Air Pollution Control Program - Stage II Vapor Recovery

Stage II Vapor Recovery Home Page

Stage II Construction and Operating Permits
Stage I and Stage II VR (GDFs)
Stage I VR requirements for gasoline delivery vessels

Welcome to the Missouri Department of Natural Resources' Department's Stage II Vapor Recovery (VR) Web Page. The department designed this Web page for easy use and access to Stage I and Stage II VR definitions and terminology. You will find several of the most Frequently Asked Questions (FAQ) about Stage I and Stage II VR answered in this Web page. You will also find "access" buttons at the bottom of each page. These buttons allow you quick access to acronyms, Internet Links and contacts for Stage I and Stage II VR issues. The paragraphs below give a brief introduction and an explanation for the need for Stage I and Stage II VR.

The U.S. Environmental Protection Agency (EPA) has designated St. Louis and Kansas City as maintenance areas for ground level ozone. This means that these areas experience a concentration of ozone at ground level that exceeds the National Ambient Air Quality Standards (NAAQS). Ozone at ground level is a significant health threat, especially to young children, the elderly and those with respiratory problems.

The Stage I and Stage II VR programs in St. Louis and the Stage I VR program in Kansas City have been very effective in reducing gasoline vapor emissions. These emissions are a type of Volatile Organic Compound (VOC). VOCs, in combination with nitrogen oxide compounds (NOx) and sunlight, contribute to the formation of ground level ozone. The department is committed to improving the effectiveness of these VOC control programs. Over the years, the department has developed these programs to control gasoline emissions. Improvements include

Improved regular inspections by better-informed and trained inspectors.
Performance testing and permitting of individual Stage II VR Gasoline Dispensing Facilities (GDFs) in St. Louis.
Use of the Missouri Performance Evaluation Testing Procedures (MOPETP) to performance test VR systems and individual components to prove overall vapor collection efficiencies and durability.
Compliance testing of individual Stage I GDFs in Kansas City.

By conducting MOPETP testing on VR systems and components we have increased our knowledge of VR systems that work and VR systems that need improvement. We have protected the majority of our GDF owners from purchasing expensive VR systems that fail to meet efficiency and durability requirements (i.e. vapor assist systems). Vapor assist systems seemed innovative early in the history of VR, but later were found to be ineffective and in need of costly improvements. The department has been instrumental in discovering problems with individual components and component systems. The MOPETP process provides the department with the data and experience needed to help ensure that the VR systems purchased by the retail GDF owners meet efficiency and durability requirements.

Stage I and II VR are by no means the only ozone control measures used in the two metropolitan areas. Other control measures include low Reid Vapor Pressure gasoline (gasoline with low evaporative characteristics), enhanced Inspection and Maintenance of vehicles, Reformulated Gasoline (clean burning gasoline), controls on industrial emissions and restrictions on open burning. It takes many control measures to eliminate enough tons per day of emissions to reduce overall ozone exceedances. For more information on ground level ozone monitoring and Missouri air quality, visit the following Web sites: www.dnr.mo.gov/AQDS/index.do and www.dnr.mo.gov/env/esp/esp-aqm.htm

Vapor Recovery Advisory Board

Nov. 10, 2005 Meeting Minutes PDF

FAQ- Stage II Construction and Operating Permits

Is there a requirement to obtain a construction permit or an operating permit before building a GDF in St. Louis?
Is there a requirement to obtain a construction permit before adding/replacing a dispenser or other VR equipment in St. Louis?
Is a stage II VR construction permit required for drilling at a GDF (i.e. drilling for monitoring wells and remediation activities)?
When should you apply for construction permits and operating permits?
Are Gasoline Bulk Loading Plants required to have Stage I VR?
Do GDFs in the St. Louis ozone maintenance area have to conduct performance testing?
Do GDFs in the Kansas City ozone maintenance area have to conduct performance testing?
Do VR Systems or components need certification or approval in Missouri?

