FREQUENTLY ASKED QUESTIONS ABOUT THE
NEW ENHANCED VAPOR RECOVERY REQUIREMENTS FOR 2005



Deadline April 1, 2005

GENERAL

1. What are these new requirements, and when do they go into effect?

ANSWER: On March 23, 2000, the Air Resources Board (ARB) approved the EVR requirements to address equipment reliability issues and to seek additional emission reductions to meet state and federal requirements. Adopting these requirements will result in the phasing-out of less effective existing equipment and will require the installation of equipment that meets the EVR requirements. State law provides that existing facilities will have four years from the effective date to comply with the new requirements. New installations or major modifications will have to comply on or after the operative date of the new requirements. To promote an orderly transition, new requirements will be phased-in over the next several years. The "EVR Implementation Timeline" that lists effective dates and operative dates of each requirement can be downloaded from ARB Web Site at http://www.arb.ca.gov/vapor/whatsnew.htm.
The first EVR requirements, Phase I vapor recovery systems and the replacement of existing nozzles with new nozzles that meet the liquid retention standard, will start on July 1, 2001. All new installations or major modifications of existing gasoline dispensing facilities will be required to comply with these requirements. Existing gasoline dispensing facilities will have until April 1, 2005, to comply with these new requirements.


2. How can I get copies of the EVR Executive Orders?

ANSWER: The easiest way is to download the Executive Orders from the ARB web site at http://www.arb.ca.gov/vapor/eo-evrphaseI.htm for a copy of certified Phase I EVR systems and http://www.arb.ca.gov/vapor/eo-PhaseII.htm for a copy of Executive Order G-70-199 listing nozzles which meet the liquid retention requirements. Otherwise, you can request a copy by calling (916) 327-0900.


3. What do I do if I am unable to buy an EVR-certified component due to limited commercial availability?

ANSWER: The ARB realizes some shortages may occur in the initial period after the new requirements take effect. If you have this problem, please send a letter that explains which components or parts are not available, along with an invoice from equipment manufacturers stating that the part or component is not available. The letter should be sent to:

Mr. William V. Loscutoff, Chief
Monitoring and Laboratory Division
Air Resources Board
P. O. Box 2815
Sacramento, California 95812-2815

Alternatively, you can send your request, along with supporting information, by FAX at (916) 322-2444 or by e-mail by using the "submit a question" feature at the bottom of the vapor recovery FAQ page.

The ARB staff will review each request and make a determination of commercial availability on a statewide basis. The determination will be available and updated on the ARB web site: http://www.arb.ca.gov/vapor/vapor.htm.

LIQUID RETENTION REQUIREMENT


4. What are the requirements for replacement nozzles after July 1, 2001?

ANSWER: The ARB has determined that nozzles listed in Exhibit 1 of Executive Order G-70-199 will not be commercially available until July 16, 2001. The new EVR liquid retention requirement will not take effect until after July 15, 2001. All nozzles certified prior to July 1, 2001, may be purchased, repaired, or replaced through July 15, 2001. After July 15, 2001, only those nozzles listed in Exhibit 1 can be used for new installations, and those nozzles listed in Exhibit 2 can be used to replace nozzles that fail and cannot be repaired.


5. Can I repair a non-EVR certified nozzle after July 15, 2001?

ANSWER: In most cases, the answer is "yes" provided that certified factory replacement parts (or kits) are available for items such as spouts, boots, vapor guards and hold-open latches. Exhibit 3 of Executive Order, G-70-199 lists nozzles which cannot be repaired, even if factory repair kits or parts are available.
To use nozzles as replacements (even those already purchased by the station) at existing facilities after July 15, 2001, the nozzles must be listed in Exhibit 2 of Executive Order G-70-199.


6. Can I install a nozzle not listed in Exhibit 2 that is in storage at a station or in inventory after July 15, 2001?

ANSWER: No. After July 15, 2001, only nozzles listed in Exhibit 2 can be used as replacements.

7. Does the Executive Order require the removal of any nozzles now in use on or after July 15, 2001?

ANSWER: No. All nozzles in use prior to July 16, 2001 may be kept in service until replaced. If replaced, only those nozzles listed in Exhibit 2 of Executive Order G-70-199 may be used.


8. The number of EVR-certified nozzles are limited. Are more certifications in progress?

ANSWER: Yes, the following nozzles are currently undergoing evaluation and certification testing by the ARB:

Catlow ICVN Emco Wheaton 4005 Emco Wheaton 4007 Emco Wheaton 4015
Emco Wheaton 4500 Emco Wheaton 4505 EZ-flo 11VF EZ-flo 5005
EZ-flo 5015 Healy 800 Husky V3 OPW 11 VAI-27
OPW 11 VAI-37 OPW 12VW Richards Astrovac
If these nozzles successfully complete testing, the ARB will add them to Exhibits 1 and 2 of the updated Executive Order G-70-199. Please check the ARB web site at http://www.arb.ca.gov/vapor/eo-PhaseII.htm for the latest version of Executive Order G-70-199. If any of the nozzles fail to meet the new Liquid Retention standard, they will be listed in Exhibit 3.

