California Air Resources Board

Section 1: Standing Loss Control (SLC) Requirements for Gasoline Dispensing Facilities Equipped with Aboveground Storage Tanks

1.1 What is an Aboveground Gasoline Storage Tank or AST?

Answer: An AST is a gasoline storage tank that is intended for fixed installations, without backfill around the tank, which could be located above or below grade.  The term "without backfill", only refers to the tank and does not include the piping, which could be buried.  ASTs are commonly classified as either “single-wall” or “protected”.  Single-wall ASTs are constructed with a primary (single) wall typically made of steel.  Protected ASTs are constructed with a primary (inner) tank encased by a secondary (outer) tank, with a layer of insulating material (at least three inches thick) between the primary and secondary walls.  The insulating material is usually lightweight concrete or a similar material.

1.2 Which ASTs are subject to standing loss control?

Answer: To determine applicability, please consult your local Air Pollution Control District (local district) to find out if your AST is affected.  Note that ASTs storing diesel or jet fuel are not required to have vapor recovery systems.

1.3 When is the standing loss control compliance date for new installations?

Answer: As of April 1, 2009, all new installations of ASTs are subject to standing loss control.  To determine applicability, please consult with your local district.  In order to meet standing loss control, new installations must choose one of the protected ASTs listed in the latest version of CARB Executive Order VR-302, along with a CARB EVR-certified pressure vacuum vent valve (P/V valve).

1.4 Are gasoline bulk plants and terminals required to comply with standing loss control requirements?

Answer: No, standing loss control does not apply to bulk plants and terminals.  Bulk plants are intermediate gasoline distribution facilities that receive and deliver gasoline via cargo tanks.  Terminals are the primary distribution facilities for the loading of cargo trucks that deliver gasoline to bulk plants, service stations, and other distribution points.  CARB certifies bulk plants under CP-202, Certification for Vapor Recovery Systems of Bulk Plants, and terminals under CP-203, Certification of Vapor Recovery Systems of Terminals. The bulk plant and terminal certification testing determine whether the transfer efficiencies to and from the cargo tank meet applicable performance standards and specifications.

1.5 If a bulk plant facility with an AST is also equipped with remote dispensers used to refuel motor vehicles, would that AST need to comply with SLC?

Answer: No, standing loss control does not apply to bulk plants, even those that are equipped to distribute fuel into cargo tanks and transfer fuel into motor vehicles.

1.6 What standing loss control systems are certified for new installations?

Answer: As of January 1, 2021, there are five protected AST manufacturers (ConVault, SuperVault MH Series, Fireguard, CSI Hoover Vault, and Above Ground Tank AGT Vault) certified for new installations as specified in the latest version of Executive Order (EO) VR-302.  Each of these ASTs must be equipped with a CARB EVR-certified P/V valve.  Single-wall ASTs are not certified for new installations.

In general, as of April 1, 2009, all new installations of ASTs are subject to standing loss control.  For more information, please consult with your local district.  For standing loss control only, a replacement of an existing AST with an AST of equal capacity (volume) is not considered a new installation.  In order to meet standing loss control, new installations must choose one of the protected ASTs listed in the latest version of CARB Executive Order VR-302 along with a CARB EVR-certified P/V valve.

1.7 When is the standing loss control compliance date for existing installations?

Answer: As of April 1, 2013, all existing ASTs subject to standing loss control were required to install one of the standing loss control systems listed in Executive Order (EO) VR-301.  For standing loss control purposes, the replacement of an existing AST with an AST of equal capacity (volume) that is equipped with a standing loss control certified system is not considered a new installation.  In such a case, the replacement AST, which is considered as an existing AST, would have been required to comply with standing loss control requirements by April 1, 2013.

1.8 What standing loss control systems are certified for existing installations?

Answer: For existing ASTs, there are two ways to comply with SLC: apply a CARB certified reflective coating and install a CARB EVR-certified P/V valve, or if you happen to have a CARB certified make and model protected AST, simply install a CARB EVR-certified P/V valve.