1. Is there a requirement to obtain a construction permit or an operating permit before building a GDF in St. Louis?

Yes. You must obtain a construction permit from the appropriate air pollution control agency before construction and then subsequently pass all necessary VR system and components testing before obtaining an operating permit. Facilities proposed for construction within the St. Louis City area must apply to the City of St. Louis Division of Air Pollution Control, 1415 North 13th Street, St. Louis, MO 63106, phone 314-613-7300. Facilities constructing within the St. Louis County area must apply to the St. Louis County Department of Health, Air Pollution Control Section, 111 South Meramec, Clayton, MO 63105, phone 314-615-8923. Facilities intending to construct within St. Charles, Jefferson and Franklin counties must apply to the Missouri Department of Natural Resources' St. Louis Regional Office Stage II Unit, 7545 South Lindbergh, Suite 210, St. Louis, MO, 63125, phone 314-416-2960.

2. Is there a requirement to obtain a construction permit before adding/replacing a dispenser or other VR equipment in St. Louis?

Yes. Construction permits must be obtained before any replacement or addition of equipment is done that may affect the vapor tightness of the VR system. This does not include routine maintenance. For further information on construction permit requirements contact the stage II vapor recovery unit at the SLRO at 314-416-2960.

3. Is a stage II VR construction permit required for drilling at a GDF (i.e. drilling for monitoring wells and remediation activities)?

Yes. A stage II VR construction permit is required anytime a GDF breaks concrete, or asphaltic concrete, over or around the facility's vapor recovery system.

4. When should you apply for construction permits and operating permits?

GDF owners or operators in the St. Louis nonattainment area should apply for a permit to construct at least 60 days before beginning construction. The application should include

complete diagrams and a thorough description of the planned facility or construction to take place
plumbing diagrams, including vapor lines, vent lines and slope of return for vapor lines
type of material for all underground, above ground and dispenser plumbing
grade of site in relation to tanks, plumbing and dispensers
current CARB executive order(s) and MOPETP Approval Letter(s) for the proposed system or components
a detailed description of the USTs to be used
a schedule of the construction.

Obtain applications for construction permits by contacting the appropriate air pollution control agency. GDFs must display the permit to construct in a prominent location on-site during construction. GDFs must also notify the appropriate air pollution control agency seven calendar days before the anticipated completion of the underground piping in order to schedule an inspection date. GDFs must not cover underground piping before local air pollution control agency staff inspect it. GDFs must conduct and pass final leak decay tests, dynamic back pressure/liquid blockage tests and stet valve bench tests within 30 days of completion of construction. GDFs must then obtain and maintain on-site in a prominent location their current operating permit. Note: this is a limited summation of the requirements.
See 10 CSR 10-5.220 for all applicable regulations concerning construction and operating permits for GDFs in the St. Louis nonattainment area.

5. Are Gasoline Bulk Loading Plants required to have Stage I VR?

Yes. Both the Kansas City and St. Louis area regulations require Stage I VR on the storage tanks and the delivery vessels that transfer gasoline into them. Bulk plants must have Stage I VR on loading racks and delivery vessels that deliver to customers as well. Gasoline delivery vessels are also required to have a valid annual Missouri tank tightness sticker. This sticker is obtained by submitting an annual tank tightness sticker application (USEPA Method 27 Tank Tightness Test - pressure/vacuum test certification application) to the APCP.

Delivery Vessel Pressure Test Certification Application

Note: if the bulk plant has an average monthly throughput of less than 120,000 gallons per month, the plant can apply for a Low Throughput Exemption from the requirement for Stage I VR on its loading rack and outgoing delivery vessels. This exemption does not apply to the incoming delivery vessels or to the VR on its storage tanks.

The application for a Low Throughput Exemption must be completed and arrive at the Missouri Department of Natural Resources' Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102, before February 1 of each year.

Low Throughput Exemption Application

6. Do GDFs in the St. Louis ozone maintenance area have to conduct compliance testing?

Yes. GDFs must conduct a pressure leak decay test, p/v valve bench test and either a backpressure blockage test or an Air/Liquid (A/L) test depending on the type of VR system employed. This testing is required when GDFs renew its operating permit (every five years) and at the completion of any construction on the facility. The VR system used by the GDF must have current CARB certification and be MOPETP approved.

7. Do GDFs in the Kansas City ozone maintenance area have to conduct compliance testing?

Yes. GDFs must conduct an initial pressure leak decay test and p/v valve bench test. Thereafter, the GDF must complete a pressure leak decay test once every five years and a p/v valve bench test once every two years.

