1. 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

2. 2 E85 Dispensing Facilities Subject to Control of Vapor Emissions “Gasoline” means any petroleum distillate with an RVP>4.0 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) California Health and Safety Code (HSC) authorizes ARB to control gasoline vapor emissions and certify vapor recovery systems (HSC Section 41954 et seq.)

3. 3 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

4. 4 Proposed CP-205 Certification Requirements for E85 Previously 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

5. 5 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

6. 6 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

7. 7 Research and Development Facilities Used to Generate Data In Support of Certification Five E85 Research and Development (R&D) 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

8. 8 Research and Development Facility Quarterly Test Results are Not Part of Certification Testing The purpose of R&D approval is to allow the installation of uncertified equipment for the purpose of generating data that used to support a certification application New R&D facility applications will only be considered if the VR system to be tested represents a change in system design from existing certified and R&D systems R&D TESTING DOES NOT QUALIFY AS CERTIFICATION TESTINGR&D TESTING DOES NOT QUALIFY AS CERTIFICATION TESTING

9. 9 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

10. 10 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

11. 11 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

12. 12 E85 Contacts Joe Guerrero –jguerrer@arb.ca.gov (916) 324-9487 Alex Santos –asantos@arb.ca.gov (916) 324-1003 www.arb.ca.gov/vapor/vapor.htm

13. 13 Questions?