State of California
AIR RESOURCES BOARD


Notice of Public Availability of Modified Text


PUBLIC HEARING TO CONSIDER THE ENHANCED VAPOR RECOVERY TECHNOLOGY REVIEW AND AMENDMENTS TO THE VAPOR RECOVERY CERTIFICATION AND TEST PROCEDURES FOR GASOLINE MARKETING OPERATIONS AT SERVICE STATIONS

Public Hearing Date: December 12, 2002
Public Availability Date: May 9, 2003
Deadline for Public Comment: May 27, 2003


At its December 12, 2002, public hearing, the Air Resources Board (the "Board") approved the amendment of sections 94010, 94011, 94163, 94164, and 94165, title 17, California Code of Regulations (CCR), which incorporate by reference the following certification and test procedures for vapor recovery systems. The Board also approved the adoption of new sections 94166 and 94167, title 17, CCR, and the documents incorporated by reference therein.

The amended procedures are:

D-200 Definitions for Vapor Recovery Procedures

CP-201 Certification Procedure for Vapor Recovery Systems at Gasoline Dispensing Facilities

TP-201.1 Volumetric Efficiency for Phase I Systems

TP-201.1B Static Torque of Rotatable Phase I Adaptors

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

Revised Title: Leak Rate of Drop Tube/Drain Valve Assembly

TP-201.1D Pressure Integrity of Drop Tube Overfill Prevention Device

Revised Title: Leak Rate of Drop Tube Overfill Prevention Device and Spill Container Drain Valves

TP-201.2 Efficiency and Emission Factor for Phase II Systems

TP-201.2B Pressure Integrity of Vapor Recovery Equipment

Revised Title: Flow and Pressure Measurement of Vapor Recovery Equipment

TP-201.2D Post Fueling Drips from Nozzle Spouts

Revised Title: Post Fueling Drips from Nozzles

TP-201.2F Pressure Related Fugitive Emissions

The adopted procedures are:

TP-201.1E Leak Rate and Cracking Pressure of Pressure-Vacuum Relief Vent Valves

TP-201.2G Bend Radius Determination for Underground Storage Tank Vapor Return Piping

TP-201.2I Test Procedure for In-Station Diagnostic Systems

TP-201.2J Pressure Drop Bench Testing of Vapor Recovery Components

TP-201.7 Continuous Pressure Monitoring

At the hearing the staff presented, and the Board approved, modifications to the regulations originally proposed in the Staff Report released on October 25, 2002 in response to continuing review and comments received since the Staff Report was published. The modifications affect the text of certification and test procedures D-200, CP-201, TP-201.1C, TP-201.1D, TP-201.1E, TP-201.2D, and TP-201.2F.

Modifications to D-200

D-200 provides definitions and acronyms of vapor recovery terms used in the certification and test procedures.

The definition of "major modification" has been changed to clarify that Phase II upgrades to add ORVR compatibility or install under-dispenser containment are not considered "major modifications" and do not trigger Phase II EVR.

As originally noticed, "multi-product dispenser" was defined as a dispenser of multiple products with two or more hoses per dispenser side. As unihose dispensers can also be multi-product dispensers, this definition has been corrected to be a dispenser with one or more hoses per dispenser side.

As originally noticed, "unihose dispenser" dispenser was missing the word "one", as in "only one hose and nozzle per dispenser side". This definition has been corrected to include the word "one".

The acronym for "NPT" which means "national pipe threads" has been added as this acronym is used in the test procedures.

Modifications to CP-201

CP-201 is the certification procedure that contains the Phase I and Phase II standards and specifications and references the test procedures to be used during the certification of vapor recovery systems.

Section 1.1 has been modified to clarify the identification of the Office of the State Fire Marshall.

As originally noticed, section 2.4.4 provides an exemption for most EVR standards for existing facilities located in districts in attainment with state ozone standards. Section 2.4.4 has been revised to identify that ARB makes the determination of whether the district meets the ozone standard and clarify that the exemption is available to such identified districts. Additional language provides that exempted facilities in districts that are reclassified from attainment to non-attainment will have four years to comply with EVR requirements.

