Vapor Recovery Program - Frequently Asked Questions (FAQs) For Aboveground Storage Tanks (ASTs)

1.0 Standing Loss Control (SLC) EVR Requirements 

1.1  What is an Aboveground Gasoline Storage Tank or AST?

Answer: An AST is a gasoline storage tank that is intended for fixed installations, without backfill, that is located above or below grade.  ASTs are commonly classified as either “single-wall” or “protected”.  Single-wall ASTs are constructed with a primary (single) wall typically made of steel.  Protected ASTs are constructed with a primary (inner) tank encased by a secondary (outer) tank, with a layer of insulating material (at least three inches thick) between the primary and secondary walls.  The insulating material is usually lightweight concrete or a similar material.

1.2  Which ASTs are subject to standing loss control?

Answer: Your local Air Pollution Control District (district) will determine which ASTs are subject to vapor recovery requirements such as standing loss control.  Check with your local district to find out if your AST is affected.  Note that ASTs storing diesel or jet fuel are not required to have vapor recovery systems.

1.3  When is the standing loss control compliance date for new installations?

Answer: As of April 1, 2009, all new installations of ASTs are subject to standing loss control if vapor recovery control is required by district rule.  In order to meet standing loss control, new installations must choose one of the protected ASTs listed in ARB Executive Order VR-302, along with an ARB EVR-certified pressure vacuum vent valve (P/V valve).

1.4  Are gasoline bulk plants and terminals required to comply with standing loss control requirements?

Answer: No, standing loss control does not apply to bulk plants and terminals.  Bulk plants are intermediate gasoline distribution facilities that receive and deliver gasoline via cargo tanks.  Terminals are the primary distribution facilities for the loading of cargo trucks that deliver gasoline to bulk plants, service stations, and other distribution points.  ARB certifies bulk plants under CP-202, Certification for Vapor Recovery Systems of Bulk Plants, and terminals under CP-203, Certification of Vapor Recovery Systems of Terminals. The bulk plant and terminal certification testing determine whether the transfer efficiencies to and from the cargo tank meet applicable performance standards and specifications.

1.5  If a bulk plant facility with an AST is also equipped with remote dispensers used to refuel motor vehicles, would that AST need to comply with SLC?

Answer: No, standing loss control does not apply to bulk plants, even those that are equipped to distribute fuel into cargo tanks and transfer fuel into motor vehicles.

1.6  What standing loss control systems are certified for new installations?

Answer: As of January 2013, there are five protected AST manufacturers (ConVault, SuperVault MH Series, Fireguard, CSI Hoover Vault, and Jensen PreCast Armor Cast) certified for new installations as specified in Executive Order (EO) VR-302.  Each of these ASTs must be equipped with an ARB EVR-certified P/V valve.  In 2013, ARB staff expects to amend this Executive Order to include one additional AST manufacturer and one additional P/V valve manufacturer.  Single-wall ASTs cannot be installed for cases that qualify as a new installation.

As of April 1, 2009, all new installations of ASTs are subject to standing loss control if vapor recovery control is required by district rule.  For standing loss control, a replacement of an existing AST with an AST of equal capacity (volume) is not considered a new installation.  In order to meet standing loss control, new installations must choose one of the protected ASTs listed in ARB Executive Order VR-302 along with an ARB EVR-certified P/V valve.

1.7  When is the standing loss control compliance date for existing installations?

Answer: All existing ASTs subject to standing loss control must comply by April 1, 2013, by installing one of the standing loss control systems listed in Executive Order (EO) VR-301.  For standing loss control purposes, the replacement of an existing AST with an AST of equal capacity (volume) that is equipped with a standing loss control certified system is not considered a new installation.  In such a case, the replacement AST, which is considered as an existing AST, will have to comply with standing loss control requirements by April 1, 2013.

1.8  What standing loss control systems are certified for existing installations?

Answer: For existing AST, there are two ways to comply with SLC: apply a reflective coating and install an ARB EVR-certified P/V valve, or if you happen to have an ARB certified make and model protected AST, simply install an ARB EVR-certified P/V valve.