As of January 1, 2021, EO VR 301 lists six protected ASTs that are not required to apply one of the certified coatings, if the existing OEM paint is in good condition (Refer to Exhibit 4, please email vapor@arb.ca.gov to request a copy).  These protected ASTs are: ConVault, SuperVault MH series, Fireguard, Hoover Vault, Jensen Precast Armor Vault, and Above Ground Tank AGT Vault.  Your AST must be of the same model and make listed in VR-301.  Additionally, based on engineering evaluation, CARB staff has included protected ASTs from the pre-EVR Executive Orders that are also listed under Underwriters' Laboratories (UL) Standard 2085.  These tanks are Trusco Tank, Inc.'s SuperVault FL (G-70-132), Ace Tank and Equipment Company's Fuel Safe (G-70-137), Mosier Brother Tanks and Manufacturing AST (G-70-152), RECoVault Inc.'s Ecovault (G-70-156 and G-70-157), Hoover Containment Systems, Inc.'s Hoover Fuelmaster (G-70-161), and Bakersfield Tank Company's EnviroVault (G-70-167).  UL-2085 listed ASTs generally have placards or other markings identifying them as such. Additionally, the ASTs should be labeled with one of the names listed above, or be identified as such on the facility permit. If UL-2085 identifying markings are absent, it will be up to the discretion of Air District staff whether to accept the AST as a EO VR-301 certified existing AST. All protected ASTs listed in EO VR-301 also need to be equipped with a CARB EVR-certified P/V valve.

For existing single wall ASTs, application of one of the coatings listed in the latest version of EO VR-301 and the installation of a CARB EVR-certified P/V valve will satisfy the standing loss control requirement.  Table 1 lists the coating systems that are certified as of January 1, 2021. 

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

Table 1: Standing Loss Control Coating Systems Certified by CARB (As of January 1, 2021)

1.9 Can I apply any of the certified coatings listed in EO VR-301 throughout the state of California?

Answer: Your local air district may have specific rules that limit the volatile organic content of the coatings.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.10 What if my protected AST is not listed in EO VR-301?

Answer: If your existing AST’s make and model is not listed in EO VR-301, compliance with standing loss control can be achieved by the application of any coating system listed in EO VR-301 (see Table 1 above) and installing a CARB EVR-certified P/V valve.

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.11 What if I have an existing single-wall AST?

Answer: First, consult your local district to determine if your AST is exempt from vapor recovery requirements.  If your AST is subject to vapor recovery requirements, you must comply with standing loss control by applying one of the paints listed in EO VR-301 series along with a CARB EVR-certified P/V valve. 

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.12 What if my existing protected AST listed in EO VR-301 needs to be repainted for aesthetic or maintenance reasons?

Answer: Except for gasoline dispensing facilities equipped with Jensen Precast “Armor Cast” AST, if an existing protected AST that is listed in EO VR-301 needs to be repainted for aesthetic, maintenance, or other reasons, the AST owner can choose between using a coating system listed in EO VR-301, or they can use the same coating system applied by the original equipment manufacturer (OEM) at the production facility.  If the latter option is selected, the AST owner is advised to contact the appropriate AST manufacturer to obtain current specifications of the OEM coating system. Due to the uniqueness of the OEM exterior finish applied to Jensen Precast “Armor Cast” AST, such owners are advised only to follow manufacturer’s specifications.  Additionally, existing Jensen Precast “Armor Cast AST with exposed aggregate finish should not be painted.

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.13 What are the maintenance requirements for SLC (e.g. how often does the AST need to be painted; what do you do if the AST has graffiti; if the paint starts to peel; if covered in dust or other dark materials, etc.)?

Answer: Maintenance for SLC will be based on individual manufacturer Installation, Operation, and Maintenance Manuals (IOMs).  For protected ASTs, the manufacturers generally call out periodic (weekly or monthly) inspections of the surface of the AST for cracks, chips, corrosion, etc.

