:**
- Refinery Cost
- Vehicle Cost
- Fuel Econ. Credit*
- Evap. Recov. Credit
- Weight Penalty
- Total Cost
"Onboard" Case:
- Refinery Cost
- Vehicle Cost
- Fuel Econ. Credit*
- Evap. Recov. Credit
- Weight Penalty
- Total Cost
"No Exhaust" Case:
- Refinery Cost
- Vehicle Cost
- Fuel Econ. Credit*
- Evap. Recov. Credit
- Weight Penalty
- Total Cost
"Evap. I/M" Case:
- Refinery Cost
- Vehicle Cost
- Fuel Econ. Credit*
- Evap. Recov. Credit
- Weight Penalty
- Total Cost
* For R = 1.0; when.R
** Ac cnme>=: hassline in
11.5

0
28
0
-196
8
-160

N.A.***
N.A.
N.A.
N.A.
N.A.
N.A.

0
28
0
-196
8
-160

0
28
0
-124
8
: - 88

0
28
0
-166
	 8
-no
= 0.6,
-use RVP
11.0

192
23
- 72
-224
7
- 75

0
23
0
-137
7
-107

192
23
- 72
-219
7
- 69

192
23
- 72
-152
	 7
2

192
23
- 72
-186
7
- 36
10.5

421
18
-163
-254
5
"~28

229
18
- 91
-165
5
- 4

421
18
-163
-243
5
38

421
18
-163
-181
	 5
100

421
18
-163
-205
	 5_
76
fuel economy credit
of 11.0 r>s i . inste;
10.0

686
14
-261
-283
3
159

494
14
-189
-194
3
128

686
14
-261
-267
3
~TJ5

686
14
-261
-210
3
232

686
14
-261
-224
3
~2"T8
(psi )
9.5

962
9
-366
-311
2
~296

770
9
-294
-222
2
~264

962
9
-366
-289
2
318

962
9
-366
-238
	 2
368

962
9
-366
-242
2
365
is reduced by
3d of 11.5 osi ,

9.0

1256
0
-477
-339
0
440

1064
0
-405
-251
0
"408

1256
0
-477
-312
0
"467

1256
0
-477
-267
0
~BT2

1256
0
-477
-266
	 0
513
40%.
•
***  Not Applicable.

-------
                              6-10
     The    methodology    for    valuing    recovered/prevented
evaporative  HCs  from  the  gasoline  storage  and  distribution
system,  vehicle  refueling,   and motor  vehicle  operation  was
derived  in  Section VI  of  Chapter 4.   There, the  value  of  HC
(butane)  control  was  determined to  be $335.26  per  ton.   The
overall emission  reductions shown in  Table 6-1 for  the various
cases  can  simply be  multiplied by  this value  to  derive  the
annual recovery credits.  These are  shown in Table 6-3.

     As alluded to in Chapter 3, redesigning  motor  vehicles for
higher  volatility  would  increase   the  weight  of  the  motor
vehicle slightly, as a  larger canister would  be  required.   This
weight  increase  would cause the motor  vehicle to  consume more
fuel over  the course of  its  lifetime than  if the  vehicle  did
not have added weight  due  to  redesign.   This weight penalty and
associated discounted lifetime costs per vehicle  are derived in
Appendix 6-B  at  the end  of  this chapter  and are summarized in
Table  6-B-2.   These  per-vehicle costs  are  multiplied by  the
sales  projections  described  earlier  to  derive  annual  costs,
which are summarized in Table 6-3.

     The  net   costs  for  each  control   scenario   are   then
calculated by simply adding costs and subtracting credits.  The
long-term,  steady-state  cost  effectiveness   is  determined  by
simply dividing net annual cost by annual emission reduction.

     The calculations for the  4-month analysis are very similar
to those for  the 12-month  period.   Again,  the 4-month analysis
assumes  commercial  (in-use)  fuel  RVP  control   is  implemented
only   during   a   4-month   summer   period.    Of   course,   as
certification fuel changes affect vehicle  design, year-round HC
control  is  inherently  provided  and,  thus, no   option  for
seasonal control is available with that approach.

     Based  on the above assumptions, emission reductions  for a
4-month summer period (shown in Table 6-4)  are simply one-third
of  those developed  for  the  12-month  analysis.    Any emission
reductions due to  vehicle-related control  during  the non-summer
period are ignored.

     The cost calculations, however,  must  take into account the
fact that  vehicle-related  costs and  credits  occur year-round,
even   though  any  commercial  fuel  volatility   controls  are
removed.   Thus,   4-month  refinery  costs  and  credits  due  to
increased  fuel  density are simply  one-third  of  the year-round
values.   Vehicle  redesign  costs  and  the  associated  weight
penalty  are  the  same  as  the  year-round   values,  since  all
vehicles must be  modified  in  any case.   However, derivation of
the  evaporative  recovery/prevention  credit   is  more  complex.
During  the  summer period,  this  credit  is  simply  one-third  of
the  year-round  figure since  both  fuel-  and  vehicle-related
controls are fully operable.  However,  some  additional emission

-------
                                6-11


                              Table 6-4

                  4-Month  Emission  Reductions  Under
          Long-Term  Control  Scenarios  in 2010 (103 Tons)*

                                   In-Use = Cert.  RVP (psi)
123
72
0
0
0
195
139
72
6
4
2
223
157
72
11
8
4
252
171
72
17
13
7
280
187
72
23
17
9
Toe
205
72
28
21
11
337
Case/Category        11.5     11.0     10.5     10.0     9.5     9.0

"Base Case":
   - Evap. HC
   - Exhaust HC
   - Refueling
   - Bulk Storage
   - Stage I
   - Total

"Lower Baseline" Case:**
   - Evap. HC          -       77       95       109     125
   - Exhaust HC        -       59       59        59      59
   - Refueling         -        0        5        11      17
   - Bulk Storage      -        0        4         9      13
   - Stage I           -      	0      	2       	5     	7
   - Total             -      136      165       193     221

"Onboard" Case:
   - Evap. HC        123      139      157       171     187     205
   - Exhaust HC       72       72       72        72      72       72
   - Refueling         001         112
   - Bulk Storage      0        4        8        13      17       21
   - Stage I         	0      	2      	4       	7       9       11
   - Total           195      217      242       264     I8~6~     311

"No Exhaust" Case:
   - Evap. HC
   - Exhaust HC
   - Refueling
   - Bulk Storage
   - Stage I
   - Total

"Evap. I/M" Case:
   - Evap. HC
   - Exhaust HC
   - Refueling
   - Bulk Storage
   - Stage I
   - Total
123
0
0
0
0
123"
139
0
6
4
2
151
157
0
11
8
4
180
171
0
17
13
7
208
187
0
23
17
9
236
205
0
28
21
11
265
94
72
0
0
0
166
101
72
6
4
2
185
109
72
11
8
4
204
114
72
17
13
7
223
120
72
23
17
9
24T
126
72
28
21
11
238
*    Non-Cali fornia emission reductions only.
**   Assumes baseline in-use RVP of 11.0 psi, instead of  11.5 psi

-------
                              6-12


control occurs  in the non-summer period  in all scenarios where
vehicle redesign  is  required  (i.e.,  except for the  9.0-psi RVP
case,   where  no  change   is   made   to   certification  fuel
volatility).     These  non-summer   emission   reductions   were
estimated  by  running  MOBILES  (described  in  Chapter  5)  to
simulate a commercial fuel RVP  of  11.5  psi  with certification
volatilities  varying  between   9.5   and   11.5  psi  RVP.   The
development  of   these   non-summer   credits   for   the  4-month
analysis is  described in Appendix 6-C.   The  resulting  summer
and non-summer credits,  as  well  as  all the other  4-month costs
and credits,  are  summarized in Table 6-5.

     The cost effectiveness for  summer-only emission reductions
is  again  calculated  by  dividing the  net  4-month cost  by the
4-month emission  reductions.   All cost effectiveness  estimates
(both 12-month and 4-month) will be presented  in  Section  III in
Tables  6-6  through  6-21 and shown  graphically  in  Figures 6-1
through 6-8.   Their  relative  significance will be analyzed and
interpreted as the estimates are presented.

     B.    Short-Term Analysis

     As alluded  to throughout this study,  ozone  control  is the
primary focus  of the various   HC  reduction  strategies  being
evaluated.   Any reductions  achievable  in  the shorter term could
be  important in view of  the Clean Air act  requirement that all
urban  areas  be  in   attainment  of  the  ozone NAAQS  by 1987.
Although the long-term strategy  is to  ensure that certification
fuel  RVP  is  representative  of in-use   levels,  a  short-term
strategy could be to control  in-use fuel  RVP to  a  level lower
than  the  long-term  specification  in  order  to  achieve  the
additional  benefits  associated  only  with  in-use RVP  control.
These benefits  include:   1) an  immediate effect  on the  entire
motor vehicle  fleet, including  older  vehicles not  affected by
the  revised  certification fuel,  and   2)  further  control  of
in-use  RVP-related   emissions   such  as  gasoline   storage,
distribution,   refueling,   and  vehicular   emissions   due  to
tampering,  malmaintenance and defects.

     Therefore,  a short-term  analysis has been  performed  to
focus  on  the  incremental costs  and  emission   reductions  of
additional  in-use RVP control over  and above  the  long-term RVP
control strategies.   This analysis focuses on the  years 1988,
1990,  1992,  1995,  1997   and  2000.   As  before,  the  12-month
analysis is described first, followed by the 4-month analysis.

     Year-round  non-California  HC  emission  inventories  with
additional   short-term in-use  RVP  control  were  estimated  in
Chapter 5  and  summarized  in  Table  5-14; emission  reductions
were calculated from this  table  and  used  directly for  the base
case  here.   Modification  of  these  estimates  for the  various
sensitivity  cases is  handled  in  exactly  the same manner  as
described  for  the   long-term   analysis.    As  these   emission
reductions  are  due solely to in-use  RVP  control,  the emission
reductions  for the 4-month  analysis  are  simply one-third of the
year-round  reductions.

-------
                                  6-13
                               Table 6-5
Case/Category
4-Month Costs Under Long-Term
Control Scenarios in 2010 (lO^S/yr)
In-Use = Cert.
RVP ( ps i )
                    11.5
11.0
10.5
10.0
9.5
"Base Case":
   - Refinery Cost          0
   - Vehicle Cost          28
   - Fuel Econ. Credit*     0
   - Evap. Recov. Credit -191
   - Weight Penalty         8
   - Total Cost          -155
"Lower Baseline" Case:**
   - Refinery Cost
   - Vehicle Cost
   - Fuel Econ. Credit*
   -.Evap. Recov. Credit
   - Weight Penalty
   - Total Cost

"Onboard" Case:
   - Refinery Cost
   - Vehicle Cost
   - Fuel Econ. Credit*
   - Evap. Recov. Credit
   - Weight Penalty
   - Total Cost

"No Exhaust" Case:
   - Refinery Cost
   - Vehicle Cost
   - Fuel Econ. Credit*
   - Evap. Recov. Credit
   - Weight Penalty
   - Total Cost
"Evap. I/M" Case:
   - Refinery Cost          0
   - Vehicle Cost          28
   - Fuel Econ. Credit*     0
   - Evap. Recov. Credit -162
   - Weight Penalty      	8
   - Total Cost          -126
9.0
N.A***
N.A.
N.A.
N.A.
N.A.
N.A.
0
23
0
-132
7
-102
76
18
- 31
-131
	 5
- 63
165
14
- 63
-125
3
- 6
257
9
- 98
-113
2
56
355
0
-135
- 82
0
138
0
28
0
-191
8
-155
64
23
- 24
-194
7
-124
140
18
- 55
-189
5
- 81
229
14
- 87
-179
3
- 20
321
9
-122
-147
2
63
419
0
-159
-103
0
157
0
28
0
-119
8
^57
64
23
- 24
-137
7
^T7
140
18
- 55
-146
5
=~35
229
14
- 87
-146
3
T2~
321
9
-122
-127
2
~ST
419
0
-159
- 87
0
T73
321
9
-122
-154
2
-36
257
9
- 98
-113
2
56
321
9
-122
-147
2
63
321
9
-122
-127
2
~§T
321
9
-122
- 97
2
113
419
0
-159
-112
0
148
355
0
-135
- 82
0
138
419
0
-159
-103
0
157
419
0
-159
- 87
0
T73
419
0
-159
- 85
0
175
**
***
For R = 1.0; when R = 0.6, fuel economy credit is reduced by
Assumes baseline in-use RVP of 11.0 psi, instead of 11.5 psi,
Not Applicable.
                                                                  40%.

-------
                              6-14


     The  year-round  costs   of  additional  in-use  RVP  control
consist of only  three parts:   1)  refinery costs,  2) credit due
to  increased  fuel  density;  and  3)  credit  due to  recovered/
prevented evaporative emissions.   As before,  the  refinery cost
of each 0.5 psi of RVP control was taken  from Table 4-3.   Here,
however, the  "no-investment"  costs were  used for 1988 and 1990,
as there  would not  likely  be time  for  refiners  to  invest  in
capital equipment  for the  most  economic RVP control  refinery
processes.  "With  investment" costs were assumed  to  apply for
later years  as:   1)  at  least five years of  leadtime should be
available prior to 1992 and  2) the  short-term control would be
in place  sufficiently long  to justify capital investment (i.e.,
5-10 years).   These costs per barrel  were again multiplied by
on-highway,  non-California   fuel  consumption projections  from
EPA's MOBILES Fuel Consumption Model.[4]

     The  density-related  fuel economy credit  for  each 0.5 psi
of  additional RVP  control  is again taken from Table  4-11 and
multiplied by non-California  fuel consumption.   The evaporative
emission  recovery/prevention  credit   is  again   obtained  by
multiplying the  emission  reductions  calculated  from  Table 5-14
for  additional  in-use  RVP  control . by  the butane  value  of
$335.26  per  ton.     Since,    in   this  analysis  of  additional
short-term  in-use  RVP control,  all costs  are  related to fuel
control  and  none   to vehicle  control,  the  4-month  seasonal
control costs are simply one-third of the year-round costs.

