Vapor Recovery Program Requirements

Vapor Recovery Information and Compliance Requirements

Vapor Recovery 101

Stage I Vapor Recovery or 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 Gasoline Dispensing Facility, or GDF.

Stage II Vapor Recovery 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 underground storage tank at the GDF. Infared demonstrations of fuel vapors escaping are available online. The storage tank holds the vapors until a gasoline delivery vessel using Stage I VR refills the tank. These vapors are then returned, by way of the gasoline delivery vessel, back to the terminal for processing or destruction. Currently only Balance VR systems are approved in Missouri. Diagrams of both systems are available online.

Areas Required to Maintain Vapor Recovery Systems

Stage I and Stage II VR are required by Missouri Regulation 10 CSR 10-5.220, "Control of Petroleum Liquid Storage, Loading and Transfer,"and are required 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 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. For more information on these regulations see the Code of State Regulations.

A nonattainment area is an area that has failed to attain the health-based National Ambient Air Quality Standards or NAAQS set by EPA for certain air pollutants, in this case ground-level ozone. In comparison, a maintenance area is an area that records air pollutant concentrations at levels at or near the health-based standard and the air quality must be maintained to ensure that the area stays in attainment for the ozone standard. EPA requires the state to develop a maintenance plan for the area as well. 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/.

Vapor Recovery is also required in several outstate areas due to recent promulgation of federal Maximum Achievable Control Technology, or MACT, standards. For more information on these requirements see subparts 6B and 6C on the Area Source Standard page.

Other state and federal regulations may also apply to your facility. For more information on any additional regulations contact the Missouri Department of Agriculture's Division of Petroleum Quality and Inspection at 573-751-4278 for state safety regulations and Hazardous Waste Program's Tanks Unit for Underground Storage Tank regulations at 573-751-3176. Further information can also be obtained from the Hazardous Waste Program's newsletter Tank Wise.

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 or VOC. VOCs, in combination with nitrogen oxide compounds or 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 in St. Louis.
Use of the Missouri Performance Evaluation Testing Procedures or 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.

Missouri Performance Evaluation Testing Procedures

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 or the California Air Resources Board 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.

The MOPETP is a bank of individual test procedures that apply to manufacturers of VR systems and components. The Department 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 and MOPETP-approved VR systems and components with current CARB certification and MOPETP approval can be used by GDFs in the St. Louis nonattainment area.

MOPETP Approval Letters

MOPETP Approved Components List PDF

The Technical Review Committee or 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 air pollution control agencies in the state and VR equipment manufacturers. Representatives from petroleum equipment contract companies and other interested parties also routinely attend. Currently the Vapor Recovery Rules Stakeholder Workgroup is acting in this capacity.

Technical Review Committee Meetings and Minutes

Jan. 28, 2010 - Meeting Announcement

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Vapor Recovery Permitting Requirements

Permitting Requirements for Building a GDF in St. Louis
You must obtain a construction permit from the appropriate air pollution control agency before constructing a GDF in St. Louis. Passing all necessary VR system and components testing is required before obtaining an operating permit. A Stage II VR construction permit is also required anytime a GDF breaks concrete, or asphaltic concrete, over or around the facility's vapor recovery system.

Facilities proposed for construction within St. Louis City must apply to the City of St. Louis Division of Air Pollution Control, 1415 North 13th Street, St. Louis, MO 63106, 314-613-7300.

Facilities constructing within St. Louis County must apply to the St. Louis County Department of Health, Air Pollution Control Section, 111 South Meramec, Clayton, MO 63105, 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, 314-416-2960.

Permitting Requirements for Adding or Replacing a Dispenser or VR equipment in St. Louis
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 St. Louis Regional Office, 314-416-2960.

Stage II Vapor Recovery System Construction/Operating Permit Applications

St. Louis County Application PDF

St. Louis City Application PDF

St. Louis Regional Office Application Adobe PDF/ Fill-in MS Word DOC

Permit Application Timeline
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 orders and MOPETP Approval Letters for the proposed system or components.
A detailed description of the Underground Storage Tanks or USTs being used.
A schedule of the construction.

Construction permits applications may be obtained by contacting the appropriate air pollution control agency above. 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 inspects 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 a current operating permit and maintain it on-site in a prominent location.

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.

Gasoline Bulk Loading Plant Requirements

Stage I VR Requirements for Gasoline Bulk Loading Plants
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 fuel 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 (U.S. EPA Method 27 Tank Tightness Test - Pressure/Vacuum Test Certification Application) to the Air Pollution Control Program.

Delivery Vessel Pressure Test Certification Application, Form--MO 780-1262 (06/09) Adobe PDF / Fill-in MS Word DOC

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.

Request for Exemption Stage 1 Requirement Regulation 10 CSR 10-5.220,
(4) - St. Louis; 10 CSR 10-2.260, (3) - Kansas City Bulk Plants / "Gasoline Loading", Form--MO 780-1528 (06/09) Adobe PDF / Fill-in MS Word DOC

Compliance Testing and Inspection Requirements

St. Louis VR Compliance Requirements
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 a GDF renews 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.

Kansas City VR Compliance Requirements
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.

VR Systems or Components Certification in Missouri
All VR systems and components installed in Missouri must be first CARB-certified and then MOPETP-approved.

VR System Inspections and Tag Out Procedures
DNR and 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, the GDF is issued a Notice of Violation for the defects and the equipment will be "tagged out" of service by the inspector. If GDF equipment is tagged out, the station owner or operator needs to immediately repair or replace the defective equipment. Once repairs or replacements are complete, the station owner or operator should contact the Department or appropriate local agency to re-inspect. Inspectors must re-inspect and remove “tag outs” before the equipment can be put into service. It is the GDF owner or operator's responsibility to ensure the defective equipment remains “tagged out” until cleared by the Department or local agency inspector. If the GDF allows dispensing from the tagged out equipment prior to re-inspection, the Department may pursue further enforcement action, including monetary penalties, in order to penalize the GDF for this illegal dispensing. Generally, the Department does not pursue monetary penalties for Notices of Violation issued for defective equipment unless this illegal dispensing occurs. However, there are certain violations which automatically trigger monetary penalties, such as the use of unapproved equipment, or failure to apply for or comply with a construction or operating permit. Depending on the location of the GDF one of the following offices should be contacted for reinspection:

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.
DNR, St. Louis Regional Office, Stage II Unit, 314-416-2960

Enforcement Memos and Guides

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

Gasoline Delivery Vessel Requirements

Stage I VR Requirements for Gasoline Delivery Vessels
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 Part 60, Subpart XX or Part 63, Subpart 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.

Testing Requirements for Gasoline Delivery Vessels
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 the Delivery Vessel Pressure Test Certification Application, Form--MO 780-1262 Adobe PDF / Fill-in MS Word DOC. The APCP will review the application and will issue a sticker.

Note: Missouri also accepts pressure/vacuum test certificate application from other states as long as that state uses method 27 as the standard. However, the delivery vessel must still have a Missouri sticker.

Illegal Drops and Enforcement Actions
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.

The Department will take enforcement against gasoline delivery company 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. Enforcement actions will also be taken for failure to have method 27, method 27 paperwork and a Missouri sticker on the truck.

Training

Stage II Vapor Recovery Designated Person Certification PDF

Contacts

Missouri Department of Natural Resources - Air Pollution Control Program, Compliance and Enforcement Section, 573-751-4817 or fax 573-751-2706.

Missouri Department of Natural Resources - St. Louis Regional Office, 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, Tanks Unit, 573-751-3176.

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