The protected AST manufacturers do not have a timeframe for cleaning or repainting, so sound judgment should be used.  If there are portion(s) of the AST covered in graffiti, covered in dust or other dark materials that darkens the coating, have cracks, where rust is coming through the paint, or the paint is peeling, then the standing loss control may no longer be effective and the AST paint should be cleaned, repaired, or repainted as needed.  Similarly, existing single-wall ASTs that have damage to their coatings need to cleaned or be repainted.

Except for gasoline dispensing facilities equipped with Jensen Precast “Armor Cast” AST, if an existing protected AST that is listed in EO VR-301 needs to be repainted for aesthetic, maintenance, or other reasons, the AST owner can choose between using a coating system listed in EO VR-301, or they can use the same coating system applied by the original equipment manufacturer (OEM) at the production facility.  If the latter option is selected, the AST owner is advised to contact the appropriate AST manufacturer to obtain current specifications of the OEM coating system. Due to the uniqueness of the OEM exterior finish applied to Jensen Precast “Armor Cast” AST, such owners are advised only to follow manufacturer’s specifications.  Additionally, existing Jensen Precast “Armor Cast AST with exposed aggregate finish should not be painted.

If an existing single-wall AST needs to be repainted, then the AST owner must apply one of the certified coating systems listed in EO VR-301.

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.14 Am I required to paint the bottom of a rectangular protected AST which is not manufactured by the one of the companies listed in EO VR-301?

Answer: No, it is not necessary to paint the bottom of protected rectangular AST.

1.15 Am I required to paint over the manufacturer’s and UL placards?

Answer: No, it is not necessary, nor recommended, to paint the placards.

1.16 Is spot (partial) painting of the AST allowed?

Answer: No, except for the bottom of rectangular ASTs and labels, all exposed surfaces of the AST must be repainted if applying an EO VR-301 coating for the first time.  If an AST has already been painted with one of the coatings listed in EO VR-301, and small blemishes have occurred, then touch-ups are acceptable. 

1.17 Do the various tank top components and pipe fittings need to be painted in order to comply with SLC?

Answer: No, the various tank top components and pipe fittings do not need to be painted, nor is it recommended that they be painted, with an EO VR-301 coating, just the AST.  If an owner/operator decides to paint these fittings, then the paint must not impede the functionality of any tank top components.

1.18 If an existing protected AST shows chalking, cracks, rust, exposed concrete, etc., does it need to be repainted?

Answer: Yes, however, if damage has occurred to more than just the original paint coating, then the AST needs to be repaired according to manufacturer instructions.  Once chalking, cracks, rust, etc. have been addressed, then it will need to be repainted with either one of the certified coating systems listed in EO VR-301, or the AST owner can contact the AST manufacturer to obtain current specifications for the coating system applied at the production facility prior to installation in the field.

Note: Due to the uniqueness of the OEM exterior finish applied to Jensen Precast “Armor Cast” AST, such owners are advised not to apply one of the certified coating systems listed in EO VR-301.  Instead, they will need to follow manufacturer’s specifications.  Additionally, existing Jensen Precast “Armor Cast AST with exposed aggregate finish should not be painted.

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.19 What must be done if the UL and manufacturer’s labels are missing from the existing protected AST?

Answer: If an existing protected AST is missing its identifying UL and manufacturer labels, an effort should be made to identify the AST make and model via owner/operator records.  If the AST cannot be confidently identified as one of the certified ASTs, then it will need to be repainted with one of the certified coating systems listed in EO VR-301 and an effort made to secure new labels.

1.20 Do below-grade vaulted ASTs need to meet SLC requirements?

Answer: No.  SLC does not apply to below grade vaulted ASTs because such ASTs are subject to different performance standards and specifications.  A below grade vaulted AST is an AST that is below the level of the earth's surface, is contained in an enclosure, without backfill, and requires continuous ventilation.

