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
.
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.
|