Table 2-1 provides the operative and effective dates for the vapor recovery requirements. Table 2-1 has been modified to reflect the change in effective and operative dates for ISD and Phase II standards and specifications from April 1, 2003 to October 1, 2003. This is necessary to allow sufficient time to certify EVR Phase II systems. The nozzle criteria requirement has been changed to conform the Table with the amendment of the post-refueling drops ("dripless nozzle") standard from 1 to 3 drops. Table 2-1 has been revised to change the ISD exemption throughput from 160,000 to 600,000 gallons/year to include service stations in the GDF2 category as requested by districts. The appropriateness of the GDF2 exemption level will be addressed in the ISD implementation review to be completed within 18 months after certification of the first ISD system as directed by the Board in Resolution 02-35. The unihose requirement has been added to Table 2-1 as the operative and effective date for the unihose specification are now different from other Phase II standards and specifications.

Table 4-1 provides a summary of the Phase II performance standards and specifications applicable to all Phase II system types. Column three for the ORVR compatibility standard has been corrected to reference "4.4," rather than "4.1."

Section 4.1.1 describes the determination of the Phase II emission factor and efficiency. As originally noticed, the last sentence of section 4.1.1 provides that the efficiency is only calculated for vehicles identified as "non-ORVR". This sentence was not marked as an amendment in the October 25, 2002 version, although the change was discussed on page 17 of the ISOR. The sentence is now identified as an amendment.

Section 4.4 describes the ORVR compatibility standard requirements. As originally noticed, section 4.4.1 required that refueling of ORVR vehicles shall not cause the system to exceed the Phase II emission factor and/or efficiency. This is incorrect as exceeding the efficiency standard is acceptable. The language has been revised to require that ORVR fuelings shall not cause the system to exceed the Phase II emission factor and/or reduce the efficiency.

Section 4.11 discusses the unihose configuration requirement. As originally noticed, the unihose requirement does not apply to "facilities installed prior to the effective date of this procedure." This is confusing as CP-201 is updated regularly and it is not clear which effective date is intended. Section 4.11 has been revised to conform with section 19.1.5 to state that the unihose exemption can be claimed by facilities installed prior to April 1, 2003.

As originally noticed, Section 8 described Phase II performance standards and specifications for assist systems using processors. As processors may be used on both assist and balance systems, the references to "assist" have been removed from section 8.

Section 10 describes the requirements for in-station diagnostics systems. Section 10.1.1 has been revised to conform with the ISD exemption throughput change to 600,000 gallons per year in Table 2-1.

Section 10.1.8 discusses the requirements for the ISD electronic archive. The requirements have been revised to require storage of monthly reports for a period of 12 months and daily reports for the last rolling 365 days.

Section 10.1.11 provides for limited repairs during the certification operational test if the failure was detected by the ISD system and is included in the system maintenance manual. The word "maintenance" has been substituted for "failure" to better represent allowed equipment repairs.

Section 10.2.1 describes the ISD Air/Liquid (A/L) ratio monitoring requirements. The word "ratio" has been substituted for "range" to clarify the correct A/L value to be used.

Section 10.2.4(d) provides the ISD malfunction criteria for pressure integrity. Section 10.2.4(d) has been revised to clarify that the requirement is a minimum value and to provide a reference to the leak rate standard in section 4.2.

Section 10.2.5 adds requirements for Phase I vapor transfer monitoring which were mistakenly proposed for deletion in the original staff proposal.

Section 10.3 has been revised to clarify the required information for the ISD reports.

Sections 10.8 and 10.9 have been merged into section 10.8 and renamed "Electronic Access." Duplicative language on ISD report requirements has been deleted.

Section 19.1.5 has been corrected by replacing "reminder of useful life" with "remainder of useful life."

Section 19.2 allows installation of systems with terminated certifications if systems meeting the operative standards are not commercially available. Modifications have been made to section 19.2 to clarify requirements for systems that may be installed under these circumstances.

Modifications to TP-201.1C

TP-201.1C measures the leak rate of the Phase I drop tube/drain valve assembly. This procedure is used both for certification and compliance testing. As originally noticed, the proposed changes to TP-201.1C were focused on the use of the procedure for compliance purposes and deleted some aspects of the procedure necessary for certification use. The suggested modifications described below include changes to make TP-201.1C appropriate for use as both a certification and compliance procedure.