     The cost effectiveness  estimates for both the 12-month and
the 4-month  analyses are simply  net costs divided  by emission
reductions.   These  estimates of  cost/ton will be  summarized
along with  long-term estimates in Tables 6-6 through  6-21 and
Figures 6-1 through 6-8 in the following section.

III. Results

     Using the methodologies  described  in the previous section,
12-month  and  4-month   costs  and  emission  reductions   were
determined  for  each  of  the  long-  and  short-term RVP  control
scenarios.  Using  these  results,  cost  effectiveness  estimates
(control  costs  per   ton)   were  determined  as  a  basis  for
comparison of  the  various alternatives.   This  section  focuses
on these  cost  effectiveness  estimates for the base case and for
each  of  the  sensitivity  cases   (i.e., -lower  baseline  RVP,
onboard,  no  exhaust  benefits, and  evaporative  I/M).   The base
case and  the  first  two  sensitivity cases  are  evaluated  using
"R" values of  both  1.0 and  0.6;  the other two cases  assume R =
1.0 only.   Results  of  the   12-month  and  4-month  analyses  for
each of the cases will  be  presented in  tabular form and their
relative  significance will  be discussed.   The  12-month  tables
will  be  supplemented by  figures showing emission  reductions
over time, with constant cost effectiveness lines superimposed.

-------
                              6-15


     A.    "Base" Case

     The base  case  represents  the combination of  the  current
regulatory situation and EPA's  best  technical estimates.   As
outlined earlier,  this  includes:  1)  no  onboard or Stage  II
control of refueling losses,  2)  no evaporative I/M  program,  3)
full  utilization  of  increased  gasoline  energy  content  and
recovered/prevented  evaporative  emissions by vehicles  (i.e.,  R
= 1.0),  and  4) an  assumption that in-use  RVP  will  continue to
rise until ASTM limits  are  reached  (i.e.,  Class C summertime
RVP will equal 11.5 psi, on average, by 1988).

     Twelve-month   emission   reductions,   costs,   and   cost
effectiveness estimates  are  shown  for  the base  case in  Table
6-6; year-round  reductions and  costs are  assumed.   Results  of
this 12-month  analysis  are   also  shown  graphically in  Figure
6-1.   Emission reductions  over  time are  shown  for each  RVP
control  scenario.   Constant  cost  effectiveness  lines  (dashed)
have been drawn to  facilitate comparison of the various control
options.  For  instance,  a  specific  cost-per-ton  line  can  be
traced  over  time  and across  RVP control scenarios  to  indicate
equivalent  control approaches for each year.

     The top portion of Table 6-6  presents  the  long-term (2010)
analysis, where  certification  fuel  and in-use  fuel RVPs  are
made   equal.    The   11.5-psi   scenario   represents   purely
vehicle-oriented  control  as  it  only  requires  a  change  in
certification fuel RVP (i.e.,  in-use RVP  is expected to  average
11.5  psi);   the  9.0-psi  case,   on  the  other  hand,  requires
primarily  in-use  fuel   control,   with  improvements   to  the
evaporative  emission  test  procedure  but  no  change  in  the
certification  fuel.   All  of the  intermediate  RVP  scenarios
combine  the  fuel-related   and   vehicle-oriented  approaches.
Table  6-6  shows that,  by 2010,  the vehicle-oriented  approach
(11.5-psi scenario)  is  significantly more cost-effective  than
the scenarios  involving fuel control,  and  actually  results  in
an overall savings  (i.e., negative $/ton).   This occurs because
fuel  economy  credits   from   recovered   evaporative  emissions
outweigh the costs  of  vehicle  redesign.  However,  additional
incremental  emission control is   achievable  via  more  in-use
fuel-oriented programs at increasing cost per  ton.

     The center  and bottom portions of Table 6-6  summarize the
short-term analysis,  where the  strategy is  to control  in-use
fuel RVP to  a  level   lower  than  the  long-term  certification
specification;   after a specified  time,  in-use  fuel  control
would  be  relaxed  to  the  long-term certification  RVP  level
chosen  via   the  long-term analysis.   The  short-term  analysis
focuses on years  between 1988 and  2000  (inclusive).   The  first
column ill this portion of the table shows the increment  between
the  long-term   certification/in-use  specifications  and  the
short-term   in-use  RVP;  0.5-psi  increments  are  shown  (e.g.,
long-term RVP  =  11.5,  short-term  in-use  RVP  lower  at  11.0).

-------
                              6-16
                            Table 6-6
             "Base" Case; 12-Month Analysis, R = 1.0
           In-Use Gasoline RVP Control Equal to Revised
              Cert.  Fuel  RVP  in the Long Term  (2010)
 In-Use =
 Revised

Cert. Fuel
 RVP (ps i)
  11.5
  11.0
  10.5
  10.0
   9.5
   9.0
 Emission
Reductions
(103 Tons/Yr)
Net
584
669
755
840
925
1010
Incr.
584
85
86
85
85
85
Net Cost*
(106 $/Yr)
                   Net
                  -160
                  - 75
                    28
                   159
                   296
                   440
      Incr.
      -160
        85
       102
       132
       137
       144
    Cost
Effectiveness
 ($/Ton)
Net
-274
-112
37
190
320
435
Incr.
-274
998
1197
1542
1619
1681
             Additional  In-Use Gasoline RVP Control
                  in  the  Short Term  (1988-2000)
Incremental
Control Step
 RVP (psi)
11.5-11.0
11.0-10.5
10.5-10.0
10.0- 9.5
 9.5- 9.0
Emission Reductions (10 Tons)
1988
283
255
216
193
169
1990
260
233
196
174
155
1992
217
196
166
151
137
1995
167
151
131
123
114
1997
138
128
113
107
105
2000
110
105
95
94
92
Incremental
Control Step
 RVP (ps i)

11.5-11.0
11.0-10.5
10.5-10.0
10.0- 9.5
 9.5- 9.0
Incremental Cost Effectiveness
1988
395
598
1036
1200
1551
1990
438
685
1101
1316
1666
1992
239
425
670
841
1046
1995
382
607
883
1053
1244
($/Ton)**
1997
586
840
1154
1327
1490
2000
697
972
1262
1389
1571
*    Bonner & Moore  refinery  costs  are  for  the baseline case with
     investment and  with NGL purchases treated  as  midway between
     the open and fixed NGL purchase scenarios.
**   1988  and  1990  costs are  based  on  no investment;  1992  and
     later assume  investment  has taken place;  refinery costs  are
     midway  between  those   of  open  and  fixed   NGL  purchase
     scenarios.

-------
                                 Figure 6-1
NON-CALIF.  EMISSION  REDUCTION/COST
                               BASE CASE*
  1200
                                                          EFF
                            1996
                               2000
2004
                                                                     T
1988
                            YEAR
 *With exhaust emission effect, without onboard, no evaporative I/M, with R = 1.0.
                                                           200B

-------
                              6-18


The  incremental  values  (based on 0.5-psi  intervals)  at  a given
in-use  RVP  (e.g.,  10.0  psi)  are  the   same   regardless  of
long-term  certification fuel  RVP  (e.g.,   10.5,  11.0,  or  11.5
psi).   It  should  be   noted  that  the   emission   reductions
associated with  equating certification  and in-use RVPs (i.e.,
the  long-term strategy)  are not  included in the  center  portion
of  the  table, but  rather only  the additional  reductions  that
can be obtained with short-term additional  in-use control.   The
cost/ton  estimates for  each  of  these  control  increments are
shown in the bottom portion of the table.

     As indicated  in  Table 6-6,  short-term cost  effectiveness
($/ton) rises  between  1988  and 1990, but then falls  in 1992.
This is easily explained — the  1988  and  1990  analyses assume
no  investment  on  the  part  of  refineries,   while  post-1990
calculations  use control  costs based  on  capital  investments
which   improve   the   efficiencies  of   refinery   operations.
Therefore, later-year costs  of in-use RVP control are  reduced
and resultant cost/ton  in  1992 is  lower  than in 1990.  However,
while in-use  RVP control costs remain  rather  constant  between
1992 and  2000,   emission  reductions  achievable with  in-use RVP
control decrease with time as the vehicle  fleet  gradually turns
over  (i.e.,  vehicles  with  larger  canisters  designed  for the
revised long-term  certification RVP,  beginning  with the  1990
model  year,   start to  make  up more  and  more  of  the  in-use
fleet).   Therefore, incremental cost/ton rises between 1992 and
2000 and  tends  to approach the  long-term  figures shown in the
top  portion  of  Table  6-6.   Actually,  if  2010  estimates  were
shown  for   short-term   additional  in-use  RVP  control,   the
cost/ton   would   be   slightly  higher   than   the   long-term
incremental estimates  because the  vehicle fleet  would  consist
entirely of post-1990 vehicles which  were  overdesigned  for the
lower in-use RVP level.

     The  4-month analysis for  the base  case  is  summarized in
Table 6-7.  As described in Section II of  this  chapter,  4-month
emission  reductions  are  simply   one-third   of  the  12-month
estimates; however, control costs  are less straightforward and
represent  more  than one-third of  annual costs.   Therefore,  as
indicated  in Table   6-7,  the  4-month  cost  effectiveness  is
arithmetically   higher   than  the   12-month  estimates  shown
previously.

     The  base case  results  discussed   above  are  based   on  a
100-percent utilization  (R  = 1.0) of the  increased  fuel energy
density.    As  mentioned  earlier,  there  is  some  uncertainty in
this  estimate as  the very  limited data  available   indicate  a
wide  range  of  efficiencies.   Therefore,  to   determine  the
sensitivity  of  the  base  case  results  to  this  "R"  value,
calculations  were  repeated   using  a   60-percent  utilization
efficiency (i.e., R =  0.6  instead of R =  1.0).   The  results of
this sensitivity analysis are  shown for  12-month and  4-month

-------
                               6-19


                            Table 6-7

              "Base"  Case:  4-Month Analysis,  R =  1.0
           In-Use Gasoline  RVP Control Equal  to  Revised
              Cert.  Fuel  RVP  in  the  Long Term (2010)
 In-Use =
 Revised
Cert. Fuel
 RVP (psi)
 Emission
Reductions
  11,
  11.
  10,
  10,
   9,
   9.0
(10 Tons/Yr)
Net
195
223
252
280
308
337
Incr.
195
28
29
28
28
28
         Net Cost*
         (106 $/Yr)
                   Net
                  -155
                  -126
                  - 85
                  - 25
                    56
                   148
               Incr.

               -155
                 30
                 41
                 60
                 81
                 92
                     Cost
                 Effectiveness

                  ($/Ton)
               Net
              - 799
              - 563
              - 336
              -  89
                182
                440
                Incr.

                - 799
                 1045
                 1442
                 2092
                 2880
                 3229
             Additional  In-Use Gasoline  RVP  Control
                  in  the  Short Term  (1988-2000)
Incremental
Control Step
 RVP (psi)

11.5-11.0
11.0-10.5
10.5-10.0
10.0- 9.5
 9.5- 9.0
Emission Reductions (10 Tons)
1988
94
85
72
64
56
1990
87
78
65
58
52
1992
72
65
55
50
46
1995
55
50
44
41
38
1997
46
43
38
36
35
2000
37
35
32
31
30
Incremental
Control Step
 RVP (psi)

11.5-11.0
11.0-10.5
10.5-10.0
10.0- 9.5  ,
 9.5- 9.0
      Incremental Cost Effectiveness ($/Ton)**
  1988

   395
   598
  1036
  1200
  1551
1990

 434
 690
1104
1323
1683
1992

 247
 453
 728
 972
1234
1995

 412
 684
1066
1430
1756
1997

 633
 955
1404
1866
2177
2000

 797
1170
1708
2279
2732
'    Bonner sT~Moore  refinery  costs  are  for  the baseline case with
     investment and  with  NGL purchases treated  as  midway between
     the open and fixed NGL purchase scenarios.
**   1988  and  1990  costs  are  based  on  no investment;  1992 and
     later assume  investment  has taken place;  refinery costs are
     midway  between   those   of  open  and   fixed   NGL  purchase
     scenarios.

-------
                              6-20


control periods .in  Tables  6-8 and  6-9,  respectively.   Figure
6-2 presents the  results  of the  12-month analysis in  the same
manner as in Figure  6-1.   As indicated in the tables, the lower
R-value results  in  slightly higher costs (due  to  lower  fuel
economy   credits)    and,   thus,    arithmetically   higher   cost
effectiveness.   For  example,  in  the  12-month  analysis of  the
9.0-psi long-term  scenario, incremental  cost/ton  increases  by
31 percent,  or by $520/ton, with the lower  R-value.  However,
as with   the  R =  1.0  case,  net  savings (negative  $/ton)  are
still  projected  for   the  11.5-psi  and  11.0-psi   long-term
scenarios.

     B.    "Lower Baseline RVP" Case

     The  base  case  analyzed  above  assumes  that,   by  1988,
average summer  in-use RVPs  will  have reached  the ASTM limits
recommended  for  various   areas   (see  Chapter  2,   Section  IV).
This second sensitivity analysis  examines the  possibility that
in-use RVP will not  actually reach the ASTM limits by 1988,  but
will  instead  stay  at  current levels  (i.e.,  roughly  0.5  psi
below  ASTM  limits).   Since our   analysis focuses on  Class  C
summertime RVPs,  this changes the baseline  in-use RVP of  the
study  from  11.5  to  11.0  psi.   (The baseline certification  RVP
is 9.0 psi in both cases.)   Therefore, emission reductions from
baseline  are  lower  than  under   the  base  case   discussed  in
Section A, as  uncontrolled  levels are  lower (based on  11.0  psi
instead of  11.5 psi).   The sensitivity of  lower  baseline  RVP
was analyzed for  both the  12-month  and  4-month  control cases.
The   results   are   summarized   in   Tables   6-10   and  6-11,
respectively,  for  R  equal  to 1.0,  and  Tables  6-12   and  6-13,
respectively,  for  R equal  to 0.6.   The 12-month results  are
also shown graphically  for  R = 1.0 and R =  0.6 in Figures  6-3
and 6-4,  respectively.

