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Vapor Recovery Requirements for E85 Dispensing
Facilities
Meeting to Discuss Vapor Recovery Requirements
for Facilities that Dispense E85 February 2, 2006
Alex Santos California Air Resources Board
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E85 Dispensing Facilities Subject to Control of
Vapor Emissions

• California Health and Safety Code (HSC)
  authorizes ARB to control gasoline vapor
  emissions and certify vapor recovery systems (HSC
  Section 41954 et seq.)

• Gasoline means any petroleum distillate with an
  RVPgt4.0 psi and meeting the requirements of CCR,
  Title 13, section 2250 et seq.
• (CCR, Title 13, Section 94010)
• E85 (Ethanol 85, 15 gasoline) meets the
  definition of gasoline.
• California has a specification for E85
  (CCR, Title 13, Section 2292.4)

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CARB Must Certify E85 Vapor Recovery Systems
Before They Are Installed, Sold, or Offered for
Sale

• E85 dispensing facilities are considered novel
  facilities, which are certified under
  Certification Procedure (CP)-205
• CP-205 allows ARB staff discretion in determining
  certification requirements
• Currently, no certified vapor recovery (VR)
  systems for E85

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Proposed CP-205 Certification Requirements for
E85Previously Certified VR Systems (Gasoline)

• Existing certified VR systems
• Aboveground storage tanks (ASTs)
• Enhanced Vapor Recovery (EVR)
• Pre-EVR
• may be certified for use with E85, if the VR
  systems meet following criteria
• Materials Compatibility
• Pressure Integrity
• 180 day field demonstration
• Engineering Evaluation

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Proposed CP-205 Certification Requirements for
E85 New Design VR Systems for E85 Facilities
That Use Aboveground Storage Tanks

• Requirements based on the Interim Guidelines for
  Certifying Vapor Recovery Systems Using Above
  Ground Storage Tanks, November 30, 2001.
• Materials Compatibility

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Proposed CP-205 Certification Requirements for
E85 New Design VR Systems for E85 Facilities
That Use Underground Storage Tanks

• Must be certified to EVR requirements (CP-201)
• Materials Compatibility

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Research and Development Facilities Used to
Generate Data In Support of Certification

• Five E85 Research and Development (RD)
  facilities in California
• One facility open to general public San Diego
• Four facilities fueling private fleets
  Vandenberg AFB, Berkeley, Livermore, Sacramento
• Two are AST systems, three are UST systems
• Each facility is required to provide ARB with
  quarterly test results

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Research and Development Facility Quarterly Test
Results are Not Part of Certification Testing

• The purpose of RD approval is to allow the
  installation of uncertified equipment for the
  purpose of generating data that used to support a
  certification application
• New RD facility applications will only be
  considered if the VR system to be tested
  represents a change in system design from
  existing certified and RD systems
• RD TESTING DOES NOT QUALIFY AS CERTIFICATION
  TESTING

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Overview of Pathway to Certification of E85 Vapor
Recovery Equipment Apply for Certification

• Application includes
• VR system description
• Evidence materials compatibility with E85
• Evidence of Reliability of VR System
• Installation and maintenance requirements of
  system
• Warranty information
• Challenge or failure modes and test protocols
• Proposed Test Station Information
• Approvals from Other Agencies

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Overview of Pathway to Certification of E85 Vapor
Recovery Equipment Evaluation and Certification

• ARB Staff Responsibilities
• Evaluate application, test data, and other
  information
• Conduct certification testing in accordance with
  existing or new procedures
• Document the certification process
• Prepare Executive Order to certify or letter if
  certification is denied
• Submit invoice to reimburse ARB for the time
  spent for system certification
• Certification Report
• Executive Order

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Executive Order is the Blueprint for E85 Vapor
Recovery System Installations

• Once certified, the E85 VR system can be offered
  for sale, sold and installed throughout the State

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E85 Contacts

• Joe Guerrero
• jguerrer_at_arb.ca.gov [phone]
• Alex Santos
• asantos_at_arb.ca.gov [phone]
• www.arb.ca.gov/vapor/vapor.htm

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Questions?