The term "pressure measuring device" has been replaced with the more common "pressure gauge" throughout the test procedure.

Section 1 discusses the purpose and applicability of the test procedure. Modifications have been made to section 1 to clarify the equipment tested and delete references that the procedure can verify the zero leak limit of drop tube seals and threaded components.

Section 2 provides the principle and summary of the test procedure. This section has been rewritten for clarity.

Figure 1 has been modified to show the placement of the bladder in the drop tube.

Section 3 provides information on biases and interferences. Section 3.1 notes that Phase I component leaks could contribute to the total leak rate measured. As originally noticed, section 3.1 suggested testing the Phase I components for leaks before conducting the test. Section 3.1 has been revised to suggest checking the Phase I components only in the event of a test failure. As originally noticed, renumbered section 3.2 included a low product level which failed to completely submerge the drop tube as a bias. This section has been deleted, as the bladder used in the drop tube eliminates this bias. The revisions to the renumbered section originally noticed as section 3.3 have been changed to return to the original adopted language regarding leak checks of the test equipment.

Section 4 discusses the sensitivity, range and precision of the test procedure. Section 4.1 has been revised to provide specific requirements for the flowmeter necessary to meet the required precision. Similarly, section 4.2 has been modified to more completely describe the required pressure gauge.

Section 5 provides a listing of the equipment needed to conduct the test. The originally noticed section 5.1 has been deleted and replaced with new sections 5.2 and 5.7. Sections 5.2 and 5.3 has been renumbered to sections 5.1 and 5.2 respectively, and revised to conform to section 4. The word "inert" has been removed from the description of nitrogen in renumbered section 5.3 as unnecessary. The accuracy of the stopwatch in renumbered section 5.4 has been changed from 0.2 to 0.10 seconds. Section 5.7 regarding traffic cones and caution tape has been removed as not necessary for conducting the test procedure. Section 5.8 regarding use of the tank gauging stick has been deleted as the product level is not pertinent to this test. New sections 5.6 and 5.7 provide requirements for the inflatable bladder and product adaptor test cap.

Section 6 describes the pre-test procedures. The calibration requirements for the pressure gauge have been added to section 6.1 and section 6.2 has been deleted. Section 6.3 regarding traffic cones and caution tape has been removed as not necessary for conducting the test procedure. Renumbered section 6.2 has been modified to clarify the inspection of the drain valve configuration. The original section 6.5 has been deleted as verification of product level is not necessary for this test. A new section 6.3 has been added to direct the tester to inspect the Phase I product adaptor before conducting the test.

Figure 3 has been added to illustrate the product adaptor test cap.

Section 7 discusses the test procedure. The changes to this section are rearrangement and clarification of the steps to conduct the test. The originally noticed sections 7.1 through 7.4 have been clarified in new sections 7.1 through 7.5. These new sections have eliminated the reference to 2.00 inches H2O and instead reference the pressure specified in CP-201.

Section 8 provides the post-test procedures. The originally noticed sections 8.1 through 8.3 have been clarified in new sections 8.1 and 8.2.

Section 9 describes the calculation of the test results. Section 9.1 has been revised to conform the calculations to the pressure specified in CP-201, rather than 2.00 inches H2O. New section 9.2 provides common flow rate conversions.

Modifications to TP-201.1D

TP-201.1D measures the leak rate of drop tube overfill prevention devices (OPDs) and spill container drain valves. The title of TP-201.1D has been revised to clarify that both OPD and drain valve leak rates are determined by this test procedure.

The term "pressure measuring device" has been replaced with the more common "pressure gauge" throughout the test procedure.

Section 1 sets forth the purpose and applicability of the test procedure. Section 1 has been modified to clearly identify which drain valves may be tested using this procedure. Other revisions have been made to simplify the applicability of the procedure to show compliance with the specifications in the certification procedure.

Section 2 describes the principle and summary of the test procedure. As originally noticed, TP-201.1D assumed a steady-state pressure of 2 inches H2O for all components tested. Section 2 has been revised to reference the specifications in CP-201, rather than a specific pressure. The reference to a "plumber's bladder" has been modified to allow other types of bladder devices. Section 2.2 has been deleted and similar language has been added to the end of Section 2 to clarify that the leak rate of the drain valve must be determined in order to quantify the leak rate of the OPD.