     As  indicated  by  comparing   these   four  tables with  the
previous  four, a  lower  baseline RVP  results  in reduced  net
emission   benefits   and   arithmetically   higher   net   cost
effectiveness.    For   example,  with  the  12-month   long-term
9.0-psi case,  net reductions are  26  percent lower  and net costs
are just slightly lower, which results in a  26-percent increase
in overall  cost/ton.  However, as incremental cost/ton is  the
most  relevant,  it  is important  to  note  that  in  the  12-month
analysis  the  incremental  values below  the new  11.0-psi  RVP
baseline  remain  essentially unchanged from  the base   case.   In
both  cases,  the  12-month   long-term  9.0-psi  scenario has  an
incremental cost/ton  of almost $1700.   The effect  of the  lower
R value is the same as under the base case.

-------
                               6-21


                            Table 6-8

             "Base" Case; 12-Month Analysis, R = 0.6
           In-Use Gasoline  RVP Control Equal  to  Revised
             Cert.  Fuel  RVP  in  the Long Term (2010)
 In-Use =
 Revised
Cert. Fuel
 RVP (psi)

  11.5
  11.0
  10.5
  10.0
   9.5
   9.0
 Emission
Reductions
(103 Tons/Yr)
Net
584
669
755
840
925
1010
Incr.
584
85
86
85
85
85
Net Cost*
(106 $/Yr)
             Cost
         Effectiveness
          ($/Ton)
                   Net

                  -160
                  - 46
                    93
                   264
                   444
                   631
      Incr,
      -160
       114
       139
       171
       179
       188
Net
-274
- 69
123
314
479
624
Incr.
-274
1334
1625
2001
2114
2201
             Additional  In-Use  Gasoline  RVP  Control
                  in  the  Short Term  (1988-2000)
Incremental
Control Step
 RVP (psi)

11.5-11.0
11.0-10.5
10.5-10.0
10.0- 9.5
 9.5- 9.0
Emission Reductions (10 Tons)
1988
283
255
216
193
169
1990
260
233
196
174
155
1992
217
196
166
151
137
1995
167
151
131
123
114
1997
138
128
113
107
105
2000
110
105
95
94
92
Incremental
Control Step     	
 RVP (psi)       1988:

11.5-11.0         507
11.0-10.5         756
10.5-10.0        1235
10.0- 9.5        1437
 9.5- 9.0        1839
       Incremental Cost Effectiveness ($/Ton)**
             556
             840
            1329
            1572
            1972
1992

 376
 605
 932
1128
1328
1995

 553
 830
1201
1391
1628
1997

 770
1074
1480
1668
1865
2000

 944
1281
1679
1809
2035
*Bonner& Moore  refinery  costs  are  for  the baseline case with
     investment and  with  NGL purchases treated  as  midway between
     the open and fixed NGL purchase scenarios.
**   1988  and  1990  costs  are  based  on  no investment;  1992  and
     later assume  investment  has taken place;  refinery costs  are
     midway  between   those   of  open  and   fixed   NGL  purchase
     scenarios.

-------
                              6-22


                            Table 6-9

              "Base"  Case; 4-Month Analysis,  R  = 0.6
           In-Use Gasoline  RVP Control Equal to Revised
              Cert.  Fuel  RVP  in  the Long Term  (2010)
 In-Use =
 Revised
Cert. Fuel
 RVP (psi)
              Emission
             Reductions
    .5
    ,0
    ,5
11,
11,
10,
10.0
 9.5
 9.0
(10 Tons/Yr)
Net
195
223
252
280
308
337
Incr.
195
28
29
28
28
28
   Net  Cost*
   (106 $/Yr)
 Net
-155
-116
- 63
  10
 105
 212
Incr.
-155
  39
  53
  73
  95
 107
               Cost
           Effectiveness
            (ft/Ton)
 Net
- 799
- 520
- 250
   35
  340
  629
Incr.

- 799
 1382
 1871
 2551
 3375
 3749
             Additional  In-Use Gasoline RVP  Control
                   in  the Short Term  (1988-2000)
Incremental
Control Step
 RVP (ps i)

11.5-11.0
11.0-10.5
10.5-10.0
10.0- 9.5
 9.5- 9.0
Emission Reductions (10 Tons)
1988
94
85
72
64
56
1990
87
78
65
58
52
1992
72
65
55
50
46
1995
55
50
44
41
38
1997
46
43
38
36
35
2000
37
35
32
31
30
Incremental
Control Step     	_
 RVP (ps i)       1988

11.5-11.0         507
11.0-10.5         756
10.5-10.0        1235
10.0- 9.5        1437
 9.5- 9.0        1839
                    Incremental Cost Effectiveness ($/Ton)**
                         1990

                          552
                          845
                         1332
                         1578
                         1989
   1992

    384
    633
    990
   1258
   1570
  1995

   584
   907
  1383
  1768
  2141
   1997

    817
   1188
   1729
   2207
   2553
 2000

 1044
 1479
 2124
 2699
 3196
**
   Bonner & Moore  refinery  costs are  for  the baseline case with
   investment and  with  NGL purchases treated  as  midway between
   the open and fixed NGL purchase  scenarios.
   1988  and  1990  costs  are based  on no investment?  1992  and
   later assume  investment  has  taken place; refinery costs  are
   midway  between   those   of   open  and   fixed   NGL  purchase
   scenarios.

-------
                        Figure 6-2
 NON-CALIF.  EMISSION  REDUCTION/COST  EFF
                           BASE CASE WITH R = 0.6
o
8
O
O
Ul
flC


O
bl
      1988
200B
                                                         (O
                                                         Ul

-------
                               6-24


                           Table 6-10

      "Lower Baseline RVP" Case; 12-Month Analysis, R = 1.0
           In-Use Gasoline  RVP Control Equal  to  Revised
              Cert.  Fuel  RVP  in  the Long Term (2010)
 In-Use =
 Revised
Cert. Fuel
 RVP (psi)

  11.0
  10.5
  10.0
   9.5
   9.0
 Emission
Reductions
(10 Tons/Yr)
Net
407
493
578
663
748
Incr.
407
86
85
85
85
         Net Cost*
         (106 $/Yr)
                   Net
                  -107
                  -  4
                   128
                   264
                   408
               Incr.
               -107
                103
                132
                136
                144
                     Cost
                 Effectiveness
                  ($/Ton)
               Net
              -263
              -  8
               221
               399
               546
                Incr,

                -263
                1207
                1541
                1611
                1685
             Additional  In-Use Gasoline  RVP  Control
             	  in  the Short Term  (1988-2000)
Incremental
Control Step
 RVP (ps i )

11.0-10.5
10.5-10.0
10.0- 9.5
 9.5- 9.0

1988
255
216
193
169
Emission Reduction (10
1990 1992 1995
233 196 151
196 166 131
174 151 123
155 137 114
Tons)
1997
128
113
107
105

2000
105
95
94
92
Incremental
Control Step
 RVP (ps i)

 11.0-10.5
 10.5-10.0
 10.0- 9.5
  9.5- 9.0
       Incremental Cost Effectiveness ($/Ton)
                                 **
  1988

   598
  1036
  1200
  1551
1990

 685
1101
1316
1666
1992

 425
 670
 841
1046
1995

 607
 883
1053
1244
1997

 840
1154
1327
1490
2000

 972
1262
1389
1571
*  Bonner &  Moore refinery costs  are for the  baseline  case with
   investment  and with  NGL purchases  treated  as  midway  between
   the open and fixed NGL purchase scenarios.
** 1988 and  1990  costs  are  based  on  no investment;  1992 and later
   assume investment  has taken place; refinery  costs  are midway
   between those of open and fixed NGL purchase scenarios.

-------
                               6-25


                            Table  6-11

        "Lower Baseline" Case;  4-Month Analysis, R = 1.0

           In-Use Gasoline  RVP Control  Equal  to  Revised
              Cert.  Fuel  RVP in the  Long  Term (2010)
 In-Use =
 Revised

Cert. Fuel
 RVP (psi)

  11.0
  10.5
  10.0
   9.5
   9.0
             Emission
            Reductions
(10 Tons/Yr)
Net
136
165
193
221
249
Incr.
136
29
28
28
28
Net Cost*
(106 $/Yr)
                               Net
                              -102
                               -63
                                -6
                                56
                               138
      Incr,

      -102
        39
        57
        62
        82
       Cost
   Effectiveness
    ($/Ton)
 Net
-755
-384
 -32
 253
 552
Incr.

-755
1379
1996
2204
2866
             Additional  In-Use  Gasoline  RVP  Control
                   in  the Short  Term (1988-2000)
Incremental
Control Step
 RVP (ps i)

 11.0-10.5
 10.5-10.0
 10.0-9.5
  9.5-9.0

1988
85
72
64
56
Emission Reduction (10
1990 1992 1995
78 65 50
65 55 44
58 50 41
52 46 38
Tons)
1997
43
38
36
35

2000
35
32
31
30
Incremental
Control Step
 RVP (ps i)
 11.0-10.5
 10.5-10.0
 10.0-9.5
  9.5-9.0
                   Incremental Cost Effectiveness ($/Ton)**
                                                          2000
                                                          1170
                                                          1708
                                                          2279
                                                          2732
**
Bonner &  Moore refinery costs  are for the  baseline case with
investment  and with  NGL purchases  treated  as  midway between
the open and fixed NGL purchase scenarios.
1988 and  1990  costs are  based  on  no investment; 1992 and later
assume investment  has taken  placer refinery  costs  are midway
between those of open and fixed NGL purchase scenarios.

-------
                               6-26


                            Table 6-12

      "Lower Baseline RVP" Case; 12-Month Analysis, R = 0.6
           In-Use Gasoline  RVP Control Equal  to  Revised
              Cert.  Fuel  RVP  in  the Long Term (2010)
 In-Use
 Revised

Cert. Fuel
 RVP (ps i)
  11.0
  10.5
  10.0
   9.5
   9.0
 Emission
Reductions
(103 Tons/Yr)
Net
407
493
578
663
748
Incr.
407
86
85
85
85
         Net  Cost*
         (106 $/Yr)
                     Cost
                 Effectiveness
                  ($/Ton)
                   Net
                  -107
                    33
                   204
                   382
                   570
               Incr.
               -107
                139
                171
                178
                188
               Net
              -263
                66
               352
               576
               763
                Incr,
                -263
                1633
                2000
                2108
                2205
             Additional  In-Use Gasoline RVP Control
                   in  the Short Term  (1988-2000)
Incremental
Control Step
 RVP (ps i)

11.0-10.5
10.5-10.0
10.0- 9.5
 9.5- 9.0
Emission Reduction (10"
1988
255
216
193
169
1990
233
196
174
155
1992
196
166
151
137
1995
151
131
123
114
Tons)
1997
128
113
107
105

2000
105
95
94
92
Incremental
Control Step
 RVP (psi)

 11.0-10.5
 10.5-10.0
 10.0- 9.5
  9.5- 9.0
       Incremental Cost Effectiveness ($/Ton)
                                 **
  1988

   756
  1235
  1437
  1839
1990

 840
1329
1572
1972
1992

 605
 932
1128
1328
1995

 830
1201
1391
1628
1997

1074
1480
1668
1865
2000

1281
1679
1809
2035
*  Bonner &  Moore refinery costs  are for the  baseline  case with
   investment  and with  NGL purchases  treated  as  midway  between
   the open and fixed NGL purchase scenarios.
** 1988 and  1990  costs  are  based  on  no investment;  1992  and later
   assume investment  has taken  place;  refinery  costs are midway
   between those of open and fixed NGL purchase scenarios.

-------
                               6-27


                            Table  6-13

        "Lower Baseline" Case;  4-Month Analysis, R = 0.6
           In-Use Gasoline  RVP  Control  Equal  to  Revised
              Cert.  Fuel  RVP  in the Long Term (2010)
 In-Use =
 Revised
Cert. Fuel
 RVP (ps i)
  11.0
  10.5
  10.0
   9.5
   9.0
 Emission
Reductions
(103 Tons/Yr)
 Net
 136
 165
 193
 221
 249
Incr,

 136
  29
  28
  28
  28
             Net Cost*
             (106 $/Yr)
 Net
-102
 -51
  19
  95
 192
Incr,

-102
  51
  70
  76
  96
                        Cost
                    Effectiveness
                     ($/Ton)
 Net

-755
-310
  99
 431
 769
Incr,

-755
1805
2455
2701
3386
             Additional  In-Use Gasoline  RVP  Control
                   in  the Short Term  (1988-2000)
Incremental
Control Step
 RVP (ps i )
 11.0-11.5
 10.5-10.0
 10.0-9.5
  9.5-9.0

1988
85
72
64
56
Emiss
1990
78
65
58
52
ion Reduction (10
1992 1995
65 50
55 44
50 41
46 38
Tons)
1997
43
38
36
35

2000
35
32
31
30
Incremental
Control Step
 RVP (ps i)

 11.0-10.0
 10.5-10.0
 10.0-9.5
  9.5-9.0
  	Incremental Cost Effectiveness ($/Ton)**
  1988      1990     r9~9219^519^7    2000
   756.
  1235
  1437
  1839
     845
    1332
    1578
    1989
    633
    990
   1258
   1570
   907
  1383
  1768
  2141
   1188
   1729
   2207
   2553
 1479
 2124
 2699
 3196
*Bonner&Moore refinery costs  are for the  baseline case with
   investment and with  NGL  purchases  treated  as  midway between
   the open and fixed NGL purchase scenarios.
** 1988 and  1990  costs are based  on  no investment; 1992 and later
   assume investment  has taken  place; refinery  costs  are midway
   between those of open and fixed NGL purchase scenarios.