As of January 2013, EO VR‑301 lists five protected ASTs that are not required to apply one of the certified coatings, if the existing OEM paint is in good condition.  These protected ASTs are manufactured by: ConVault, SuperVault MH series, Fireguard, Hoover Vault, and Jensen Precast Armor Vault.  Your AST must be of the same model and make listed in VR-301.  These ASTs also need to be equipped with an ARB EVR-certified P/V valve.

For existing single wall ASTs, application of one of the coatings listed in EO VR-301 and the installation of an ARB EVR-certified P/V valve will satisfy the standing loss control requirement.  Table 1 lists the coating systems that are certified as of January 2013. 

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.    

Table 1:  Standing Loss Control Coating Systems Certified by ARB
(As of January 2013)

1.9  Can I apply any of the certified coatings listed in EO VR-301 throughout the state of California?

Answer: Your local air district may have specific rules that limit the volatile organic content of the coatings.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.10      What if my protected AST is not listed in EO VR-301?

Answer: If your existing AST’s make and model is not listed in EO VR-301, compliance with standing loss control can be achieved by the application of any coating system listed in EO VR-301 (see Table 1 above) and installing an ARB EVR-certified P/V valve.

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.11      What if I have an existing single-wall AST?

Answer: First, check with your local district to determine if your AST is exempt from Phase I vapor recovery requirements.  If the district determines that your AST is not exempt, then one of the paints listed in EO VR-301 series must be applied along with an ARB EVR-certified P/V valve. 

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.12      What if my existing protected AST listed in EO VR-301 needs to be repainted for aesthetic or maintenance reasons?

Answer: Except for gasoline dispensing facilities equipped with Jensen Precast “Armor Cast” AST, if an existing protected AST that is listed in EO VR-301 needs to be repainted for aesthetic, maintenance, or other reasons, the AST owner can choose between using a coating system listed in EO VR-301, or they can use the same coating system applied by the original equipment manufacturer (OEM) at the production facility.  If the latter option is selected, the AST owner is advised to contact the appropriate AST manufacturer to obtain current specifications of the OEM coating system. Due to the uniqueness of the OEM exterior finish applied to Jensen Precast “Armor Cast” AST, such owners are advised only to follow manufacturer’s specifications.  Additionally, existing Jensen Precast “Armor Cast AST with exposed aggregate finish should not be painted.

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.13      What are the maintenance requirements for SLC (e.g. how often does the AST need to be painted; what do you do if the AST has graffiti; if the paint starts to peel; etc.)?

Answer: Maintenance for SLC will be based on individual manufacturer Installation, Operation, and Maintenance Manuals (IOMs).  For protected ASTs, the manufacturers generally call out periodic (weekly or monthly) inspections of the surface of the AST for cracks, chips, corrosion, etc.

The protected AST manufacturers do not have a timeframe for repainting, so sound judgment should be used.  If there are portion(s) of the AST covered in graffiti, have cracks, where rust is coming through the paint, or the paint is peeling, then the standing loss control may no longer be effective and the AST should be repaired and repainted.  Similarly, existing single-wall ASTs that have damage to their coatings need to be repainted.

Except for gasoline dispensing facilities equipped with Jensen Precast “Armor Cast” AST, if an existing protected AST that is listed in EO VR-301 needs to be repainted for aesthetic, maintenance, or other reasons, the AST owner can choose between using a coating system listed in EO VR-301, or they can use the same coating system applied by the original equipment manufacturer (OEM) at the production facility.  If the latter option is selected, the AST owner is advised to contact the appropriate AST manufacturer to obtain current specifications of the OEM coating system. Due to the uniqueness of the OEM exterior finish applied to Jensen Precast “Armor Cast” AST, such owners are advised only to follow manufacturer’s specifications.  Additionally, existing Jensen Precast “Armor Cast AST with exposed aggregate finish should not be painted.

If an existing single-wall AST needs to be repainted, then the AST owner must apply one of the certified coating systems listed in EO VR-301.

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.14      Am I required to paint the bottom of a rectangular protected AST which is not manufactured by the one of the companies listed in EO VR-301?

Answer: No, it is not necessary to paint the bottom of protected rectangular AST.