8. Do VR systems or components need certification or approval in Missouri?

Yes. All VR systems and components installed in Missouri must be first CARB-certified and then MOPETP-approved.

MOPETP Approval Components List PDF

FAQ- Stage I and Stage II VR (GDFs)

Why are Stage I and II VR necessary in St. Louis and Kansas City?
What are Stage I and Stage II VR?
Where are Stage I and Stage II VR used?
Is Stage I and Stage II VR required for new GDFs that are not located in the St. Louis or Kansas City ozone maintenance areas?
Where can I get a copy of the Stage I and Stage II VR regulations for St. Louis and Kansas City?
How do the booted Stage II VR nozzles work in capturing gasoline vapors?
How does the state ensure that the vapor recovery systems are maintained in working order?
How can Stage II GDF owners get the tags removed from their nozzles after an inspection?
Can a GDF face enforcement action for dispensing gasoline from a nozzle that was "tagged out" of service?
What is Missouri Performance Evaluation Testing Procedures (MOPETP)?
Why was the MOPETP program established?
What is a MOPETP approval?
- MOPETP Approval Components List? PDF
- MOPETP Approval Letters
What is the California Air Resources Board (CARB)?
What is the Technical Review Committee (TRC)?
What is the Stage II VR Advisory Group?
What is a VR system?
What is a VR component?
What are nonattainment and maintenance areas?

1. Why are Stage I and Stage II VR necessary in St. Louis and Kansas City?

Stage I and Stage II VR programs have been enacted by the state in response to the U.S. EPA's designation of the St. Louis Metropolitan area and the Kansas City Metropolitan area as maintenance areas for ozone. A high level of ozone concentration is unhealthy for people, animals and plants as well as being corrosive to buildings, bridges and infrastructure.

Ozone is a major part of what EPA more commonly calls smog. EPA has grouped gasoline vapors, along with paint solvents, printing solvents and other industrial and combustion materials into a pollutant group known as volatile organic compounds (VOCs). VOCs, along with oxides of nitrogen, in the presence of intense sunshine, are some of the precursors for formation of ozone.

In an effort to block unhealthy ozone formation, EPA has required Missouri to control the release of VOCs in nonattainment and maintenance areas. One of the control methods used is VR (Stage I and Stage II). Regulations require GDFs to use VR to control their emissions. Other VOC control measures are regulations to control industrial VOC emissions, automotive inspection and maintenance tests and open burning restrictions. These controls reduce the potential for ozone creation.

2. What are Stage I and Stage II VR?

Stage I VR is the capture and control of gasoline vapors that would normally be released into the atmosphere during the storage of gasoline at a terminal or bulk plant or during the loading of a gasoline delivery vessel and the subsequent delivery and unloading of a gasoline delivery vessel into another storage tank, usually at a GDF.

Stage II VR is the capture and control of gasoline vapors that would normally be released into the atmosphere during the refueling of motor vehicles at a GDF. When you refill your automobile gas tank, the fresh gas forces out the vapors left in the tank from the last tankful into the atmosphere. Stage II VR, recognized by the black boots on the gasoline nozzles at St. Louis area stations, captures the vapors from the automobile tank and returns these vapors to the UST at the GDF. The UST holds the vapors until a gasoline delivery vessel using Stage I VR refills the UST. These vapors are then returned, by way of the gasoline delivery vessel, back to the terminal for processing or destruction.

3. Where are Stage I and Stage II VR used?

Stage I and Stage II VR are required by Missouri State Air Regulation 10 CSR 10-5.220, "Control of Petroleum Liquid Storage, Loading and Transfer," are used in the St. Louis ozone maintenance area. This area includes St. Louis City, St. Louis County, St. Charles County, Franklin County and Jefferson County.

Stage I VR, required by Missouri State Air Regulation 10 CSR 10-2.260, "Control of Petroleum Liquid Storage, Loading and Transfer," is currently used in the Kansas City ozone maintenance area. This area includes Kansas City, Jackson County, Platte County and Clay County.

4. Is Stage I and Stage II VR required for new or existing GDFs that are not located in the St. Louis or Kansas City ozone maintenance areas?