-------
                          Figure 6-3
  NON-CALIF.  EMISSION REDUCTION/COST EF
   1200
   1100 -
                     LOW RVP BASELINE CASE
R
O
8
O
O
Ul
(XL
O
Ul
      1988
2008
                                                        KJ
                                                        00

-------
                         Figure 6-4
  NON-CALIF. EMISSION REDUCTION/COST EF
O

8
O
o
ui
O
UI
   1200
                     LOW RVP BASELINE CASE WITO R = 0.6
      1988
2008
                                                        NJ

                                                        VO

-------
                              6-30
     C.    "With Onboard Control" Case

     The   third  sensitivity  case  examines  the  effect of  an
onboard  refueling  loss  control  program  on  the  RVP  control
measures  being examined  in  this report.   Because  an  onboard
rulemaking would  likely be  running  about one year ahead of any
evaporative  control  rule,   an onboard  implementation  date  of
1989  was  assumed.   However,  a  year's delay   in  the  onboard
rulemaking (if  decided upon)  —  meaning an  implementation date
of 1990 — would  not  be expected to have a great  impact on the
results  of this  sensitivity  analysis.  For  all years except
1988   (pre-onboard   control),  the   emission   reductions   are
somewhat  lower  than under the base  case because onboard control
would  capture  a  certain   percentage   of  the  reductions  in
refueling  losses  previously  attributed to in-use RVP control.
As  indicated  earlier  in  Table  6-1,  the  overall  fleetwide
efficiency  of  onboard control  (including tampering)  will  be
approximately 94  percent  by the year 2010; therefore, emission
reductions in  the refueling loss category were reduced  by this
percentage under  the  onboard sensitivity case.   Overall  onboard
efficiencies assumed  for  1990, 1992,  1995,  1997, and 2000 are
as follows:  22, 41, 62, 73, and 83  percent,  respectively.

     The   emission   reductions,  costs,   and   resulting  cost
effectiveness  estimates  for this  onboard  control  sensitivity
case  are presented in Tables  6-14  through  6-17.   As  before,
both  12-month  and  4-month analyses  are summarized,  and the
sensitivity  of "R"  is  also  examined.  The   results  of  this
onboard  control  sensitivity case are  shown graphically  for the
12-month analysis in  Figures 6-5  and 6-6,  with R =  1.0  and R =
0.6,   respectively.     The   effect    of  implementing  onboard
refueling  controls   is  a  slight  worsening  of   the  cost
effectiveness  for  the various  RVP  control   strategies.   For
example,  in  the  12-month,   R  =  1.0   onboard  analysis  (Table
6-14),  the  incremental emission  reductions in  2010  are  roughly
19 percent lower  than with  the base case (69,000  tons compared
to  85,000 tons).    Incremental costs  are  from  3  to  7  percent
higher,  resulting in  a cost/ton  that  is  28-31  percent higher
(depending on RVP scenario).

     D.    "Without Exhaust Benefits" Case

     As discussed in  Chapter 2,  lower RVP fuels have been  shown
to  produce lower exhaust HC  emissions.   Based  on  testing  to
date,  this effect  is  statistically significant. The  base case
discussed  in   Section A  above   includes  these   exhaust  HC
reductions.    In  order  to  illustrate  the    impact  of   these
particular benefits on the  cost/ton estimates made  in the base
case,   the  sensitivity   of   eliminating   these   exhaust  HC
reductions was examined here.

-------
                              6-31



                           Table 6-14

            "Onboard" Case: 12-Month Analysis,  R  =  1.0
          In-Use Gasoline RVP Control Equal to Revised
             Cert. Fuel RVP  in the Long Term  (2010)
 In-Use =
 Revised

Cert. Fuel
 RVP (psi )
  11.5
  11.0
  10.5
  10.0
   9.5
   9.0
 Emission
Reductions
(103 Tons/Yr)
 Net
 584
 653
 723
 792
 861
 930
Incr.
 584
  69
  70
  69
  69
  69
             Net Cost*
             (106 $/Yr)
                        Cost
                    Effectiveness
                     ($/Ton)
 Net
-160
 -69
  38
 175
 318
 467
Incr,
-160
  91
 108
 137
 142
 149
Net
-274
-106
53
222
369
502
Incr .
-274
1305
1550
1976
2076
2147
             Additional In-Use Gasoline  RVP Control
                   in  the  Short Term  (1988-2000)
Incremental
Control Step
 RVP (psi)
11.5-11.0
11.0-10.5
10.5-10.0
10.0- 9.5
 9.5- 9.0
Emission Reductions (10 Tons)
1988
283
255
216
193
169
1990
256
230
191
171
152
1992
210
189
160
144
130
1995
157
141
121
113
104
1997
127
116
102
96
94
2000
98
91
83
81
78
Incremental
Control Step     	_
 RVP (ps i)        1988

11.5-11.0         395
11.0-10.5         598
10.5-10.0        1036
10.0- 9.5        1200
 9.5- 9.0        1551
       Incremental Cost Effectiveness ($/Ton)**
                                              2000
    1990

     451
     700
    1128
    1359
    1713
   1992

    258
    454
    710
    899
   1122
  1995

   427
   673
   992
  1173
  1406
1997

 668
 954
1306
1523
1695
                                               828
                                              1164
                                              1503
                                              1673
                                              1874
*    Bonner & Moore refinery  costs  are  for  the baseline case with
     investment and with  NGL purchases treated  as  midway between
     the open and fixed NGL purchase scenarios.
**   1988  and  1990 costs  are based  on  no  investment;  1992  and
     later assume  investment  has  taken place;  refinery costs  are
     midway  between   those   of   open  and   fixed   NGL  purchase
     scenarios.

-------
                              6-32


                           Table 6-15

            "Onboard" Case;  4-Month Analysis, R =  1.0
           In-Use Gasoline RVP Control Equal to Revised
             Cert.  Fuel  RVP  in the Long Term  (2010)
 In-Use =
 Revised

Cert. Fuel
 RVP (psi)
  11.5
  11.0
  10.5
  10.0
   9.5
   9.0
 Emission
Reductions
(103 Tons/Yr)
Net
195
218
241
264
287
310
Incr.
195
23
23
23
23
23
         Net  Cost*
         (106 $/Yr)
                   Net
               Incr.
               -155
                 32
                 43
                 61
                 83
                 94
                     Cost
                 Effectiveness
                  ($/Ton)
Net
-799
-569
-336
-74
221
507
Incr .
-799
1364
1853
2652
3632
4052
             Additional  In-Use Gasoline RVP Control
                   in  the Short Term  (1988-2000)
Incremental
Control Step
 RVP (psi)
 11.5-11.0
 11.0-10.5
 10.5-10.0
 10.0-9.5
  9.5-9.0
Emission Reductions (10 Tons)
1988
94
85
72
64
56
1990
85
77
64
57
51
1992
70
63
53
48
43
1995
52
47
40
38
35
1997
42
39
34
32
31
2000
33
30
28
27
26
Incremental
Control Step
 RVP (ps i)

 11.5-11.0
 11.0-10.5
 10.5-10.0
 10.0- 9.5
  9.5- 9.0
  	Incremental Cost Effectiveness ($/Ton)**
  1988      1990     1992    1995     1997    2000
   395
   598
  1036
  1200
  1551
 448
 706
1131
1366
1730
 267
 483
 770
1036
1320
 459
 755
1190
1582
1971
 719
1080
1582
2127
2461
 941
1391
2015
2710
3220
*  Bonner &  Moore refinery costs  are  for the  baseline  case with
   investment  and with  NGL  purchases  treated  as  midway  between
   the open and fixed NGL purchase scenarios.
** 1988 and  1990  costs  are based  on  no investment;  1992 and later
   assume investment  has taken place; refinery costs  are midway
   between those  of open and fixed NGL purchase scenarios.

-------
                              6-33


                           Table 6-16

            "Onboard" Case: 12-Month Analysis,  R =  0.6
           In-Use Gasoline RVP Control Equal  to  Revised
             Cert. Fuel RVP  in the Long Term (2010)
 In-Use =
 Revised

Cert. Fuel
 RVP (psi)

  11.5
  11.0
  10.5
  10.0
   9.5
   9.0
 Emission
Reductions
(103 Tons/Yr)
Net
584
653
723
792
861
930
Incr.
584
69
70
69
69
69
         Net Cost*
         (106 $/Yr)
                     Cost
                 Effectiveness
                  ($/Ton)
                   Net
               Incr,

               -160
                119
                144
                176
                184
                193
Net
-274
-62
143
354
539
707
Incr.
-274
1719
2077
2541
2686
2787
             Additional  In-Use Gasoline  RVP  Control
                   in the Short Term  (1988-2000)
Incremental
Control Step
 RVP (ps i )

11.5-11.0
11.0-10.5
10.5-10.0
10.0- 9.5
 9.5- 9.0
Emission Reductions (10 Tons)
1988
283
255
216
193
169
1990
256
230
191
171
152
1992
210
189
160
144
130
1995
157
141
121
113
104
1997
127
116
102
96
94
2000
98
91
83
81
78
Incremental
Control Step
 RVP (psi)

 11.5-11.0
 11.0-10.5
 10.5-10.0
 10.0- 9.5
  9.5- 9.0
  	Incremental Cost Effectiveness ($/Ton)**
  1988      1990     1992    1995     1997    2000
   507
   756
  1235
  1437
  1839
 571
 858
1360
1621
2026
 400
 641
 982
1200
1477
 690
 911
1337
1540
1830
 868
1211
1666
1906
2113
1106
1519
1982
2163
2412
*  Bonner &  Moore refinery costs  are for the  baseline  case with
   investment  and with NGL  purchases  treated  as  midway between
   the open and fixed NGL purchase scenarios.
** 1988 and  1990  costs are based  on  no investment;  1992 and later
   assume investment  has  taken place; refinery costs  are midway
   between those of open and fixed NGL purchase scenarios.

-------
                               6-34


                            Table 6-17

            "Onboard"  Case;   4-Month Analysis,  R  =  0.6

           In-Use Gasoline RVP  Control Equal  to Revised
              Cert.  Fuel  RVP in the Long Term (2010)
 In-Use =
 Revised

Cert. Fuel
 RVP (psi)
  11.5
  11.0
  10.5
  10.0
   9.5
   9.0
 Emission
Reductions
(103 Tons/Yr)
Net
195
218
241
264
287
310
Incr .
195
23
23
23
23
23
         Net Cost*
         (106 $/Yr)
                   Net
                  -155
                  -114
                  - 59
                    15
                   112
                   221
               Incr,
               -155
                 41
                 55
                 74
                 97
                109
                     Cost
                 Effectiveness
                  ($/Ton)
               Net
              -799
              -525
              -246
                58
               391
               712
                Incr.
                -799
                1778
                2380
                3217
                4242
                4692
             Additional  In-Use Gasoline  RVP  Control
                   in  the Short Term  (1988-2000)
Incremental
Control Step
 RVP (ps i )
11.5-11.0
11.0-10.5
10.5-10.0
10.0- 9.5
 9.5- 9.0
Emission Reductions (10 Tons)
1988
94
85
72
64
56
1990
85
77
64
57
51
1992
70
63
53
48
43
1995
52
47 .
40
38
35
1997
42
39
34
32
31
2000
33
30
28
27
26
Incremental
Control Step
 RVP (psi)

 11.5-11.0
 11.0-10.5
 10.5-10.0
 10.0- 9.5
  9.5- 9.0
       Incremental Cost Effectiveness ($/Ton)**
  1988

   507
   756
  1235
  1437
  1839
1990

 568
 863
1363
1628
2044
1992

 409
 669
1042
1337
1674
1995

 641
 993
1536
1950
2395
1997

 919
1336
1942
2510
2879
2000

1219
1746
2494
3199
3758
*  Bonner &  Moore refinery costs  are  for the  baseline  case with
   investment  and with  NGL purchases  treated  as  midway  between
   the open and fixed NGL purchase scenarios.
** 1988 and  1990  costs  are  based  on  no  investment; 1992 and later
   assume investment  has taken  place;  refinery  costs  are midway
   between those of open and fixed NGL purchase scenarios.

-------
                          Figure 6-5


  NON-CALIF.  EMISSION  REDUCTION/COST  EFF
                         WITH ONBOARD
V>

I
o
8
Z
O
o
Ul
(XL


O
u
     o -*
      1988
1992
1996
     1    T
2004     2008
                                                          o>

                                                          Ul
                            YEAR

-------
                       Figure 6-6
  NON-CALIF. EMISSION  REDUCTION/COST EFF
                       WITH ONBOARD AND R = 0.6
Ul
     1988
2008
                                                    T
                                                    UJ

-------
                              6-37


     Tables  6-18  and 6-19  summarize  the  cost  effectiveness,
etc., of the various RVP control  strategies without  benefits in
the  exhaust  HC category.  (The  sensitivity  of the  R-value was
not  evaluated  for  this  case.)   The  12-month  results  are  also
shown  in  Figure  6-7.   For  this  sensitivity case,  base-case
emission  reductions  were  simply  reduced  by  the  amount  of
benefits  previously   attributed  to  exhaust  emissions.    As
indicated earlier in Table 6-1, this  amount was estimated to be
215,000  tons  in  2010;  however,  for earlier  years  before the
fleet has completely turned over with new vehicles,  the tonnage
attributed to  exhaust  reductions  varies  with  RVP.  (See details
on this  in Chapter  2,  Section V.)  The fuel economy credit due
to  increased  energy  content  does  not  change from base  case
because the  same amount  of butane  is still  being  removed  from
the  fuel.  However,  the evaporative  recovery/prevention credit
is  lower  with  this   sensitivity  case  because  the  total  HC
emission reductions used to calculate this credit  are  lower if
exhaust  HC  reductions  are  not   included.   This  reduction  in
overall  emission benefits,  coupled with the slight  increase in
overall  costs,  results in slightly  higher net  costs  per  ton.
As shown in  Tables  6-18  and 6-19, the elimination of exhaust HC
benefits predictably  increases  the  short-term $/ton estimates
by  as  much  as  27  percent in  1988.   However,  in the long-term
2010  analysis,  12-month  incremental emission  reductions  and
incremental  costs  are the  same  as  in the  base case,  so  2010
costs per ton do not change on the increment.

