CALIFORNIA AIR RESOURCES BOARD
70 West Hedding Street
San Jose, CA
October 8, 1987
87-13-1 An Informational Report by the Santa Clara 001
Fire Chiefs' Association on "The Toxic Gas
87-13-2 Public Hearing to Consider the Adoption of 318
an Airborne Toxic Control Measure for
Benzene Emissions from Retail Gasoline
Service Stations (Continued from July 9, 1987).
a. Closed Session
1. Personnel (as authorized by State Agency Open Meeting
Act, Govt. Code Sec. 11126(a).).
2. Litigation (Pursuant to the attorney-client privilege,
Evidence Code Sec. 950-962, and Govt. Code Sec.
b. Research Proposals
c. Delegations to Executive Officer
ITEM NO.: 87-13-1
Public Meeting to Hear Representatives of the Santa Clara County
Fire Chief Association Present the Informational Report "The
Toxic Gas Management Study".
Assembly Bill 1021, authored by Assemblyman Byron Sher in 1985,
required and authorized the Santa Clara study of the use and
management of toxic gases and emergency response to accidental
releases of toxic gases. The Air Resources Board was designated
as the funding agency for the $100,000 study. The original
legislation required that the study be completed and submitted to
the Legislature by January 1, 1987. Subsequent legislation
extended the due date to July 1, 1987. The final study report
was submitted to the ARB on July 1, 1987, and duly transmitted to
the Legislature soon thereafter.
As funding agency, the Board staff was responsible for contract
preparation, review of the study report to ensure that all of the
elements required by AB 1021 were addressed, and approval of the
disbursement of funds to the SCCFCA for its contractors,
Practicon Associates and Microsafe, Inc. Acceptance of the study
report was based on its fulfillment of the requirements of AB
1021 and does not imply any endorsement of the findings and
recommendations contained in the study.
The basic objectives of the study were to develop working
standards, a regulation, and guidelines for the handling,
storage, and transportation of toxic gases and emergency response
to accidental releases.
The specific elements of the final study report include:
1) An evaluation of the feasibility and desirability of applying
the standards that govern the transportation of nuclear materials
to the transportation of toxic materials;
2) a model for a public information and education program in the
form of a synchronized slide-tape presentation;
3) a model emergency response plan using 15 toxic gases as a
sample of those common to California;
4) training guidelines for public safety and industry personnel
to ensure appropriate inspection and compliance practices; and
5) a model ordinance as an example of one method a local
community can utilize to reduce the likelihood of unauthorized
toxic gas releases.
ITEM NO.: 87-13-2
Airborne Toxic Control Measure (Benzene) (Regulatory).
The ARB staff recommends that the Board adopt the proposed
airborne toxic control measure for benzene emissions from retail
service stations. Staff recommends that the measure have an
exemption level of 120,000 gallons and that existing stations
with annual sales from 120,000 to 480,000 gallons have four years
after district adoption of the measure to install the vapor
Previous Board action-The Board previously considered the
proposed measure at its July 1987 hearing. Staff had proposed
that Phase I and II vapor recovery systems be required at all new
stations and at existing stations with an annual throughput of at
least 240,000 gallons per year. The vapor recovery systems which
would be required by this measure for control of benzene
emissions are already required in most areas of the state for
control of ozone.
At the July hearing, the Board passed a motion approving a
requirement that Phase I and II systems be installed on existing
service stations selling over 480,000 gallons per year within two
years after district adoption of the measure and on all new
retail service stations. The Board continued until October the
matter of the benzene emissions controls, if any, which should be
required of stations which sell 480,000 or fewer gallons per
year. The Board directed its staff to further analyze the costs
and benefits of imposing Phase I and II controls on existing
stations which sell 480,000 or fewer gallons per year and to
present the results and a staff recommendation at the October
1987 Board hearing.
Staff response to Board direction.-In response to Board
direction, we have analyzed the costs and benefits of requiring
ARB-certified Phase I and II vapor recovery at existing retail
service stations selling 480,000 or fewer gallons per year. We
performed this analysis for the rural counties of Siskiyou,
Tuolumne, Butte, Shasta, and Mendocino. Data from surveys of
retail service stations and bulk gasoline distributors were used
to identify the gasoline throughput and the number of service
stations affected in these rural counties. Ambient benzene
monitoring and surveys were conducted in the five rural counties
and in San Bernardino County to compare with the previous
estimates of neighborhood and ambient benzene concentrations and
cancer incidence from service station benzene emissions.
Staff recommendation.-Based on this analysis, we recommend that
the Board adopt a control measure requiring ARB-certified Phase I
and II vapor recovery at all existing stations that sell at least
120,000 gallons per year and at all new stations. Existing
stations selling more than 480,000 gallons per year have two years
to comply after district adoption of the measure. Staff
recommends that existing stations selling between 120,000 and
480,000 gallons per year have four years to comply after district
adoption of the measure.
District actions.-If the Board adopts this measure, districts are
required by state law to adopt a regulation that is equally
effective or more stringent than this measure at controlling
benzene emissions from retail service stations. After the
effective date of Board adoption, a district has 120 days to
propose its regulation and 6 months to adopt it.
Risk and risk reduction.-The primary service-station related
benzene exposure and cancer risk occurs near the nozzle during
vehicle fueling. Additional exposures occur to nearby residents
and to the general public. The proposed measure would reduce the
individual risk from vehicle fueling (7 to 51 cancers per
million) by 85% and would reduce the overall cancer incidence
from uncontrolled service station benzene emissions by 83% (8.3
to 64 excess lifetime cancers reduced). The measure would reduce
benzene emissions by 71 tons and hydrocarbon emissions by 8,900
tons in year 2000, saving about 2.2 million gallons of gasoline
annually which would otherwise be emitted to the atmosphere.
This measure will also aid in achieving the State oxidant
standard and maintaining the Federal ozone standard in areas
where the State standard is violated but the Federal standard is
not. This measure will also reduce the cancer risk from exposure
to total gasoline vapor which may be significantly greater than
the risk from benzene vapors alone.
Control alternatives considered.-We have considered these
potential control alternative: 1) requiring full-service stations
and protective masks for attendants; 2) requiring installation of
vapor recovery controls when underground tanks are replaced; or
3) requiring onboard vehicle vapor controls.
Requiring full-service and protective masks for pump attendants
was rejected because this alternative does not represent best
available control technology and would not reduce benzene
exposure to nearby residents or the general population. Further,
the ARB does not have the authority to require pump attendants to
wear protective masks. Requiring installation of vapor recovery
when underground tanks are replaced was rejected because tank
replacements are minimal in rural areas. Requiring onboard
vehicle vapor controls was rejected because it would take 20
years to become fully effective as new controlled vehicles
replace older uncontrolled vehicles.
SUMMARY AND IMPACTS OF PROPOSED BOARD ACTION
Adoption of the proposed control measure is not expected to
result in any adverse health, safety or environmental impacts.
The measure would have an annual cost of 9.2 million dollars; the
equivalent average cost per gallon of gasoline controlled by this
measure is 0.8 cent. The average cost per cancer reduced would
be 10 to 78 million dollars which is within the cost range of the
vehicular and fuel-related potential control measures identified
in the Benzene Control Plan (2.2 to 110 million dollars per