1.21 If an existing AST is fully enclosed within a structure, does the AST need to be painted for SLC?

Answer: CARB has not certified any ASTs enclosed within a structure as complying with SLC standards. CARB lacks certification data regarding the emission factor standards of fully enclosed ASTs.  If an owner of an AST that is fully enclosed within a legal structure believes that such an AST can comply with standing loss control emission factor standards, the owner can submit a request for a site specific certification.  The AST owner would need to notify their local district of their request and the structure would need to meet all applicable local and state requirements. 

A request for a site specific certification should be sent in writing to CARB at the following address:

Chief of the Vapor Recovery and Fuel Transfer Branch

Monitoring and Laboratory Division

California Air Resources Board

P. O. Box 2815

Sacramento, California 95812-2815

1.22 Do protected ASTs listed in VR-301 have to be a certain color?

Answer: The protected ASTs listed in EO VR-301 have to be the original color when shipped from the manufacturer, or one of the CARB-certified colors from that specific original equipment manufacturer (OEM) if more than one is listed in the EO.  In many cases the original color will be white.  In the case of the Hoover Vault and Supervault, some ASTs may be a tan color.  In the case of Jensen Precast “Armor Cast” some existing AST may have an exposed aggregate exterior.

Except for gasoline dispensing facilities equipped with Jensen Precast “Armor Cast” AST, if an existing protected AST that is listed in EO VR-301 needs to be repainted for aesthetic, maintenance, or other reasons, the AST owner can choose between using a coating system listed in EO VR-301, or they can use one of the original coating systems applied by the original equipment manufacturer (OEM) at the production facility.  If the latter option is selected, the AST owner is advised to contact the appropriate AST manufacturer to obtain current specifications of the OEM coating system. Due to the uniqueness of the OEM exterior finish applied to Jensen Precast “Armor Cast” AST, such owners are advised only to follow manufacturer’s specifications.  Additionally, existing Jensen Precast “Armor Cast” AST with exposed aggregate finish should not be painted.

Table 2: OEM Coating Color of Protected ASTs

1.23 If an existing protected AST is painted a color other than what is shown in Exhibit 1 of EO VR-301, are they required to repaint the AST?

Answer: Yes, an existing protected AST that is painted any color other than the original color from the manufacturer (OEM) as shown in Exhibit 1, would be required to be repainted with either a CARB certified coating system from EO VR-301, or the AST owner can contact the AST manufacturer to obtain current specifications for the coating system applied at the production facility.  Note: existing Jensen Precast “Armor Cast” AST with exposed aggregate finish should not be painted.

Your local air district may have specific rules that limit the volatile organic content of the coating.  All existing AST owners must consult with their local district to ensure that the selected coating complies with applicable rule limits before the application of the coating.

1.24 If an AST is in a shaded area, or has a shade structure covering it, does it still need to be painted for SLC?

Answer: Yes, this AST would still need to comply with standing loss control requirements.  The regulations allow CARB to evaluate SLC configurations that include shade structures; as of January 1, 2021, no manufacturers have submitted an application for a shade structure.  At this time, CARB has not issued an Executive Order which allows a shade structure as an option to meet SLC emission factor standards.  See response to 1.21 regarding site certification of a shade structure. 

1.25 Can decals (e.g. safety reflectors, no smoking signs, flammable signs, etc.) be added to the AST after it is painted?

Answer: Yes.  Required safety decals should be added back to the AST once it is painted.

1.26 If a protected AST is of a manufacturer listed in Executive Orders VR-301 or VR-302, but does not have a model number or serial number that is listed in either Executive Order, does that AST need to be repainted with a certified coating system?

Answer: Yes, if the protected AST is not listed by manufacturer, model number, and serial number in either EO VR-301 or EO VR-302, then it is not a certified AST and must be repainted with an approved coating system listed in EO VR-301.  However, AST owners can contact the AST manufacturer to determine if unlisted model numbers are compliant with SLC.  If yes, it will be the responsibility of the manufacturer to notify CARB.  Only after CARB lists the name of the manufacturer and model number, or serial number, in writing is the AST exempt from SLC painting.

