Gasoline Vapor Recovery Guidelines 

[Minimum SIP Requirements for EPA Region IX to Approve a 

Phase I or Phase II Gasoline Transfer Rule for Ozone Nonattainment Areas]

 April 24, 2000 

Rationale: 

• In California, require the use of equipment with CARB certification standards. 

• In California, determine certain required approval standards that would not be included in 

CARB certification standards covered by a certification procedure (CP). 

• In California, determine certain recommended approval standards that need not be in the 

rule, because they are included in CARB certification standards. 

• In other states, require the use of equipment with CARB certification standards or 

substantially equivalent certification standards. 

• In other states, determine the analogous required approval standards that would not be 

included in the certification standards.. 

• In other states, determine the analogous approval standards that need to be in the rule, 

unless the state has adopted CARB certification standards or unless it can be shown that 

the approval standards are included in substantially equivalent certification standards. 

a. Applicability:

• Generally, exemptions may be allowed for special applications, such as fueling aircraft, 

marine vessels, or animal husbandry equipment. [To meet the requirements of RACT] 

• Exemptions should not be allowed for Phase I transfer into tanks larger than 250 gallons, 

unless constructed before 1980. [To meet the requirements of RACT] 

• Exemptions should not be allowed for Phase II transfer with a throughput of greater than 

10,000 gallons per month. [To meet the requirements of RACT] 

• Exemptions should not be allowed for Phase II transfer into tanks larger than five gallons. 

[To meet the requirements of RACT] 

b. Definitions:

• Define appropriate terms. 

c. Standards (Minimum Required to Approve a California Rule):

• Require that Phase I and Phase II systems use California Air Resources Board (CARB)-

certified vapor recovery equipment. [To meet the requirements of RACT] 

• List the Phase I and Phase II vapor recovery system defects contained in California Code 

of Regulations (CCR) 94006 or cite CCR 94006 as a reference for these defects. [To 

meet the requirements of RACT] 

• Prohibit operation of a Phase I or Phase II vapor recovery equipment that has liquid leaks, 

vapor leaks, fails to pass tests, or contains CCR 94006 defects that substantially impair 

effectiveness of vapor recovery equipment. [To meet the requirements of RACT] 

• Require that Phase I gasoline storage tanks be equipped with submerged liquid fill pipes. 

[To meet the requirements of RACT] 

• Require that Phase II systems have a warning posted prohibiting topping-off, which may 
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cause spillage of gasoline. [To meet the requirements of RACT] 

d. Standards (Recommended for a California Rule) [These standards need not be explicitly 

stated in the rule to approve a California rule, because these standards are included in the 

equipment Certification Procedure (CP) used by CARB and referenced below]: [To meet the 

requirements of RACT] 

• [CP-201-4] Require that Phase I vapor recovery system emissions should not exceed 

0.15 lb of hydrocarbons/1000 gallons of fuel or the vapor recovery efficiency should be 

at least 98% of the gasoline vapors displaced from the tank into which the gasoline was 

transferred. 

• [CP-201-5] Require that Phase I gasoline storage tanks be equipped with a 

pressure/vacuum relief valve. 

• [CP-201-5] Require that Phase I systems use a poppeted dry break or spring-loaded 

vapor check valve on break-away liquid or vapor couplings. 

• [CP-201-7] Require that Phase II system emissions should not exceed 0.38 lb of 

hydrocarbons/1000 gallons of fuel or the vapor recovery efficiency should be at least 

95% of the gasoline vapors displaced from the tank into which the gasoline was 

dispensed. 

• [CP-201-9] Require that Phase II systems be compatible with on-board refueling vapor 

recovery for rules adopted after July 1, 2001. 

• [CP-201-10] Require that Phase II systems use a “dripless” nozzle after July 1, 2003. 

• [CP-201-11] Require that Phase II systems use a coaxial hose to the nozzle. 

• [CP-201-13,15] Require that Phase II systems use a vapor check valve in the nozzle. 

• [CP-201-13] Require that Phase II vapor-balance systems use an insertion interlock on 

the nozzle. 

