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As of Feb. 1, 2019, St. Louis County no longer oversees the requirements of 10 CSR 10-5.220. All inquiries regarding 5.220 should be should be directed to the department.

Vapor recovery is the capture of gasoline vapors released from various activities into the atmosphere. Vapor recovery programs in Missouri are key components of plans to address ozone pollution in the St. Louis ozone nonattainment area and the Kansas City ozone maintenance area. Information in the links below explains vapor recovery in general and gives specific guidelines for programs here in Missouri.

Vapors emitted by gasoline contain high levels of volatile organic compounds. When mixed with sunlight and heat, these pollutants aid in the formation of ground-level ozone. While effective in protecting Earth in the stratosphere, ozone is harmful to humans, animals and vegetation at the Earth’s surface. For more information regarding ground-level ozone and its effects, visit EPA's Ozone - Good Up High, Bad Nearby webpage.

Capturing gasoline vapors during loading and refueling prevents the release of these vapors into the atmosphere. This is known as vapor recovery. Two different kinds of vapor recovery exist: Stage I and Stage II. Only Stage I vapor recovery is used in Missouri.

Stage I vapor recovery controls the release of gasoline vapors when tanker trucks receive or deliver gasoline. In the above image, black arrows represent gasoline flowing into a gasoline storage tank while orange arrows represent vapors forced from the tank back into the truck. The truck takes these vapors back to the terminal where they are burned off or condensed back into gasoline. Note that the tanker truck fills the gasoline storage tank at the bottom of the tank to further minimize gasoline vapor emissions by eliminating splashing and turbulence.

Stage I vapor recovery also controls the release of gasoline vapors from storage tanks at bulk plants and terminals.

EPA created an informational video describing Stage I gasoline filling requirements according to federal regulations; it does an excellent job of illustrating components of a typical Stage I system.

Stage I Vapor Recovery

stage i vapory recovery diagram

Graphic image credit: Connecticut Department of Energy and Environmental Protection Gasoline Dispensing Facilities

Vapor recovery programs regulate the release of gasoline vapors from various activities into the atmosphere. Vapor recovery programs in Missouri are key components of the state implementation plans (SIPs) that the department has with the U.S. Environmental Protection Agency (EPA) designed to manage ozone concentrations in the St. Louis and the Kansas City areas.

Vapor recovery is also required at many stations outside the Kansas City and St. Louis areas due to promulgation of federal maximum achievable control technology (MACT) standards. See below for more information about these federal standards.

 

Kansas City Area (Clay, Jackson and Platte counties) Stage I Vapor Recovery at Gasoline Dispensing Facilities

Unless otherwise exempt, owners/operators of gasoline storage tanks in the Kansas City area are regulated by 10 CSR 10-2.260. An amendment to 10 CSR 10-2.260 “Control of Emissions During Petroleum Liquid Storage, Loading and Transfer” became effective Feb. 28, 2019. The amended language is available online.

Under the amended regulation:

  • Subject gasoline storage tanks greater than 550 gallons and less than 40,000 gallons in the Kansas City area are required to have California Air Resources Board or department approved pressure/vacuum valves installed on all tank vents.
  • Subject gasoline storage tanks greater than 2,000 gallons are required to be equipped with a vapor recovery system that demonstrates 90 percent collection efficiency. Owners/operators must pass a pressure decay test on all Stage I vapor recovery systems upon installation and again every six years. Additionally, owners/operators must pass a pressure/vacuum valve test at the time of installation and every three years thereafter.

See the Gasoline Dispensing Facilities webpage for more information regarding the amendment.

 

St. Louis Area (Franklin, Jefferson, St. Charles and St. Louis counties and the City of St. Louis) Stage I Vapor Recovery at Gasoline Dispensing Facilities

Unless otherwise exempt, owners/operators of gasoline storage tanks in the St. Louis area are regulated by 10 CSR 10-5.220. An amendment to 10 CSR 10-5.220, "Control of Emissions During Petroleum Liquid Storage, Loading and Transfer" became effective March 30, 2019. The amended regulation is available online.

Under the amended regulation:

  • Subject gasoline storage tanks with a capacity greater than 550 gallons and less than or equal to 1,000 gallons are required to have California Air Resources Board or department approved pressure/vacuum valves installed on all tank vents.
  • Subject gasoline storage tanks with a capacity greater than 1,000 gallons and less than 40,000 gallons must have a Stage I vapor recovery system that demonstrates 98 percent collection efficiency. Owners/operators must submit a notification prior to constructing/modifying a Stage I vapor recovery system. Complete replacements or new installations require testing after the project is complete. Additionally, owners/operators must pass a pressure decay test and pressure/vacuum valve test every three years.