1.27 In some districts, a permit may not be required for a gasoline AST at a non-retail site that is under 550-gallons.  Would this AST need to comply with the SLC requirement?

Answer: It is possible that an AST is not subject to permits but may be required to comply with SLC in accordance with district rules.  Thus, it is very important to check with your local district since regulations may vary. 

1.28 Is there a size limitation or facility type where SLC does not apply (i.e. gasoline storage, bulk dispensing at refineries (wholesale bulk), and airports (retail bulk or in-house usage))?

Answer: SLC does not apply to bulk plants and terminals.  In all other cases please consult your local district to determine SLC applicability. 

1.29 Are gasoline dispensing facilities equipped with ASTs located in “attainment areas” for the Federal standard for ozone exempted from SLC requirements?

Answer: Yes, existing ASTs in Federal ozone attainment areas are not required to comply with SLC, but these ASTs must keep their pre-EVR Phase I and Phase II equipment. However, air district rules may require new ASTs installed after April 1, 2009 to comply with SLC regardless of attainment status.  See responses to questions 3.3 and 3.4 for Phase II requirements for new AST installations.

​​​​​​​1.30 Do the SLC requirements apply to ASTs used at marina operations?

Answer: Yes, if subject to district vapor recovery requirements.

​​​​​​​1.31 What does the Husky P/V Vent Valve “remove after” date mean and does the CARB require enforcement of this date?

Answer: The “remove after” date is a recommendation from Husky.  This date is not a CARB requirement and is not referenced in the applicable Executive Order.  If the P/V valve passes all applicable performance tests then that valve can remain installed regardless of the “remove after” date.

​​​​​​​1.32 Do the SLC requirements apply to ASTs containing aviation gasoline?

Answer: No. CARB EVR requirements, including SLC, do not apply to aviation gasoline.  The fact that it is not subject to CARB vapor recovery regulations does not necessarily mean that it is exempt from control.  Districts are allowed by state law to impose controls that are more stringent than CARB.  Therefore, all owners of AST storing and dispensing aviation gasoline should contact the appropriate district.

1.33 If an existing protected AST, such as the ConVault, has experienced severe damage (i.e. major cracks and pieces missing from the concrete insulation) can the AST be repaired?

Answer: The AST operator will need to contact the district, the OEM, and the applicable state and local agencies for further instruction on approved repair practices.  If the AST is missing part of its exterior, it is no longer in the condition it was certified under and the AST may need to be replaced with protected tanks listed in Executive Orders VR-301 and VR-302.

​​​​​​​1.34 Are gasoline bulk plants and terminals required to comply with SLC requirements?

Answer: No, SLC requirements do not apply to bulk plants and terminals.  Bulk plants are intermediate gasoline distribution facilities that receive and deliver gasoline via cargo tanks.  Terminals are the primary distribution facilities for the loading of cargo trucks that deliver gasoline to bulk plants, service stations, and other distribution points.  CARB certifies bulk plants under CP-202, Certification for Vapor Recovery Systems of Bulk Plants, and terminals under CP-203, Certification of Vapor Recovery Systems of Terminals. The bulk plant and terminal certification testing determine whether the transfer efficiencies to and from the cargo tank meet applicable performance standards and specifications.

Section 2: Phase I Vapor Recovery Requirements for Gasoline Dispensing Facilities Equipped with Aboveground Storage Tanks

2.1 Who is subject to Phase I EVR?

Answer: To determine applicability, please refer to sections 2.4.4, 2.4.5, and 2.4.6 of the Certification Procedure for Vapor Recovery Systems at Gasoline Dispensing Facilities Using Aboveground Storage Tanks (CP-206 ) and consult your local district to find out if your AST is affected.  The requirement to upgrade to Phase I EVR is based upon location and annual gasoline throughput, and varies among the local Air Districts.  Note that ASTs storing diesel or jet fuel are not required to have enhanced vapor recovery systems.​​​​​​​

2.2 What are the Phase I EVR requirements on or after July 1, 2010?

Answer: As of July 1, 2010, new AST installations must install Phase I equipment that complies with the new EVR performance standards and specifications.  For existing installations, please refer to sections 2.4.4, 2.4.5, and 2.4.6 of CP-206 to determine if your AST was subject to the Phase I EVR deadline of July 1, 2014.  The requirement to upgrade to Phase I EVR is based upon location, annual gasoline throughput, and varies among the local Air Districts.  Regardless, whether your AST is subject to Phase I EVR requirements, all owners/operators are advised to consult with your local district.  Existing installations that choose to replace their AST on or after July 1, 2010, are considered new installations for the purpose of Phase I.