1.15      Am I required to paint over the manufacturer’s and UL placards?

Answer: No, it is not necessary to paint the placards.

1.16      Is spot (partial) painting of the AST allowed?

Answer: No, except for the bottom of rectangular ASTs and labels, all exposed surfaces of the AST must be repainted if applying an EO VR-301 coating for the first time.  If an AST has already been painted with one of the coatings listed in EO VR-301, and small blemishes have occurred, then touch-ups are acceptable. 

1.17      Do the various tank top components and pipe fittings need to be painted in order to comply with SLC?

Answer: No, the various tank top components and pipe fittings do not need to be painted with an EO VR-301 coating, just the AST.  If an owner/operator decides to paint these fittings, then the paint must not impede the functionality of any tank top components.

1.18      If an existing protected AST shows chalking, cracks, rust, exposed concrete, etc., does it need to be repainted?

Answer: Yes, however damage that has occurred to more than just the original paint coating, then the AST needs to be repaired according to manufacturer instructions.  Once chalking, cracks, rust, etc. have been addressed, then it will need to be repainted with either one of the certified coating systems listed in EO VR-301, or the AST owner can contact the AST manufacturer to obtain current specifications for the coating system applied at the production facility prior to installation in the field.

Note: Due to the uniqueness of the OEM exterior finish applied to Jensen Precast “Armor Cast” AST, such owners are advised not to apply one of the certified coating systems listed in EO VR-301.  Instead, they will need to follow manufacturer’s specifications.  Additionally, existing Jensen Precast “Armor Cast AST with exposed aggregate finish should not be painted.

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.19      What must be done if the UL and manufacturer’s labels are missing from the existing protected AST?

Answer: If an existing protected AST is missing its identifying UL and manufacturer labels, an effort should be made to identify the AST via owner/operator records.  If the AST cannot be confidently identified as one of the certified ASTs, then it will need to be repainted with one of the certified coating systems listed in EO VR-301 and an effort made to secure new labels.

1.20      Do below-grade vaulted ASTs need to meet SLC requirements?

Answer: No.  SLC does not apply to below‑grade vaulted ASTs because such ASTs are subject to different performance standards and specifications.  A below‑grade vaulted AST is an AST that is below the level of earth surface contained in an enclosure, without backfill, and requires continuous ventilation.

1.21      If an existing AST is fully enclosed within a structure, does the AST need to be painted for SLC?

Answer: Currently, an existing AST fully enclosed within a structure would need to comply with SLC requirements.  ARB lacks certification data regarding the emission factor standards of fully enclosed ASTs.  If an owner of an AST that is fully enclosed within a legal structure believes that such an AST can comply with standing loss control emission factor standards, the owner can submit a request a site specific certification.  The AST owner would need to notify their local district of their request and the structure would need to meet all applicable local and state requirements. 

A request for a site specific certification should be sent in writing to ARB at the following address:

Chief of the Engineering and Certification Branch
California Air Resources Board
P. O. Box 2815
Sacramento, California 95812-2815

1.22      Do protected ASTs listed in VR-301 have to be a certain color?

Answer: The protected ASTs listed in EO VR-301 have to be the original color when shipped from the manufacturer.  In many cases this will be white.  In the case of the Hoover Vault and Supervault, some ASTs may be a tan color.  In the case of Jensen Precast “Armor Cast” some existing AST may have an exposed aggregate exterior.

Except for gasoline dispensing facilities equipped with Jensen Precast “Armor Cast” AST, if an existing protected AST that is listed in EO VR-301 needs to be repainted for aesthetic, maintenance, or other reasons, the AST owner can choose between using a coating system listed in EO VR-301, or they can use the same coating system applied by the original equipment manufacturer (OEM) at the production facility.  If the latter option is selected, the AST owner is advised to contact the appropriate AST manufacturer to obtain current specifications of the OEM coating system. Due to the uniqueness of the OEM exterior finish applied to Jensen Precast “Armor Cast” AST, such owners are advised only to follow manufacturer’s specifications.  Additionally, existing Jensen Precast “Armor Cast” AST with exposed aggregate finish should not be painted.

