Retooling the Vapor Recovery System: Part 3 - Reactions by Equipment Makers: Some Fugitive Emissions Remain At Large |
Negative environmental costs? |
| The common assumption in the petroleum industry is that if new environmental protection technology has to be developed, it will be costly to all stakeholders. This assumption is not valid in the case of controlling storage tank evaporative losses. The membrane technology exists today and the robustness of that technology has been proven. (Refer to "Membranes, Molecules and the Science of Permeation", T.P. Tiberi, April 1999, p.30).
The savings of salable product via ARID’s membrane technology generates positive net present values with favorable internal rates of return. Environmentalists, petroleum industry professionals and consumers have become sophisticated enough to question whether stricter environmental controls are worth the economic price that they typically impose. Economic concerns have taken on a new importance in the wake of reduced public support for initiatives that impose far reaching environmental restrictions. The US Supreme Court, in its ongoing review of a landmark clean-air dispute with the US EPA, is considering the costs of compliance along with health effects. To even consider calculating a financial payback instead of debating costs of compliance is a concept very new to the environmental arena. The savings from reducing evaporative losses are real, but another important question is, "To whom do the savings accrue?" In a typical wholesaler-to-dealer transaction, the dealer owns the product in the tanks and, therefore, suffers the loss due to evaporation. The wholesaler has no immediate incentive to reduce these losses (they have already collected their money) and they typically control the hardware installed at the dealer’s site. |
A challenge for CARB |
| An additional challenge for CARB is to provide incentive by linking the savings in salable product (and associated emissions reductions) to incremental revenues for both the wholesaler and the dealer. A simple alignment of objectives is made possible by the wholesaler basing the dealer’s purchased volumes on cumulative dispenser meter readings.
For example, if a site is picking up 0.7 percent volume in heat gain and suffering 0.5 percent loss due to evaporation, the net effect, without additional evaporative controls, is a positive 0.2 percent. If controls, such as ARID’s membrane system, are added to reduce the evaporative losses by 95 percent, the net gain at the dispenser meter is 0.7 - (.05 x 0.5) or 0.68 percent, which is more than three times the previous figure of 0.2 percent. With one small change in custody transfer, previously conflicting objectives are elegantly aligned between wholesaler, dealer and regulator. |
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