CALIFORNIA AIR RESOURCES BOARD
City Council Chambers
1900 Lake Tahoe Blvd.
South Lake Tahoe, CA
July 15, 1988
88-10-1 Report on Use of Hold-Open Latches to Reduce 001
88-10-2 Report by the South Coast District on Development
of 1988 Air Quality Plan.
88-10-3 Appointment of Members to the Modeling Advisory
88-10-4 Public Hearing to Consider Amendments to 046
Regulations Regarding Certification of Federally-
Certified Light-Duty Motor Vehicles for Sale in
88-10-5 Status Report: Air Resources Board's In-Use Motor
Vehicle Compliance Program (Recall).
Report on Use of Hold-Open Latches to Reduce Benzene Exposure.
The staff recommends that the Board issue an advisory on
hold-open latches and forward it, along with the staff report, to
local air pollution control districts for their review and
action. The advisory would request that the local districts
consider requiring greater availability of hold-open latches on
gasoline-dispensing nozzles, while taking into account the local
Fire Marshals' recommendations in their areas.
In July of 1987, the Board considered an airborne toxic control
measure for emissions of benzene from gasoline marketing at
retail service stations. At this hearing, the Board considered
an airborne toxic control measure for emissions of benzene from
gasoline marketing at retail service stations. At this hearing,
the Board expressed a desire for more information on the use of
hold-open latches on gasoline-dispensing nozzles as a supplement
to vapor recovery systems. The Board directed the staff to
report back with this information within one year. This report
is in response to the Board's direction, and presents the staff's
findings with regard to health benefits, cost, the availability
of hold-open latches to refuelers, and fire safety.
Estimated Health Benefits
We estimate that the use of hold-open latches could reduce
personal exposure to benzene during refueling by 75 percent
resulting in 4 to 29 potential lifetime cancer cases avoided,
calculated for year 2000 conditions. (This estimate is based on
the assumption that customer use of hold-open latches could be
increased to 60 percent). We estimate the individual risk to a
typical customer refueling at a vapor recovery station to be
about 1 to 8 potential excess lifetime cancers per million
persons exposed. If hold-open latches were used in conjunction
with vapor recovery, the individual cancer risk would drop to
about 0.2 to 2 potential excess cases per million persons
The use of hold-open latches on gasoline-dispensing nozzles can
reduce personal exposure to benzene, but does not reduce
emissions. Hold-open latches should be used in conjunction with
vapor recovery and is not a substitute for vapor recovery.
Hold-open latches on gasoline-dispensing nozzles are perceived as
a safety feature by some people, and as a fire hazard by others.
After careful evaluation, the Office of the State Fire Marshal
has to date remained neutral on the issue. A survey of the local
Fire Marshals within the state shows that 57 percent have no
opinion on the safety issue and that the remainder which have
opinions are about evenly divided, pro and con. The ARB staff
does not have the expertise to resolve the question of fire
safety, and direct implementation of the use of hold-open latches
in a given area may ultimately require approval of the local Fire
Availability of Hold-Open Latches to Refuelers
Nozzles come from the manufacturer already equipped with
hold-open latches, which are removed by station personnel where
the latches are not allowed or desired. Approximately 50 percent
of the nozzles at self-serve stations within the state are now
equipped with hold-open latches. There seems to be little, if
any, correlation between the local Fire Marshals' recommendations
and the availability of hold-open latches, since latches seem to
be prevalent even in areas where they are specifically prohibited
by the local Fire Marshal.
Our analysis indicates that the cost of increasing hold-open
latch use statewide would be relatively small. We have estimated
the total undiscounted 70-year cost to be $3.4 million, which
translates into about $0.1 to 0.9 million per potential cancer
case avoided, and about 0.0003 cents per gallon. The estimated
initial implementation cost for a typical station having 12
dispensing nozzles is up to $55.