     E.    "Evaporative I/M Program" Case

     The  final  sensitivity   analysis examines  the  impact  an
effective  inspection   and   maintenance . (I/M)   program   for
evaporative   emission   controls   would  have  on   the   cost
effectiveness  of RVP  control strategies.  For purposes of  this
analysis,  this  evaporative  I/M  program  is  assumed  to  be
implemented  nationwide  by  1988  (the  first  projection  year
examined).    As discussed  earlier,  such  a program  would  most
likely be  initiated only  in urban ozone non-attainment areas,
but the  relative impact  would parallel the nationwide  analysis
in terms of  percent reduction in emissions (to be  demonstrated
below).   Through  the   detection  and  prevention   of   certain
vehicle  problems,   the  program  is  assumed  to  eliminate  70
percent  of certain types of  malmaintenance  and defects  and 70
percent  of  all evaporative  system  tampering  (i.e.,   missing
canisters    and    missing    fuel   caps).     Contribution    of
malmaintenance/defects and tampering  to the excess  evaporative
problem are  outlined  in  Chapter 2, Section V.  Details  of the
adjustments  made to the evaporative emission rates (including
specific problems that can potentially  be addressed) under the
I/M  program  are provided  in Appendix  6-A at  the  end  of  this
chapter5.

-------
                               6-38


                            Table  6-18

          "No Exhaust" Case; 12-Month Analysis, R = 1.0
           In-Use  Gasoline  RVP Control Equal  to  Revised
              Cert.  Fuel  RVP  in  the Long Term (2010)
 In-Use =
 Revised
Cert. Fuel
 RVP (psi)
             Emission
            Reductions
  11
  11
  10
  10
   9
 ,5
 ,0
 ,5
 ,0
 ,5
   9.0
(10° Tons/Yr)
Net
369
454
540
625
710
795
Incr.
369
85
86
85
85
85
         Net Cost*

         (106 $/Yr)
                     Cost
                 Effectiveness
                  ($/Ton)
       Net

      -88
      - 2
      100
      232
      368
      512
      Incr,
      -88
       86
      102
      132
      137
      144
Net
-238
- 5
184
371
518
644
Incr.
-238
998
1197
1542
1619
1681
              Additional  In-Use  Gasoline  RVP  Control
                   in  the Short  Term  (1988-2000)
Incremental
Control Step
 RVP (ps i )

11.5-11.0
11.0-10.5
10.5-10.0
10.0- 9.5
 9.5- 9.0
Emission Reductions (10 Tons)
1988
251
222
187
160
138
1990
227
198
161
140
121
1992
185
165
134
120
106
1995
142
128
107
100
91
1997
121
111
94
90
85
2000
99
95
85
82
81
Incremental
Control Step
 RVP (psi)

 11.5-11.0
 11.0-10.5
 10.5-10.0
 10.0- 9.5
  9.5- 9.0
              	Incremental Cost Effectiveness ($/Ton)**
              1988      1990     1992    1995     1997    2000
               492
               733
              1252
              1515
              1977
 547
 852
1401
1700
2225
 338
 569
 895
1157
1453
 508
 778
1158
1375
1643
 711
1025
1443
1650
1882
 807
1108
1445
1652
1801
**
Bonner &  Moore refinery costs  are  for the  baseline  case with
investment  and with  NGL  purchases  treated  as  midway  between
the open and fixed NGL purchase scenarios.
1988 and  1990  costs  are based  on  no investment;  1992 and later
assume investment  has taken  place;  refinery  costs  are midway
between those of open and fixed NGL purchase scenarios.

-------
                               6-39


                            Table  6-19

          "No Exhaust" Case;  4-Month Analysis, R = 1.0
           In-Use Gasoline  RVP Control  Equal  to  Revised
             Cert.  Fuel  RVP  in  the  Long Term (2010)
 In-Use =
 Revised
Cert. Fuel
 RVP (psi)
 Emission
Reductions
(10  Tons/Yr)
                                Net  Cost*
                                (106 $/Yr)
                              Cost
                          Effectiveness
                           ($/Ton)
  11
  11
  10
  10
   9
,5
,0
,5
,0
,5
   9.0
 Net
123
151
180
208
236
265
Incr,
123
 28
 29
 28
 28
 29
                             Net
               Incr
               -83
                16
                30
                50
                70
                90
Net
-673
-444
-208
58
347
651
Incr.
-673
555
1033
1757
2466
3199
             Additional  In-Use  Gasoline  RVP  Control
                   in  the  Short  Term  (1988-2000)
Incremental
Control Step
 RVP (ps i )
11.5-11.0
11.0-10.5
10.5-10.0
10.0- 9.5
 9.5- 9.0

1988
84
74
62
53
46
Emiss
1990
76
66
54
47
40
ion Reduct
1992
62
55
45
40
35
ions (10
1995
47
43
36
33
30
Tons)
1997
40
37
31
30
28

2000
33
32
28
27
27
Incremental
Control Step
 RVP (psi)

 11.5-11.0
 11.0-10.5
 10.5-10.0
 10.0- 9.5
  9.5- 9.0
                  Incremental  Cost  Effectiveness ($/Ton)**
             1988

              492
              733
             1252
             1515
             1977
1990

 545
 846
1401
1692
2212
                     1992

                      323
                      582
                      935
                     1285
                     1664
                     1995

                      466
                      789
                     1275
                     1737
                     2177
1997

 655
1035
1604
2120
2552
2000
•^•^••MMB^

 688
1127
1683
2403
2834
*  Bonner &  Moore refinery costs  are for the  baseline case with
   investment  and with  NGL purchases  treated  as  midway between
   the open and fixed NGL purchase scenarios.
** 1988 and  1990  costs are  based  on no investment; 1992 and later
   assume investment  has taken  place; refinery  costs  are midway
   between those of open and fixed NGL purchase scenarios.

-------
                           Figure 6-7
 NON
-CALIF. EMISSION REDUCTION/COST EFF
I
o
8
o

u
o
3E
Ul
                      WITHOUT EXHAUST BENEFITS
   1200
   1100 H
       1988
         1992
1996     2000

      YEAR
                                         2004
                                           2008

-------
                              6-41


     Also  included  in  Appendix  6-A  is   an  analysis  of  the
potential effectiveness  of  an evaporative  I/M program such  as
the   one   described   above.     As   Table   6-A-7   indicates,
extrapolating  I/M benefits  nationwide  (excluding  California)
could reduce  HC emissions by  roughly 100,000 tons  in 1988 and
343,000  tons  in  2010.   Looking  specifically  at  the 47  ozone
non-attainment  areas,  HC emissions  could  be reduced  by  39,000
tons  in  1988  and by  122,000  tons  in  2010 with an  effective
evaporative  I/M program.  As  alluded to  earlier,  the  47-city
reductions  would  parallel  the  non-California  reductions  in
terms  of  percentage   change   from   baseline,   representing  a
0.7-percent  reduction  in total  NMHC emissions  in  1988  and  a
2.2-percent  reduction  in  the  year 2010.   The  overall  cost
effectiveness  ($  per ton)  of such an I/M program  is estimated
at $3780 per  ton  in  the short term  (1988)  and  $1350 per  ton in
the  long  term  (2010).   The  development  of  these  emission
reductions and costs  is outlined in Appendix 6-A.

     The sensitivity of the RVP  control strategies  examined in
this study to  the implementation of  an evaporative  I/M  program
is  summarized in  Tables  6-20  and  6-21 and  Figure  6-8.   (For
this analysis,  "R" was  held  constant at 1.0.)   As  indicated in
these  12-month  and  4-month tables,  emission  reductions  are
lower than in  the base case because  the  I/M program  will  have
eliminated  portions   of  motor  vehicle  evaporative  emissions
previously  reduced  by   in-use  RVP  control.    (The  tonnage
reductions attributed  to evaporative HC under  the  evaporative
I/M case were compared to the  base  case  for  the year 2010 in
Table  6-1).    Due  to  these  lower emission reductions and the
reduced  credits  for  retained evaporative  HCs,  the  cost/ton  of
RVP  control  would  be  significantly higher  if  an  effective
evaporative I/M program were implemented  prior  to RVP control.
As shown in  Table 6-20,  for  the long-term 9.0-psi scenario, the
incremental cost/ton with an evaporative  I/M  program would  be
approximately  66  percent  higher  than under the base case ($2792
versus $1681 per ton  of reduction).

     F.     Summary

     Based on  the technical estimates  and assumptions used  in
the base  case analysis, purely  vehicle-oriented control  (i.e.,
certification  fuel RVP revised to 11.5  psi and test procedure
modified) appears  to be the  most cost-effective approach in the
long term.   As shown  earlier for  the  12-month  analysis in Table
6-6, a total  of 584,000 tons of  HC  emissions  can be eliminated
via this strategy in the year 2010 at a net  savings of  roughly
$274  per  ton  to  the  public.    However,  because  a  change  in
certification  fuel and test procedure  can only  affect  vehicle
design,    strategies    involving   in-use   RVP    control   can

-------
                              6-42


                           Table 6-20

           "Evap.  I/M"  Case;  12-Month Analysis,  R  =  1.0

           In-Use  Gasoline  RVP Control Equal  to  Revised
              Cert.  Fuel  RVP  in  the Long Term (2010)
 In-Use =
 Revised
Cert. Fuel
 RVP (psi)
  11,
  11,
  10.
  10,
   9,
 Emission
Reductions
(103 Tons/Yr)
   9.0
Net
499
555
611
668
722
775
Incr.
499
56
56
57
54
53
         Net Cost*
         (106 $/Yr)
                   Net
                  -130
                   -36
                    76
                   218
                   365
                   513
               Incr.
               -130
                 94
                112
                142
                147
                148
                     Cost
                 Effectiveness
                  (ft/Ton)
Net
-261
-65
124
326
505
662
Incr.
-261
1679
2000
2491
2722
2792
             Additional  In-Use  Gasoline  RVP  Control
                   in  the Short  Term  (1988-2000)
Incremental
Control Step
 RVP (psi)
 11.5-11.0
 11.0-10.5
 10.5-10.0
 10.0- 9.5
  9.5- 9.0

1988
266
238
210
186
162
Emission Reductions (10
1990 1992 1995
234 189 138
207 169 123
182 150 111
161 134 102
141 119 93
Tons )
1997
109
100
89
83
81

2000
81
76
69
69
67
Incremental
Control Step
 RVP (psi)

 11.5-11.0
 11.0-10.5
 10.5-10.0
 10.0- 9.5
  9.5- 9.0
      Incremental Cost Effectiveness ($/Ton)**
  1988

   442
   665
  1077
  1259
  1634
1990

 523
 812
1214
1453
1868
1992

 325
 546
 778
 989
1253
1995

 530
 826
1098
1330
1624
1997

 827
1168
1548
1818
2002
2000
^^^MUMV*^—

1071
1464
1857
2008
2257
*    Bonner & Moore  refinery  costs  are for the baseline case with
     investment and  with NGL purchases treated  as  midway between
     the open and fixed NGL purchase scenarios.
**   1988  and  1990  costs  are  based  on  no  investment;  1992  and
     later assume  investment  has taken place;  refinery costs  are
     midway  between  those   of  open  and   fixed   NGL  purchase
     scenarios.

-------
                               6-43


                           Table  6-21

           "Evap. I/M" Case;  4-Month Analysis, R = 1.0

           In-Use Gasoline  RVP  Control  Equal  to  Revised
             Cert.  Fuel  RVP  in the  Long Term (2010)
 In-Use =
 Revised
Cert. Fuel
 RVP (ps i)
  11,
  11,
  10,
  10,
   9,
                Emission
               Reductions
   9.0
(10 Tons/Yr)
Net
166
185
204
223
241
258
Incr.
166
19
19
19
18
18
         Net Cost*
         (106 $/Yr)
                                  Net
                                 -126
                                 - 82
                                 - 37
                                   28
                                  113
                                  175
               Incr.
               -126
                 44
                 45
                 65
                 85
                 62
                     Cost
                 Effectiveness
                  ($/Ton)
               Net
              -760
              -441
              -180
               122
               468
               676
                Incr.
                -760
                2397
                2411
                3407
                4733
                3477
             Additional  In-Use  Gasoline  RVP  Control
                   in  the Short  Term  (1988-2000)
Incremental
Control Step
 RVP (psi)
 11.5-11.0
 11.0-10.5
 10.5- 9.5
 10.0- 9.5
  9.5- 9.0
Emission Reductions (10 Tons)
1988
89
79
70
62
54
1990
78
69
61
54
47
1992
63
56
50
45
40
1995
46
41
37
34
31
1997
36
33
30
28
26
2000
27
25
23
23
22
                    Incremental Cost Effectiveness ($/Ton)**
Incremental
Control Step
 RVP (psi)

 11.5-11.0
 11.0-10.5
 10.5-10.0
 10.0- 9.5
  9.5- 9.0

*Bonner&Moore refinery costs  are for the  baseline case with
   investment  and with  NGL purchases  treated  as  midway between
   the open and fixed NGL purchase scenarios.
** 1988 and  1990  costs are  based  on  no investment; 1992 and later
   assume  investment  has taken  place; refinery  costs  are midway
   between those of open and fixed NGL purchase scenarios.
                 1988.