No. Stage I and Stage II VR do not currently apply to areas in Missouri outside the St. Louis and Kansas City ozone maintenance areas (only Stage I VR applies in the Kansas City ozone maintenance area). However, other state and federal regulations do apply. For more information on these regulations contact the MDOA Division of Petroleum Quality and Inspection at 573-751-4278 for state safety regulations and HWP Tanks Unit for UST regulations at 573-751-3176. Further information can also be obtained from the HWP's newsletter Tank Wise.

5. Where can I get a copy of the Stage I and Stage II regulations for St. Louis and Kansas City?

You may contact the Missouri Secretary of State's office at 573-751-1816 and ask for copies of 10 CSR 10-5.220 for St. Louis and 10 CSR 10-2.260 for Kansas City. You can also find these regulations on the Internet at www.sos.mo.gov/adrules/csr/current/10csr/10csr.asp#10-10

6. How do the booted Stage II VR nozzles work in capturing gasoline vapors?

The boot is part of a balance type VR system. It is located on the outside of the gasoline nozzle spout and seals against the automobile fuel port neck. It makes a continuous pathway from the automobile fuel tank back to the GDF's UST. Coaxial hoses make this pathway possible. The inner portion of the coaxial hose delivers gasoline to the vehicle as the outer portion returns vapors to the vapor plumbing in the dispenser, which goes back to the UST. When you begin to fuel your vehicle, the incoming fuel pressurizes the fuel tank of your vehicle. This pressurization in the vehicles fuel tank is equalized by vapor being drawn out of the vehicles fuel tank and back into the GDF's UST where a vacuum has occurred due to the removal of fuel that was dispensed into the vehicle's fuel tank. This happens on approximately a one-to-one volume basis. If you fuel your vehicle with 10 gallons of gasoline, then the equivalent volume of 10 gallons of vapor is returned to the GDF's UST.

7. How does the state ensure that the VR systems are maintained in working order?

Local air pollution control agency staff inspect Stage II VR GDFs twice a year. These inspections look for defective equipment, required permits and general compliance with Stage I and Stage II VR regulations. If defects are found that would significantly affect the efficiency of the VR system, these nozzles or equipment are "tagged out" of service by the inspector. Local agency inspectors must re-inspect and remove tag outs before GDFs can put the equipment back in service. If the GDF allows dispensing from the tagged out equipment before repair and re-inspection, the department will penalize the GDF for illegal dispensing/pumping. It is the station owner or operator's responsibility to "lock down" the defective equipment until cleared by the local agency inspector. At this time, the department does not place penalties on station owners for Notice of Violations issued for defective equipment unless the station pumps or uses the tagged out equipment before inspector clearance.

8. How can Stage II GDF owners get the tags removed from their nozzles after an inspection?

The station owner or operator needs to immediately repair or replace the defective equipment. After repair or replacement the station owner or operator should contact their local air pollution control agency, either St. Louis City Air Pollution Control, St. Louis County Department of Health, or the Stage II unit at MODNR's St. Louis Regional Office and inform them the repairs have been made and request a re-inspection. After re-inspection and confirmation that all repairs have been made in an appropriate manner, the inspector will remove the "tag out." The station owner or operator may return the equipment to service at that time.

St. Louis City, Division of Air Pollution Control, Stage II Unit, 314-613-7300
St. Louis County, Air Pollution Control Section, Stage II Unit, 314-615-8923
MODNR, St. Louis Regional Office, Stage II Unit, 314-416-2960

9. Can a GDF face enforcement action for dispensing gasoline from a nozzle that was "tagged out" of service?

Yes. Any GDF owner or operator who illegally dispenses gasoline from a nozzle that was tagged out of service can face enforcement action. Tagged out equipment must be re-inspected by the local air pollution control agency and the tag out removed by an inspector before the equipment can be put back in service.

10. What is Missouri Performance Evaluation Testing Procedures (MOPETP)?

The MOPETP is a bank of individual test procedures that apply to manufacturers of VR systems and components. The MODNR uses these test procedures to evaluate the overall efficiency and performance of the various types of gasoline VR equipment and systems. GDFs use these systems to control the emission of gasoline vapors during the refueling of automobiles Only CARB-certified (current CARB-EVR) and MOPETP-approved VR systems and components with current CARB certification and MOPETP approval can be used by GDFs in the St. Louis ozone maintenance area.