Table 2:  OEM Coating Color of Protected ASTs

1.23      If an existing protected AST is painted a color other than what is shown in Exhibit 1 of EO VR-301, are they required to repaint the AST?

Answer: Yes, an existing protected AST that is painted any color other than the original color from the manufacturer (OEM) as shown in Exhibit 1, would be required to be repainted with either an ARB certified coating system from EO VR-301, or the AST owner can contact the AST manufacturer to obtain current specifications for the coating system applied at the production facility.  Note: existing Jensen Precast “Armor Cast” AST with exposed aggregate finish should not be painted.

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.24      If an AST is in a shaded area, or has a shade structure covering it, does it still need to be painted for SLC?

Answer: Yes, this AST would still need to comply with standing loss control requirements.  The regulations allow ARB to evaluate SLC configurations that include shade structures; as of January 2013, no manufacturers have submitted an application for a shade structure.  At this time, ARB has not issued an Executive Order which allows a shade structure as an option to meet SLC emission factor standards.

1.25      Can decals (e.g. safety reflectors, no smoking signs, flammable signs, etc.) be added to the AST after it is painted?

Answer: Yes.  Required safety decals should be added back to the AST once it is painted.

1.26      If a protected AST is of a manufacturer listed in Executive Orders VR-301 or VR-302, but does not have a model number or serial number that is listed in either Executive Order, does that AST need to be repainted with a certified coating system?

Answer: Yes, if the protected AST is not listed by manufacturer, model number, and serial number in either EO VR-301 or EO VR-302, then it is not a certified AST and must be repainted with an approved coating system listed in EO VR-301.  However, AST owners can contact the AST manufacturer to determine if unlisted model numbers are compliant with SLC.  If yes, it will be the responsibility of the manufacturer to notify ARB.  Only after ARB lists the name of the ARB and model number or serial number in writing is the ARB exempt from SLC painting.

1.27      In some districts, a permit may not be required for a gasoline AST at a non-retail site that is under 550-gallons.  Would this AST need to comply with the SLC requirement?

Answer: The requirements to install vapor recovery controls at gasoline dispensing facilities vary by district.  It is possible that an AST is not subject to permits but may be required to comply with SLC in accordance with district rules.  Thus, it is very important to check with your local district since regulations may vary.   

1.28      Is there a size limitation or facility type where SLC does not apply (i.e. gasoline storage, bulk dispensing at refineries (wholesale bulk), and airports (retail bulk or in-house usage))?

Answer: SLC does not apply to bulk plants and terminals, however, other than those circumstances, the size of an AST at which SLC is applicable will be determined by district rules.  In some cases there is a lower limit on the AST size at which a district will require vapor recovery control systems.

1.29      Are gasoline dispensing facilities equipped with ASTs located in “attainment areas” for the state standard for Ozone exempted from SLC requirements?

Answer: Existing ASTs in State Ozone Attainment areas are not required to comply with SLC, but these ASTs must keep their pre-EVR Phase I and Phase II equipment.  Any new AST install after April 1, 2009, regardless of whether it is in an attainment area or not, must comply with SLC requirements.  See responses to questions 3.3 and 3.4 for Phase II requirements for new AST installations.

1.30      Do the SLC requirements apply to ASTs used at marina operations?

Answer: Yes, if subject to district vapor recovery requirements.

1.31      What does the Husky P/V Vent Valve “remove after” date mean and does the ARB require enforcement of this date?

Answer: The “remove after” date is a recommendation from Husky.  This date is not an ARB requirement and is not referenced in the applicable Executive Order.  If the P/V valve passes all applicable performance tests then that valve can remain installed regardless of the “remove after” date.

1.32      Do the SLC requirements apply to ASTs containing aviation gasoline?

Answer: No.  ARB EVR requirements, including SLC, do not apply to aviation gasoline.  The fact that it is not subject to ARB vapor recovery regulations does not necessary mean that it is exempt from control.  Districts are allowed by state law to impose controls that are more stringent than ARB.  Therefore, all owners of AST storing and dispensing aviation gasoline should contact the appropriate district. 

1.33      If an existing protected AST, such as the ConVault, has experienced severe damage (i.e. major cracks and pieces missing from the concrete insulation) can the AST be repaired?