Section 3 provides information on biases and interferences. Section 3.1 notes that Phase I component leaks could contribute to the total leak rate measured. As originally noticed, section 3.1 suggested testing the Phase I components for leaks before conducting the test. Section 3.1 has been revised to suggest checking the Phase I components only in the event of a test failure. As originally noticed, section 3.4 stated that positive pressures in the storage tank headspace could provided a bias toward compliance. Section 3.4 has been modified to note that both negative and positive pressures can bias the test.

Section 4 discusses the sensitivity, range and precision of the test procedure. Section 4.1 has been revised to provide specific requirements for the flowmeter necessary to meet the required precision. Similarly, section 4.2 has been modified to more completely describe the required pressure gauge.

Section 5 provides a listing of the equipment needed to conduct the test. The originally noticed section 5.1 has been deleted and replaced with new sections 5.2 and 5.7. Section 5.2 has been renumbered and revised to conform to section 4. Section 5.6 has been revised to remove language not pertinent to the equipment description and to remove reference to the vapor poppet. Section 5.7 has been renumbered and modified to allow other bladders, as well as a plumber's bladder for isolation of the drain valve from the OPD. Section 5.8 has been renumbered and revised to acknowledge that the tank gauging stick may or may not be required to ascertain that the drop tube opening is completely submerged.

Section 6 describes the pre-test procedures. Section 6.2 has been revised to remove language regarding quantifying Phase I adaptor leaks, which is not the intent of the test procedure. Section 6.5 has been modified to clarify the inspection of the drain valve configuration. Section 6.6 has been added to discuss how to bring the ullage space to zero gauge pressure.

Renumbered Figure 2, Inflatable Bladder Installation, has been revised to provide a generic depiction of the bladder that may be used.

Section 7 discusses the test procedure. The changes to this section are rearrangement and clarification of the steps to conduct the test. Sections 7.1 and 7.2 have been replaced with the new section 6.6 as described above. As originally noticed, section 7.3 allowed measurement of the combined leak rates of the drain valve and OPD. This section has been deleted and similar language is now in section 7.8. New section 7.1 alerts the tester to proceed directly to section 7.8 if the drain valve does not drain into the drop tube. New sections 7.2 through 7.4 describe the steps to test the drain valve alone and replace the original section 7.5. The renumbered section 7.5 has been revised to eliminate the reference to 2.00 inches H2O and instead reference the pressure specified in CP-201. Section 7.6 has been rewritten to clarify recording of flow rate and pressure data. New section 7.7 describes removal of the bladder. New sections 7.8 through 7.11 describe the steps to test the entire drop tube assembly.

Section 8 provides the post-test procedures. Section 8.2 has been deleted as it is duplicative of new section 7.7. Section 8.4 has been deleted as it is duplicative of language in section 9.1.

Section 9 describes the calculation of the test results. Section 9.1 has been revised to conform the calculations to the pressure specified in CP-201, rather than 2.00 inches H2O. Section 9.2 has been modified to clarify the calculation of the leak rate of both components. Equation 9.2 has been added for the calculation described in section 9.2. New section 9.3 provides common flow rate conversions.

Section 10 describes reporting of results. Modifications to section 10 clarify how to report the test results.

Section 11 provides the mechanism for use of alternate procedures. Section 11 has been revised to clarify the reference to CP-201.

Modifications have been made to Form 1, Drop Tube/Drain Valve Assembly Data Sheet, to conform to changes in the test procedure.

Modifications to TP-201.1E

Staff discovered that some test equipment in the proposed TP-201.1E, Leak Rate and Cracking Pressure of Pressure/Vacuum Vent Valves, has limitations when used to test pressure/vacuum vent valves (P/V valves) at or above maximum allowable leak rate. Therefore, staff proposes to withdraw the proposed TP-201.1E and revert to the previously adopted TP-201.2B Appendix. In the future staff will develop a revised P/V valve test procedure that will include specifications for test equipment that can quantify the leak rates and cracking pressures for a wider range of performance criteria. The revised test procedure will be part of a new rulemaking that will include opportunities for stakeholders and public to provide formal and informal comments. At this time staff will consider comments regarding the proposed withdrawal of TP-201.1E.