See the Gasoline Dispensing Facilities webpage for more information regarding the amendment.

Federal Regulations 40 CFR 63 Subparts BBBBBB (6B) and CCCCCC (6C)

These federal regulations are applicable to all Missouri terminals and bulk plants (6B) and to all gasoline dispensing facilities (6C). The St. Louis area is currently in compliance due to the SIP-required vapor recovery program. While most Kansas City stations in compliance with the state regulation were in compliance with this federal regulation, some may have required additional controls. The final compliance date for all sources was Jan. 10, 2011.

The state of Missouri has not adopted enforcement delegation for these regulations. Therefore, please direct any questions regarding these regulations to EPA Region 7. Basic information regarding 6B and 6C is located on EPA’s Area Source Standards website.

Kansas City Area (Clay, Jackson and Platte counties)

Unless otherwise exempt, under the most recent amendment to 10 CSR 10-2.260, owners/operators with tanks between 550 gallons and 40,000 gallons in the Kansas City area, are required to use pressure/vacuum valves that are California Air Resources Board (CARB) certified or department approved. The pressure/vacuum valve must have a positive pressure setting of 2.5 to 6.0 inches of water column and a negative pressure setting of 6.0 to 10.0 inches of water. Following is a list of the pressure/vacuum valves that are approved for use in the area:

Pressure/Vacuum Vents +

  • FFS P/V Zero
  • Husky 4885
  • Husky 5885
  • OPW 623V
  • OPW 723V
  • Morrison Brothers model 948A

St. Louis Area (Franklin, Jefferson, St. Charles and St. Louis counties and the City of St. Louis)

Unless otherwise exempt, under the most recent amendment to 10 CSR 10-5.220, owners/operators in the St. Louis area have gasoline storage tanks with a capacity greater than 1,000 gallons and less than 40,000 gallons are required to install a Stage I vapor recovery system that demonstrates 98 percent collection efficiency.

The gasoline storage tank must be equipped with Enhanced Vapor Recovery (EVR) components that are approved by a CARB Executive Order or that are approved by the Air Pollution Control Program as having a collection efficiency of 98%. See the CARB Executive Orders online. The gasoline storage tank must include the following EVR components:

  • A rotatable product adaptor.
  • A product adaptor dust cap.
  • A rotatable vapor recovery adaptor.
  • A vapor recovery dust cap.
  • A product spill container.
  • A drop-fill tube or drop-fill tube with overflow prevention.
  • Any other component that is newly installed but not listed above must be EVR approved if an EVR equivalent is available.

In 2016, the department started an implementation schedule for installation of 98 percent efficient Stage I gasoline vapor recovery equipment that would coincide with updates to the Hazardous Waste Program rule.

Owners/operators must follow the EVR implementation schedule below:

  • Starting Jan. 2, 2019, all Stage I vapor recovery components must be compliant with the rule for any owner/operator that modifies a Stage I vapor recovery system or performs a required pressure decay test. At a minimum, an owner/operator must replace all non-EVR components in the list above prior to completing the construction project or required testing.
  • By Dec. 31, 2020, all Stage I vapor recovery equipment required in the list above must be compliant with 10 CSR 10-5.220.

It is important to note that the Hazardous Waste Program has revised their underground storage tank regulations. In order to be in compliance with this Hazardous Waste Program rule revision, some gasoline dispensing facilities in the St. Louis area may be required to replace some components of their Stage I vapor recovery system, such as drop fill tubes or spill buckets. The Air Pollution Control Program is committed to coordinating with the Hazardous Waste Program on these issues. When it is practical, and makes sense, the requirement to replace existing stage I vapor recovery equipment will be coordinated with the requirement to replace other equipment as required by the Hazardous Waste Program revised rule. In these cases, deviation from the compliance schedule outlined above may be appropriate. This will be considered on a case by case basis.

Also under the most recent amendment to 10 CSR 10-5.220, subject owners/operators of storage tanks in the St. Louis area must vent the tanks via a conduit that is equipped with a pressure/vacuum valve that is EVR certified by CARB or equivalent as approved by the director. The pressure/vacuum valve must have a positive pressure setting of 2.5 to 6.0 inches of water column and a negative pressure setting of 6.0 to 10.0 inches of water.

