Air Pollution Control Program

Vapor Recovery Information and Compliance Requirements

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Gasoline Dispensing Facilities

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As a facility owner, there are many different regulations to remain in compliance with. Below is information about the Air Regulations that we hope you find helpful. If you have any questions regarding these regulations, contact your local office.

Self-Inspections

Facility Testing

Gasoline Deliveries

Reid Vapor Pressure

Department Inspections

Equipment Tag-outs

Permitting

Enforcement 


Self-Inspections
The department recommends you inspect your facility at least once a week for an average facility, more for higher throughput facilities. It is also recommended that you inspect your Stage I Vapor Recovery equipment after every delivery as you may be held responsible for any damage or neglect of the equipment. Self-Inspection log example. Records must be kept for two years and made available to department inspectors upon request.

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Facility Testing
The department recommends that all facility testing be done by a third party contractor due to the special equipment and specific test methods required for each test type. For additional information, see the appropriate Vapor Recovery Rule or contact your local office.

Kansas City
Facilities in Kansas City are required to conduct a pressure leak decay test and p/v valve bench test upon startup. Thereafter, the facility must complete a pressure leak decay test once every five years and a p/v valve bench test every two years. Department or City staff must be notified at least seven days in advance of testing to allow for observation. All results should be sent to the appropriate local office following testing.

St. Louis
Facilities in St. Louis must conduct a pressure leak decay test, p/v valve bench test and a backpressure blockage test upon startup. This testing is also required for renewal of an operating permit and after completion of construction. Department or County staff must be notified at least seven days in advance and be present during testing.

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Gasoline Deliveries
While it is mostly the responsibility of the delivery vessel driver to conduct gasoline deliveries in compliance with Missouri Air regulations, the facility may be held responsible as well. See the Delivery Vessels page for more information regarding gasoline delivery compliance.

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Reid Vapor Pressure, or RVP
From June 1 through September 15 of each year, Missouri State Regulation 10 CSR 10-2.330 requires that no person shall sell, dispense, or transport gasoline in the Kansas City ozone maintenance area that exceeds the RVP limit. Gasoline blends with an ethyl alcohol content of up to 9 percent must have an RVP of 7.0 psi or lower. Blends with an ethyl alcohol content of 9-10 percent are allowed an RVP of up to 8.0 psi. Testing for this regulation is conducted by the Department of Agriculture’s Fuel Quality Lab with violations referred to the Air Program for enforcement.

Gasoline facilities located in the St. Louis area are required to sell Reformulated Gasoline, which is a federally regulated program.

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Department inspections
Periodically, your local office inspectors will come out to inspect your station. They will typically take a look at all your equipment and may ask to see your recordkeeping. In the St. Louis area, the inspectors will also verify that the appropriate permits are displayed. When finished, the inspector should discuss their findings with you and give you a copy of the inspection report. If they find any deficiencies, the inspector may issue a Notice of Violation or tag-out some of your equipment.

Depending on the severity of the violation, it may be referred to the department’s Air Pollution Control Program for further enforcement. A copy of the defect and enforcement guide the inspectors use can be found here. This guide may change periodically to reflect policy changes and updates.

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Equipment Tag-outs
Equipment that is found to be in severe non-compliance with the regulations will be tagged-out, putting it out of service. This tag should not be permanently removed by anyone except a department inspector. Contractors may remove the tag to repair the equipment, but must put the tag back on immediately when finished. No gasoline may be dispensed.

As soon as the equipment is repaired, the inspector should be notified to come back and reinspect the equipment. At that time, if the repairs are sufficient, the inspector will remove the tag, putting the equipment back into service. Any equipment that has been tagged out must be reinspected and approved by a department inspector before being put back into service. Failing to follow this procedure will result in a Notice of Violation and referral to the Air Program for enforcement, which will include monetary penalties.

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Permitting
All facilities located in the St. Louis non-attainment area are required to have either a valid operating or construction permit at all times. If your facility is located in St. Louis County, there may be additional requirements to operate your facility. Depending on your facility’s location, you must complete one of the applications below and submit to the appropriate office along with payment. You may apply and pay for a Construction and subsequent Operating Permit on the same application. Directions regarding where to send the completed applications and payment are on the back of each form.