Modifications to TP-201.2D

As approved by the Board, staff has withdrawn the proposed amendments to TP-201.2D dated October 25, 2002 and has modified TP-201.2D as adopted February 1, 2001.

TP-201.2D determines post-fueling drips from nozzles. The title of the test procedure has been modified to correctly reflect that the procedure determines drips from any part of the nozzle, not just the nozzle spout. The term "refueling" has been replaced with the more common terms, "fueling" or "dispensing", throughout the test procedure.

Section 1 sets forth the purpose and applicability of the test procedure. Both the introduction and section 1.1 have been revised to clarify the reference to CP-201. Section 1.2 has been added to clarify that the terms "drip" and "drop" may be used interchangeably.

As originally adopted, section 2.1 required that nozzles be inspected and verified to be in good working order, as specified in CCR, title 17, section 94006. Section 2.1 has been removed as TP-201.2D is only applicable for system certification tests, not for compliance testing. The original section 2.2 has been renumbered as section 2.1 and revised to simplify the summary of the test procedure. The original section 2.3 has been renumbered as section 2.2 and revised to clarify the determination of compliance with the standard.

Section 3 provides details on identified biases and interferences for the test procedure. Section 3.2 regarding CCR Title 17 defects has been deleted to conform to the removal of section 2.1. The original section 3.3 has been renumbered as section 3.2 and revised to clarify the data from runs with spitback may be excluded only if the spitback was due to a vehicle fillpipe which does not conform to the requirements of title 13, CCR, section 2235. Section 3.3 has been added to specify that gasoline that exits the nozzle as a trickle, rather than distinguishable drips that can be counted, will be reported as 2.5 drops where the total gasoline collected for that run is less than 0.3 ml. Section 3.4 has been added to recognize that the conversion of 1 ml to 20 drips may underestimate the actual volume, due to variations in gasoline composition.

The sensitivity and precision of TP-201.2D have been clarified in section 4.2.

Section 5 describes the equipment requirements for conducting the test procedure. Section 5.1 has been revised to clarify that more than just the number of drips is recorded for each fueling on the Field Data Sheet. Section 5.2 has been added to reference the new nozzle data sheet. The original section 5.2 regarding stopwatch specifications has been renumbered to section 5.3 and revised to reference a timing device. The language suggesting use of the stopwatch split function has been removed. Sections 5.4 through 5.9 have been added to specify additional equipment needed to conduct the test procedure.

Section 6 contains the pre-test procedures. Section 6.1 has been modified to describe how to mark the nozzle horizontal position, as well as to delete language relating to title 17 to conform with changes to sections 2.1 and 3.2. Section 6.2 has been added to direct the tester to record data on the nozzle data sheet.

As originally adopted, Figure 1 depicts nozzle orientation. Figure 1 has been replaced with a new Figure 2. The new Figure 1 shows how to mark and observe nozzle attitude in order to verify that the nozzle is pointing downward during the fueling. The new Figure 2 clarifies how to determine nozzle orientation.

Section 7 has been revised to clarify each step of the test run. The original section 7.1 has been deleted as the vehicle survey ID has been replaced with a "time of day" entry on Form 1 to identify a test run. The original section 7.2 has been renumbered to section 7.1 with editorial changes. A new section 7.2 has been added to describe use of the graduated cylinder and funnel. Section 7.3 has been modified to clarify the position of the nozzle during the fueling. A new section 7.4 discusses determination of the nozzle attitude during the fueling to verify the spout is pointing downward. The original section 7.4 has been renumbered to section 7.5 and revised to clarify that the nozzle shall be set on high clip during the fueling and correct the reference to the stopwatch. The original section 7.5 has been renumbered as section 7.6 and revised to remind the tester to verify that at least 4.5 gallons are dispensed and to wait for 10 seconds before removing the nozzle. Sections 7.6.1 and 7.6.2 have been modified to clarify the removal of the nozzle from the fillpipe and the counting of the drips. New section 7.6.3 gives instructions on how to record gasoline that exits the nozzle as a trickle, rather than discrete drips. Modifications to Section 7.7 clarify the total number of runs required and data collection procedures.