MOPETP Approval Components List PDF

11. Why was the MOPETP program started?

The department established the MOPETP program to ensure the efficiency and overall performance of VR systems and equipment installed in Missouri. Missouri has varying climatic conditions that differ greatly from California's climatic conditions. CARB certifies VR equipment under California's climatic conditions. Therefore, to ensure that VR systems and equipment will function properly in Missouri, further testing is required.

12. What is a MOPETP approval?

13. What is the California Air Resources Board (CARB)?

CARB is the state agency that originally started VR as a control measure to reduce VOCs, a precursor to ground level ozone. CARB is also responsible for establishing the original "Certification Procedures" for the various VR systems and components.

California Air Resources Board (CARB)
(CARB) What's New In Vapor Recovery
The California Air Pollution Control Officers Associations (CAPCOA)

14. What is the Technical Review Committee?

The Technical Review Committee (TRC) is a creation of MOPETP. The intent of the TRC is to provide a panel of qualified experts to listen to the requests of VR system and component manufacturers and petroleum equipment contractors. The panel collects information and advises the staff director on technical decisions involving the applicability of the various tests needed to demonstrate compliance with Missouri requirements for control efficiency. The TRC is made up of representatives from APCP, SLRO, St. Louis City Division of Air Pollution Control, St. Louis County Department of Health Air Pollution Control Section, MODNR's oversight contractor, and VR equipment manufacturers. Representatives from petroleum equipment contract companies and other interested parties also routinely attend.

15. What is the Stage II VR Advisory Group?

Missouri State Air Regulation 10 CSR 10-5.220 "Control of Petroleum Liquid Storage, Loading and Transfer" established the Stage II Vapor Recovery Advisory Group. The Stage II Advisory Group members include representatives from the various organizations, which are influenced by Stage II regulations. This group discusses issues of importance to the regulated community and makes recommendations to the staff director.

16. What is a VR system?

A VR system is a collection of petroleum equipment components specifically manufactured to capture and control gasoline vapors. There are two basic types of VR systems: Balance and Vapor Assist systems. The Balance system uses only natural forces to move vapor from the vehicle tank to the UST. The Vapor Assist systems use an active vapor pump to draw vapor back into the UST. Each system is made up of dozens of components all made by various manufacturers. Currently only Balance VR systems are approved in Missouri. See diagrams of both systems in the MOPETP section.

17. What is a VR component?

A VR component is a single unit of a petroleum VR system. Examples of individual components are VR nozzles, coaxial hoses, dispensers, breakaways, check valves, VR plumbing, etc.

Stage II Vapor Recovery Enforcement Policy - Husky 3360 Breakaway Identification PDF
Stage I/II Vapor Recovery Enforcement Policy - Expiration of Vapor Recovery Components PDF
Permit Violations Guide PDF
Self Inspection Example PDF
Self Inspection Table PDF

18. What are nonattainment and maintenance areas?

A nonattainment area is an area that has failed to attain the air quality standards set in the NAAQS for a certain air pollutant, in this case ground-level ozone. This ozone standard is health-based. In comparison, a maintenance area is an area that once was a nonattainment area but EPA has reclassified the area as reaching attainment for the ground-level ozone standard. In order to ensure that a maintenance area stays in attainment for the ozone standard, EPA requires a maintenance plan for the area. This plan outlines what actions the area will take to stay in compliance with ground-level ozone standards. For more information visit www.epa.gov/airprogm/oar/oaqps/gooduphigh/

FAQ - Stage I VR requirements for gasoline delivery vessels

Do gasoline delivery vessels require a Stage I VR system?
What are the testing requirements for a gasoline delivery vessel?
What is an illegal drop?
Will enforcement action be taken for an illegal drop?
Will enforcement action be taken for failure to have method 27, method 27 paperwork, and MOSticker on the truck?