The following list includes components that are approved for use in the St. Louis area:

Ball Float +

OPW 61VSA-MA (GAS/E85)
Universal Model 37

Bladder Plug +

McGard PSI104

Drain Valve Kit +

CNI Mfg. RP12-Push
EBW 705-337-19
EBW 70533729 (Gas)
EBW 708-255-01 DrainValve Isolation Kit
EBW 90022 Drain Valve Blank
EBW 90079 Isolation test kit
EBW 90089 Drain Valve Security Blank Kit
EMCO Model 494118
OPW 1DK-2100 (GAS/E85)
OPW 1DP-2100 Drain Plug Kit
Phil-Tite 85400 (Gas/E85)

Drop Tube (components) +

CNI Mfg. DT100 (various lengths)
CNI Mfg. DT101 Drop Tube O Ring (original)
CNI Mfg. RP101 Drop Tube O Ring (replacement)
EBW 782-2041X-2
EBW 782-204-3X2 (Gas/E85)
EMCO Model A0020EVRC-X
EMCO Model A0020EVR-X
EMCO Wheaton Retail Drop Tube O Ring 569461
FFS 70550901EC (Drop tube Riser clamp)
OPW 61T (various lengths)
OPW 61T-SS (various lengths) (GAS/E85)

Drop Tube with Device to Prevent Overfill +

EBW Defender Series OPV 70859X9YZ
EBW 708 49X 1Y (Gas)
EBW 708-49X-3Y (Gas/E85)
EBW 90079 Drop Tube Isolation Test Kit
EMCO Model A1100EVR-X
OPW 61SO
OPW 61SOM-412C-EVR (GAS/E85)
OPW 71SO
OPW 71SO Testable
OPW 71SOM-412C (GAS/E85)

Extractor Valve +

OPW 233-series (-4432 tested)
Universal Model V421

Face Seal Adaptor +

OPW FSA-400
OPW FSA-400-S (Gas/E85)

Fuel Lock +

McGard FL1 – Standard Fuel Lock (125007)
McGard FL1 – Standard Fuel Lock (125007)
McGard FL2 – Sampling Fuel Lock 25008
McGard FL2 – Standard Fuel Lock (125008)

Jack Screw Kit +

OPW 61JSK-4410
OPW 61JSK-44CB
OPW 61JSK-4RMT (Only Used on Remote Fill)
OPW 71JSK-44MA (GAS/E85)
OPW 71JSK-4RMT (GAS/E85)

Pressure Vacuum Vent +

FFS P/V Zero
Husky 4885
Husky 5885
OPW 623V
OPW 723V
Morrison Brothers model 948A

Product Adaptor +

EMCO A0030-124S
OPW 61SALP-1020-EVR
OPW 61SALP-MA (Gas/E85)
Phil-Tite SWF-100-B (Gas)
Phil-Tite SWF-100-SS (Gas/E85)

Riser Components +

EMCO Model 494096
Phil-Tite M/F 4X4* (Gas/E85)
Phil-Tite M/F 4X4-R* (Gas/E85)
Phil Tite M 1600 (Riser Support Bracket)
Phil-Tite M-6050 Riser Offset

Spill Container +

CNI 205P - Product Assembly - 5 gal
CNI 205V - Vapor Assembly
CNI 214P - Product Assembly - 5 gal
CNI 214V - Vapor Assembly - 5 gal
CNI CON1-31103
CNI CON2-31103
CNI Mfg. GAC Gravity Cover
CNI Mfg. STP-200 Snap Tight Cover
CNI Mfg. STP-39 Snap Tight Cover Ring
EBW 7054401X (lid)
EBW 7XX-49Y-0Z
EBW 90087 Upgrade Kit (product)
EBW 90088 Upgrade kit (vapor)
EBW Defender 705 Series*
EMCO Model A1004EVR-X Series
OPW 1-2100 Series
OPW 1-2200 Series
OPW 1-3100 Series
OPW P500 Series
OPW P700 Series
Phil-Tite 85000 Series (Gas/E85)
Phil-Tite 85011* Spill Container Lid (Gas/E85)

Tank Bottom Protector + 

PHIL-TITE TBP-3516-E (Gas/E85)