​​​​​​​2.3 What are the Phase I EVR requirements on or after July 1, 2014?

Answer: For existing installations, the upgrade to Phase I EVR was required by July 1, 2014.  Owner/operators should refer to sections 2.4.4, 2.4.5, and 2.4.6 of CP-206 and check with your local air district to determine whether  if you are subject to these requirements.  The requirement to upgrade to Phase I EVR is based upon location, annual gasoline throughput, and varies among districts.  If your AST is currently required to have a Phase I system, but is not required to upgrade to EVR, you must maintain your pre-EVR Phase I system in accordance with the appropriate Executive Order. 

​​​​​​​2.4 What Phase I EVR systems are currently certified?

Answer: Currently there are two systems certified.  OPW has a Phase I system certified under EO VR-401 and Morrison Brothers has a Phase I system certified under EO VR 402.

​​​​​​​2.5 What if my existing AST does not have enough ports/bungs/openings to accommodate the Phase I EVR System?

Answer: The currently certified Phase I EVR systems require a number of ports/bungs/openings to accommodate various components which comprise the system. As indicated in Exhibit 2 of each Phase I EVR AST Executive Order, a dedicated opening must be provided for an appropriately sized emergency vent, product adaptor with submerged drop tube, vapor adaptor, pressure/vacuum vent valve, and dedicated gauging port.  CARB staff recognizes that many existing ASTs may not have an available dedicated port for each component.  There are also ASTs that do not have the correct size ports for each component.  In some cases for ASTs with limited numbers of openings, pipe fittings can be used to accommodate more than one component on a single port. 

CARB staff has worked collaboratively with the local districts and Phase I equipment manufactures to identify alternative installation configurations which utilize various pipe fittings to enable multiple components on ASTs with limited openings.  Figure 1, Figure 2, Figure 3, and Figure 4 (within Exhibit 2 of the Executive Orders mentioned above) provide examples of acceptable alternative installation configurations.  For those ASTs that still cannot accommodate modifications for the alternative configurations, CARB has issued Executive Order G-70-216 to address that there are no commercially available, compatible Phase I EVR systems for these ASTs.  These ASTs will have at least four years from the date when the first compatible Phase I EVR system is certified to comply. 

​​​​​​​2.6 What should I be aware of prior to ordering a new AST?

Answer: New ASTs must be one of the ASTs listed in the latest version of Executive Order VR-302 and have sufficient openings to accommodate the components which comprise one of the Phase I EVR systems.  These components include, but are not limited to, product adaptor, vapor adaptor, overfill prevention device, submerged drop tube, emergency vent, and dedicated gauging port.  (See Section 3 of this page for Phase II Vapor Recovery Requirements)

At a minimum, you should contact your city, fire department, local Air District, and the Certified Unified Program Agency (CUPA) to ensure that your plan meets their requirements.

​​​​​​​2.7 In some districts, a permit may not be required for a gasoline AST at a non-retail site that is under 550-gallons.  Would this AST need to comply with the Phase I EVR requirement?

Answer: Please consult with your local air pollution control or air quality management district to determine Phase I EVR applicability. 

​​​​​​​2.8 If an existing single-wall AST has only two openings and thus is not compatible with a Phase I EVR upgrade, yet the legal language of the EO says it must follow the requirements of other agencies, what can be done?

Answer: Please see response to 2.5. 

​​​​​​​2.9 If an existing AST already has an automatic tank gauge (ATG) tied into the Veeder-Root TLS 350, will a dedicated gauging port still be required?

