EPA-AA-SDSB-87-07

                   Technical Report
 Investigation of the Need for In-Use Dispensing Rate
    Limits  and  Fuel Nozzle Geometry Standardization
                       May 1987
                        NOTICE

Technical Reports  do not  necessarily represent  final  EPA
decisions  or  positions.   They  are  intended  to  present
technical   analysis   of   issues   using  data   which  are
currently available.  The  purpose in  the release  of  such
reports  is   to   facilitate  the  exchange  of  technical
information   and   to  inform  the   public   of   technical
developments  which  may  form  the  basis  for  a  final  EPA
decision, position or regulatory action.
       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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                        Table  of  Contents



Section                                                 Page



   I. Introduction                                        3



  II. Definition of Terms                                 3



 III. Discussion of the Issues                            5



      A. In-Use Dispensing Rates                          6



      B. Nozzle Geometries                                8



  IV. CAA Authority                                      12



   V. Benefits                                           13



  VI. Implementation                                     14



 VII. Economic Analysis                                  17



VIII. Summary and Conclusions                            19

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I.    Introduction

     As a part  of  the technical information received during the
development of  EPA's  draft  refueling emissions  test  procedure,
one auto manufacturer  suggested that the in-use dispensing rate
of  gasoline  would  have  to be  controlled  and gasoline  nozzle
geometries standardized  in order  to assure  the proper  in-use
operation   of   onboard   vapor   recovery   systems   (onboard
systems).[!]   In  response to this  suggestion,  the  effects that
these two parameters  (dispensing rate and nozzle geometry)  may
have  on  refueling  emissions  control   were  studied.    As  is
discussed  below,   this  study  led  to  the  conclusion  that  a
dispensing rate limit of 10  gallons per minute  (gpm)  would be
complementary to  the  operation of  an  onboard  system  and  the
control  of   spillage-related  refueling  emissions  since  the
maximum  in-use  dispensing  rate  and the  dispensing  rate  for
vehicle  refueling  emission certification  testing  would  be the
same.   However,  with regard to  the  second  parameter,  additional
information  and public  comment  is  needed  on  the effects  of
nozzle geometries on  refueling  emissions control before  it can
be concluded that action is needed.

     As a result of the  conclusions from this study, the Agency
pursued the  development  of a voluntary in-use  dispensing rate
standard  with  the  American  Petroleum  Institute  (API),  which
represents  petroleum  industry  interests.   As  summarized  in
their  statement of  August 6,  1986, [2] API  concluded  that it is
not  feasible  to  develop  a  voluntary  standard.   API  also
concluded that  it  should be the  motor vehicle manufacturers'
responsibility to develop refueling control  systems which cause
nozzle  shut-off without spitback   if  design  flow limits  are
exceeded.

     This report presents the  results  of  the  investigation of
the effects  of  dispensing rates  and fuel nozzle geometries on
refueling emissions  and supports  EPA's proposal  to  regulate
in-use  dispensing   rates  and further study  the need  for some
form  of  nozzle standardization.   The  first  portion  of  the
report  is  devoted  to background.    After  defining  a  few  key
terms, the report begins  with a  discussion  of the issues.  This
is   followed  by  a presentation  of  EPA's statutory  authority to
regulate  fuel   dispensing   rates.    After    this  background
information   is   presented,    the   benefits,   implementation
approach, and economic impact  of  a  dispensing rate limit  are
discussed.    The   report  closes   with  a   brief  summary  and
conclusions.

II.   Definition of Terms

     Defined  below   are  some  key  terms  related   to  fuel
dispensing,  fuel dispensing units,  and  related hardware.   Items
related to the fuel nozzle itself are identified in Figure l.

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                             -4-
                                  Fioure 1
                                  Fuel PutQ Nozzle
Nozzle Body
                                                   Length of Spout—^
                                                          Spout's
                                                          Straight —»
                                                          Section
                                    Hand Lever
                                                             Automatic Shutoff
                                                                   Port
          Automatic Clip

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                               -5-
     "Spills" -  loss  of  gasoline during the refueling event due
     to  one  or  more  of  four causes:  pre-fill  drip,  spitback,
     overflow, and post-fill drip.[3]

     "Spitback"  -  discharge  of  gasoline  from  the  fillpipe
     resulting from pressure build-up  in  the  vapor space during
     an automatic fill.[3]

     "Overflow"  -  loss   of  fuel  from  the  fillpipe  when  the
     amount  of  gasoline  dispensed  exceeds the  tank  capacity;
     often caused by topping off.[3]

     "Dispensing  unit"  - the  entire  refueling  hardware  that
     exists above ground.

     "Pump"  - the  refueling hardware  that  exists  beneath  the
     ground or within the dispenser  which drives the dispensing
     unit.

     "Nozzle" -  the  hand-held  portion of  the  dispensing  unit
     which consists of the nozzle body, stem,  and spout.

     "Spout"  -  the terminal end  of  the  fuel  nozzle which fits
     into the vehicle's fillpipe when refueling.

     "Automatic Shut-off  Port"  - the  hole  near  the tip  of  the
     spout which activates  the  nozzle automatic  shut-off  when
     covered with liquid.

     With these  basic term  definitions,  it  is  now  possible to
discuss the issues involved  in this study.

Ill.  Discussion of the Issues

     A   limited   amount   of   information   available   in   the
literature  suggests  that both  the   fuel dispensing  rate  and
nozzle geometry  can  affect the  amount of emissions generated in
a  refueling  event.   This  relationship exists because both  the
dispensing rate  and  nozzle  geometry  can affect  the  amount of
turbulent mixing  which occurs in  the fillpipe,  and experience
shows that refueling  emissions  vary  directly with the amount of
turbulent mixing.[4]   Thus  these  parameters  may  have  a small
effect on both  the uncontrolled refueling emission rate and the
refueling emissions  load to the  canister  in an  onboard vapor
recovery  system.   Further,  in  a  related  area,  one  source
suggests  that  gasoline   spills  during  refueling   are  also
directly affected by the nozzle  configuration and dispensing
rate.[3]

     The effect  of  dispensing  rates  and nozzle  geometries  on
the  control   of  refueling  emissions  and gasoline  spillage  is
discussed below,  together with  the  rationale  for  any  potential
regulatory controls.   Dispensing  rates are  considered first and
nozzle geometries follows.

