NotesonStageIIVOCs

1、3Comhshaoi Pobal agus Rlailias AlfJdllEnviron mend, ConnnnLinilY and Local GovernmenlConsultation paper on the introduction ofStage II petrol vapour recoveryDURING REFUELLING OF MOTOR VEHICLES AT SERVICE STATIONSSubmissi ons should be forwarded by5pm on Friday, 21 October, 2011 to:Eoin Deega n,Depar

2、tme nt of the En vir onment, Com mun ity and Local Gover nment, Newtow n Road,Wexfordoreoin _deega nen vir on .ie1. Backgro und11.1 Directive 2009/126/EC of the European Parliament and of the Council of 21 October 2009 on Stage II Petrol Vapour Recovery (PVR II) is due to be tran sposed in to n ati

3、on al legislationbefore 1 January 2012.1.2 The objective of Directive 2009/126/EC is to reduce emissi ons of volatile orga nic compo unds (VOC) in to the atmosphere from vehicle re-fuelli ng activities at service stations, in order to reduce the adverse impact of VOC on human health and the en vir o

4、nment.1.3 Petrol contains VOC, carb on-based chemicals that evaporate readily into the atmosphere. Once emitted to air, VOC are associated with several health and en vir onmen tal problems:o Formati on of groun d-level ozone and photochemical smog;o Poor local air quality (be nzene in air);o Atmosph

5、eric warm ing and climate cha nge.1.4 Once released into the atmosphere VOC can react in the prese nee of sun light with nitrogen oxides emitted from combustion processesto form ground level ozone and other comp onents of photochemical smog. The pote ntial impacts of groundlevel ozone in clude reduc

6、ed lung fun ctio n, in creased in cide nce of respiratory symptoms, respiratory hospital admissi ons and mortality. Groun d-level ozone can also cause damage to many pla nt species leadi ng to loss of yield and quality of crops, damageto forests and impacts on biodiversity. Benzene is a VOC and a co

7、mp onent of petrol. It is also a known huma n carci nogen and is associated with a heighte ned risk of ill nesses such as leukaemia.1.5 Directive 94/63/EC on the con trol of VOC emissi ons result ing from the storage of petrol and its distributi on from term in als to service statio ns (ofte n refer

8、red to as Stage I Petrol Vapour Recovery or PVR I) has bee n give n effect in the State since 1997 by the followi ng Regulatio ns:oEn vir onmen tal Protectio n Age ncy Act, 1992 (Con trol of volatile orga niccompo und emissi ons result ing from petrol storage and distributio n) Regulatio ns, 1997 (S

9、.I. no. 374 of 1997；o Air Pollution Act, 1987 (Petroleum Vapour Emissio ns) Regulatio ns, 1997 (S.I. no 375 of 1997) http:/eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:285:0036:0039:EN:PDF h卄 p:/www.irishstatutebook.ie/1997/e n/si/0374.html h卄 p:/www.irishstatutebook.ie/1997/e n/si/0375.

10、html.1.6 The Environmental Protection Agency (EPA) regulates petrol storage and distribution terminals under S.I. no. 374 of 1997. Petrol storage installations invo Ived in the load ing of petrol in to, or uni oad ing of petrol from, mobile containers are required to apply to the EPA for a VOC permi

11、t. Further in formatio n on VOC permits issued by the EPA for petrol storage and distribute n can be obta ined from the EPA website at the link below: http:/www.epa.ie/whatwedo/lice nsi ng/voc/1.7 Service stations and mobile tankers are regulated by local authorities under S.no. 375 of 1997. Owners

12、of service stations are required to ensure that petrol loading and storage equipment at a service station are designed and operated in accordanee with the Regulations. Local authorities appoint suitable persons to carry out assessme nts to en sure complia nee.1.8 Directive 2009/126/EC extends the re

13、quirement to control and recover VOC emissi ons to the refuelli ng of in dividual vehicles. In side a petrol tank, petrol vapour accumulates in the space above the liquid petrol. When a vehicle is refuelled, the vapour is forced out from the fuel tank by the incoming fuel and, uni ess con trolled, e