1. Do gasoline delivery vessels require a Stage I VR system?

Yes. If the owner or operator of a gasoline delivery vessel wishes to operate a gasoline delivery vessel that is loaded or unloaded in the St. Louis or Kansas City ozone maintenance areas, the delivery vessel must be equipped with proper Stage I VR. Further, if the gasoline delivery vessel loads at a bulk plant or terminal regulated by 40 CFR Port 60, Subport XX or Port 63, Subport R, the vessel must be equipped with Stage I Vapor Recovery. Also, all gasoline delivery vessels operating in the St. Louis or Kansas City ozone maintenance areas must have a valid tank tightness sticker for Missouri. Tank tightness stickers are attached to delivery vessels and provide proof that the gasoline delivery vessel has passed all necessary Federal Testing Regulations concerning gasoline delivery vessels equipped with Stage I VR. The APCP issues tank tightness stickers. See testing requirements below for further information on tank tightness stickers.

2. What are the testing requirements for a gasoline delivery vessel?

Gasoline delivery vessels that operate in the St. Louis and Kansas City ozone maintenance areas are required to test annually to demonstrate compliance with the test method specified in 40 CFR part 63, subpart R, section 63.425(e). Once a gasoline delivery vessel successfully passes annual testing, the owner or operator of the vessel must submit the results to APCP on a Tank Tightness Sticker application. The APCP will review the application and will issue a sticker. Note: Missouri also accepts the Illinois EPA and the Kansas Department of Health and Environment versions of the tank tightness (pressure/vacuum) test certificate application. But in this case the delivery vessel must still have a Missouri Sticker.

3. What is an illegal drop?

An illegal drop is when a gasoline delivery vessel unloads gasoline at a GDF inside the St. Louis or Kansas City ozone maintenance areas without properly using Stage I VR. Drivers must use one vapor return line per gasoline product line during stage I VR bulk gasoline deliveries. Vapor return lines must be no smaller than three inches in inside diameter and product lines must be no larger than four inches in inside diameter.

4. Will enforcement action be taken for an illegal drop?

Yes. The department will take enforcement against gasoline delivery companies drivers that fail to properly use Stage I VR when unloading gasoline at a GDF. Gasoline delivery vessel drivers and GDF owner or operators may also be held responsible for illegal drop violations and enforcement action may be taken.

5. Will enforcement action be taken for failure to have method 27, method 27 paperwork and MOSticker on the truck?

Yes.

Acronyms

APCP - Missouri Department of Natural Resources - Air Pollution Control Program
CAPCOA - California Air Pollution Control Officers Association
CARB - California Air Resource Board
FAQ - Frequently Asked Questions
GDF - Gasoline Dispensing Facility
HWP - Hazardous Waste Program
MDOA - Missouri Department of Agriculture
MOPETP - Missouri Performance Evaluation Testing Procedures
NOx - Nitrogen Oxides
SLRO - Missouri Department of Natural Resources - St. Louis Regional Office
EPA - U.S. Environmental Protection Agency
UST - Underground Storage Tank
VA - Vapor Assist
VOC - Volatile Organic Compounds
VR - Vapor Recovery

Contacts

Missouri Department of Natural Resources - Air Pollution Control Program (APCP)
Compliance and Enforcement Section, subject - Vapor Recovery or MOPETP 573-751-4817 or
fax 573-751-2706

Missouri Department of Natural Resources - St. Louis Regional Office (SLRO), Stage II Unit
314-416-2960 or fax 314-416-2970

City of St. Louis - Division of Air Pollution Control, Stage II Unit
314-613-7300 or fax 314-613-7275

St. Louis County Department of Health - Air Pollution Control Section, Stage II Unit
314-615-8923 or fax 314-615-8951

Missouri Department of Natural Resources - Hazardous Waste Program (HWP), Tanks Unit
(UST regulations) 573-751-3176

Missouri Department of Agriculture - Division of Petroleum Quality and Inspection
573-751-4278

Links

California Air Resources Board (CARB)

CARB - What's New In Vapor Recovery

The California Air Pollution Control Officers Associations (CAPCOA)

Missouri Department of Agriculture- Division of Petroleum Quality and Inspection

Missouri Department of Natural Resources' Hazardous Waste Program (MDNR- HWP)

Petroleum Storage Tank Insurance Fund (PSTIF)

Missouri Petroleum Marketers and Convenience Store Association (MPCA)