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     A.    In-use Dispensing Rates

     The  fuel  dispensing  rate  is  important  because  of  its
effect  on  the  design  and  performance  of  an  onboard  vapor
recovery  system.   As mentioned  above,  the  fuel dispensing rate
slightly  affects  the refueling  emission  rate  which  is one  of
the  factors  impacting  canister  size.  In  addition,   since  the
fuel dispensing rate determines the rate  at which  fuel vapor  is
displaced  from  the  tank during   a  refueling  event,  it  also
impacts the design of an  onboard system.  The  major effects  are
on   the  vapor   line  diameter   needed   to   optimize   system
backpressure  characteristics,  and  the size  and  shape  of  the
canister needed to capture the refueling emissions.

     The  dispensing  rate also has  some effect  on  the potential
for gasoline  spillage  (spitback)  during a refueling  event.   If
the  fuel  is  dispensed  at  a  rate greater than  vapors can  be
displaced from  the system,  backpressure  within the  system  can
increase  and  cause a premature shut-off  of the fuel  nozzle  and
the possibility of a fuel spitback.

     Since the  fuel  dispensing rate  is one  of the key factors
affecting the design  of an  onboard system,  EPA had to establish
a  dispensing   rate   value   for   use   in  refueling   emissions
testing.   Rather  than  arbitrarily  choosing  a value,  it  was
important that  the values specified  in the  certification test
procedure  be  representative  of  the  dispensing rates expected
in-use.

     An investigation of  the current  in-use  dispensing rates  by
API  revealed  that  values generally  range  from 6-12  gpm, with
values normally  lying  between  8-10 gpm.  The  in-use  dispensing
rates  of  gasoline  varies depending  on  a  number  of  different
factors.  Older and smaller service stations  use  a suction pump
which  is  located   inside   the   individual  dispenser.   These
suction pump  dispensers  normally   operate  at  8  to  9  gpm.[5]
Newer,  higher  volume  facilities  use  submersible  turbine  pumps
which are located away from the dispensers and  are either  on or
in the underground  storage tank.   They serve all the dispensers
and nozzles drawing product from the  tank, thus the actual flow
rate varies depending on the  number  of  nozzles  being operated
from  one  pump.   These  submersible  pumps  are   of  a  higher
horsepower,   and  deliver gasoline at  rates   of  10  to 12  gpm
(presumably when only one or  two nozzles  are  in operation) with
a few  newer  facilities  capable  of operating  at  levels  as high
as 15  gpm under  the  same conditions.[2,5]   One  in-use  survey
reported  full  serve  dispensing rates  of  6.5 to  8  gpm with self
service rates slightly  higher  at  9 to 11 gpm.[5]   These  rates
were  observed   at  various   dispensers  and  from  nozzles  of
different  manufacturers.   All  of  the  available  information
indicates that  most in-use dispensing  rates  fall  in  the  range
of 8 to 10 gpm  with evidence of a  trend  toward higher rates  in
new stations using higher horsepower pumps.

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     Based on this  information,  the maximum dispensing  rate in
EPA's  draft  refueling  emissions  test procedure  was set  at 10
gpm to correspond to  values near the higher end  of  the  current
in-use   dispensing   rate   range.[6]    The  automobiles   being
certified will  then be  designed  for and  tested  at  conditions
most   comparable  to   those  presented   in-use.    EPA's  draft
refueling test procedure would also  essentially  reguire  that no
fuel  spillage  occur  during  the  refueling  test,  since  any
spilled  fuel  which  evaporates during the  test  is  included in
the  overall  emission  results.   Thus,  the  implementation  of
onboard  controls  could  also  result  in  a reduction  in  fuel
spillage  (spitback)  which  now  occurs  when  the  fuel  nozzle
automatic shut-off is activated.

     However,  if  the  in-use dispensing rates  increase  as  API
predicts, the dispensing  rate used  for  certification testing of
onboard  vehicles  will   no  longer  be   comparable   to  those
in-use.[2]  Vehicles  equipped with  onboard systems  will not be
refueled in-use at  the  dispensing rates  they were  designed  for
in  certification.    Furthermore,  many  vehicles  will  not  be
designed  to   accept  such  high  refueling   rates  and  premature
shut-offs and  fuel  spillage  related  to  spitbacks may increase.
Consequently,  the  expected  reductions   in  emissions  due  to
spitback spillage could be  decreased or lost  totally,  and some
of  the  benefits  of  controlling  refueling  emissions  may  be
offset if spillage increases.

     There are  basically  two options available  to  prevent an
incompatibility between  the certification  and  in-use dispensing
rates.  The first option is to set the dispensing rate used for
certification  testing  equal  to  the  maximum  rate  reasonably
expected in-use  in  the future, rather than 10  gpm.   This would
ensure that the in-use  dispensing rates  do not exceed  the rate
used  for  certification,   but it  could   increase  the  cost  of
onboard  systems  because  they  would have  to  be  designed  to
handle much  higher  flow rates.  This option also allows in-use
dispensing rates to increase even  further in the  future since
the vehicles  would  be able  to accept these higher rates.  Thus
incompatibility  between  certification  and  in-use  dispensing
rates  could  reappear  in the future,  and  the  problem would not
be solved.