                  442
                  665
                 1077
                 1259
                 1634
1990

 549
 793
1220
1540
1741
1992

 390
 549
 846
1225
1185
1995

 697
 904
1307
1891
1679
1997

1049
1326
1889
2585
2207
2000
^••^MI^MMB

1517
1725
2495
3325
2709

-------
                      Figure 6-8
NON-CALIF.  EMISSION REDUCTION/COST EFF
1                     _.*«n  I VkJ /*ACC
                    EVAP. IXM CASE
1200
    1988
                                         2008

-------
                              6-45


potentially  eliminate  additional  emissions.   This  is  possible
because in-use  RVP levels affect  those  portions of evaporative
emissions    attributable    to    malmaintenance/defects    and
evaporative  system  tampering,  as  well  as stationary  sources
such as gasoline  storage,  distribution,  and vehicle refueling,
whereas   certification   fuel  RVP   has  no   impact   on  these
emissions.   In  2010,  year-round in-use  fuel  RVP  control  could
eliminate up to an additional  426,000  tons of  HC emissions at
an incremental  cost per  ton  ranging between $998  and  $1681  per
ton.

     In the  short term,  vehicle-oriented control is relatively
ineffective  since  control  is achieved  only as  the  fleet  turns
over (i.e.,  roughly seven years are required  to obtain half of
eventual  control).   However,  since  all  commercial  gasoline
would  be  affected, in-use RVP  control  is  completely effective
immediately.    For example,  HC  emission  reductions  of  up  to
1,116,000  tons  at  an  incremental   cost   effectiveness   of
$395-1551  per  ton  could  be  achieved   in 1988 with  12-month
commercial fuel RVP control.

     The above  12-month  projections  are based on the absence of
onboard  or  Stage  II  controls  and  evaporative  I/M,  and  a
100-percent   utilization  of   increased   energy  density   of
less-volatile  fuels  (i.e.,  R  =  1.0).    As   indicated  by  the
sensitivity  analyses,   any  of  these  factors  could  influence
these  results.   Less efficient  energy  utilization (i.e.,  R  =
0.6)  would  not affect emission reductions, but would increase
costs  (because of  reduced  fuel  economy credits);  therefore,
cost per  ton estimates  are  higher by as much as 35 percent in
both the  short and  long terms.   A  lower  baseline RVP has no
effect  on   incremental   emission  reductions   or   costs,   so
long-term incremental  cost effectiveness  is   not  affected.   An
onboard control program reduces  incremental  emission  benefits
and  slightly increases  incremental  costs,  so  the  incremental
cost per ton is increased  by as much as 31 percent.  Finally,  a
maximally effective  evaporative I/M program   would  have little
effect  on  vehicle-oriented  control  programs,  but would have  a
fairly  significant  impact  on  in-use  RVP   control,  reducing
long-term  incremental  emission reductions  by  34 percent  and
raising long-term incremental  cost  per  ton   by  as  much  as 68
percent over the base case estimates.

-------
                              6-46
                     References (Chapter 6)

     1.    "Evaluation  of Air  Pollution  Regulatory  Strategies
for Gasoline  Marketing Industry," U.S.  EPA,  Office of Air  and
Radiation, EPA-450/3-84-012,  July 1984.

     2.    "The  Feasibility,  Cost,  and  Cost  Effectiveness  of
Onboard    Vapor   Control,"    Glenn    W.    Passavant,    U.S.
EPA/OAR/OMS/ECTD/SDSB, EPA-AA-SDSB-84-01, March 1984.

     3.    "Anti-Tampering  and   Anti-Misfueling   Programs   to
Reduce    In-Use   Emissions    from   Motor   Vehicles,"    U.S.
EPA/OAR/OMS/ECTD/TSS,  EPA-AA-TSS-83-10, December 31, 1983.

     4.    "MOBILES Fuel  Consumption Model,"  Mark A.  Wolcott,
EPA, and Dennis F. Kahlbaum,  CSC, February 1985.

     5.    "The Highway Fuel Consumption  Model:  Tenth Quarterly
Report,"  Energy  and   Environmental  Analysis,   Inc.,  for  U.S.
Department of Energy,  November 1983.

     6.    "Anti-Tampering  and   Anti-Misfueling   Programs   to
Reduce In-Use Emissions from Motor Vehicles,"  EPA-AA-TSS-83-10,
December 31, 1983.

     7.    "Reoccurrence  of  Evaporative  System  Malmaintenance
and  Tampering,"  EPA   memo  from  David  J.  Brzezinski to  Phil
Carlson, October 4, 1985.

     8.    "MOBILES Fuel  Consumption Model,"  Mark A.  Wolcott,
EPA, and Dennis F. Kahlbaum,  CSC, February 1985.

-------
                              6-47
                          Appendix 6-A

             Evaluation of  an  Inspection/Maintenance
        Program for Evaporative Emission Control Systems


     This appendix  details the calculations used  to derive the
effectiveness   and  cost   effectiveness   of   an   inspection/
maintenance  (I/M)  program  for  evaporative  emission  control
systems.  The program was  assumed to begin in  1988  as  this was
the assumed  year  of implementation  for in-use RVP  control and
is also  likely  the earliest  feasibile implementation  date for
evaporative  I/M.   Application was restricted to  1978 and later
model  year  LDVs  and  LDTs,  as  earlier   vehicles  were  not
certified using the comprehensive SHED test.   Their evaporative
emission  control  systems  are not very effective  and are  not
amenable  to  cost-effectiveness  repair.   Heavy-duty  vehicles
were not included as current  I/M  programs  for  exhaust emissions
generally do not include HDVs.

     The  first  section  of this  appendix will  describe how the
evaporative  emission reductions   were  estimated.   The  second
section will present the  costs associated with the I/M program,
and  the  last  section  will  present  the  cost  effectiveness
results for 1988 and 2010, representative of the long-run.

Evaporative I/M Emission Reductions

     The  total   emission  reductions   obtainable   through  an
evaporative  I/M program  were  based  on the  results  of  EPA's
in-use  emission factors  (EF)  test program, which  is described
in Chapter  2.   Tables  6-A-l  and 6-A-2 present  the  types  of
malmaintenance and defect  (M&D)  problems checked and discovered
in the  EF  test program  and  the rate of  occurrence of  each
problem   for   fuel-injected   (FI)   and   carbureted  vehicles,
respectively.  Tables 6-A-l  and  6-A-2 also present  the average
diurnal  and  hot-soak  emission  effect  associated  with  each
problem,  as  measured   in  the  EF  test program  vehicles,  on
Indolene and commercial  fuels.

     The  percentage  of  the total M&D  effect due  to each  defect
is contained  in Tables  6-A-3 and 6-A-4 for  fuel-injected and
carbureted   vehicles,   respectively.    The  percentages  were
calculated using  the following  equation  and   then  normalized.
(All  negative  percentage   contributions,   due  to  presumedly
anomalous emission improvements, were  assumed to  be zero  before
the total percentage was normalized.)

Avg Evap Emissions     Problem Free     Rate of        Percent
due to M&D Problem  -    Emissions    x Occurrence  =  of M&D
          Total M&D Effect              of M&D         Problem
                                        Problem        due to
                                                       Defect

-------
                              6-48
                          Table 6-A-l
     In-Use EF Test Program M&D Types,  Rates of Occurrence,
    and Diurnal/Hot Soak Emissions for Fuel-Injected Vehicles
Avg. Evap. Emissions (g/test)
No. of Rate*
Defect Vehicles (%)
Gas Cap Leak
Air Cleaner
Gasket Broken/
Missing
Canister Filter
Dirty
Canister Saturated
w/Liguid Fuel
Canister Broken
2

2
2
1
1
3

3
3
1
1
.6

.6
.6
.8
.8
Indolene
DI
5

3
2
3
0
.25

.62
.24
.38
.98
HS
2.

5.
0.
2.
1.
13

92
60
14
67
Commercial
DI HS
14

14
5
11
2
.75

.00
.59
.84
.14
6

13
2
1
13
.49

.21
.66
.93
.06
Problem Free Emissions             0.87   0.64      4.67   0.90
Total M&D Effect                   0.34   0.29      0.84   0.93
     Fifty-five fuel injected vehicles tested.

-------
                         6-49
                      Table  6-A-2

In-Use EF Test Program, M&D Types,  Rates of Occurrence,
and Diurnal/Hot Soak Emissions for Carbureted Vehicles
Avg. Evap. Emissions (g/test]

Defect
Gas Cap Leak
Canister Filter
Dirty
Canister Saturated
w/Liquid Fuel
Canister Broken
EFE TVS Stuck
Bowl Vent Value
Stuck
Vacuum Line
Damaged
Vacuum Line
Plugged
Bowl Vent Line
Damaged
VCV Inoperative
Purge Solenoid/
Value Sticking
Purge Solenoid/
Value Inoperative
Purge Solenoid/
No. of
Vehicles
6

1

7
0
1

1

6

1

1
1

3

1

Value Leaks Vacuum 2
Rollover Valve
Leaking
Carburetor Leaks
Fuel
Carburetor
Exceptionally
Dirty

1

1


2
Rate*
(%)
5.5

0.9

6.4
0
0.9

0.9

5.5

0.9

0.9
0.9

2.8

0.9

1.8

0.9

0.9


1.8
Problem Free 'Emissions
Total M&D Effect :


Indolene
DI
8.29

3.45

3.50
—
6.90

1.68

6.79

2.15

1.89
1.34

2.24

3.73

3.90

10.35

0.58


1.90
1.25
1.11
HS
2.89

1.40

2.29
-
1.50

1.25

4.06

9.72

5.00
5.16

4.70

13.78

5.25

6.27

13.82


1.51
1.50
0.83
Commercial
DI
14.45

17.67

12.25
-
3.52

16.61

16.66

9.76

3.77
16.63

8.70

3.72

22.96

22.55

3.40


16.29
7.40
1.61
HS
4.96

1.55

2.68
-
2.83

1.15

6.05

3.42

6.41
4.13

7.70

15.94

7.38

11.69

10.57


2.15
2.60
1.24
109 carbureted vehicles tested.

-------
                              6-50
                          Table  6-A-3

           Normalized Percentages of Total M&D Effect
     Due to Specific M&D Problems on Fuel-Injected Vehicles
Indolene
Defect
Gas Cap Leak*
Air Cleaner Gasket Broken/
Missing*
Canister Filter Dirty
Canister Saturated w/Liguid
Fuel
Canister Broken*
Total
DI
44.6
28.0
14.0
12.8
0.6
100.0
HS
18.6
65.7
9.3
6.4
100.0
Commercial
DI
42.1
39.0
3.9
15.0
—
100.0
HS
21.3
46.8
6.7
1.9
23.3
100.0
Total Percentage Addressable
 w/ I/M
73.2
90.7
81.1   91.4
     Addressable through an evaporative I/M program.
     Indicates  the defects  had  a  negative  M&D effect  before
     normalization of the total, and was eliminated.

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                              6-51
                          Table  6-A-4

          Normalized  Percentages of Total MS.D Effect
       Due to  Specific M&D Problems on Carbureted Vehicles

                                   Indolene         Commercial
Defect                             DI     HS        D_i     HS
Gas Cap Leak*                     34.5    9.1      18.3   14.6
Canister Filter Dirty              1.8    -         4.5    -
Canister Saturated w/Liquid
 Fuel                             12.9    6.1      14.7    0.6
EFE TVS Stuck                      4.6    0         -      0.3
Bowl Vent Value Stuck              0.4    -         4.0
Vacuum Line Damaged*              27.2   16.9      24.1   21.3
Vacuum Line Plugged                0.7    9.0       1.0    0.8
Bowl Vent Line Damaged*            0.5    3.9       -      3.9
VCV Inoperative                    0.1    4.0       4.0    1.5
Purge Solenoid/Valve Sticking      2.5   10.5       1.7   15.8
Purge Solenoid/Valve Inoperative   2.0   13.5       -     13.8
Purge Solenoid/Valve Leaks
 Vacuum                            4.3    8.2      13.5    9.9
Rollover Valve Leaking             7.4    5.3       6.5    9.3
Carburetor Leaks Fuel*             -     13.5       -      8.2
Carburetor Exceptionally Dirty     1.1    0         7.7    -
Total                            100.0  100.0     100.0  100.0


Total Percentage Addressable
 w I/M                            62.2   43.4      42.4   48.0
     Addressable through an evaporative I/M program.
     Indicates  the  defect had  a  negative  M&D  effect  before
     normalization of the total,  and was eliminated.

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                              6-52
     Tables 6-A-3 and 6-A-4 also contain  the  maximum percentage
of  the  M&D  effect  addressable  through  an  evaporative  I/M
program broken  down into the diurnal  and hot-soak  components.
Leaking gas  caps,  missing or broken carburetor  gaskets,  broken
canisters  and  damaged hoses are  assumed to  be detectable  for
signs of defects.   To detect  a  leaky gas cap, the fuel  tank is
sealed off, pressurized through  its  connection to the  charcoal
canister  and  allowed to  sit  for  five minutes.    A  drop  in
pressure  noted  with  a  pressure  gauge  indicates  a  possible
leaking gas cap.   To detect  a  broken/missing gasket, propane is
sprayed around  the intake manifold  in an engine  at idle.   An
increase  in  engine  RPM  indicates  a  broken/missing  gasket.
Broken  canisters  and  damaged  hoses   are   detected  visually.
Table  6-A-5  contains  the  maximum  portion  of M&D  effects
addressable through an evaporative   I/M program  which  is  100
percent effective.   (The rates are  an  average of the percentage
reductions obtainable on Indolene and  commercial  fuels  shown in
Tables 6-A-3  and 6-A-4.)   I/M programs  are  generally projected
to  be 70  percent  effective.[6]   Thus,  potential  M&D  effect
emission reductions  should be reduced by 30  percent to reflect
more realistic I/M effectiveness  (also  listed in Table 6-A-5).