 Tank Gauge (in tank probe cap and adaptor) +

CNI Mfg. 613BC set (Cap 64, Adaptor 613)
EBW 90037 (In Tank Probe Cap and Adaptor Kit) (Gas)
EBW 90037-E (In Tank Probe Cap and Adapter Kit) (Gas/E85)
EMCO Model A0030-014 (Adaptor)
EMCO Model A0097-010 (Cap)
Morrison Brothers 305-0200AAEVR (replacement adaptor) (Gas/E85)
Morrison Brothers 305XP-110ACEVR (replacement cap) (Gas/E85)
Morrison Brothers 305XPA1100AKEVR (cap and adaptor kit) (Gas/E85)
OPW 62M-MA (GAS/E85)
Veeder-Root 312020-952 (cap and adaptor kit) (Gas/E85)

Vapor Adaptor +

EMCO Model A0076-124S
Emco Wheaton Retail A0076-124
OPW 61VSA
OPW 61VSA-MA (GAS/E85)
Phil-Tite SWV-101-B (Gas)
Phil-Tite SWV-101-SS (Gas/E85)

Vapor/Product Dust Cap +

CNI Mfg. 611-VR-3 (vapor)
CNI Mfg. 64 (product)
CNI Mfg. 65 Dust Cap Gasket
CNI Mfg. RP65 (Dust cap gasket replacement)
CompX CSP1-634LPC
CompX CSP2-634LPC (product)
CompX CSP3-1711LPC (vapor)
CompX CSP4-1711LPC (vapor)
EBW 304 301 XX (vapor) (Gas)
EBW 304-200-XX (vapor) (Gas)
EBW 777-201-02 (product) (Gas)
EBW 777-202-02 (product) (Gas/E85)
EMCO MODEL A0097-005 (product)
EMCO Model A0099-X (vapor)
Morrison Brothers 305C-0100ACEVR (product) (Gas/E85)
Morrison Brothers 323C-0100ACEVR (vapor) (Gas/E85)
OPW 1711LPC (vapor) (GAS/E85)
OPW 1711T-EVR (vapor) (GAS/E85)
OPW 634LPC (product) (GAS/E85)
OPW 634TT-EVR (product) (GAS/E85)

As a facility owner, there are many different regulations with which to comply. Below is information about the air regulations that we hope you find helpful. If you have any questions regarding these regulations, contact your local department office.

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 to or neglect of the equipment.

Department Inspections

Periodically, your local office inspectors will inspect your station. They typically will look at all of your equipment, and they may ask to see your recordkeeping. When finished, the inspector should discuss their findings with you and give you a copy of the inspection report.

Gasoline Deliveries

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

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 department local office.

Kansas City Area (Clay, Jackson and Platte counties)

Unless otherwise exempt, the most recent amendment to 10 CSR 10-2.260 requires owners/operators of gasoline storage tanks with capacities greater than 2,000 to pass a pressure decay test and a pressure/vacuum valve test at the time of installation. Thereafter, the owner/operator must pass a pressure decay test once every six years and a pressure/vacuum valve test once every three years. Notification at least seven days in advance of testing is required to allow an observer the opportunity to be present. All results should be sent to the appropriate local office no later than 14 days following completion of the testing.

Owners/operators of any gasoline storage tank between 250 gallons and 2,000 gallons pressure/vacuum valve are no longer be required to pass a pressure/vacuum valve test under the amendment.

Missouri performance testing evaluation procedures (MOPETP) are no longer approved methods for compliance. Please click the links for the department approved pressure decay test and pressure/vacuum valve test methods.

St. Louis Area (Franklin, Jefferson, St. Charles and St. Louis Counties and the City of St. Louis)

Unless otherwise exempt, the most recent amendment to 10 CSR 10-5.220 requires owners/operators of gasoline storage tanks between 1,000 gallons and 40,000 gallons, with new Stage I vapor systems or Stage I vapor recovery systems that are completely replaced, to conduct a pressure decay test and a pressure/vacuum valve test within 30 days of construction completion. Testing is not required following partial modifications to Stage I vapor recovery system or as a result of breaking concrete near a Stage I vapor recovery system. Thereafter, owner/operators must pass a pressure decay test and a pressure/vacuum valve test at least once every three years. A notification of at least seven days prior to the test date is required in order to allow an observer to be present. The results must be provided to the department within 14 days of the test event.

Please click the links for the department approved pressure decay test and pressure/vacuum valve test methods.