     The second  option  is  to  implement  an in-use  dispensing
rate  limit  which  is  equal  to  the  maximum rate  used  in  the
certification   testing    of  onboard-equipped   vehicles.    As
discussed  above,   this  value  would be  10 gpm.   Under  this
option,    retail     gasoline    marketers     and    wholesale
purchaser-consumers  would  be  required  to  limit  the dispensing
rate .of their gasolines to  10 gpm.   The  maximum dispensing rate
chosen for  certification  testing  (10 gpm) is based  on values
found  near the  high end  of the current  in-use range,  so most
service  stations would  not  be  affected  except to  restrict  any

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                               -8-
future   changes.    This   option   would   ensure   that   the
certification and in-use  dispensing rates remain  comparable in
the  future.   This  compatibility  would  enhance  the  overall
effectiveness  of the  onboard  refueling controls  and  achieve
additional  control  of  refueling  emissions  by  reducing  the
amount of in-use spillage.

     Based  on  the  discussion above,  the .second option  is  more
favorable in assuring  that  the  maximum certification and in-use
dispensing  rates  remain equivalent.   Establishing  an  in-use
dispensing  rate  limit equal  to the maximum  certification  rate
(10 gpm)  would guarantee that  the rate used  in the design of
the onboard system for  certification testing  is  comparable to
that in-use.  This would complement the performance  of  onboard
controls  and  reduce  in-use spitback  spillage.   In addition, an
in-use dispensing rate limit  will  prevent  increasing dispensing
rates as  vehicles that are  designed to handle higher flow rates
enter the fleet, as may  have occurred  under  the  first  option
considered.  As  will  be discussed  further  below,  this  option
could   also  provide  additional   environmental   benefits   by
decreasing  the  amount  of gasoline  spillage  which  occurs during
the refueling of vehicles without onboard controls.

     B.     Nozzle Geometries

     As was mentioned  previously in the introduction,  at least
one automobile  manufacturer  has  expressed  concern  to  EPA that
without uniform  nozzle geometries  mechanical  fillpipe seals may
not  be  feasible.    They  feel  such  design  standards  should
include at  minimum an  in-use  dispensing rate limit,  as  well as
specifications  on  length,   diameter,  position  and  angle  of
nozzle  bends,  position  of  latching  mechanisms and  control on
burrs and protrusions that  could  potentially  damage  the  seal
mechanism  and  harm  the   onboard  control efficiency.[1]    In  a
broader context,  the  SAE Fuel  Supply  Systems  Subcommittee has
also expressed similar concerns  regarding standard nozzle spout
specifications.   At  a  recent   meeting of  this  Subcommittee,
several auto manufacturers  conveyed  a  belief that  such  nozzle
standards  are  needed  to ensure proper  interface  between the
nozzle spout and auto fillpipe.[7]

     In  response  to  these  concerns,   EPA  investigated  the
effects of  fuel  nozzle  geometries.   During  this investigation,
it was  learned  that  nozzle  geometries may  have  an effect on
spillage.    First,   according  to  a  study  by  Scott  Research
Laboratories, the nozzle bending angle  and spout length are two
factors   affecting   spitback   spillage.[3]    These   can  cause
increased  splashing  against  the  fillpipe  wall  and  greater
turbulence.[4]    This  splashing  and turbulence  could cause more
frequent  premature  nozzle  shut-offs.   The   greater  number  of
premature nozzle shut-offs  results  in an increase in the amount
of spitback spillage which occurs during refueling operations.

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     Second, the  bending angle  of the  spout affects  the  fuel
flow to  the vehicle tank  within  the  fillpipe.   The  increased
splashing  against  the  fillpipe  walls  and  greater  turbulence
created by  some  bending angles  prevent  optimum fuel  flow.[4]
Due to this variance  in angles,  some fillpipes may  not be  able
to achieve  their  design  fill  rate without premature shut-offs.
Therefore,   standardized  nozzle  geometries  could   ease   the
automobile  manufacturers'   design  of  fillpipes  which  ensure
optimum  fuel flow  to  the vehicle tank and  minimize  premature
shut-offs.

     Third,  since nozzle geometries also affect  the  location of
the automatic shut-off port within the fillpipe, varying nozzle
and fillpipe designs can impact the potential  for  fuel spitback
when the  automatic  shut-off device is activated at the end of a
refill.    The closer  the  shut-off  port  is  to  the  fillpipe
outlet,   the higher the  fuel  must  rise  in the   fillpipe  to
activate  the shut-off,  and thus  the  greater  the  chance for  a
fuel spitback to occur.

     In  addition,  this  investigation  studied  the  currently
available fuel nozzles.  As is discussed in more  detail below,
current nozzle configurations  and geometries  were  investigated
and  found  to   be  relatively   similar.   This   similarity  in
configurations   is  sought  primarily   for   marketing  reasons.
Underwriters  Laboratories   examines   the   compatibility   of
different  manufacturers'   nozzles  with  listed  power-operated
dispensing units and labels the  nozzles  as  "interchangeable" if
compatible.[8]   All "interchangeable"  nozzles  can  be  used on
any  listed  dispensing  unit.    Therefore,   in  order   to   be
"interchangeable"  and more  marketable, the  design of  the spout
and handle  location of  most  nozzles  are comparable,  but  not
necessarily identical.

