• ARID’s PERMEATOR System Earns CARB Certification...
• PERMEATOR Systems to be Installed at ALL H-E-B Houston area sites...
• ARID Receives Certification from Maryland...
• Independent 3rd Party Field Testing Confirms...
• Texas ORVR Certification Approval...
• ARID Announces Completion of Study...
• ARID announces appointment...
• Vapor Recovery Around the World
• Retooling the Vapor Recovery System
• Membranes, Molecules and the Science of Permeation

The total system approach, in my opinion, is not appropriate for "back-end" storage tank system components, such as combustion units and membrane processors. These components are designed to maintain storage tank pressures within a prescribed range by periodically actuating in response to prevailing tank conditions. If the tank pressure is not controlled beyond the normal operating range of pressure/vacuum valves, these systems will not negatively affect the operation of the front-end systems.

Membrane systems are complete back-end systems - not components of the front-end systems. Back-end systems, in effect, are subsystems of the overall vapor recovery system at a dispensing facility. Membrane systems can be installed on uncontrolled (no Stage II) facilities or retrofit to existing Stage II balance or assist systems. The system operates independently of the front-end system (if one is present) and recovers, concentrates and returns vapors which would otherwise be emitted from storage tanks.

From a commercial perspective, ARID and other back-end system suppliers are restrained in sales and marketing efforts because we are forced to collaborate with dispenser-based Stage II system suppliers before attempting to retrofit our system to their installed base.

ARID urges CARB to consider a certification protocol that considers both the technical and commercial implications as outlined above. Back-end systems should be certified to deliver a given vapor recovery efficiency and to operate within a specified tank pressure range regardless of the presence of a Stage II vehicular vapor recovery system at any dispensing facility. Perhaps CARB could categorize back-end systems as Stage III systems - stand-alone, complete systems that minimize storage tank vapor emissions.

If one considers passive back-end processors as components that must be certified as part of complete systems offered by competitors, the costs of certification and time requirements can be estimated as follows:

• Number of Phase II certifications listed on CARB’s EVR Internet site: 64
• CARB’s estimated cost for Phase II certification: $340,000
• Minimum time to earn certification: 12 months

A company wishing to have a processor-based system certified with all existing systems would have to incur costs of about $22 million and devote at least 128 staff-years to obtaining certification. We hope that reasonable requirements will be implemented to avoid excessive costs and other problems with the existing certification protocol. In addition to the costs, the certification protocol will cause the following problems.

• Environmental and economic benefits that can be generated by novel technologies will be delayed significantly.
• Other countries will lead the United States in implementing technologies that reduce health risks for the general population.
• Existing certification holders may have monopoly power and free trade will be restrained.
• Human health risks from poor air quality will remain unduly high if product improvements are restricted.
• Excessive re-certifications of a large number of systems will put a drain on staff time and resources and create a large backlog.

In conclusion, I think it will be just a matter of time until CARB concludes that evaporative emissions from uncontrolled stations are significant in magnitude and also must be controlled. Petroleum marketers who want to stay ahead of the game and operate cleaner facilities will seek a solution that meets both the short-term and the anticipated long-term CARB requirements.

The optimum solution should be economical, flexible, maintenance free and safe. Also, CARB can make the certification process less cumbersome and time-consuming, as well as more equitable, by not requiring back-end or processor systems to be certified as integral parts of front-end refueling vapor recovery systems.