14、scapes into the atmosphere through the filler n eck of the fuel tank (see Appe ndix 1).1.9 Stage II Petrol Vapour Recovery (PVR II) captures this escap ing vapour. This is done by creat ing a vacuum to draw back and capture the vapour through the dispensing hose and nozzle, either to the stations un

15、derground storage tank( conventional PVsteIi Appendix 2 ) or directly back to the fuel pump ( at pump PVR II -see Appendix 3). Conventional PVR II results in the vapour eve ntually being retur ned to the oil supplier via the petrol tan ker, much in the same way as curre ntly happe ns un der Stage I

16、Vapour recovery (See Appe ndix 4). The ap ump PVR II tech no logy is a more rece nt developme nt and does not require any modificati on of the un dergro und pipe work of the service stati on. In this scenario, the petrol is recovered and resold at the usual forecourt price, however, duty and supply

17、costs will have already bee n paid for the recovered fuel.1.10 Directive 2009/126/EC obliges Member States, as a mi nimu m, to put in place measuresto provide for petrol vapour recovery during the refuelling of motor vehicles at service stations. Member States may decide, following consultation with

18、 the Europea n Commissio n, to impleme nt more stri ngent protective measures an d/or limits tha n those set out in the Directive.1.11 Nati on al legislati on will be in troduced un der the Europea n Commun ities Acts 1972 to 2007, as amended, to give effect to the provisions of Directive 2009/126/E

19、C. There is an obligation on all Member States to transpose the Directive before 01 January 2012. Member States that fail to do so are liable for infrin geme nt proceedi ngs and may be fin ed.2. Stage I Petrol Vapour Recovery (already in effect)2.1 Directive 94/63/EC on Stage I Petrol Vapour Recover

20、y provides for measures to minimise VOC emissions from the storage of petrol at terminals and service stati ons, from load ing and uni oad ing at term in als, and from uni oad ing at service stati ons.2.2 The Air Pollution Act, 1987 (Petroleum Vapour Emissions) Regulations, 1997 (S.l. no 375 of 1997

21、) transposed into Irish law certain articles of Directive 94/63/EC concerning the distribution of petrol to, and the storage of petrol at service stati ons. The Regulati ons also provide for the mon itori ng of complia nee of service stati on and mobile container operators by the releva nt local aut

22、horities.Certificati on Process for Service Statio n2.3 The local authority approves such pers on or pers on sas it con siders possessthe appropriate kno wledge, trai ning and experie nee to perform the functions of an approved assessor un der the Regulati ons.2.4 Owners of service stati ons are req

23、uired to en sure that petrol loadi ng and storage equipme nt at a service statio n are desig ned and operated in accorda nee with the provisi ons of the Regulatio ns. It is the duty of a man ager of a service stati on to ensure that testing is carried out by an approved assessor so as to ensure comp

24、lia nee with the requireme nts of the Regulati on s. If the approved assessor is satisfied that a service station is in compliance with the Regulations, a report to that effect is submitted to the local authority. If the local authority is satisfied thatthe approved assessor s report dem on strates

25、complia nce with the Regulati on s, it issues a certificate of testing to the service station which is valid for up to three years.Certification Process for Mobile Carriers (petrol tanker operators)2.5 A similar process is in operati on, I ocal authorities approve pers ons con sidered to have the ap

26、propriate kno wledge, training and experie nce to carry out the proper checks and tests (vapour tight ness etc.) on mobile containers to en sure that they are in complia nce with the regulati ons.2.6 The approved assessor sig ns the certificate of complia nce if they are satisfied that the carrier i

27、s in compliance with the Regulations. The carrier is required to keep available the certificate issued for in specti on at his/her place of bus in ess. In addition, the carrier must fit his/her mobile container with a metal plate with details of whe n the complia nce testi ng was carried out and who

28、 the approver was. A certificate of compliance needs to be obtained no later than 3 years after the last certificate was issued. It is matter for the local authority to carry out periodicin spect ion of the certificate of complia nce and the metal plate.#3. Application of Directive 2009/126/EC3.1 Di

