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August 23, 2007

 From:               Gabe Messerly

 Subject:           VMI Approved Catastrophic Testing Guidelines, 08/23/07

Under EPA CFR § 280.44(a) of the UST rules, Vaporless Manufacturing, Inc. is required to inform the owners and operators of mechanical line leak detectors of annual test requirements. This document will update company information regarding catastrophic testing of VMI MLLDs and ELLDs, approved catastrophic leak testing equipment and certification guidelines.  While this guideline is specifically for VMI MLLD and ELLD equipment, it is also applicable to any mechanical or electronic catastrophic line leak detection equipment insofar as manufacturer guidelines do not exclude this method or equipment for generating catastrophic leaks.  From the introduction of the LDT-890 equipment and protocol in 1989, up to and including the present (08/2007), there have been and are no known exclusions by manufacturers of line leak detection equipment for this method and equipment.

 Leak test threshold for catastrophic testing: 3 gallons per hour @ 10 pounds per square inch.

 VMI testing requirements are met using the LDT-890 & LDT-890\AF Leak Detector Tester and protocol as posted on our web site at www.vaporless.com.

• Testers must pass the certification test for the VMI LDT-890(\AF) Leak Detector Tester and recertify every two years.
• Certification for Operation of VMI LDT-890(\AF) is dependent upon testing with an LDT-890(\AF).
• VMI requires factory recalibration of VMI LDT-890(\AF) every two years.

Other Equipment Recognized by VMI for Catastrophic Line Leak Testing

 As of May 2006, VMI and Tanknology have jointly established a training and certification program.  The Tanknology Leak Detector Tester Model 5000 (TLDT – 5000) is recognized as authorized equipment for Catastrophic Testing of VMI MLLDs and ELLDs and other equipment as described above.

• Testers must pass the Tanknology – Vaporless Certification Exam for the TLDT - 5000 Tester and recertify every two years.

• Certification for Operation of the TLDT - 5000 Tester is dependent upon use of that equipment only.
• VMI - Tanknology requires factory recalibration of the TLDT - 5000 every two years.

Please contact me if you have any questions.

Sincerely,

Gabe Messerly

Vaporless Manufacturing, Inc.

Last modified: November 15, 2008

Vaporless Manufacturing, Inc.

8700 E. Long Mesa Drive

Prescott Valley, Arizona  86314

E-mail:  vmi@vaporless.com

1-800-367-0185     Fax (928) 775-5309