

  
RE: Stage II Decertification
  
Shepard, Dave 
 to:
 Glenn Passavant, Jones, Christian
                                                            04/27/2011 12:08 PM

 
Cc:
 Lynn Dail, "lrector@nescaum.org"
 
                                                                               
 


Glenn,
As a first step I'll answer the questions you posed in your email as best as I can. It sounds like these issues may be the topic of a conference call with NESCAUM. If you'd like to schedule a separate phone call just let me know.

(1) how many GDFs in VT have Stage II.?  I realize that it only applies to stations exceeding 400,000 gal/yr. 
In Vermont approximately 394 GDFs were equipped with Stage II before we started phasing out the program. The number that currently have Stage II is probably around 340.

(2) for a typical GDF, say 1.2 1.4 million  gal/yr what are the estimated costs for decommissioning Stage II? 
We haven't made an attempt to estimate the cost of decommissioning Stage II and so far I haven't seen any invoices or other information for any of the GDFs that have been decommissioned so far to provide any cost figures. 

(3) before decommissioning what were the average annual inspection,testing, and hardware maintenance costs for this typical station due to Stage II? 
We don't have a good estimate of the annual cost of compliance as we have only anecdotal knowledge of the hardware maintenance costs for GDFs. The Stage II regulation was amended in 2001 to require GDFs to perform specified maintenance of their tank top fittings annually (including replacement of the vapor adaptors) or to perform an annual pressure decay test. At that time we estimated the cost of the pressure decay test to range from $350 to $800 and the cost to replace vapor adaptors at $100 per adaptor (typically a GDF has between one and three adaptors). There wasn't an estimate of the labor costs. In addition to the annual maintenance/pressure decay test requirement the Vermont Stage II regulations require Stage II testing every five years. The required tests include a pressure decay test for all GDFs equipped with Stage II and either  an air to liquid ratio test (for vacuum-assist equipped GDFs) or a dynamic backpressure test (balance equipped GDFs). 

(4) Is it correct to assume that  essentially all GDFs in VT are vacuum assist. 
In Vermont approximately 90% of the GDFs with Stage II are/were equipped with vacuum-assist systems.

Dave Shepard
Vermont Department of Environmental Conservation
Air Pollution Control Division
103 South Main Street
Waterbury, VT  05671-0402
Phone: (802) 241-3857
Fax: (802) 241-2590
 
From: Passavant.Glenn@epamail.epa.gov [mailto:Passavant.Glenn@epamail.epa.gov] 
Sent: Tuesday, April 26, 2011 12:38 PM
To: Jones, Christian; Shepard, Dave
Cc: Dail.Lynn@epamail.epa.gov; lrector@nescaum.org
Subject: Stage II Decertification

Hi Chris and Dave 

I am Glenn Passavant of EPA's Office of Transportation and Air Quality.  I have worked the ORVR/Stage II control areas for EPA for over 20 years.   

As you may be aware, EPA is now developing a rule to relieve the states of their legal obligation to maintain Stage II controls.  We hope to propose that rule this Spring. 

As we have been developing the rule, a few questions have come up which I hope you might be able to help us answer since VT has already acted to remove Stage II and you have a fairly rigorous process and checklist. 

I will summarize below and perhaps we can have a follow-up teleconference. 

(1) how many GDFs in VT have Stage II.?  I realize that it only applies to stations exceeding 400,000 gal/yr. 

(2) for a typical GDF, say 1.2 1.4 million  gal/yr what are the estimated costs for decommissioning Stage II? 

(3) before decommissioning what were the average annual inspection,testing, and hardware maintenance costs for this typical station due to Stage II? 

(4) Is it correct to assume that  essentially all GDFs in VT are vacuum assist. 

Thank you for your help. 

GLENN W. PASSAVANT
CENTER DIRECTOR
ASSESSMENT & STANDARDS DIVISION
OFFICE OF TRANSPORTATION AND AIR QUALITY
US EPA  ANN ARBOR, MI
734-214-4408

