10
Clarification on Periodic Compliance Testing for Vapor Balance Systems (VBS) (required at >100,000 gallon per month GDF)
nCurrent rule: Who
is required to test ?(section 63.11120(a))
¨Periodic (initially
& every 3 years) testing of VBS:
nPressure-Vacuum
valve leak rate and cracking pressure test
nVBS static pressure
test
¨All vapor balance
systems must be tested as specified in this rule.
nExcept: if installed prior to 1/10/08,
1.the installed VBS meets specific requirements, and
2.it complies with a required SLT permit or rule (the
SLT permit or rule may have its own testing
requirements)
nTiming of tests for existing vapor balance systems
¨Current rule
requires initial test “at the time of installation” of VBS
¨What about existing
VBS at existing GDF? … Proposing the following:
nVBS installed on or
before 12/15/2009 … no later that 180
days after the compliance date (1/10/2011)
nVBS installed after
12/15/09 … test upon installation of the complete VBS