Answer: The AST operator will need to contact the district, the OEM, the applicable state and local agencies for further instruction on approved repair practices.  If the AST is missing part of its exterior, it is no longer in the condition it was certified under and the AST may need to be replaced with one that can meet the Executive Order.

1.34      Does the SLC compliance deadline require a full upgrade of the pre-EVR Phase I system on April 1, 2013?

Answer: No.  In regards to compliance deadlines, SLC is a separate module of the EVR requirements for ASTs.  There is no requirement to upgrade to Phase I EVR when upgrading to SLC.  The compliance deadline for EVR Phase I on existing ASTs is not until July 1, 2014.  Thus, the decision to upgrade SLC and Phase I at the same time is up to AST owners.

Section 2: Phase I EVR Requirements:

2.1  Who is subject to Phase I EVR?

Answer: Air district rules determine which ASTs are subject to Phase I vapor recovery requirements.  Check with your air district to find out if your AST is affected.  Note that ASTs storing diesel or jet fuel are not required to have enhanced vapor recovery systems.

2.2  What are the Phase I EVR requirements on or after July 1, 2010?

Answer: As of July 1, 2010, new AST installations must install Phase I equipment that complies with the new EVR performance standards and specifications.  Existing installations that choose to replace their AST on or after July 1, 2010, are considered new installations.

2.3  What are the Phase I EVR requirements on or after July 1, 2014?

Answer: All existing installations will be required to install Phase I EVR equipment for AST by July 1, 2014.  Again, check with your local air district to determine if you are subject to these requirements.  There may be exemptions based on AST capacity or volume.

2.4  What Phase I EVR systems are currently certified?

Answer: As of January 2013, two systems are certified.  OPW has a Phase I system certified under EO VR-401-B.  Morrison Brothers has a Phase I system certified under EO VR‑402‑A.  New EOs detailing additional certified Phase I systems will be released in the future. 

2.5  What if my existing AST does not have enough ports/bungs/openings to accommodate the Phase I EVR System?

Answer: The currently certified Phase I EVR systems require a number of ports/bungs/openings to accommodate various components which comprise the system.   As indicated in Exhibit 2 of each Phase I EVR AST Executive Order, a dedicated opening must be provided for an appropriately sized emergency vent, product adaptor with submerged drop tube, vapor adaptor, pressure/vacuum vent valve, and dedicated gauging port.   ARB staff recognizes that many existing ASTs may not have an available dedicated port for each component.   There are also ASTs that do not have the correct size ports for each component.  In some cases for ASTs with limited number of openings, pipe fittings can be used to accommodate more than one component on a single port.  

ARB staff has worked collaboratively with the local districts and Phase I equipment manufactures to identify alternate installation configurations which utilize various pipe fittings to enable multiple components on ASTs with limited openings.   Figure 1, Figure 2, Figure 3,and Figure 4 provide examples of acceptable alternate installation configurations.

2.6  What should I be aware of prior to ordering a new AST?

Answer: New ASTs must be one of the ASTs listed in VR-302 and have sufficient openings to accommodate the components which comprise the Phase I EVR system.  These components include, but are not limited to, product adaptor, vapor adaptor, overfill prevention device, submerged drop tube, emergency vent, and dedicated gauging port.

At a minimum, you should contact your city, fire department, and the Certified Unified Program Agency (CUPA) to ensure that your plan meets their requirements.

2.7  In some districts, a permit may not be required for a gasoline AST at a non-retail site that is under 550-gallons.  Would this AST need to comply with the Phase I EVR requirement?

Answer: The requirements to install vapor recovery vary by district rules.  The fact that a permit is not required does not mean that ASTs are exempt from vapor recovery.  Thus, all AST owners should check with the district to determine the regulatory requirements. 

2.8  If an existing single-wall AST has only two openings and thus is not compatible with a Phase I EVR upgrade, yet the legal language of the EO says it must follow the requirements of other agencies, what can be done?