9. A dispensing nozzle is missing as a result of a drive-off and needs to be replaced. What nozzle can I use as a replacement after July 15, 2001?

ANSWER: The replacement nozzle is one of those nozzles listed in Exhibit 2 of Executive Order G-70-199 for your system.


10. What if there are no EVR-certified nozzles for my system?

ANSWER: Exhibit 2 of Executive Order G-70-199 lists replacement nozzle models by Phase II system type. All Phase II systems will have at least one model of replacement nozzle. However, you may not use a nozzle listed in Exhibit 3 of the EVR Nozzle Executive Order, G-70-199.

11. I have a Gilbarco/Marconi system (G-70-150-AE) which uses a nozzle at an Air-to-Liquid (A/L) range of 1.00 to 1.20 (such as Emco Wheaton A4500, Husky V3, or OPW VAI-27). The only nozzle available is for the lower range (.90 to 1.10), what am I required to do? What if it is a multi hose dispenser?

ANSWER: The nozzle must be replaced with a nozzle listed in Exhibit 2, and the system must be adjusted to the lower A/L range. In the case of multi hose dispensers, one vapor pump controls all three nozzles and therefore the nozzles requiring different A/L ranges may not be used. Thus all three nozzle would have to be replaced.

12. What should I do if someone wants to sell me a nozzle not listed on Exhibits 1 or 2 after July 15, 2001?

ANSWER: State law and Executive Order G-70-199 prohibit the offer for sale, or installation of nozzles that are not listed on Exhibits 1 or 2 after July 15, 2001. Installation of such nozzles after July 15, 2001, would be illegal and subject to enforcement action by districts.

13. When a boot or spout fails, I remove the nozzle from the hose and replace it with an identical one that was previously in service, but has been repaired. For nozzles not listed on Exhibit 2, can I continue this practice?

ANSWER: If the nozzle is not listed on Exhibit 2, the answer is "no" after
July 15, 2001. Only nozzles operating on July 15, 2001, (except those listed in Exhibit 3) can be repaired. New or refurbished nozzles in storage not listed in Exhibit 2 cannot be used or installed.

14. Is it all right to remove a nozzle from the hose to perform a repair?

ANSWER: Yes. Before removing the nozzle, the dispenser must be taken out of service. The same nozzle body must be returned to use after the repair is completed.

15. If a station installs a new hose or changes the hose configuration on a dispenser, must the station replace the nozzle with one which meets the liquid retention requirement?

ANSWER: No, the replacement of a hose or change in hose configuration (examples of hose configurations are included in the Exhibits of G-70-52-AM) is not considered a major modification and does not initiate a requirement to replace the nozzle.

PHASE I EVR SYSTEM

16. What is the status of available EVR-certified, Phase I systems for new or modified construction?

ANSWER: Currently, one system is certified: the Phil-Tite Phase I Vapor Recovery System (Executive Order VR-101-A). This system must be used for all new gasoline dispensing facilities or for major modifications of existing gasoline dispensing facilities on or after July 1, 2001. Please refer to the response to Question 17 pertaining to facilities receiving an Authority to Construct prior to July 1, 2001, where actual construction will not begin until after July 1.
Other Phase I system manufacturers have submitted applications to the ARB.
NOTE: As more EVR-certified systems become available, future Executive Orders will list components that can be interchanged among various certified systems.


17. I currently have an open Authority to Construct from my local air pollution agency. Can I still install a non-EVR certified Phase I system after July 1, 2001?

ANSWER: Consult with your local APCD/AQMD permitting authority as permitting practices vary somewhat from district to district.


18. What about replacement of Phase I components?

ANSWER: In general, you replace failed components on Phase I systems with EVR-certified components or parts. However, if Phase I EVR components or parts are not compatible, pre-EVR certified parts or components may continue to be sold and used. For example, the Phil-Tite Phase I EVR system is certified with a ball float overfill prevention valve. If an existing system has a drop tube overfill prevention valve which malfunctions, the facility operator can replace the drop tube overfill prevention valve with any certified drop tube overfill prevention valve that was certified prior to July 1, 2001. If a drop tube overfill prevention valve is later certified and is deemed compatible with specific pre-EVR Phase I systems, only that drop tube overfill prevention valve can be used as a replacement part.


19. Do I have to replace everything in the Phase I system if one non-EVR-certified component fails?

ANSWER: No, replacing one component will not trigger the requirement that the current Phase I system be upgraded to comply with the Phase I EVR requirements. However, by April 1, 2005, all existing Phase I systems must use 100% EVR-certified equipment. As mentioned earlier, new installation of gasoline dispensing facilities or major modifications of gasoline dispensing facilities occurring on or after July 1, 2001, must use a Phase I EVR certified system. Please consult with your local air district to determine the requirements

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20. What if the Phil-Tite system can't be easily installed on my system?

ANSWER: Please refer to answer from question 16 for new installations and major modifications, and questions 18 and 19 for replacement parts.