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Critical Deadlines to Install Gasoline Dispensing
Vapor Recovery Systems (Phase II) Compatible with
Onboard Refueling Vapor Recovery (ORVR) Equipped Vehicles
State law requires that all retail and non-retail gasoline dispensing
facilities (GDFs) with underground storage tanks be equipped with Phase II
vapor recovery systems that have been certified as compatible for fueling
vehicles equipped with Onboard Refueling Vapor Recovery (ORVR) systems. The
deadlines for existing facilities to comply with this requirement are:
- September 1, 2005 GDFs with a calendar year 2003 gasoline throughput
of 2 million gallons or greater
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January 1, 2006 GDFs with a
calendar year 2003 gasoline throughput of 1 million gallons or more but
less than 2 million gallons.
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March 1, 2006 GDFs with a calendar year 2003 gasoline throughput of less
than 1 million gallons.
This is one of several requirements in the State’s Enhanced Vapor Recovery (EVR)
program designed to further reduce emissions of gasoline vapors which
contain toxic compounds and which contribute to the formation of atmospheric
ozone (smog).
Failure to comply by the applicable deadline may result in significant
non-compliance penalties and your gasoline dispensing equipment being tagged
out-of-service.
As the regional air pollution control agency responsible for permitting and
enforcement activities relating to GDFs, the South Coast Air Quality
Management District (AQMD) is required to implement and enforce these State
requirements. Presently, the California Air Resources Board (CARB) has
certified four (4) ORVR compatible Phase II systems:
• Balance (CARB Executive Order G-70-52-AM and Approval Letter 03-04)
• Gilbarco Vapor Vac/OPW Vaporsaver (CARB Executive Order G-70-204)
• Healy (CARB Executive Orders G-70-191-AA and VR-201-A)
• Hirt (CARB Executive Order G-70-177-AA and Approval Letter 03-06)
If your present Phase II vapor recovery system is not one of these four
systems, it must be replaced with an ORVR compatible Phase II system by the
date above that corresponds with your throughput for calendar year 2003.
Additional EVR (Phase II) Requirements
In addition to the above deadlines for installing ORVR compatible Phase II
vapor recovery systems, CARB regulations also require that all existing GDFs
be equipped with EVR Phase II systems by January 1, 2009. Beginning as of
April 1, 2005, new GDFs and facilities undergoing “major modifications” (see
discussion below) must install an EVR Phase II system at the time of
construction. Presently, CARB has certified only one Phase II system (Healy
- CARB Executive Order VR-201-A) that meets both ORVR and EVR requirements.
However, it is expected there will be other EVR Phase II systems certified
and available in the next 6 to 18 months with additional systems certified
in the future.
Major Modifications
A major modification is any construction or renovation that results in the
addition, replacement, or removal of 50% or more of the buried vapor piping,
replacement of 50% or more of a facility’s dispensers, or the number of
dispensers at the facility is increased by 50% or more. In the event of a
major modification, all dispensers must be replaced with unihose dispenser
configurations, and the vapor control equipment must be upgraded to a
State-certified EVR Phase II system. The unihose dispenser requirement does
not apply to identical replacements of existing dispensers due to damage
from an accident or vandalism. Also, CARB has determined that the EVR Phase
II upgrade requirement does not apply if an existing vacuum assist-type
Phase II system is replaced with a balance-type Phase II system to meet ORVR
compatibility requirements and the existing dispensers are replaced with
unihose configurations as part of the same modification.
Unless the aforementioned 50% limits are exceeded, upgrading to an ORVR
compatible Phase II vapor recovery system does not, by itself, constitute a
major modification and will not immediately trigger unihose dispenser or EVR
Phase II requirements. However, facilities that will be replacing their
existing Phase II systems with an ORVR compatible Phase II system should
consider whether to install a system that will meet both ORVR and EVR Phase
II requirements.
Things to Remember
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Know the facts – Take the time to carefully review this advisory.
Additional information is available at CARB’s web page at http://www.arb.ca.gov/vapor/vapor.htm.
or you can visit AQMD’s website at
www.aqmd.gov/comply/Rule461/EVR-Update.htm.
If you have questions regarding ORVR-compatible or EVR Phase II system
requirements, please call AQMD at 1.866.770.9140.
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Assess your compliance status – Become familiar with your GDF’s current
compliance status and the efforts that will be necessary to comply with ORVR
and EVR requirements by the specified deadlines. As of April 1, 2005, your
station must already be equipped with:
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Nozzles approved to meet a standard for retention of liquid in the nozzle
and listed in Exhibit 1 of ARB Executive Order G-70-199-AJ. If the nozzles
at your facility are not listed in Exhibit 1, you need to replace them with
the listed approved nozzles corresponding to your existing Phase II system;
and
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EVR Phase I vapor recovery.
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Permitting - Submit to the AQMD a permit application to modify your GDF’s
existing Permit to Operate and ensure that you have an AQMD approved Permit
to Construct in your possession before you start installation of the new
equipment.
Permit applications and related information is available by calling
909.396.3385 or by visiting our website at
www.aqmd.gov/comply/Rule461/R461EVRPermits.htm. Please allow at least 6
to 8 weeks for permit application processing.
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Select a qualified contractor/installer – While AQMD can not provide a list
of recommended contractors, we encourage you to do the research necessary to
ensure you hire a qualified professional that can successfully complete the
installation by the specified deadline. Request a commitment that the
equipment will be obtained and installed by that time and that it will be
installed in compliance with all applicable state and AQMD rules and
regulations.
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Plan ahead – Since the lead times for permit approval, the ordering
of the necessary equipment, and the scheduling of the installation may be
lengthy, take the necessary steps to ensure that sufficient time is provided
to ensure your installation is completed before the deadlines. In some
cases, additional approval may also be required from the fire department or
local municipalities. If you anticipate not being able to meet your
installation deadline for reasons beyond your reasonable control, consider
filing a petition for a variance at least twenty (20) days before the
deadline.
Consult the AQMD webpage at www.aqmd.gov/hearbd/variances.html for more information on variances.
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Testing – System performance testing is required within 30 days of
initiating operation of the new system. When conducted properly by a
qualified testing company, testing verifies that the system was installed
correctly and is operating in accordance with applicable CARB requirements.
A list of testing companies can be found at
www.aqmd.gov/comply/Testersweblist.xls. This list identifies those
companies that employ persons that have attended the AQMD's Tester
Orientation Class (required to conduct testing in AQMD). The fact that a
person has attended this class is not a representation that the tester is in
good standing with the AQMD. Testing is a vital component of the
installation process that can save you time and additional expenses later.
Please practice all due diligence when selecting a testing company.
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