     Table  6-A-6  contains  tampering   problems  and  rates  of
tampering  expected in an  evaporative  I/M  program.   Gas caps,
canisters  and  connecting  hoses  which  have  been  removed  or
disconnected  are  considered  to  be  tampering.  An  evaporative
I/M program is  also expected  to  be 70 present effective  in the
detection of tampering problems.

     Based   on   these  70-percent    emission   reductions   in
addressable  M&D excess  emissions  effects,   and  a  70  percent
reduction  in  tampering excess emissions  effects,  new emissions
factors were  calculated  and used  to  run  the MOBILES  computer
program.   The  MOBILES  results   were  used  in  determining  the
non-California emissions inventory according  to  the  methodology
described  in  Chapter 5.  The total  non-California  NMHC emission
reductions  obtained  with  an  evaporative  I/M  program  at  70
percent effectiveness,  with in-use  fuel at  11.5 psi  RVP,  and
certification  fuel  at 9.0  psi  RVP  are  contained  in  Table
6-A-7.  The  total  47  ozone non-attainment cities  NMHC emission
reductions are  also contained in Table  6-A-7.  An  evaporative
I/M  program  would  only  be  instituted  in  cities  with  I/M
programs for exhaust  emissions.   These are  best  represented by

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                              6-53
                           Table  6-A-5

   Portion of M&D Effects Addressable Through Evaporative I/M
   	(Percent)	

                     @ 100% Effectiveness    @ 70% Effectiveness
Vehicle Type

FI
Garb
DI*
77.2
52.3
HS*
91.1
45.7
DI
54.0
36.6
HS
63.7
32.0
     Rates  are  average  of  percentage reductions  obtainable on
     Indolene and  Commercial  fuels listed  in Tables  6-A-3  and
     6-A-4.

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                              6-54


                          Table 6-A-6

       Tampering  Types of Problems and Rates of Occurrence

Problem                                       Rate of Occurrence (%)
Gas Cap Removed                                        1.2
Canister Vacuum Disconnected                           1.7
Cap Removed & Canister Vacuum Disconnected             0.1
Canister Removed                                       0.3
Canister Mechanically Disconnected                     0.2

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                              6-55
                          Table  6-A-7

      Total NMHC Emission Reductions Obtainable with a 70%
        Effective Evaporative I/M Program (1000 tons/year)
Non-California
   Scenario

Baseline*
Baseline* w/Evap I/M
Reduction due to
 Evap I/M

47 Non-Attainment
 Cities Scenario

Baseline*
Baseline* w/Evap I/M
Reduction due to
 Evap I/M
                Year
 1988  1990  1992  1995  1997  2000  2010

14307 13821 13513 13350 13397 13642 15298
14207 13634 13293 13094 13124 13350 14955
  100
187
220   256

  Year
     273   292
           343
 1988  1990  1992  1995  1997  2000  2010

 5592  4879  4757  4699  4716  4816  5461
 5553  4813  4679  4609  4620  4713  5339
   39
 66
 78
90
96
103
122
     Baseline  refers  to  In-use  fuel  at  11.5  psi  RVP  and
     Certification fuel at 9.0 psi RVP.

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                              6-56


the 47 ozone non-attainment  cities,  so the last set of emission
reductions is most pertinent.  However,  non-California emission
reductions  assuming  evaporative  I/M  programs  are  instituted
everywhere, are presented since nationwide  emission effects are
most  commonly  available  for  other   control   programs.    The
non-California  figures  here  can  then  be  used   to  compare
relative effectiveness  with  those programs,  realizing that the
control  is  only available in  areas with  exhaust  emission I/M
programs.

Evaporative I/M Costs

     The costs  of an  evaporative  I/M program arise from the two
steps of an  I/M program,  the inspection and  the repair of the
malmaintained,   defective  and/or   tampered  parts.  The  cost per
inspection  assumes  a  three  minute  inspection  per vehicle (in
addition to  the time  required for  an exhaust  inspection)  at a
labor rate of $20/hour.   The increase in time  is primarily due
to the procedure  to  check for leaky gas caps.   This  results in
an incremental inspection cost per vehicle of $1.00.

     Table 6-A-8 contains the estimated  costs of the  parts and
the  amount  of  time  necessary to carry out  the repairs.   The
part  costs  are based on  typical  costs  of  parts  found  in
"Mitchells  Mechanical Parts/Labor  Estimating  Guides" and the
labor costs  are based  on a basic  shop fee  of  $35/hour.   The
repair costs associated with each problem for fuel-injected and
carbureted  vehicles   on  both a   repaired  vehicle  and  average
in-use vehicle  basis  are listed in  Tables  6-A-9 and 6-A-10.
Inspection and  total  inspection   and  repair costs  are  shown as
well.

     The total  first  year repair  cost is greater than the total
second  (and  later)   year repair  cost.   This  occurs  because
during the  first year of the  evaporative I/M program (1988),
all  of  the  vehicles   from  model  years  back  to  1978 must  be
repaired.   In  the second and subsequent  years, only  the  cars
which have  had  malmaintenance and  defect  problems and/or  have
been tampered with within the last year need to be repaired.  A
reoccurrence  rate of  60 percent was assumed.[7]   Thus,  the
second year (and  later) repair  costs  are  60 percent of the
first  year  repair  costs.    The   incremental  inspection  cost
remains unchanged since all  vehicles must still be inspected.

     An   economic  credit   is   realized   from  the   emission
reductions  derived  from  the  evaporative  I/M  program.    The
excess emissions  which would have been  lost  without  repairs to
the  evaporative control  system,  will now  be  captured by the
charcoal canister  and  combusted  in the  engine.   The economic
credit  is  determined as explained previously  in  Chapter  4,
Section  VI  by  assuming the composition of  the  emissions  is all

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                         6-57


                     Table  6-A-8

     Evaporative I/M Parts and Labor Repair Costs
Part Replaced
Gas Cap
Intake Gasket
Evaporative Canister
Hose
Carburetor Gasket
Cost($)
10
10

2
40
Hours of Labor*
_
3.0

0.3
1.4
Total Cost($)
10.00
115.00

12.50
89.00
Labor  time  was  estimated  based  on "Mitchell  Mechanical
Parts/Labor Estimating Guides"  for Domestic Cars  1984 and
Imported  Cars  and  Trucks   1984.    Published  by  Mitchell
Manuals, Inc., San Diego, California,  1984.  A  basic shop
fee of $35/hour labor cost was used.

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                              6-58
                          Table 6-A-9

                Evaporative I/M Cost per Vehicle
              Inspected for Fuel-Injected Vehicles

                                      Repair         Repair Cost
M&D Problem                Rate(%)     Cost($)        /Vehicle($)
Leaking Gas Cap             3.6         10.00             0.36
Leaking Gasket              3.6        115.00             4.14
Broken Canister             1.8         67.50             1.22

Tampering Problem

Gas Cap Removed             1.2         10.00             0.12
Canister Vacuum
 Disconnected               1.7         12.50             0.21
Cap Removed & Canister
 Vacuum Disconnected        0.1         22.50             0.02
Canister Removed            0.3         67.50             0.20
Canister Mechanically
 Disconnected               0.2         12.50             0.03

                             Repair Cost                  6.30

      First Year Repair Cost (at 70% effectiveness)       4.41
      Incremental Inspection Cost                         1.00

  Total First Year Repair & Inspection Cost per vehicle   5.41


      Second year(+) Repair Cost (at 70% effectiveness)   2.65
      Incremental Inspection Cost                         1.00

  Total Second Year Repair and Inspection Cost
    per vehicle                                           3.65

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                            6-59
                        Table 6-A-10

             Evaporative  I/M Cost per Vehicle
             Inspected for Carbureted Vehicles
M&D Problem Rate(%)
Leaking Gas Cap
Damaged Vacuum Line
Damaged Vent Line
Leaking Carburetor
Tampering Problems
Gas Cap Removed
Canister Vacuum
Disconnected
Cap Removed & Canister
Vacuum Disconnected
Canister Removed
Canister Mechanically
Disconnected
First Year Repair Cost
Incremental Inspection
Total First Year Repair &
Second Year(-i-) Repair
Incremental Inspection
5.5
5.5
0.9
0.9
1.2
1.7
0.1
0.3
0.2
Repair
Repair Repair Cost
Cost($) /Vehicle($)
10.00 0.55
12.50 0.69
12.50 0.11
89.00 0.80
10.00
12.50
22.50
67.50
12.50
Cost
(at 70% effectiveness)
Cost
Inspection Cost per vehicle
Cost (at
Cost
70% effectiveness)
0.12
0.21
0.02
0.20
0.03
2.73
1.91
1.00
2.91
1.15
1.00
Total Second Year Repair & Inspection Cost per vehicle  2.15

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                              6-60


butane.   (Table  4-12 contains  the values  used to  convert  the
butane to a gasoline equivalent and then  to economic credits.)
Tables 6-A-ll  and 6-A-12 contain the fuel  recovery  credits  for
the evaporative I/M program for 1988 and 2010, respectively.

Evaporative I/M Cost Effectiveness

     Tables  6-A-ll  and  6-A-12  present  the  derivation of  the
cost effectiveness  (C/E)  of an evaporative  I/M  program in 1988
(first year)  and 2010,  respectively.   Both Tables   6-A-ll  and
6-A-12 utilize nationwide costs as these are the most readily
available  and nationwide  emission reductions.   However,  this
has no effect  on  the final cost-effectiveness of any particular
evaporative  I/M program since a  city's  fraction of  nationwide
vehicles  should be  the same as its fraction of  nationwide NMHC
emissions.   Therefore,  the cost  effectiveness  numbers can  be
applied  to  any  of  the  47  non-attainment cities  where  the
evaporative I/M program could be implemented.

     The  total  number  of  vehicles affected by an  evaporative
I/M program were based on the  MOBILES  fuel  consumption  model
[8] and  MOBILES  carbureted and  fuel-injected projections back
to 1978  (for  the  1988  analysis),  and back to 1990 (for the 2010
analysis).  The I/M  cost  without  the  fuel recovery credit is a
weighted-average  of  the  total  inspection  and  repair  cost  for
fuel-injected  and   carbureted  vehicles.    The   fuel  recovery
credit,  as described  in  the previous  section, is  subtracted
from the inspection and repair cost to obtain the I/M cost with
the fuel  recovery credit.   The I/M cost  with the fuel recovery
credit is  the  final  cost  of the evaporative  I/M program  and is
divided  by the  emission  reductions  listed  in  Table  6-A-7  to
determine  the  C/E  of  the   evaporative   I/M  program.    The
resulting  C/E numbers  are $3780/ton in  1988 and $1350/ton in
2010.

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                              6-61


                          Table 6-A-ll

           1988 Cost Effectiveness of Evaporative I/M

Total number of nationwide vehicles affected by I/M program1:

                      FI                  Garb.
     LDV:        38.6 x 10B            57.6 x 106
     LDT:         5.9 x 106            17.9 x 106
     Total       44.5 X 10s            75.5 X 10s

Cost of Inspection and Repair per Vehicle (first year):

               FI    = $5.41           Carb. = $2.91

Nationwide Cost of Inspection and Repair:          $4.60 x 10*

Nationwide Fuel Recovery Credit2:                  $0.37 x 10*

Nationwide I/M Cost with Fuel Recovery Credit:     $4.23 X 10*

Nationwide Emission Reduction due to I/M:  112,000 tons

Cost Effectiveness:  $4.23 x 10* = $3780/ton
                     112,000 tons
     Based  on  MOBILES  fuel  consumption model  total  number  of
     vehicles  and MOBILE3  vehicle  registration  distributions
     and carbureted and fuel injected projections back to 1978.
     Fuel recovery credit was determined  assuming the recovered
     emissions were butane.

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                              6-62


                          Table 6-A-12

           2010 Cost Effectiveness of Evaporative I/M

Total number of nationwide vehicles affected by I/M program1:

                      FI                  Carb.
     LDV:        135.6 x 106           17.1 x 10B
     LDT:         30.0 x 106            3.8 x 106
     Total       165.6 x 106           20.9 x 10e

Cost  of  Inspection  and Repair  per Vehicle  (second and  later
years):

               FI    = $3.65           Carb. = $2.15

Nationwide Cost of Inspection and Repair:          $6.49 x 10*

Nationwide Fuel Recovery Credit2:                   $1.28 x 10*

Nationwide I/M Cost with Fuel Recovery Credit:     $5.21 X 10*

Nationwide Emission Reduction due to I/M:  385,000 tons

Cost Effectiveness:  $5.21 x 10*  = $1350/ton
                     385,000 tons
     Based on MOBILES fuel  consumption  model.  Since evaporative
     I/M  program would cover  last  20 model  years,  essentially
     all LDVs and LDTs would be covered.
2    Fuel recovery credit was  determined assuming the emissions
     were butane.

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                              6-63


                          Appendix 6-B

      Effects  of  Increased Canister  Size  on  Operating Costs

     There  will  be  a  very slight  reduction  in fuel  economy
associated  with  the  increased  weight of  the  canister  in  the
modified  evaporative   control   system.   This  will  affect  a
vehicle's operating cost, and must therefore  be included in the
total  costs   associated   with   the  proposed  changes  to  the
certification  test  procedure.   The  calculation of  this weight
penalty will  be  the subject of  this  appendix.   Key  values used
in these calculations are summarized in Table 6-B-l.

     Appendix  3-A  described how the  component costs for  each
certification  fuel  RVP were calculated.  The weight associated
with  each  component  of an  850-ml  canister  is given in  Table
3-A-5.  By  scaling up these component weights,  as was done for
the costs  (described in Appendix  3-A),  the  increased canister
weight  associated  with  each  certification  fuel   RVP  can  be
determined.   These are provided in Table 6-B-2.