     Furthermore,  EPA  regulation  and  some  voluntary  standards
for nozzle designs also contribute to  the  similarity of current
nozzle geometries.  These regulations  and  standards  include the
following:

           Federal Register -  40  CFR 80.22
           This  ruling  regulates the outside  diameter for  both
           leaded   and   unleaded  nozzles   spouts.     It   also
           specifies  a  minimum   straight  section  length  and
           position of the retaining  spring  for  unleaded nozzle
           spouts.[9]

           UL 842  - "Valves for Flammable Fluids"
           This  standard of Underwriters Laboratories  specifies
           the  strength  and endurance  of the nozzle  material.
           It also gives a maximum nozzle length.[10]

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                              -10-
     •     NFPA No. 30 - "Flammable and Combustible Liquids"
           This   standard   of   the  National   Fire  Protection
           Association  specifies  that  any  nozzle  dispensing
           Class  I  liquids  such as  gasoline must  be  automatic
           closing and listed by Underwriters  Laboratories (and
           therefore conform to UL 842).[11]

     Compliance with the EPA regulation ruling  is mandatory for
all nozzle  manufacturers,  whereas most manufacturers  choose to
adopt the other  voluntary  standards  presented  above  solely for
insurance/liability  purposes.    It  is  important to  emphasize,
however,  that  to  date  no  real  limits on  the  flow  rates  or
configuration,  besides diameters and  a straight section length,
have been made.   The manufacturers  have total  freedom  in their
nozzle designs, except for market and insurance constraints.

     The   International   Standards   Organization   (ISO)   is
currently  evaluating possible  design  standards for  all  fuel
nozzles  in  order to  reduce  fire risks.  These draft  standards
include  specifications  on  the  dimensions   and geometries  for
nozzle  spouts  as  well  as  a  maximum  dispensing  rate.[12]
Response  to these  proposed  ISO  standards by  SAE  and  other
American  concerns has  not  been positive.   They  believe that
these standards  specify  too many  parameters and  are  therefore
too  restrictive.   Consequently,  the  U.S.  voted  to  disapprove
the proposed ISO standards.[13]

     As part of  this investigation  of fuel nozzle geometries,
some  key  dimensions of  nozzle  spouts  from  the two  largest
nozzle  manufacturers  were  compared.[14,15]   The  designs  of
these two  nozzles are  followed closely by  other manufacturers
and  these nozzles  are  often  rebuilt.   Thus   they  are  quite
representative of the majority  of  in-use nozzles.   These fuel
nozzle  design  characteristics   of  the  two  manufacturers  are
presented in Table 1.  This table shows that in general the two
nozzle  spouts  are  similar  with  slight  differences  in  the
straight  section length  and dispensing  rate  characteristics.
Since  the  nozzle  configurations  are  quite  similar,  nozzle
standardization  may   not  be necessary.   It  is not clear that
minor differences  such  as these would impact  the  operation of
an onboard  system,  although there is  some  evidence that nozzle
geometries  could very slightly  affect  the refueling  emission
rate  due to  varying amounts  of turbulent  mixing  and  droplet
entrainment.

     However,  even if nozzle geometries are  standardized,  it is
not  clear  than   the desired  effect  would  be  achieved.   The
nozzle spout position within the  fillpipe  is  also  affected by
the angle  at  which  the  individual  refueler inserts  the nozzle
itself during each refueling  event.   The variability  in nozzle
position caused  by  this  effect alone  could  be  enough to negate
any potential  emission  or  control  system  operation  benefits
which arise from nozzle standardization.

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                            Table  l
Fuel Nozzle Design
Dimension
Total- Spout Length
Spout Straight Sec . Length
Spout Bending Angle
Automatic Shut-off Location*
Nozzle Outside Diameter
Dispensing Rate @ 5 psi AP
@ 10 psi AP
Characteristics
OPW 11 -A EMCO
7"
3.9"
24-25°
0.73"
.81"
4gpm
lOgpm
Wheaton A2000
7.25"
2.9"
27°
0.67"
.81"
7 . 5gpm
13 . 5gpm
*    Distance from nozzle tip.
**   Maximum.

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                              -12-
     Given this  effect and  the relative uncertainty  regarding
the  impact  of  nozzle geometries  on  refueling  emissions  and
their control,  it  is not clear  that nozzle geometries  need to
be  standardized to  control   refueling  emissions.   If  further
information  becomes  available  which  demonstrates   that  the
impacts of varying nozzle geometries on refueling emissions and
effects on onboard control designs  are  significant and that the
costs  of  nozzle  standardization  are   reasonable,   then  such
standardization will be considered.

     Based on  the rationale  presented  above,  it appears  that
in-use dispensing  rate  limits would  enhance the effectiveness
of onboard controls  and reduce  spitback spillage.  Standardized
nozzle designs  may  be  considered in the  future,  but  further
study  and  information  is   required.   The  remainder  of  this
report  provides  further  background  information and  analysis
pertaining to a dispensing rate limit requirement.

IV.  CAA Authority

     The  Clean  Air  Act  (CAA) gives  EPA authority to regulate
the in-use dispensing rate.   EPA's authority in  this  area stems
from  Section  211  (c)  of  the Act.   This  section allows  EPA to
control or prohibit  the introduction into commerce or offering
for  sale of  any  fuel  for  use  in  a  motor vehicle  or  motor
vehicle engine  if  the  emission  products of  the  fuel  contribute
to  air  pollution  which  endangers public  health or welfare or
the emission products of  such fuel will impair to a  significant
degree the performance of any emission  control  system.  In this
case,  the emission  products  of the   fuel  are  the  refueling
vapors   and   evaporated  spilled   fuel  associated   with  the
dispensing  of  gasoline.    These  vapors   are   photochemically
reactive  hydrocarbons which contribute  to  the formation  of
ozone,  an  NAAQS  criteria   pollutant.    The  emission  control
system of interest  in  this  case is an onboard  vapor recovery
system.   As discussed  previously,  dispensing rate limits could
enhance  the  efficient  performance  of  an  onboard  system and
avoid  significant   impairment   in   the   control   of   refueling
emissions by onboard controls through a  reduction in spillage.

