May 10, 2000


Thomas J. Smith


P.O. Box 6818

Pico Rivera, CA 90661


Dear Mr. Smith:

Dispenser Configurations for the Hirt VCS 400-7 Stage Vapor Recovery System

This letter is in response to your letter dated April 24, 2000. You requested the approval of hose and dispenser configurations Exhibit 5 and Exhibit 11 for the VCS 400-7 system.

According to your letter, you would like to get approval for a modified version of the Exhibit 5 configuration to be used with the Hirt VCS 400-7 vapor recovery system. The modifications would include a liquid removal device located so that the liquid pickup is at the bottom of the hose loop during vehicle fuelings. It would be required that the hose not touch the island or the ground when not in use.

In your letter you also requested that Exhibit 11 be approved for use with the HIrt VCS 400-7 vapor recovery system. Upon review of these hose configuration and the VCS 400-7 system, it has been determined the modified Exhibit 5 and Exhibit 11 will not adversely effect the vapor recovery system. Therefore, these configurations will be added to Executive Order G-70-177-AA. We will also add this letter to our web page under Executive Order G-70-177-AA.

If you have any questions or wish to discuss this matter further, please call Christine McKenzie at (916) 324-7658.



Signed copy on file

James J. Morgester, Chief

Compliance Division