The original section 8, Post-Test Procedures, has been deleted as it is duplicative of language in the original section 9. The original section 9 has been renumbered to section 8 and describes calculation of results. The equations in section 8 have been revised for clarity. New language has been added to section 8.2 to account for the conversion of measured milliliters to drips.

The original section 10, Reporting Results, has been renumbered to section 9. Modifications have been made to clarify the information required to report final test results.

The original Form 1 has been replaced with two new forms to simplify the data collection for the tester. The new Form 1, Field Data Sheet, lists data collected from the actual fuelings and measurement of drips. Form 2, Nozzle Data Sheet, summarizes the nozzle and facility information.

Modifications to TP-201.2F

TP-201.2F is used to calculate the pressure-related fugitive emissions during certification of Phase II systems. As originally noticed, the flowrate at each observed pressure is calculated using an equation taken from TP-201.3 (TP-201.2F Equation 9.1.1). Based on comments that the TP-201.3 equation can overestimate the flowrate at low pressures (< 1 inch WC), an empirically-derived equation is proposed to replace the existing Equation 9.1.1. An exception is that Equation 9.1.1 will be used to calculate the maximum allowable leak at 2 inches WC. All but one of the changes to TP-201.2F described below are related to this equation change. The exception is a correction of a default butane hydrocarbon concentration associated with Equation 9.3.1.

Section 8 sets forth the post-test procedures. Section 8.9 has been modified to clarify that equation 9.1.1 is used to calculate the maximum allowable flow rate at 2 inches WC. Language describing use of multiple pressure ranges has been deleted. Section 8.10 has been revised to delete reference to calculation of flowrates using equation 9.1.1.

Section 9 describes how to calculate the test results. Section 9.1 has been revised to clarify that Equation 9.1.1 is used to calculate the maximum allowable leak at 2 inches WC. Language has been added to section 9.1 to reference Appendix A for determination of the empirical flow versus pressure (Q vs. P) equation. Section 9.2 has been modified to reference the empirical Q vs. P equation for calculation of flow rates relating to each observed pressure interval. Equation 9.2.1 has been revised to clarify the calculation of total flowrate.

Section 12 provides an example calculation for determination of pressure-related fugitives. The calculations have been modified to be consistent with the changes made to section 9.

Appendix 1 has been added to provide information on how to generate the empirical Q vs. P equation.

Editorial Corrections

Throughout the Certification Procedure CP-201 and each of the Test Procedures corrections to wording, grammar and numbering have been made to improve the clarity of the regulations. Cross-references have been added and corrected to improve clarity.

Board Resolution 02-35 sets forth the Board's action approving changes to title 17, California Code of Regulations, sections 94010, 94011, 94163, 94164, 94165, 94166 and 94167, and approving the amendment of the incorporated certification and test procedures for vapor recovery systems, D-200, CP-201, TP-201.1, TP-201.1B, TP-201.1C, TP-201.1D, TP-201.2, TP-201.2B, TP-201.2D, andTP-201.2F as modified and approving the adoption of TP-201.1E, TP-201.2G, TP-201.2I, TP-201.2J and TP-201.7. The Resolution and the text of the regulations and incorporated certification and test procedures, as modified, are available on the Board's Web site at http://www.arb.ca.gov/regact/evrtech/evrtech.htm. Copies of these documents can also be obtained by contacting Mr. George Lew at (916) 327-0900. Test methods and standard operating procedures incorporated into the certification and test procedures are also available from Mr. Lew.

In accordance with section 11346.8 of the Government Code, the Board directed the Executive Officer to adopt sections 94010, 94011, 94163, 94164 and 94165, 94166 and 94167, title 17, California Code of Regulations, and the incorporated certification and test procedures for vapor recovery systems, D-200, CP-201, TP-201.1, TP-201.1B, TP-201.1C, TP-201.1D, TP-201.2, TP-201.2B, TP-201.2D, TP-201.2F, TP-201.1E, TP-201.2G, TP-201.2I, TP-201.2J and TP-201.7, as modifi