     Section 211 (c)(2)(B) further  requires  EPA to consider all
available   scientific    and    economic   data    on    possible
alternatives,   including  a   cost  benefit   analysis   comparing
emission  control  systems, when  regulating  a fuel  in order  to
protect   the   effectiveness   of   emission   controls.    The
alternative to  onboard refueling  controls  is   Stage  II  vapor
recovery  systems.    This  alternative   has  been   thoroughly
analyzed  by EPA.   Although  Stage II is a  technically feasible
alternative,  EPA believes that vehicle-based vapor recovery, or
onboard   systems,   is   the    preferred   control    approach.
Regardless,  Stage  II  systems would most  likely also  require

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                              -13-
flow  rate  limits  to  ensure  proper  performance  as  is  now
required in California.[16]  Thus, a  limit  on  in-use dispensing
rates appear consistent with  the  requirements  of Section 211(c)
of the CAA.

V.   Benefits

     A number  of  benefits can  be achieved  by  limiting  in-use
dispensing rates.   These  include enhanced  control of refueling
emissions, gasoline  savings,  plus health  and safety benefits.
Each of these is discussed below.

     First,   as  previously   mentioned,    a  dispensing   rate
requirement  would  complement the  efficient  operation  of  an
onboard  refueling  control  system.    With  a  dispensing  rate
limit, the dispensing rate used  for  the design of  an  onboard
system would be compatible with the rates observed in-use.

     Second,   a   dispensing   rate  limit   would  provide  both
refueling emission reductions  and gasoline  savings  by reducing
in-use  spillage.    A  dispensing  rate limit  would  reduce  or
practically  eliminate premature  nozzle  shut-offs  and  spitback
from  onboard-equipped vehicles   and  reduce  the  spitback  from
current in-use vehicles without  onboard controls.   The  onboard
vehicles  would  be  designed  to   accommodate 10  gpm dispensing
rates without  spitback.    For in-use  vehicles   without  onboard
controls,   a  dispensing  rate  limit  would  reduce  spillage for
those vehicles which  can  handle  a flow rate of  10 gpm,  but not
higher values which  could occur  if in-use dispensing rates were
allowed  to  increase.  However,  some  in-use  vehicles  cannot
handle even  a  10 gpm dispensing  rate; a  dispensing rate limit
would not have any effect  on the spitback from these vehicles.

     The  current   average  emission  factor   associated  with
spitback spillage is  0.15 g/gallon of dispensed fuel.[3]  Using
this emission factor  and  EPA's  fuel consumption projection for
1995, spitback  spillage is estimated  to cause about  11,000 tons
of  refueling  emissions   in   that  year.[17]    This  spitback
spillage amounts  to  3.7 million  gallons of  gasoline spilled in
1995.   In 1995,  the vehicles  without  onboard  controls  will
comprise  about  50   percent   of   the   total  vehicle  fleet,  if
onboard  controls   are    implemented   for   1990  model   year
vehicles.[18]   Assuming  that a   dispensing rate limit  would
eliminate spitback  from  all   vehicles  with onboard  systems and
one-half of non-onboard equipped  vehicles,  and a gasoline price
of $1 per gallon, such  a  dispensing rate limit  could provide a
savings of approximately  $2.8 million for  gasoline consumers in
1995.  This  provides an  emission reduction of  8,250 tons per
year.   In  addition   to  these emission reductions  and  gasoline
savings,  a  dispensing  rate  limit  would  provide  additional
convenience  to  the  general  public   by  reducing spillage  of
gasoline on automobiles or persons.

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                              -14-
     It is  important  to  note that the current spitback spillage
emission factor of  0.15  g/gallon of dispensed fuel  is probably
conservative.   This  emission  factor originated  from  a  1972
study done by Scott Research  Laboratories.   Since  most stations
in   1972   used  suction  pump   dispensers,   which  have  lower
dispensing  rates  than the  current  stations using  submersible
turbine pumps,  it would  be  reasonable to assume that the in-use
dispensing   rates   at  that  time   were  lower   than  present
rates.[2]   Since  the  study  found  a   higher  probability  for
spitback spillage at  faster dispensing  rates,  today's spillage
emission  factor may  be  greater.   Furthermore,  at the  time  of
the  study,  most stations were  full  service and  only gasoline
attendants,  people  with  greater  experience  dispensing gasoline
than  today's   self-service  customers,   were   used   in   this
analysis.   Hence,   it is   reasonable to believe  that  today's
self-serve customers  may spill  gasoline  more frequently  and  in
larger  amounts  than  the  gasoline  attendants  used in the  1972
study.  Another important  factor in this  Scott  study is  the
presence of  a person monitoring  the gasoline attendants.   With
a monitor  present,  the attendants could have been more careful
and  less likely to  spill  gasoline.   For these reasons, the 0.15
g/gallon  emission  factor   used  in   this  report  for  spitback
spillage may be conservative.

     Third,  establishing  an  in-use dispensing rate  limit  will
provide  some  health  benefits   for  the   general  public.    A
dispensing  rate limit will help  reduce  the ozone concentration
in  the  lower  atmosphere   by enhancing  control  of  refueling
emissions.    In  addition, repeated  or prolonged  dermal contact
with  liquid  gasoline  due to  spillage can  cause  irritation  and
dermatitis  for  some   individuals.[19]   Thus,  there  are  some
health  benefits  gained  from  limiting  the  in-use  dispensing
rates.

     In  addition to  the   health benefits,  a  dispensing  rate
limit provides  some  additional  safety  benefits   for  refueling
operations.   The  refueling  operation would be  inherently  more
safe because  of reduction  in spitback and  spillage.   An in-use
dispensing  rate  limit  would help  to  reduce  spillage  during
refueling,   and would thus  contribute   to  a  reduction in  the
potential  for fires  caused by inadvertent  ignition  of spilled
gasoline.

VI.  Implementation

     Any  regulation  to  control  dispensing  rates  should  be
implemented  with  minimal  impact  on  service station operations.
With this  in mind,  the possible approaches  for  limiting in-use
dispensing rates were evaluated.   The implementation approaches
are  discussed  below  including  the  necessary   liability  and
enforcement  aspects.  However,  one  of the key factors affecting
how dispensing rate limits could be  regulated is  the nature and
structure of the nozzle industry.  This is discussed first.

