California Environmental Protection Agency
AIR RESOURCES BOARD

Notice of Public Availability of Modified Text

PUBLIC HEARING TO CONSIDER THE ADOPTION AND AMENDMENT OF VAPOR RECOVERY SYSTEM CERTIFICATION AND TEST PROCEDURES

Public Hearing Date: October 25, 2001
Public Availability Date: March 22, 2002
Deadline for Public Comment: April 22, 2002


At its October 25, 2001, public hearing, the Air Resources Board (the "Board" or "ARB") approved the amendment of sections 94010, 94011, 94153, 94155 and 94163 of title 17, California Code of Regulations (CCR), which incorporate by reference the following vapor recovery certification and test procedures:

D-200 Definitions for Vapor Recovery Procedures, as last amended
February 1, 2001

CP-201 Certification Procedure for Vapor Recovery Systems at Gasoline Dispensing Facilities, as last amended July 25, 2001

TP-201.1D Pressure Integrity of Drop Tube Overfill Protection Devices, as adopted February 1, 2001

TP-201.4 Dynamic Back Pressure, as last amended April 28, 2000

TP-201.6C Compliance Determination of Liquid Removal Rate as proposed for adoption September 7, 2001

The Board also approved the adoption of sections 94164 and 94165, title 17, CCR, which incorporate by reference the following new vapor recovery test procedures:

TP-201.1B Static Torque of Rotatable Phase I Adaptors, as proposed for adoption September 7, 2001

TP-201.1C Pressure Integrity of Drop Tube/Drain Valve Assembly, as proposed for adoption September 7, 2001

At the hearing the Board approved modifications to the regulations originally proposed in the Staff Report released on September 7, 2001, in response to continuing staff review and public comments received since the Staff Report was published. The modifications affect the text of title 17, CCR, section 94153 and certification and test procedures D-200, CP-201, TP-201.1B, and TP-201.1C. The following is a brief description of the modifications:



Modifications to D-200: Definitions for Vapor Recovery Procedures

As originally noticed, D-200 defines the term "major modification" as the addition, replacement, or removal of an underground storage tank, underground piping, vapor piping within a dispenser, or a dispenser at an existing installation. The replacement of a dispenser is not a major modification when the replacement is occasioned by end user damage to a dispenser. As modified, D-200 clarifies the term "major modification" to differentiate between the modifications that cause the Phase I system to have the same status as a new installation and which modifications cause the Phase II system to have the same status as a new installation. See attachment 1.

As originally noticed, the term "overfill protection device" is used to define a device used to stop the delivery of product to a storage tank to prevent over-filling and potential spillage. As modified, the term "overfill prevention device" has replaced the term "overfill protection device" while the definition remains unchanged. This amended term provides a more accurate description of the component and is consistent with the term referenced in Underground Tank Regulations (enforced by the State Water Resources Control Board) used to describe the same device. See attachment 1.

Modifications to CP-201: Certification Procedure for Vapor Recovery Systems

As originally noticed, the term "overfill protection device" is used in table 3-1 and section 3.3 of CP-201 to describe the device used to prevent the overfilling of an underground storage tank. As modified, the term "overfill prevention device" has replaced the term "overfill protection device." This amended term provides a more accurate description of the component and is consistent with the term used by the State Water Resources Control Board in the underground storage tank (UST) regulations (title 23, CCR, section 2635). See attachment 2.

As originally noticed, the term "containment box" is used in table 3-1 and section 3.6 of CP-201 to describe the five-gallon, bucket shaped, spill containers which surround the underground storage tank product and vapor adaptors. As modified, the term "spill container" has replaced the term "containment box." This amended term provides a more accurate description of the component and is consistent with the term used by the State Water Resources Control Board in water quality regulations (title 23, CCR, section 2635). See attachment 2.

As originally noticed, table 16-1 of CP-201 identifies four components associated with Phase II vapor recovery systems as "system-specific." The table does not identify any Phase I System components as "system-specific." By contrast, table 16-2 identifies several Phase I vapor recovery components as non-system-specific. Testifying on behalf of the California Air Pollution Control Officers Association (CAPCOA), testimony at the hearing identified the need to establish "system-specific" components for Phase I systems. Without the "system-specific" designation, critical Phase 1 components may be installed with incompatible components. Table 16-1 has been modified to include Phase I vapor recovery components identified as system specific because they are critical to the compatibility of system components: product and vapor adaptors, spill- container valves and configurations, and drop tube overfill prevention devices. The same Phase I system components have been removed from the modified table 16-2 listing of non-system-specific components. See attachment 2.

As originally noticed, section 4.8.3 was proposed to clarify the certification requirement for liquid retention testing by specifying not less than 10 refueling operations and four fill-ups (excluding top-off). Section 6.5.4 of TP-201.2E, Gasoline Liquid Retention in Nozzle and Hoses requires 10 tests (refuelings) for each nozzle. As modified, section 4.8.3 has been amended to be consistent with TP-201.2E by specifying not less than 10 refueling operations per nozzle.

Modifications to TP-201.1B: Static Torque of Rotatable Phase I Adaptors Test Procedure

As originally noticed, the cover page of TP-201.1B indicates that the procedure is a compliance test procedure. As the test procedure will be used in both certification and compliance testing, the modified cover page corrects the title as shown in Attachment 4.