Answer: If there is no way through manifolding that an existing AST can be made compliant with ARB Phase I EVR requirements and the requirements of other agencies, then the AST owner should contact their local district.  If the district concurs in writing, a request for an exemption should be sent in writing to ARB at the following address:

Chief of the Engineering and Certification Branch
California Air Resources Board
P. O. Box 2815
Sacramento, California 95812-2815

The request should at a minimum indicate the reason for the incompatibility, location of AST, and district concurrence.  ARB will conduct an engineering evaluation, may request additional information, and may approve the request in writing if a compatible certified system is not commercially available.

2.9  If an existing AST already has an ATG tied into the Veeder-Root TLS 350, will a dedicated gauging port still be required?

Answer: In this instance, the AST could keep its ATG and Veeder-Root system and not install a dedicated gauging port.  Proposed language (under Office of Administrative Law review) for Section 4.8 of CP-206 states as follows:

“An AST shall include a dedicated gauging port for determining the amount of gasoline.  This determination shall be accomplished either manually (measuring gasoline levels using a gauging stick), mechanically, or electronically.  If the determination is accomplished manually, the port shall have a drop tube which has the discharge opening entirely submerged with the liquid level is six inches above the bottom of the tank.  The gauging port shall be permanently identified.  The gauging port shall not leak when no manual gauging is occurring or at any time when mechanical or electronic components are used.” 

Therefore a dedicated gauging port will still be mandatory, but that port no longer has to be for manual gauging only. 

At a minimum, you should contact your city, fire department, and the Certified Unified Program Agency (CUPA) to ensure that your plan meets their requirements.

Section 3: Phase II Requirements:

3.1  Who is subject to Phase II EVR?

Answer: Your local district will determine which ASTs are subject to Phase II EVR requirements.  Check with your local district to find out if your AST is affected.  Note that ASTs storing diesel or jet fuel are not required to have enhanced vapor recovery systems.

3.2  What Phase II systems are certified?

Answer: As of January 2013, there are no Phase II EVR systems certified by ARB.

3.3  What are the Phase II requirements for new and existing ASTs, if there is no Phase II EVR system certified?

Answer: Executive Order G-70-213-C issued on February 23, 2012, permits the continued installation and operation of pre-EVR certified Phase II systems until such time as when ARB certifies a Phase II system, with or without an In-Station Diagnostics (ISD) system, that complies with EVR performance standards and specifications. 

3.4  When will Phase II EVR apply to AST?

Answer: The effective date for Phase II EVR for AST is the date when ARB first certifies such a system.  New ASTs installed on or after the effective date must comply with Phase II EVR for AST.  Existing ASTs will have up to four years from the effective date to comply.

3.5  What are the requirements for a pre-EVR balance system?

Answer: Operators of Phase II pre-EVR balance systems are required to install EVR certified nozzles, breakaways, hoses, and swivels (collectively called hanging hardware) upon replacement.  ARB staff has determined that EVR certified balance hardware is compatible for pre-EVR balance systems.  Please refer to the following Approval Letters and Advisory 408 for more information. 

1.    Approval Letter 07-09 to Vapor System Technologies (VST) for VST hanging hardware

2.    Approval Letter 07-03 to Goodyear for Goodyear hoses

3.    Approval Letter 09-10 to Emco Wheaton Retail for EMCO hanging hardware

Advisory 408 explains the replacement part requirement in more detail and lists the Phase II EVR hanging hardware that are found to be compatible with Pre-EVR balance system.  Please note that the Phase I and Phase II AST compliance deadlines listed Advisory 408 are incorrect and are correctly listed in the FAQs.

Section 4: E85 Fueling Facilities Equipped with AST:

4.1  Does Executive Order VR-301 or VR-302 apply to storage and dispensing of E85?

Answer: No, SLC systems compatible with E85 (15% gasoline and 85% ethanol) fuels have not been evaluated at this time.

4.2  What if I want to dispense E85?

Answer: Since no vapor recovery systems have been approved for ASTs serving E85 dispensing facilities, operators who wish to dispense E85 will need to submit a letter requesting approval as a research and development test site.  The letter should include the address of the site and list of uncertified vapor recovery components that would be installed.  The letter should be sent to:

Chief of the Engineering and Certification Branch
            California Air Resources Board
            P. O. Box 2815
            Sacramento, California 95812-2815