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                              -15-
     Since  an  in-use  dispensing   rate   limit   and/or  nozzle
geometry  standards  would  have   some   impact  on  the  nozzle
industry, it is important to highlight  its  structure.   The fuel
nozzle  industry  consists  of  both  primary  manufacturers  and
rebuilders.   The primary  nozzle manufacturers  produce equipment
from  all  new  materials  whereas rebuilders  reuse the  original
nozzle body castings and replace all the old and worn operating
parts.    According   to   the   Petroleum  Equipment   Institute,
approximately  70   percent  of  the  entire  market  consists  of
originally  manufactured  nozzles.[20]   Moreover,   the  nozzle
market  structure  consists  primarily of  a few   large  original
manufacturers,  a  few mid-size  original manufacturers  who also
rebuild nozzles, and several small  rebuilders.

     The  rebuilders,  or   remanufacturers,  range   greatly  in
size.[20]  Some rebuilders  operate  from their  trucks and travel
to  service  stations  replacing worn-out  nozzle  parts.   Other
rebuilders  are  larger  companies   who  rebuild  and  test  the
nozzles they  rebuild to  meet  given specifications.   Recently,
primary  manufacturers  have become  more  concerned  about  the
liability  of   rebuilt   nozzles  since  they   could   be   held
responsible  for  a  failure  of a  rebuilt  nozzle  with  their
original  casting.[20]   Because of  this concern, one  original
manufacturer  has  quit  rebuilding  nozzles  and has  tried  to
prevent others from rebuilding their original  nozzles.

     With respect to the  implementation of  an  in-use dispensing
rate  limit,   it  is  important  to  characterize what  causes the
variation in  dispensing  rates.   The flow  rate  from  the nozzle
spout  is  dependent  on  two factors:   the pressure  supplied to
the nozzle by  the  pump  and the pressure at the  orifice created
by  the hand  lever  position on  the nozzle.   These  combine to
form a pressure drop which governs  the flow  rate  through the
nozzle.   The  same  nozzle can produce  a  variety of  flow rates
depending  on  this  pressure   drop.    For  any  given  nozzle
configuration,  the  maximum pressure drop  is   controlled  by the
supplied  pump pressure  since  the nozzle  characteristics  are
fixed.    The    maximum    dispensing    rates    of    different
manufacturers' nozzles vary with the supplied  pump pressure due
to  different  nozzle characteristics.   Thus,   to  control  the
maximum  flow  rate  through  the nozzle,  the resulting  pressure
drop  created  by  the  pump  and  the   lever   position  must  be
controlled.    This  could  be done  by  controlling the  pressure
contribution of both the  pump  and  the  lever position.  A better
solution, however,  is using a variable  flow limiting orifice or
flow restrictor to  limit  the  flow  rate.  This would control the
wide  variance  in  dispensing  rates   that   could  occur  with
different   combinations    of   pump    pressures   and   nozzle
configurations.

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                              -16-
     As mentioned  above,  in order to  limit  the dispensing rate
a  flow  restrictor  or  limiting  orifice   would   have  to  be
incorporated  somewhere  in the  dispensing  system.   This  flow
restrictor  could  be located in  the  dispensing unit,  the hose,
or   the   nozzle  itself.   The   in-use   effectiveness   of  the
dispensing  limit  regulation may  depend  to  some  degree  on the
restrictor  location.   The  best location would  be  one where the
restrictor  provides  effective dispensing   rate  control,  easy
installation   and   resistance   to  tampering.    Inserting  the
restrictor  or  limiting  orifice  internal  to   the  nozzle  body
appears to  be  the  best way to  achieve these  requirements and
thus may be the best approach to control dispensing rates.

     There  are basically two  implementation approaches  for  an
in-use dispensing  rate limit  requirement.   First,  all gasoline
retailers and wholesale purchaser-consumers could be  required
to  limit  dispensing rates  at  the nozzle to no greater than 10
gpm.   It   places   responsibility  for   compliance  with  the
dispensing  rate limit on  the  gasoline retailers  and wholesale
purchaser-consumers, those who own and maintain the in-use fuel
nozzles.   This option allows  that no  action  be  taken  if the
dispensing  rate limit  requirement  is being   met  without  any
modifications  and  also  provides  flexibility on  how  compliance
is  achieved when  measures  are needed  (i.e.,  nozzle,  pump,  or
hose restrictor).

     The  second implementation  method considered would  be  to
require that  nozzle manufacturers design  their nozzles so that
the  maximum  dispensing  rate  would  not  exceed 10 gpm.   Under
this  approach, nozzle  manufacturers  would probably  have  to
verify compliance  with  the dispensing rate regulation through
an  EPA  certification  program.    The  gasoline  retailers  and
wholesale  purchaser-consumers  could  then  purchase  certified
nozzles  for  dispensing  gasoline at  their  facilities.   This
alternative would guarantee that  the  flow regulator was part of
the   internal  nozzle   design  and   also   would  insure  the
availability   of  a   product   which   conforms  to  the  10  gpm
dispensing  rate limit.  However,  this implementation  approach
has  several drawbacks.  First,  it puts  at  least part  of the
liability for controlling in-use  dispensing  rates  on  the nozzle
manufacturers,  who  are not responsible for the  maintenance or
condition of  the nozzles   in  use.   Second,   this   option  would
force EPA to  regulate a  new industry, the nozzle manufacturers,
which could have some economic implications on small business.
Third, under  this  approach it would  be necessary  to provide a
phase-in period for  the  effective date  of  a  dispensing rate
limit  to  prevent  a  massive   turnover  of fuel nozzles  at the
service stations.   Finally,  this  option would  make rebuilders,
which are for the most  part  small businesses,  use a different
approach in order  to  stay  in  the market.   They would  have  to
certify  each  type   of   nozzle   they  rebuild.   This  could
substantially alter their business and marketing operations.

