| Comment | I would ask that an additional evaluation be conducted prior to
adopting procedures for Remote Fill Phase 1 System Configurations
specifically, test procedures TP-201.1C and TP-201.1D. The allotted
time-to-pressurize specified at five minutes in the testing
procedures, for offset piping lengths less than 50 feet, is
insufficient to meet the requirement to pass the test. Five minutes
may be enough to pressurize the length of a vertical drop tube
however, when the remote fill pipe lengths exceed that these
procedures do not accommodate for the additional volume in the fuel
delivery pathway. I would request that additional testing by Air
Resources Board, at gasoline dispensing facilities with remote
fills, be conducted to aid in the drafting of a table in the
amendment that accurately reflects actual time-to-pressurize in
offset fuel delivery pathways shorter than 50 feet.
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