As originally noticed Section 5.1.1 of TP-201.1B states the minimum accuracy of the torque wrench shall be 1.00 percent of full-scale range. As modified, the minimum accuracy has been changed to 3.00 percent. This change is necessary to accommodate the varying degree of accuracy of torque wrenches commonly used in the field. See attachment 4.

As originally noticed, TP-201.1B failed to specify the minimum readability of the torque wrench. As modified, section 5.1.2 has been added stating that the minimum readability of the torque wrench shall be 5.00 pound-inch increments. See attachment 4.

As originally noticed, section 5.4 of TP-201.1B describes a socket extension as a piece of equipment needed to conduct the torque test. As modified, section 5.4 has been renumbered to 5.3 and modified to include the socket wrench and extension as the tools to be used to verify the rotation of the adaptor. Other sections have also been renumbered. See attachment 4.

As originally noticed, the proposed TP-201.1B is used to certify product and vapor adaptors to, and determine compliance with, the static torque specification of 108 pound-inches and to verify that adaptors rotate 360 degrees. The proposed TP-201.1B inadvertently did not specify the procedure for determining rotation and did not specify the order of conducting the rotation and static torque tests. Section 7.3 has been added to include a procedure for verifying rotation. Section 7.5 has been added to instruct on taking and recording the torque measurement valves. See attachment 4.

As originally noticed, the data sheet (Form 1) of TP-201.1B did not provide a means to indicate if the adapter passed the 360 degree rotation test. As modified, a 360-degree rotation field has been added to the data sheet (Form 1). See attachment 4.


Modifications to TP-201.1C: Pressure Integrity of Drop Tube/Drain Valve Assembly

As originally noticed, the cover page of TP-201.1C indicates that the procedure is a compliance test procedure. As the test procedure will be used in both certification and compliance testing, the modified cover page corrects the title as shown in Attachment 3.

As originally noticed, section 7 of TP-201.1C states that if the pressure does not reach 2.00 inches of water column within 90 seconds, the drop tube/drain valve assembly does not comply with the maximum allowable leak rate. In conducting the test procedure, staff found that it might take as long as 165 seconds to reach the 2.00 inches of water column. Therefore, the time to reach 2.00 inches of water column is modified from 90 seconds to 180 seconds. See attachment 3.

Modifications to Title 17 of California Code of Regulations

Section 94153 implies that Test Procedure (TP)-201.4 (Dynamic Back Pressure) is applicable solely to aboveground tanks. Since the test procedure is used for both aboveground and underground tanks, section 94153 is modified delete the implied limitation of the applicability of the test procedure. See attachment 5.

Board Resolution 01-48 sets forth the Board's action approving title 17, CCR, sections 94010, 94011, 94153, 94155, 94163, 94164, and 94165, and approving the amendment and adoption of the incorporated certification and test procedures for vapor recovery systems, D-200, CP-201, TP-201.1B, TP-201.1C, TP-201.1D, TP-201.4, TP-201.6C, as modified. The Resolution and the modified text of the regulations and incorporated test methods are available on the Board's Web site at http://www.arb.ca.gov/vapor.htm or http://www.arb.ca.gov/regact/vrmth01/vrmth01.htm. Copies of these documents can also be obtained by contacting Mr. George Lew at (916) 327-0900.

In accordance with section 11346.8 of the Government Code, the Board directed the Executive Officer to adopt sections 94010, 94011, 94153, 94155, 94163, 94164, and 94165, title 17, CCR, and the incorporated certification and test procedures for vapor recovery systems, D-200, CP-201, TP-201.1B, TP-201.1C, TP-201.1D, TP-201.4, and TP-201.6C, as modified, after making them available to the public for comment for a period of at least 15 days. The Board further provided that the Executive Officer shall consider such written comments as may be submitted during this period, shall make such modifications as may be appropriate in light of the comments received, and shall present the regulations to the Board for further consideration if warranted.







Written comments on the modifications must be submitted by postal mail, electronic mail, or facsimile as follows:

Postal mail must be sent to:

Clerk of the Board
Air Resources Board
P.O. Box 2815
Sacramento, California 95812


Electronic mail is to be sent to: mailto:vrmth01@listserv.arb.ca.gov
Facsimile submissions are to be transmitted to: (916) 322-3928.

In order to be considered by the Executive Officer, comments must be directed to the ARB in one of the three forms described above and received by the ARB by 5:00 p.m. on the last day for supplemental comment listed at the beginning of this notice. Only comments relating to the additional modifications to the text of the regulations will be considered by the Executive Officer.

If you are a person with a disability and desire to obtain this document in an alternative format, please contact the Air Resources Board ADA coordinator at (916) 323-4916.

Persons with hearing or speech impairments can contact us by using our Telephone Device for the Deaf (TDD) at (916) 324-9531 or (800) 700-8326 for TDD calls from outside the Sacramento area.


Attachments:
Excerpts from D-200
Excerpts from CP-201
Excerpts from TP-201.1B
Excerpts from TP-201.1C
Title 17, CCR, section 94153


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