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                              -17-
     Based  on the  discussion  above,  the  most  straightforward
approach  is  the  first  option  which  requires  that  gasoline
retailers  and wholesale  purchaser-consumers  dispense  gasoline
at a maximum  flow rate no greater  than 10 gpm.   This  approach
has   several   advantages.     First,    this  option   minimizes
compliance  costs  since most service  stations  would  already  be
in compliance and would not have  to  take any action.   If  the
maximum  flow  rate for a nozzle  exceeds  10  gpm,  however,  the
restrictor  or limiting orifice discussed above would need to be
placed in the system to limit flow.

     Second, this option will  not  force  EPA to  regulate  a  new
industry or have any  negative  impacts on  small  business.   For
marketing  reasons, however,  both  original  nozzle manufacturers
and rebuilders  could choose to modify  their product  designs  to
fulfill   this   in-use  dispensing   rate  limit   requirement.
Original manufacturers could either modify the  poppet  in their
current nozzles  to act as  a limiting  orifice  or  insert  a flow
regulator  (variable  orifice) in the  nozzle.   Rebuilders,  which
use the original  nozzle  bodies, could  add a  fixed or  variable
flow regulator  if the original nozzle  was not already designed
to comply with the dispensing rate  limit.

     Third,  this  option  is  preferable   from  an  enforcement
perspective.  Existing enforcement programs  at  both the state
and  federal  levels   could   easily be  expanded  to  include  a
maximum dispensing  rate measurement.   The test  procedure used
to determine  the  flow rate  would  consist  of  either  an in-line
flow meter or a volume/time measurement.

     Finally,  the  liability  for   compliance  with  the  10  gpm
maximum dispensing rate requirement would  lie  with the gasoline
retailers  and  wholesale  purchaser-consumers.   The  liability
provisions  could be  similar to those applied  to the  current
nozzle spout  diameter  regulations  for leaded and unleaded fuels
(40 CFR 80.23).

VII.  Economic Analysis

     The economic impact  of  an  in-use  dispensing  rate  limit
requirement is  expected  to be minimal.   Since the 10 gpm value
was  chosen  from values  near  the  high   end  of  the  current
dispensing  rate  range,  most   stations are  now  in  compliance
without any additional modifications  and  will incur no  costs.
Therefore,   the  primary  effect of an  in-use dispensing rate
limit would be on current service  stations which are dispensing
at rates higher  than 10  gpm,  new  service stations, and service
stations which will replace  their  current  underground pumps and
dispensing hardware in the future.

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                              -18-
     For  those  current   service   stations/nozzles   which  are
dispensing  at  rates   higher  than  10  gpm,  some  modifications
would be  necessary to attain  compliance.   They could  retrofit
their dispensing hardware to satisfy  the  dispensing rate limit
by  inserting  a flow regulator  in  the  hose,  dispenser,   or
nozzle.    In  the future they could purchase new or rebuilt fuel
nozzles which have  a  fixed or  variable flow regulator  and  can
effectively regulate dispensing rates.

     For  new service  stations  and those  stations  which will
replace their current  underground pumps and  dispensing hardware
in  the  future,  equipment they  install  will  have to  comply to
the  10  gpm  dispensing rate  requirement.    If   their  equipment
exceeds the  10  gpm requirement,  they could either  insert flow
regulators  in  their  equipment  (i.e.,  dispenser  or  hose)  or
purchase nozzles which are designed specifically to control the
maximum dispensing rate to  10 gpm.   Furthermore, these stations
would   not   need  to   install   underground  pumps   of   higher
horsepower than those  currently used since the dispensing rate
would be  regulated and  the increased  horsepower  would  provide
little  or  no  additional  benefits.   Thus  both  capital  and
operating costs related to the pump could be saved.

     Based  on  the   discussion  above,  it  appears  that  the
simplest  and most  effective  way  to   regulate the  dispensing
rates  for for  current  and future  stations would  be  through
nozzle  modifications.  The costs associated  with  these nozzle
modifications are discussed below.

     As  was  mentioned   previously,   there   are  two  ways  to
effectively regulate  fuel flow  in  the  nozzle:  1)  modify  the
existing  poppet  in most  current nozzles to  serve  as a limiting
orifice,  or  2)   insert   a  flow  regulator   in   the  nozzle.
Modifying the  existing nozzle  design would require  only minor
tooling  changes  in  the  production  of  the  nozzles.    These
tooling  changes  would  cost  approximately $1 per  nozzle  to
amortize  the  necessary  fixed  costs  needed  for these  changes.
These tooling  change  costs are only  short-term  and would be
eliminated  after  a  few  years.   Inserting  a   flow  regulator,
however,  would  provide better  control of  dispensing rates over
a  wider  pressure   range.   Based  on  discussions  with  nozzle
manufacturers, the flow  regulator and necessary tooling changes
are  estimated  to  cost between  $1  and  $5 per nozzle. [21,22]
Therefore,  the  hardware   and  tooling  costs  for  original
manufacturers to  incorporate an in-use  dispensing  rate  limit
into their  nozzle  designs will  range from $1  to  $5 per nozzle
depending on  the  type of control  the manufacturer  chooses to
implement.

     Rebuilders  have  only  one   alternative   to  effectively
regulate  dispensing  rates in the nozzle.   This alternative is
to  insert a  fixed  or variable  flow  regulator  in the internal
design  of the  nozzle.   As stated  above,  the hardware  costs
necessary to  incorporate  this  flow  regulator   into  the nozzle
design ranges between $1 and $5 per  nozzle.

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                              -19-
     Based  on  this   discussion,   the  economic  burden  of  a
dispensing rate limit  requirement  would be expected to  be very
low.  Since the flow  rate limit was selected from near the high
end of the current  in-use dispensing rate range,  most stations
would  already  meet  this requirement  and  therefore  incur  no
associated cost.    In  addition,  it is  worth  noting  that  any
additional costs to the  consumer  related to limiting dispensing
rates  could  be  substantially  offset   by   the  reduction  in
spitback spillage which may result.