• [CP-201-11] Require that Phase II vapor-balance systems use a liquid-removal device 

with a liquid-removal rate of at least five milliliters/gallon of fuel delivered.

e. Standards (Minimum Required to Approve a State Rule other than California):

• Require that Phase I and Phase II systems use California Air Resources Board (CARB)-

certified vapor recovery equipment or a substantial equivalent in another state. [To meet 

the requirements of RACT] 

• List the Phase I and Phase II vapor recovery system defects contained in California Code 

of Regulations (CCR) 94006 or cite CCR 94006 as a reference for these defects or cite a 

substantially equivalent reference in another state. [To meet the requirements of RACT] 

• Prohibit operation of a Phase I or Phase II vapor recovery system that has liquid leaks, 

vapor leaks, fails to pass tests, or contains CCR 94006 defects that substantially impair 

effectiveness of the vapor recovery equipment. [To meet the requirements of RACT] 

• Require that Phase I gasoline storage tanks be equipped with submerged liquid fill pipes. 

[To meet the requirements of RACT] 

• Require that Phase II systems have a warning posted prohibiting topping-off, which may 

cause spillage of gasoline. [To meet the requirements of RACT] 

f. Standards (Minimum Required to Approve a State Rule other than California) [These 

standards need not be explicitly stated in the rule to approve the rule, if the state has adopted 

CARB standards or if it can be shown that they are included in the certification of the equipment 
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by an agency other than CARB]: [To meet the requirements of RACT] 

• Require that Phase I vapor recovery system emissions should not exceed 0.15 lb of 

hydrocarbons/1000 gallons of fuel or the vapor recovery efficiency should be at least 

98% of the gasoline vapors displaced from the tank into which the gasoline was 

transferred for rules adopted after July 1, 2001. 

• Require that Phase I gasoline storage tanks be equipped with a pressure/vacuum relief 

valve. 

• Require that Phase II system emissions should not exceed 0.38 lb of hydrocarbons/1000 

gallons of fuel or the vapor recovery efficiency should be at least 95% of the gasoline 

vapors displaced from the tank into which the gasoline was dispensed. 

• Require that Phase II systems use a vapor check valve in the nozzle. 

• Require that Phase II systems use a “dripless” nozzle for rules adopted after July 1, 2003. 

• Require that Phase II systems be compatible with on-board refueling vapor recovery for 

rules adopted after July 1, 2001. 

• Require that Phase II vapor-balance systems use an insertion interlock on the nozzle.

g. Compliance Schedule:

• Require that performance tests required by the CARB Executive Order or Authority to 

Construct or Permit to Operate after installing new or significantly modifying Phase I or 

Phase II vapor recovery equipment start within 30 days of completion of construction. 

[To meet the requirements of RACT] 

• Require that reverification of performance tests required by the CARB Executive Order 

or Authority to Construct or Permit to Operate be performed about once every six to 

twelve months or, for gasoline dispensing facilities with In-Station Diagnostics, about 

once every two to four years. [To meet the requirements of RACT] 

• Recommend but do not require that a written inspection be performed weekly on vapor 

recovery equipment for defects listed in CCR 94006. 

• Require continuous In-Station Diagnostics for rules adopted after July 1, 2004 to monitor 

at a minimum the gasoline storage tank pressure. [To meet the requirements of RACT] 

h. Testing: 

• Specify which EPA-approved test procedure to use should any of the following 

performance tests or reverification of performance tests on vapor recovery systems 

required by the CARB Executive Order or Authority to Construct or Permit to Operate: 

[For enforcement] 

 - Static Pressure (Leak Decay) Test or Vapor Tightness Test. 

 - Dynamic Back Pressure Test. 

 - Air-to-Liquid Volume Ratio Test. 

 - Liquid Removal Rate Test. 

 

i. Training:

• Recommend but do not require that at least one person be given training approved by the 

District on how to operate the Phase I and Phase II vapor recovery systems and how to 

visually inspect for defects listed in CCR 94006. 

j. Recordkeeping:
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• Require maintaining the following records for at least two years: [For enforcement] 

 - Performance test results. 

 - Reverification test results. 

 - Maintenance performed. 

 - Gasoline throughput if a minimum throughput exemption is claimed.