29、rective 2009/126/EC provides thatnew service stations which meet either of the followi ng two criteria will be required to be equipped with PVRII tech no logy to recover VOC duri ng refuelli ng of vehicles:? throughput* 100m (or 100,000 litres) and situated under living or work ing quarters?throughp

30、ut* 500m3 (or 500,000 litres)* throughput is defined as the actual or intended annual quantity of petroluni oaded from mobile containers into a service statio n3.2 Service stati on sin existe nee before 1 Janu ary, 2012 whe n un derg oing their n ext major refurbishme nt will n eed to in stall PVRII

31、 tech no logy if they meet either of the followi ng two criteria:? throughput* 100m (or 100,000 litres) and situated under living or working quarters?throughput* 500m3 (or 500,000 litres)3.3 In additi on, the Directive requires that service stati ons with a throughput* 3,000m3 (or 3,000,000 litres)

32、will be required to in stall PVRII tech no logy by 31 December, 2018 at the latest or sooner if un dergo ing a major refurbishme nt before that date.SummaryNew or ExistingStati onActual or Inten ded throughputDeadline for installing PVR IINewServiceStati on3? Greater than 500m/year? Greater than 100

33、m3/year and it is situated un der perma nent liv ing quarters1 Jan uary, 2012Existing Service Stati on? Greater than 500m?/year? Greater than 100m3/year and it is situated un der perma nent liv ing quartersWhen the existing service station un dergoes amajor refurbishme ntExisting Service Stati on? G

34、reater than 3000m?/year1 January 2018 or undergoes a major refurbishment (whichever is sooner)new service stati on means a service stati on which is built or for which an in dividual pla nning permissi on, con struct ion lice nce or operat ing lice nce is gran ted on or after 1 January 2012;existi n

35、g service stati on means a service stati on which is built or for which an in dividualpla nning permissi on, con structi on lice nce or operati ng lice nce is gran ted before 1 January 2012;54. Directive Requireme nts: Minimum level of Petrol Vapour Recovery4.1 The Directive provides that the petrol

36、 vapour capture efficiency of PVR II systems is equal to or greater than 85% as certified by the manufacturer in accorda nee with releva nt Europea n tech ni cal sta ndards or type approval procedures referred to in Article 8 (Technical Adaptations) or in the absence these, n atio nal sta ndards. Es

37、se ntially this is a measure of the perce ntage of vapours that would otherwise have bee n emitted to air if PVR II tech no logy was not in place.An abatement efficiency test is carried as part of a type approvalcteotiof arecovery system.4.2 Where the recovered petrol is tran sferred to a storage ta

38、nk at the service stati on the vapour/petrol ratio shall be equal to or greater than0.95 but less tha n or equal to 1.05. Con trol devices within vapour recovery systems en sure that the amount of vapour recovered is in proportion to the amount of fuel dispensed. More accurate control over vapour fl

39、ow rates improves the performance of vapour recovery systems. Ideally the ratio betwee n the volume of vapour recovered and the volume of petrol dispensedshould equal 100%. It has been estimated that 1,000 litres of recovered vapour will produce 1 litre of recovered fuel.5. Directive Requireme nts:

40、Periodic checks and con sumer in formatio n5.1 -service PVRystems are to be testedat least annually to ensure the petrol vapour capture efficiency is at least 85%. This can be done by testing the vapour/petrol ratio or any other appropriate methodology.5.2 Automatically monitored PVR II systems are

41、to be tested at least once every three years to ensure the petrol vapour capture efficiency is at least 85%. This can be done by testing the vapour/petrol ratio or any other appropriate methodology. Any such PVR II system shall automatically detect faults in both the PVR II system and the monitoring

42、 system and stop the flow of petrol if the fault is not rectified with in 7 days.5.3 Service stati ons which have in stalled a PVR II system must display a sig n, sticker or other notification on, or in the vicinity of the petrol dispenser, informing customers of this fact.6. Directive Requireme nts

43、: Pen alties6.1 The State is required to introduce penalties for breaches of legislation adopted pursua nt to the Directive. The pen alties must be effective, proporti on ate and dissuasive. Curre nt pen alties allowed for un der the Europea n Commun ities Acts in clude a class A fine of up to ?5,00