Permits/Notifications

St. Louis Area (Franklin, Jefferson, St. Charles and St. Louis Counties and the City of St. Louis)

Unless otherwise exempt, under the most recent amendment to 10 CSR 10-5.220, construction notifications are required for new installations, complete replacements, and partial modifications of Stage I vapor recovery systems. All work described in the notification must be completed within 180 days of the department receiving the notification. The currently approved notification form is available online. A passing department approved pressure/vacuum valve and pressure decay test is required following a new installation or a complete replacement of a Stage I vapor recovery system within 30 days of construction completion.

Reid Vapor Pressure and Reformulated Gasoline

Kansas City Area (Clay, Jackson and Platte counties)

An amendment to 10 CSR 10-2.330, "Control of Gasoline Reid Vapor Pressure" became effective on July 30, 2013. The regulation stipulates that from June 1 through Sept. 15, no one may sell, dispense or transport gasoline exceeding the stated limit for reid vapor pressure. Gasoline blends with an ethyl alcohol content of up to 9 percent must have a reid vapor pressure of 7.0 psi or lower. Blends with an ethyl alcohol content of 9 to 10 percent may have a reid vapor pressure of up to 8.0 psi. To access the regulation click here. The Missouri Department of Agriculture’s Fuel Quality Program tests gasoline samples and shares the results with the department.

St. Louis Area (Franklin, Jefferson, St. Charles and St. Louis Counties and the City of St. Louis)

Gasoline facilities in the St. Louis area must sell reformulated gasoline, which is part of a federally regulated program.

Both Kansas City (Clay Jackson, and Platte Counties) and St. Louis (St. Louis City, and Jefferson, St. Charles, Franklin, and St. Louis Counties) area regulations generally require Stage I vapor recovery on large capacity gasoline storage tanks and gasoline loading racks. In addition, all delivery vessels loading or unloading at subject facilities must be equipped with Stage I vapor recovery and have a current, and passing, EPA Method 27 Tank Tightness Test. See Delivery Vessels for more information regarding compliance requirements.

The requirements for low throughput exemptions for bulk plants changed under the 2019 amendments to 10 CSR 10-5.220 “Control of Emissions During Petroleum Loading, Storage and Transfer” and 10 CSR 10-2.260 “Control of Emissions During Petroleum Loading, Storage and Transfer.” Under the amendments, if a bulk plant has an average monthly throughput of less than 120,000 gallons, the plant is eligible for a low throughput exemption from specific requirements of Stage I vapor recovery regulations on its loading rack and outgoing delivery vessels. The amendments require tracking of the gasoline throughputs; however, an annual request to the department is not required. Download a department approved throughput tracking form. The form must be made available to the department upon request. Additionally, the amendments do not permanently prohibit bulk plants from qualifying for the exemption after exceeding the low throughput criteria.

Stage I Vapor Recovery Requirements for Gasoline Delivery Vessels

If the owner or operator of a gasoline delivery vessel wishes to load or unload their vessel in the St. Louis area (St. Louis City, and Jefferson, St. Charles, Franklin, and St. Louis Counties) or in the Kansas City area (Clay Jackson, and Platte Counties), the delivery vessel must be equipped with proper Stage I vapor recovery. In addition, if the gasoline delivery vessel loads at a bulk plant or terminal anywhere in Missouri that is regulated by 40 CFR Part 60, Subpart XX or Part 63, Subpart R, the delivery vessel must be equipped with proper Stage I vapor recovery.

Testing Requirements for Gasoline Delivery Vessels

Gasoline delivery vessels that operate in the St. Louis and Kansas City areas are generally 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 keep a copy of the passing test in the cab of the vessel at all times.

Loading/Unloading

Delivery vessels are generally required to utilize vapor recovery equipment when loading the vessel at a bulk plant or terminal and delivering at a facility inside the St. Louis or Kansas City areas. Drivers must use one vapor return line per gasoline product line during Stage I vapor recovery gasoline deliveries. If the facility only has one vapor port, regardless of the number of product ports, the driver may only deliver one product at a time. 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.

Air Pollution Control Program
P.O. Box 176
Jefferson City, MO 65102-0176
Telephone: 573-751-4817
Fax: 573-751-2706

St. Louis Regional Office
7545 S. Lindbergh, Suite 210
St. Louis, MO 63125
Telephone: 314-416-2960
Fax: 314-416-2970

Kansas City Regional Office
500 NE Colbern Road
Lee’s Summit, MO  64086-4710
Telephone: 816-251-0700
Fax: 816-622-7044

Kansas City Department of Health

Air Quality Program
2400 Troost Ave., Suite 3200
Kansas City, MO  64108
Telephone: 816-513-6314
Fax: 816-513-6290

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