Answer: In this instance, the AST could keep its ATG and Veeder-Root system and not install an additional dedicated gauging port.  The regulation was amended in 2013 to allow for electronic, mechanical, and manual means of determining the amount of gasoline in the tank.

At a minimum, you should contact your city, fire department, local Air District, and local Certified Unified Program Agency (CUPA) to ensure that your plan meets their requirements.

2.10 ​​​​​​​Are gasoline bulk plants and terminals required to comply with Phase I EVR requirements?

Answer: No, Phase I EVR requirements do not apply to bulk plants and terminals.  Bulk plants are intermediate gasoline distribution facilities that receive and deliver gasoline via cargo tanks.  Terminals are the primary distribution facilities for the loading of cargo trucks that deliver gasoline to bulk plants, service stations, and other distribution points.  CARB certifies bulk plants under CP-202, Certification for Vapor Recovery Systems of Bulk Plants, and terminals under CP-203, Certification of Vapor Recovery Systems of Terminals. The bulk plant and terminal certification testing determine whether the transfer efficiencies to and from the cargo tank meet applicable performance standards and specifications.

Section 3: Phase II Vapor Recovery Requirements for Gasoline Dispensing Facilities Equipped with Aboveground Storage Tanks

3.1 Who is subject to Phase II EVR?

Answer: As of March 13, 2015, new installations of ASTs with remote dispensing[1] are subject to Phase II EVR requirements, if they are subject to air district rule requires installation of Phase II system. Beginning July 9, 2020, new ASTs with non-remote dispensing[2] subject to Phase II EVR requirements, if air district rules require installation of Phase II system. All new AST installations subject to Phase II requirements must install the system listed in the latest version of Executive Order VR-501.

See response to question 3.4 for Phase II requirements for existing ASTs with pre‑EVR Phase II systems.

[1]  Remote dispensing is a dispenser with a splitter valve configured in such a way that it prevents liquid condensate in the vapor return line from draining directly back into the head space of the aboveground storage tank.

[2]  Non-remote dispensing Is a dispenser with a splitter valve configured in such a way that it allows liquid condensate in the vapor return line to drain directly back into the head space of the aboveground storage tank.

​​​​​​​3.2 What Phase II systems are certified?

Answer: Currently, there is one Phase II EVR system certified by CARB.  The system is a Balance Phase II system that utilizes a Hirt thermal oxidizer and is certified under Executive Order VR-501.

​​​​​​​3.3 What existing AST facilities are required to upgrade to Phase II EVR?

Answer:  Existing remote dispensing AST facilities in ozone nonattainment areas 1) with a Phase I EVR system installed, 2) with a pre-EVR Phase II system, 3) that meet the system configuration requirements of Executive Order VR-501, and 4) which possess an annual gasoline throughput greater than 480,000 gallons, are required to meet the Phase II EVR upgrade deadline of March 13, 2019.  Non-remote existing AST facilities meeting the above requirements must upgrade by July 9, 2024.  Existing AST facilities in ozone nonattainment areas that are at or below the throughput threshold may keep their pre-EVR Phase II systems until the end of useful life of that system, and then upgrade to Phase II EVR if vapor recovery is required by the local Air District.  In attainment areas, AST facilities may keep their pre-EVR Phase II systems until the end of useful life, and then remove and upgrade to Phase II EVR if required by the local Air District. 

As mentioned in response 3.1, remote dispensing is a dispenser with a splitter valve configured in such a way that it prevents liquid condensate in the vapor return line from draining directly back into the head space of the aboveground storage tank.  Non-remote dispensing Is a dispenser with a splitter valve configured in such a way that it allows liquid condensate in the vapor return line to drain directly back into the head space of the aboveground storage tank.

​​​​​​​3.4 What are the requirements for a pre-EVR balance system?