44、0 or three mon ths in pris on or both. Pen alties for conviction on indictment under the European Communities Acts include a fine of up to ?500,000 or 3 years in prison.#Views on the transposition of Directive 2009/126/EC and on how Stage II PVR can be best impleme nted are now being in vited.As par

45、t of the consultation process, submissions are also invited on the current operation of the Stage I PVR Regulations.A number of questions which attempt to assist the consultation process are listed on the followi ng two pages.Submissi ons should be forwarded tcEoin Deega n, Departme nt of the En vir

46、 onment, Commu nity and Local Gover nment, Newtow n Road, Wexford or eoin _deega nen vir on .ie by 5pm on Friday, 21 October, 20119How is the implementation of the Stage I PVR operating and how can it be improved?Stage II Petrol Vapour RecoveryScope of the legislati onThe Directive exempts certa in

47、categories of petrol stati ons from hav ing to impleme nt PVR II measures. Should the national legislation also provide these exemptions? (It should be no ted that the legislatio n which tran sposed the Stage I PVR Directive 94/63/EC is more stri ngent (S.l. 375 of 1997- see sectio n 2 above) as it

48、applies to_all service stations, even though Directive 94/63/EC provides for an exemption for stati ons with a throughput of less tha n 100rn.Inspection / Certification process Given that a Stage I PVR inspection and certification system is already in place and complia nee must be dem on strated eve

49、ry three years, there should be scope to combine Stage I and II PVR inspection/certification process if petrol stati ons in stall an automatically mon itored PVR system.Is there a prefere nee for local authorities to approve pers ons to un dertake in spect ions or for such in spectors to be certifie

50、d cen trally?Questio ns particularly releva nt to in dustry : How many petrol stations are there in your organisation currently in operatio n in the State? How many petrol stati ons in your orga ni sati on have an annual throughput of petrol ofo 500 m3o 3,000 m3How many petrol stations in your organ

51、isation are situated under perma nent livi ng quarters or worki ng areas? How many new petrol stations are scheduled to come into operation during 2012? How ofte n do stati ons on average un dergo a major refurbishme nt? It has bee n suggested that the in vestme nt cycle in the fuel retail sector is

52、 every 15 years. Please provide a schedule of when stations with a 33throughput 500 m but 3,000m must in stall PVR II by 2018 regardless of when their next major refurbishment is). Estimates for the cost of in stalli ng the new tech no logy vary, depe nding on nu merous variables in cludi ng; which

53、type of PVR system is in stalled (conven tio nal or at pump); whether the work is scheduled or un scheduled; whether underground pipe work already exists; how many petrol dispensers are on the site; and whether nozzles will be new or retro-fitted. It has been estimated that the scheduled installatio

54、n cost is in the region of ?33,000 for a forecourt with a throughput of 2,000-3,000 m3 year (4 dispe nsers each with 4 no zzles). The cost differe nee betwee n being able to retrofit a dispe nser and hav ing to replace the dispe nser in the case of nonscheduled refurbishme nt is sig ni fica nt. Un s

55、cheduled in stallati ons of PVRII have bee n estimated to cost as much as ?86,000 (where the dispe nser in stalled is new and the throughput of the station is 2,000-3,000 m year, 4 dispenserseach with 4 nozzles). The UK has estimated that the typical capital costs of installing Stage II controls are

56、 estimated to be around ?35,000 for a new service station (or an existing service station installing controls as part of a major refurbishment) with an annual throughput of 3,000 to 3,500m3. Can you please in dicate if these figures are reas on ably stated? Can you please in dicate if the requireme

57、nt for PVR II tech no logy will impact the price of petrol? Historical estimates suggest that there prices may in crease by ?0.01 per litre for statio ns with a throughput of 500m per year to as little as ?0.003 per litre for stations with a throughput of 5,000m3-On-going costs: Annual maintenance a

58、nd power costs to run the tech no logy also vary depe nds primarily on the nu mber of dispe nsersi n operati on at the service stati on have bee n estimated to be ?625 per annum3for a service station with an annual throughput of 3,000 to 3,500m (four dispensers assumed). Can you please indicate if these figures are reas on ably stated? Complianee costs: The inspecti