Greater use of hold-open latches would provide a further
reduction in potential cancer cases due to benzene exposure at a
very low cost, even though they reduce only personal exposure and
not emissions. Staff believes, considering the low cost, that
the use of hold-open latches would be an attractive addition to
vapor recovery systems. The extent to which hold-open latches
would be used, however, is dependent on the voluntary,
unenforceable behavior of the customers. Rather than requiring
all districts statewide to adopt a control measure for hold-open
latches, we believe it is appropriate for the ARB to instead send
an advisory to the districts asking them to examine the benefits
of encouraging or requiring greater hold-open latch availability
and use, subject to the recommendations of the local Fire
Marshals in their areas.
Public Hearing to Consider Amendments to Regulations Regarding
Certification of Federally Certified Light-Duty Motor Vehicles
for Sale in California.
The staff recommends that the Board amend its regulations
regarding certification of federally certified light-duty
vehicles for sale in California. The proposed amendments would
establish a limit on sales of higher emitting federal vehicles of
no more than 1500 units per engine family per model year for 1992
and subsequent model year federal vehicles.
In 1981 the Legislature enacted AB 965, which amended Section
43102 of the Health and Safety Code. The amendments require the
Board to establish a program allowing a limited number of federal
vehicles, otherwise unavailable in California, to be sold in the
state provided their excess emissions are offset by the
manufacturer's California-certified vehicles with emissions below
the applicable standard.
In response to the legislation, the Board adopted a one-year
trial program for the 1983 model year. The program is set forth
in a set of Guidelines established by regulation. The Board
later extended the program, first through the 1987 model year and
then to include the 1988 and subsequent model years.
At the Board's request, the staff has presented annual status
reports on the program and the resulting increase in emissions.
In its most recent report presented at the November 13, 1987
Board meeting, the staff indicated that the number of federal
vehicles sold in the state under the AB 965 program was expected
to increase significantly for the 1987 model year, and might
increase more in the future as a result of the new 0.4 g/mi NOx
standard and on-board diagnostic requirements. The Board
expressed concern over the increased emissions impact and
directed the staff to return with a recommendation to more
effectively restrict the program to models which could not
otherwise be certified to California standards.
The staff has considered several alternatives for limiting usage
of the AB 965 program, and has concluded that setting a sales
limit is the most appropriate approach at this time. The staff
therefore recommends that the Board amend the AB 965 Guidelines
to limit a manufacturer's sales of 1992 and subsequent model-year
federal vehicles to 1500 units per engine family for each model
The AB 965 program was intended for use primarily for cases where
development and certification costs are too high relative to
expected sales in California or for cases of technological
infeasibility. However, some manufacturers have recently used
the program for federal models which could appropriately be
certified to California standards in light of the models' low
federal emission levels and magnitude of California sales.
The proposed 1500 unit sales limit was set at a level which is
anticipated to allow continued use of the program for models that
would not otherwise be sold in California because of their low
sales volume. In developing the proposed sales limit level, the
staff used projected sales data provided by the manufacturers to
identify the minimum sales needs to offset California
certification costs. The sales limit will help prevent potential
misuse of the program by manufacturers seeking to avoid in-use
recall liability and compliance with on-board diagnostic
requirements which could reasonably be met.
The staff believes that emission control technology has evolved
to a point where virtually all federal models have control
equipment sufficient to enable the vehicle to meet present
California standards. Deferring implementation of the proposed
sales limit until the 1992 model year is anticipated to
adequately accommodate potential technological feasibility
concerns associated with meeting the pending 0.4 g/mi NOx
standard and on-board diagnostic requirements.
IMPACTS OF PROPOSED REGULATORY CHANGES
The staff estimates that the proposal will reduce the adverse
emissions impact of the program as follows: HC by 47 percent,
from 1.16 to 0.61 tons per day, CO by 17 percent, from 4.9 to 4.1
tons per day; and NOx by 32 percent, from 2.3 to 1.6 tons per