     These weight increases can be expressed  as a percentage of
the total  weight  of  the vehicle  using  the  estimates of  total
vehicle  weights   shown  in  Table   6-B-l.    Estimated   weight
sensitivity  factors,  which  relate  a  percentage   increase  in
weight  to   a  percentage   reduction   in   fuel  economy,   and
class-average  fuel  economies are also given  in Table 6-B-l and
are  used   along   with  the  percentage  weight   increases  to
determine  the  expected  reductions  in  fuel  economy.    These
reductions  in  fuel economy  are  then coupled  with estimates of
lifetime vehicle  mileages  (shown  in Table 6-B-l) to calculate
the extra gallons  of  fuel used over the vehicle's  life.  These
lifetime mileages  are discounted  (at  10 percent per  annum) to
represent the  fact that  a  dollar  saved in  the tenth  year of
vehicle use is not  the  same  as one  saved in  the  first  year.
The net  cost  to the  consumer  is then determined using a  fuel
cost   of   $0.98  per   gallon.    Table  6-B-2   summarizes   the
calculated values  for  reduction  in fuel economy,  extra  gallons
of fuel, and cost.

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                              6-64


                          Table  6-B-l

              Summary  of Values Used in Calculation


                             LDV          LPT              HDV
Fuel Economy (mpg)*         26.64        18.97            10.39

Vehicle Weight (lb)**        3082         3832             9270

Weight Sensitivity           0.329        0.402            0.450
  Factor (% change
  in fuel economy per
  % change in weight)***

Discounted Lifetime         65,400       80,900           71,700
  Mileage****
*    1994 values from  "MOBILES  Fuel  Consumption Model," Mark A.
     Wolcott, EPA,  and Dennis F. Kahlbaum, CSC, February 1985.
**   "Light-Duty  Auto  Fuel  Economy...Trends  Through  1985,"
     Heavenrich, Murrell, Cheng and Loos, SAE 850550.
***  "Analysis Memorandum:   Design Factor Update,"  prepared by
     Energy and Environmental Analysis,  Inc., for  EPA,  October
     1, 1982.
**** "Regulatory Impact  Analysis,  Oxides of  Nitrogen Pollutant
     Specific  Study  and  Summary  and  Analysis  of  Comments,"
     EPA/OAR/OMS, March  1985.   (Discounted  at 10  percent  over
     life of vehicle.)

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                         6-65
                      Table 6-B-2

    Values of Weight Increase, Penalty Factor, and
     Weight  Penalty for  Various  Certification Fuels
Class
LDV
Increased Weight (Ib)
Reduced Fuel Economy
(gal/mi X 102)
Extra Fuel
(gal/vehicle life)
Cost* (I/vehicle)
LDT
Increased Weight (Ib)
Reduced Fuel Economy
(gal/mi x 102)
Extra Fuel
(gal/vehicle life)
Cost* ($/vehicle)
HDV
Increased Weight (Ib)
Reduced Fuel Economy
(gal/mi X 102)
Extra Fuel
(gal/vehicle life)
Cost* ($/vehicle)
Certification Fuel RVP(psi)
9.5

0.16
0.04
0.04
0.04

0.20
0.04
0.09
0.09

0.42
0.02
0.14
0.14
10.0

0.32
0.09
0.08
0.08

0.39
0.08
0.17
0.17

0.83
0.04
0.28
0.27
10.5

0.48
0.14
0.13
0.12

0.59
0.12
0.26
0.26

1.25
0.06
0.42
0.41
11.0

0.64
0.18
0.17
0.16

0.80
0.16
0.36
0.35

1.67
0.08
0.56
0.55
11.5

0.81
0.23
0.21
0.20

0.98
0.20
0.44
0.43

2.10
0.11
0.70
0.69
Using $0.98/gallon

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                              6-66


                          Appendix 6-C

         Development of Non-Summer Evaporative Emission
            Recovery Credits for Four-Month Analyses

     Cost calculations for  the  4-month analysis must  take into
account the  fact  that vehicle-related  effects occur year-round
while commercial fuel-related effects  occur during  the  4-month
period only.   Thus,  refinery costs and the  fuel  economy credit
due to the  increased  energy content of commercial  gasoline are
simply one-third  of  the  annual  cost  since these  effects only
appear when volatility  control  is operative.   Vehicle redesign
costs and the associated weight  penalty  are  equivalent  to the
annual cost  since these are unaffected by  the  removal  of in-use
RVP controls.   The derivations  of  the individual  vehicle- and
fuel-related  control  costs  are  provided  in Chapters  3  and  4,
respectively.  Determining  the  evaporative  prevention/recovery
credit  is  not  as  straightforward,  however,  and  this   is  the
focus of this appendix.

     During  the summer  period the evaporative credit  is simply
one-third of  the year-round figure  since  both  fuel  and  vehicle
controls are  in place.  However,  since vehicle controls operate
year-round,   additional  emission  recovery  occurs  during  the
non-summer period  even  when the  fuel  controls are inoperative.
These non-summer emission  reductions  were estimated by  running
MOBILE3 to  simulate  a commercial fuel RVP of  11.5  psi (i.e,  no
in-use  RVP   control)  with  certification   fuel   volatilities
varying between 9.5  and 11.5 psi RVP  (i.e.,  various  levels  of
vehicle  control).    The  evaporative  and  exhaust  HC  emission
factors  used  as   input  to  these  MOBILES  runs  are  described
below.  Only  post-1989 model year vehicles are  affected,  since
1990  model  year  vehicles  are  assumed to be  the  first  to  be
affected  by  changes  to   certification   fuel   and/or   test
procedure.    Pre-1990  emission  rates  were  the  same  as  the
baseline case (certification fuel  of  9.0-psi RVP with in-use
fuel of 11.5-psi RVP).

     As  described  in  Chapter   2,   motor  vehicle  evaporative
emissions can be attributed to  emissions  from properly designed
and   operating  systems   and  excess   emissions   due   to:   1)
insufficient design of the  purge system;   2)  malmaintenance and
equipment  defects;   3)   commercial  fuel  RVP  in  excess  of
certification  fuel  RVP;   and  4)  evaporative  control  system
tampering.    The  size of   each  of  these  sources  (except  for
tampering,  which  is  handled separately)  as  a function  of  RVP
was  estimated  in Section  V  of  Chapter  2  (Table   2-15)  and
summarized in Tables  5-1  and 5-2 of  Chapter  5.   There,  in-use
and certification  fuel RVP  changed  simultaneously or in-use RVP
was varied  while  certification  fuel RVP  was  held  at 9.0 psi.
Each  of these sources  will  be  re-estimated here   under  the
different condition of unchanging in-use  fuel RVP, but  varying
certification fuel RVP.

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                              6-67


     Tables 6-C-l through 6-C-3 summarize  the  estimates of each
of these  sources  and total  non-tampered emissions for post-1989
light- and heavy-duty  vehicles.   Emission  factors  for properly
designed  and operating  vehicles  are not  a  function of  RVP.
Thus, they  were taken directly  from Tables 5-1  and  5-2.   The
effect of improper  design was assumed in Chapter 2 to disappear
with revision of the evaporative  emission  test procedure, again
irrelevant of  in-use or  certification RVP.  Thus,  its level is
zero  throughout Tables  6-C-l  through  6-C-3.   The   effect  of
malmaintenance  and  defects  was  shown  in  Chapter  2  to  be
dependent only  upon in-use  RVP.  As  in-use RVP is  constant at
11.5 psi  here,  the  effect of malmaintenance and defects is that
from Table 2-15 for 11.5-psi RVP at  all certification fuel RVP
levels.   The RVP  effect  described in Chapter 2 was described as
being a  function of the difference  between  certification and
in-use RVP.  Table  2-15  shows this effect for in-use  RVP values
between 9.0  and 11.5 psi with certification  RVP  held constant
at 9.0  psi, or in  other words,  for RVP  differences of 0-2.5
psi.   These  results were simply transposed to apply  here where
the  certification  RVP varied and  in-use  RVP remained  at 11.5
psi.   For example,  the RVP  effect during  the  non-summer  period
for  a certification RVP  of  9.5 psi  (difference  of  2.0 psi RVP)
was taken to be that shown  in Table  2-15  corresponding to 11.0
psi RVP for in-use fuel.

     Also relevant  is the  exhaust emission effect.   Chapter 2
discusses EPA's test  results which  show  fuel  RVP  to have an
effect  on   exhaust HC   and  CO  emissions.   This   effect  on
emissions was  accounted  for in  the  analysis  in  Chapter  5 by
applying  multiplicative  factors  for  each  RVP scenario  to the
original    MOBILES    exhaust    emission    factors.     These
multiplicative  adjustment factors are shown in  Tables 5-10 and
5-11.  For the non-summer scenario, the  adjustment factors were
assumed   to   vary   with  the  in-use/certif ication   fuel  RVP
differences  like  that  used  above to  determine  the  RVP  effect
during  the  non-summer  period   (i.e.,  in  proportion  to  the
difference between  in-use and certification RVP).

     Given the  above inputs, the reductions in evaporative HC
emissions  were  determined   from  MOBILES  runs.   This emission
reduction was   multiplied by  0.67 to  obtain the  evaporative
emission  recovery  credit in  the  eight-month non-summer period.
The  methodology for  calculating  an  annual   credit   for  these
reductions is the same as that for the 12-month analysis and is
outlined  in  detail  in  Section VI  of Chapter 4.    Table 6-C-4
summarizes the  long-term costs  and credits of the base case for
both the 12-month and 4-month analyses.

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                        6-68
                    Table 6-C-l

    Diurnal  Emissions  (g/test)  from Non-Tampered
            Post-1989 LDVs and LDTs for
Non-Summer Period (In-Use RVP Constant at 11.5 psi)
Certification RVP (psi)
Carbureted Vehicles
Properly Designed
and Operated
Improper Design
Malmaintenance
and Defect
RVP Effect
Total
Fuel-Injected Vehicles
Properly Designed
and Operated
Improper Design
Malmaintenance
and Defect
RVP Effect
Total
9.5
0.91
0.00
1.61
4.33
6.85
0.91
0.00
0.84
2.03
3.78
10.0
0.91
0.00
1.61
2.78
5.30
0.91
0.00
0.84
0.79
2.54
10.5
0.91
0.00
1.61
1.54
4.06
0.91
0.00
0.84
0.48
2.23
11.0
0.91
0.00
1.61
0.62
3.14
0.91
0.00
0.84
0.24
1.99
11.5
0.91
0.00
1.61
0.00
2.52
0.91
0.00
0.84
0.00
1.75

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                              6-69
                           Table  6-C-2
          Hot-Soak  Emissions  (g/test) from Non-Tampered
                   Post-1989  LDVs and LDTs for
       Non-Summer Period  (In-Use  RVP Constant at  11.5  psi)
                                   Certification RVP (psi)
Carbureted Vehicles
  Properly Designed
  and Operated
  Improper Design
  Malmaintenance
  and Defect
  RVP Effect
    Total
Fuel-Injected Vehicles
  Properly Designed
  and Separated
  Improper Design
  Malmaintenance
  and Defect
  RVP Effect
    Total
                               9.5
      10.0
10.5   11.0
0.93  0.93   0.93
0.24  0.18   0.11
1.78  1.72   1.65
11.5
1.09  1.09   1.09   1.09   1.09
0.00  0.00   0.00   0.00   0.00

1.24  1.24   1.24   1.24   1.24
0.73  0.42   0.20   0.06   0.00
3.06  2.75   2.53   2.39   2.33
0.61  0.61   0.61   0.61   0.61
0.00  0.00   0.00   0.00   0.00
       0.93   0.93
       0.05   0.00
       1.59   1.54

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                              6-70
                          Table 6-C-3

         Diurnal  and  Hot-Soak Emissions  (g/test) from
                Non-Tampered Post-1989 HDVs for
      Non-Summer  Period  (In-Use RVP Constant at  11.5 psi)
                                   Certification RVP (psi)
                               9.5   10.0   10.5   11.0   11.5
Diurnal Emissions

  Properly Designed
  and Operated                 1.44  1.44   1.44   1.44   1.44

  Improper Design              0.00  0.00   0.00   0.00   0.00

  Malmaintenance
  and Defect                   2.57  2.57   2.57   2.57   2.57

  RVP Effect                   6.90  4.43  'a.46   0.98   0.00

    Total                     10.91  8.44   6.47   4.99   4.01

Hot-Soak Emissions

  Properly Designed
  and Operated                 1.73  1.73   1.73   1.73   1.73

  Improper Design              0.00  0.00   0.00   0.00   0.00

  Malmaintenance
  and Defect                   1.97  1.97   1.97   1.97   1.97

  RVP Effect                   1. 15  0.67   0.31   0.09   0.00
                                           •*
    Total                      4.85  4.37   4.01   3.79   3.70

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                            6-71
                         Table  6-C-4

              Costs  and Credits for "Base Case"
                  in 2010 ( $ million/yr.)
12-Month Analysis
In-Use/Cert .
Refinery Cost
Fuel Econ. Credit
Vehicle Cost
Weight Penalty
Evap. Recv. Credit
Total Cost

11.5
0
0
28
8
196
-160

11.0
192
72
23
7
224
- 75
4 -Month
10.5
421
163
18
5
254
28
Analysis
In-Use/Cert .
Refinery Cost
Fuel Econ. Credit
Vehicle Cost
Weight Penalty
Evap. Recv. Credit
Summer Period
Winter Period
11.5
0
0
28
8
64
127
11.0
64
24
23
7
85
111
10.5
140
55
18
5
100
93
RVP (psi)
10.0
686
261
14
3
283
159
RVP (psi)
10.0
229
87
14
3
111
73

9.5
962
366
9
2
311
296

9.5
321
122
9
2
114
40

9.0
1256
477
0
0
339
440

9.0
419
159
0
0
112
0
Total Cost
-155
-126
- 85
- 25
56
148

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