VIII.      Summary and Conclusions

     From  the  discussion  of  the   issues   studied   in  this
investigation,  an  in-use  dispensing  rate  limit would  enhance
the  onboard   effectiveness   and   reduce   spitback  caused  by
premature nozzle shut-offs.  Such a limit  would ensure that the
maximum   in-use  dispensing   rates   are  equivalent   to  the
dispensing rates used in  the  design  and certification  of  the
vehicle's refueling control  system.   It  may  also be beneficial
to specify nozzle geometries to assist in controlling refueling
emissions and  prevent spillage.  Further  information  regarding
the  impacts  of nozzle  geometries  on  refueling emissions  and
onboard  system  designs,  however,    is   needed  before  such
standardization is considered.

     Section  211   (c)  of the  Clean  Air  Act  gives  EPA  the
authority to  regulate the dispensing  rates  and  geometries  of
fuel  nozzles.   A  dispensing  rate   limit   requirement  would
enhance  the  performance  and efficiency of onboard controls  as
well as  provide additional  refueling  emission  reductions  and
gasoline  savings  by  reducing  spillage.   In  addition,  the
reduction in gasoline  spillage  will provide  several  health and
safety  improvements for refueling  operations.  A recommended
approach for  a dispensing rate  limit would  require  that  all
commercial gasoline retailers  and wholesale purchaser-consumers
use nozzles with a  maximum dispensing rate of  10  gpm.  Federal
and  state  surveillance  teams  would  have  to  expand  their
enforcement programs to  measure the maximum  dispensing  rate  at
service  stations.   Furthermore,  such  regulations should have
very small economic impact since most  stations  would already be
in compliance with the dispensing rate limit.

     In  conclusion,  it  appears that  development of  an  in-use
dispensing rate limit  is in  order to  ensure  proper functioning
of   onboard   control   systems   and   reduce   in-use   gasoline
spillage.   The  benefits  received  from  such  a   regulation
outweigh  any  costs which may result.   In addition,  further
investigation of the effects of nozzle geometry standardization
should be further  studied for the same reasons.

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                              -20-
                           References

     1.    Memorandum  to  R.  Fred  Holbert   from Ford,  W.  M.
Kreucher, June 17, 1986.

     2.    "API  Response  to   EPA  Request  for   Comments  on
Petroleum   Marketing    Industry    Refueling   Rate   Voluntary
Standard," August 6, 1986.

     3.    "Investigation  of Passenger  Car   Refueling  Losses,"
Malcolm  Smith,  Scott Research  Laboratories,  Inc.,  September 1,
1972.

     4.    "A  Study of  Variables  that  Effect   the  Amount  of
Vapor  Emitted  During the  Refueling of Automobiles,"  Edward M.
Liston, Stanford Research Institute, May 16,   1975.

     5.    Memorandum   to   Charles   L.   Gray   from   American
Petroleum Institute, E.  P. Crockett, August 8, 1984.

     6.    "Summary  and Analysis  of  Comments on the Recommended
Practice for the Measurement of Refueling Emissions,"  U.S.  EPA,
OAR, QMS, ECTD, [MO] 1986.

     7.    Meeting  of   SAE  Fuel   Supply  Systems  Subcommittee,
Cobo Hall, Detroit, MI., February 23, 1987.

     8.    "Underwriters  Laboratories  Gas   and  Oil  Equipment
Directory," Underwriters Laboratories, September  1985.

     9.    "Controls  Applicable   to   Gasoline   Retailers   and
Wholesale  Purchaser-Consumers,"  Code  of  Federal  Regulations,
Volume 40, Part 80, Section 22.

     10.   "Valves for Flammable  Fluids - UL 842," Underwriters
Laboratories,  June 30,  1980.

     11.   "Flammable and Combustible  Liquids Code,"  National
Fire Protection Association Code No. 30.

     12.   "Working  Draft:  Road   Vehicles-   Nozzle  Spouts  for
Unleaded Gasoline," ISO/TC22/SC16/WG3/N24.

     13.   "Annex  with  U.S.   Disapproval  to  N74  and  N75,"  R.
Thomas Northrup,  Society of Automotive Engineers,  November 14,
1985.

     14.   Product    Catalogs    and    Subsequent    Telephone
Conversations  with  Dover  Corp./OPW  Division regarding  nozzle
spout dimensions, July 1986.

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                              -21-
     15.   Product    Catalogs    and    Subsequent    Telephone
Conversations   with  EMCO   Wheaton   regarding   nozzle   spout
dimensions, July 1986.

     16.   Performance   Test   Procedures   for   Gasoline  Vapor
Recovery Systems, Stationary Source Test Methods, February 1984.

     17.   "MOBILES  Fuel  Consumption   Model,"   Mark  Wolcott,
EPA-AA-TEB-85-2, February 1985.

     18.   "Evaluation  of Air  Pollution  Regulatory Strategies
for Gasoline Marketing  Industry -  Response to Public Comments,"
Draft RIA (Vol. 1), November 5, 1986.

     19.   Patty's   Industrial   Hygiene   and  Toxicology,   G.D
Clayton and F.E. Clayton, 1978-1982.

     20.   Telephone   Conversation   with   Howard   Upton   of
Petroleum Equipment Institute, July 1986.

     21.   Memorandum    to    Kathleen   Steilen   from   Husky
Corporation, Arthur C.  Fink,  Jr.,  March 3,  1987 and Subsequent
Telephone Conversation on March 6, 1987.

     22.   Conversation  with  Alex  Podgers  of  EMCO  Wheaton,
Meeting  with  Nozzle  Manufacturers  from  Petroleum  Equipment
Institute, September 23, 1986.

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