Answer: Owners and operators of Phase II pre-EVR balance systems are required to install EVR certified nozzles, breakaways, hoses, and swivels (collectively called hanging hardware) upon replacement.  CARB staff has determined that EVR certified balance hardware is compatible for pre-EVR balance systems.  Please refer to the following Approval Letters and Advisory 408 for more information. 

• Approval Letter 07-09 to Vapor System Technologies (VST) for VST hanging hardware
• Approval Letter 07-03 to Goodyear for Goodyear hoses
• Approval Letter 09-10 to Emco Wheaton Retail for EMCO hanging hardware​​​​​​​

Advisory 408 explains the replacement part requirement in more detail and lists the Phase II EVR hanging hardware that are found to be compatible with pre-EVR balance system.  Please note that the Phase I and Phase II AST compliance deadlines listed in Advisory 408 are incorrect and are correctly listed in the FAQs.

​​​​​​​3.5 Are gasoline bulk plants and terminals required to comply with Phase II EVR requirements?

Answer: No, Phase II EVR requirements do not apply to bulk plants and terminals.  Bulk plants are intermediate gasoline distribution facilities that receive and deliver gasoline via cargo tanks.  Terminals are the primary distribution facilities for the loading of cargo trucks that deliver gasoline to bulk plants, service stations, and other distribution points.  CARB certifies bulk plants under CP-202, Certification for Vapor Recovery Systems of Bulk Plants, and terminals under CP-203, Certification of Vapor Recovery Systems of Terminals. The bulk plant and terminal certification testing determine whether the transfer efficiencies to and from the cargo tank meet applicable performance standards and specifications.

Phase II EVR Executive Order VR-501 does not allow a configuration that would include a GDF with a bulk plant.  Equipment and components certified in Executive Order VR-501 have not been evaluated or tested with a bulk plant configuration.  Currently there are no certified EVR Phase II systems for this type of configuration, and such a facility would need to be built with a pre-EVR system such as G-70-138/139, using the Hirt VCS-200 processor.  Advisory 408 allows current Phase II EVR hanging hardware to be used with G-70-138/139. Additionally, with the pre-EVR configuration, the bulk plant facility will be required to go through a one-time source test certification as outlined on the Vapor Recovery of Bulk Plants and Terminals page.

3.6 ​​​​​​​When are liquid condensate traps required?

Answer: Liquid condensate traps are devices designed to collect liquid gasoline that condenses in the vapor return line, allowing the liquid to be automatically evacuated, ensuring that the vapor return line will not be blocked by the accumulation of liquid.  ASTs with remote dispensing (i.e., dispensers with splitter valves configured in such a way that prevents the liquid condensate in the vapor return line from draining directly back into the headspace of the AST) must have a liquid condensate trap installed to prevent the accumulation of liquid gasoline and potential blockage of the vapor return line.

3.7  What are the Phase II requirements for non-retail ASTs fueling predominately vehicles equipped with on-board refueling vapor recovery or ORVR?

Answer: Please see dedicated FAQ for webpage for GDF exempted from Phase II requirements available at: https://ww2.arb.ca.gov/resources/documents/frequently-asked-questions-g… 

Section 4: E-85 Fueling Facilities Equipped with Aboveground Storage Tanks​​​​​​​

4.1 Does Executive Order VR-301 or VR-302 apply to storage and dispensing of E85?

Answer: No, SLC systems compatible with E85 (15% gasoline and 85% ethanol) fuels have not been evaluated at this time.

​​​​​​​4.2 What if I want to dispense E85?

Answer: Since no vapor recovery systems have been approved for ASTs serving E85 dispensing facilities, operators who wish to dispense E85 will need to submit a letter requesting approval as a research and development test site.  The letter should include the address of the site and list of the uncertified Phase I vapor recovery components that would be installed.  E85 facilities are exempt from Phase II by district rules, since the refueled vehicles are predominately equipped with on-board refueling vapor recovery.  The letter should be sent to:

Chief of the Vapor Recovery and Fuel Transfer Branch

Monitoring and Laboratory Division

California Air Resources Board

P.O. Box 2815

Sacramento, California 95812-2815