Facilities located in Franklin, Jefferson, or St. Charles counties or the City of St. Louis:
St. Louis Regional Office Vapor Recovery Permit Application

Facilities located in St. Louis County:
St. Louis County Department of Health Vapor Recovery Permit Application

Operating Permits
Your Vapor Recovery Operating Permit is valid to operate your Vapor Recovery system only. You may be required to have other permits from the State for other aspects of your facility.

Your Operating Permit is valid for five years and must be posted at all times. If you apply for a Construction Permit, your current Operating Permit becomes invalid and you must apply for a new one post-construction.

In order to renew your Operating Permit, your facility must pass a pressure leak decay test, p/v valve bench test and a backpressure blockage test. This testing will be observed by either a St. Louis County or department inspector; therefore, you must notify your local office at least seven days in advance of scheduled testing.

Construction Permits
A construction permit is required for most non-maintenance repairs or updates. A complete list of activities that require a Construction Permit can be found here. As always, when in doubt, contact your local office for clarification.

On the back of the permit application is a list of supplemental information required when submitting a construction permit application. Read this list carefully to ensure a smooth application process.

The Construction Permit is valid for one year and must be posted at all times. You are only approved for construction listed on this permit. If at any time you find additional work that needs to be done, contact your local office immediately to amend your permit.

Your Construction Permit acts as your Operating Permit during construction. However, within 30 days of construction completion, you must conduct testing and apply for an Operating Permit. An end of construction inspection is required for most activities, so be sure to keep in contact with your local office about progress and requirements.

On May 16, 2012, the U.S. EPA issued a rule allowing states to phase out their Stage II Vapor Recovery Programs. The department intends to phase out the Stage II program in the St. Louis area as soon as feasible and therefore believes it is not reasonable to require new or reconstructed gasoline dispensing facilities to install Stage II at this time. The department’s full policy can be found here. See the EPA’s Widespread Use Rule page for more information. Note that you must still apply for, and receive, a valid Construction Permit before proceeding without Stage II equipment.

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Enforcement
While the inspections are conducted by your local office, most enforcement action will be initiated from the department’s Air Pollution Control Program. Enforcement action will not be initiated for simple defective equipment; however, there are four violations that trigger automatic enforcement action: illegal dispensing, unapproved equipment, illegal gasoline deliveries, and construction without a permit. In addition, prolonged, excessive, or repeated deficiencies of any type may result in further action.

Illegal dispensing occurs when a piece of equipment has been tagged-out, but the tag is removed and/or gasoline dispensed. It does not matter if the equipment has been repaired; only a department inspector is allowed to remove a tag and put a pump back into service.

As noted in the MOPETP section, all Stage I and Stage II equipment at the facility must be MOPETP approved. If an unapproved piece of equipment is found, the inspector will tag-out the equipment until it is replaced, and will issue a Notice of Violation.

Illegal deliveries occur when a driver either does not use Vapor Recovery equipment at all or dispenses more than one product per vapor hose. Per Missouri Regulations, drivers must use one vapor return line per gasoline product line during Stage I Vapor Recovery gasoline deliveries. This requirement is applicable at all facilities in the St. Louis and Kansas City areas. If the facility only has one vapor port, regardless of the number of product ports, the driver may only load one product at a time. The delivery company, individual driver, and facility owner/operator may all be held responsible for illegal delivery violations.

If construction is discovered at your site without a valid construction permit, or beyond the scope of your current permit, you will be issued a Notice of Violation and referred to the Air Program for enforcement. If you have applied for a permit, you must wait until you receive it before beginning construction. The facility and the contractor will both be held liable and will both be referred for enforcement action.

After a Notice of Violation is referred for enforcement, the case is reviewed by the Compliance/Enforcement section. If it is determined that a monetary penalty is appropriate, you will be contacted by someone in the Enforcement section who will begin the process of negotiating a settlement. If you fail to respond, or we are unable to reach agreement, the facility will be placed on the agenda of the Missouri Air Conservation Commission where the Air Program will seek referral of the case to the Missouri Attorney General’s Office to pursue civil litigation.

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