| First Name | Burke |
|---|---|
| Last Name | Albelda |
| Email Address | bdalbelda@speedway.com |
| Affiliation | |
| Subject | Test Procedures for Remote Fill Phase I Systems |
| 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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| Original File Name | |
| Date and Time Comment Was Submitted | 2020-12-04 13:56:05 |
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