The Vapor Recovery Compliance Inspections, Maintenance, Logs task is part of the Vapor Recovery Program on Complyrpedia.
Vapor recovery systems are approved by the California Air Resources Board. However, compliance implementation is delegated to local air districts. This creates a patchwork of requirements across California. Most local air districts will expect facility operators to conduct the inspections and minimum maintenance tasks found in the Vapor Recovery Executive Order(EO). However, other local air districts require more frequent inspections and documentation. Fortunately, these tasks can be grouped and we provide general instructions on compliance. However, you should verify requirements with your local air district to determine your compliance obligations.
Inspect Hoses, Nozzles, Breakaways, Spill Containment
Vapor recovery systems have numerous components that are used heavily during fuel transfers; both the the fuel facility storage tank and vehicle tanks. This heavy use means that the equipment must be inspected regularly to insure that it is working properly. Equipment inspections should include hoses, nozzles, breakaways, and spill containments. These inspections should be done daily to ensure hanging hardware is in satisfactory condition.
Inspection Requirements by Vapor Recovery Executive Order
Inspection Checklists by Air District
More air district forms to come
For vapor recovery systems to operate correctly, the flow rate of gasoline must be within specifications designated in the corresponding Vapor Recovery EO.
For Balance Systems, such as Executive Order (EO) VR 204, the gasoline dispensing rate must be between 5.0 and 10.0 gallons/minute. EO VR-204 does not require operators to conduct flow rate tests, except for when conducting Vapor Recovery Annual Compliance Testing. However, some local air districts, such as the San Diego Air Pollution Control District, require monthly flow rate testing and documentation. Check with your local agency to make sure you are completing all inspections as required.
For Vac-Assist Systems, such as VR 202, the gasoline dispensing rate must be between 6.0 and 10.0 gallons/minute.
The flow rates for Vac-Assist systems must be tested and recorded at least quarterly. The form to record this test can be found in the Inspection and Maintenance Manual for VR-202.
Some agencies require documentation of flow rates for every grade point. The San Diego Air Pollution Control District requires flow rates to be tested and recorded monthly. With the advent of In Station Diagnostics (ISD), many air districts no longer require flow rate recordings other than during Vapor Recovery Annual Compliance Testing. Check with your local agency to make sure you are completing all inspections as required.
Testing flow rates
Flow rate testing should be done into an approved container. Always wear and deploy appropriate safety equipment. Remember after testing flow rates, return the fuel to the grade it came from or lower. (Premium can go in 89 and 87 grade, but not the other way around.)
Flow Rate Testing Resources
Record form: San Diego APCD has a form to record testing results.
Gasoline Throughput Logs
Gasoline throughput logs allow regulators to calculate the potential pollution created by a gas station. Vapor recovery systems are designed to catch fuel vapors that would escape during fuel transfer operations. The amount of fuel vapors generated is proportional to the volume of fuel that is transferred through the system. Because of this, most air districts require gasoline dispensing facilities to record fuel throughput (the volume of fuel dispensed) on a monthly basis.
Record the volume of GASOLINE, including E-85, dispensed during each calendar month. Some agencies require annual throughput volumes to be submitted. Check your permit conditions or contact your local air district to determine if submission is required.
Resources by Local Air District
Forms for other air districts coming soon.
Vapor Processor Inspection
Vapor processors reduce gasoline vapor pollution by preventing excess vapor saturated air from escaping the fueling system through the Pressure/vacuum valve. Some vapor processors remove gasoline from air before it is expelled into the atmosphere. Others provide extra space to store saturated air. Because vapor processors perform such an important task in preventing air pollution, they must be inspected regularly to ensure proper operation.
Vac Assist – EO VR-202 Clean Air Separator (CAS)
EO VR-202 requires a quarterly inspection of the Clean Air Separator for proper operating configuration. This inspection can be done by the gasoline station owner or operator or someone they designate. Information on performing the inspection correctly is below.
Balance – EO VR-204 Vapor Processors
If a balance system is equipped with the Clean Air Separator from VR-202, the quarterly inspection procedure is identical. Refer to the section above.
Annual inspection and maintenance is required for other vapor processors. The procedures can be found in the VR-204 I,O&M.
Note: vapor processors other than the Clean Air Separator must be inspected by a certified vapor recovery technician.
Balance System Liquid Removal
Balance vapor recovery systems use positive displacement to transfer vehicle-tank vapors to the fueling facility storage tank. Because the pressure differential between the vehicle-tank and the facility storage tank is small, the vapor path must be clear for the system to operate correctly. When motorists “Top off, the vapor path can get filled with gasoline. This can completely disable the vapor recovery system for that fueling point. To prevent this, all balance hoses are equipped with liquid removal devices. These devices must be tested to ensure proper function. This is usually done by a certified vapor recovery technician during Vapor Recovery Compliance Testing. However, some agencies may require facility operators to drain balance hoses and measure the volume that comes out. Hoses that contain more than 175 ml of gasoline in the vapor path are considered defective and should be Tagged out of service. Check with the local air district to determine balance hose liquid removal requirements.
Balance Liquid Removal Inspection Resources
Gasoline dispensing nozzles have insertion interlock mechanisms that prevents the dispensing of fuels unless the bellows are depressed. Insertion interlocks prevent the inadvertent discharge of gasoline unless the nozzle is depressed into a vehicle fill pipe. To ensure this important safety mechanism works, nozzle insertion interlock mechanisms must be checked at regularly.
Vac Assist – EO VR-202 Insertion Interlocks
Conduct the Vac Assist systems insetion interlock test weekly. It is called the “Nozzle Dispensing Check” and is described in the VR-202 Inspection, Operation and Maintenance Manual as item 1.2.3:
Verify that the nozzle will not dispense fuel when the dispenser is authorized (ready to dispense fuel) and the boot is in a free state. To conduct this inspection, remove the nozzle from dispenser, authorize dispenser, hold nozzle into an approved container (do not compress the mini-boot in any manner) and actuate the nozzle lever. No fuel should dispense. Any nozzle that dispenses fuel with the miniboot in a free state condition, as determined by this inspection procedure, shall be removed from service until repaired or replaced.
The record-keeping form is the same one used for Clean Air Separator (CAS) inspection.
Balance – EO VR-204 Insertion Interlocks
Check balance nozzle insertion interlock mechanisms weekly.
Insertion interlock procedure and record forms can be found in the VR-204 Inspection, Operation and Maintenance manual.
Other Insertion Interlock Resources
Annual Vapor Recovery Compliance Inspection
Note: This requirement is not to be confused with Compliance Vapor Recovery Testing.
Some local air districts require an annual review of compliance requirements. The South Coast Air Quality Management District is one of the agencies that requires such an inspection.
South Coast AQMD Rule 461 Annual Compliance Inspection.
Note: you must take the Rule 461 Annual Inspection Training to comply with this requirement.
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