Vapor Recovery Information and Compliance Requirements
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 aide 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.
Stage I Vapor Recovery
Stage I vapor recovery controls the release of gasoline vapors when tanker trucks deliver gasoline to a local gas station. 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 as well as vapors released during the transfer of gasoline from a terminal to delivery trucks.
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 II Vapor Recovery (Discontinued in Missouri on Dec. 31, 2015)
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 gas station. The above image represents a typical refueling using Stage II. Black arrows represent gasoline pumped from a storage tank to an automobile. Orange arrows show the flow of vapors from the automobile tank back into the storage tank. These vapors are held in the storage tank until the next gasoline delivery when they are returned to the truck.
Stage II vapor recovery is generally categorized by the “boot” on the nozzle that allows it to capture vapors during refueling. The hose used is a coaxial hose specially designed to allow gasoline to flow through an inner hose surrounded by a larger hose that allows vapors to be pushed back down to the storage tank. The California Air Resources Board used an infrared camera in this video to document the release of gasoline vapors from a nonStage II nozzle.
Beginning on Dec.1, 2014, Missouri Air Conservation Commission regulation 10 CSR 10-5.220, “Control of Petroleum Liquid Storage, Loading and Transfer," was changed to no longer allow the installation of new Stage II systems. All affected gas stations were required to remove existing Stage II systems by Dec. 31, 2015. Information regarding the removal of Stage II systems may be found on the department’s widespread use rule webpage.
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) to address the St. Louis ozone nonattainment area and the Kansas City ozone maintenance area.
A nonattainment area is an area that has failed to attain the health-based national ambient air quality standards (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 or near the health-based standard. The air quality must be maintained to ensure the area stays in attainment with the ozone standard. EPA requires the state to develop a maintenance plan for the area. This plan outlines what actions the area will take to stay in compliance with the ground-level ozone standards. For more information regarding ozone, visit EPA's Ozone Information webpage.
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 - Stage I Vapor Recovery
Clay, Jackson and Platte counties
Gas stations in the Kansas City ozone maintenance area are regulated by the Missouri Air Conservation Commission. To access "Control of Petroleum Liquid Storage, Loading, and Transfer,” go to page 16 of 10 CSR 10-2.260. Under this regulation, all gasoline storage tanks greater than 250 gallons in the Kansas City area are required to install MOPETP approved pressure/vacuum (P/V) valves on all tank vents. In addition, storage tanks greater than 2,000 gallons must be equipped with a vapor recovery system that demonstrates 90 percent collection efficiency. Facilities must perform a leak decay test on all Stage I vapor recovery systems upon installation and again every five years in addition to testing of all P/V valves before installation and every two years thereafter. See the Gasoline Dispensing Facilities webpage for more information regarding facility compliance.
St. Louis Area - Stage I and II Vapor Recovery
Franklin, Jefferson, St. Charles and St. Louis counties and the City of St. Louis
Gas stations in the St. Louis ozone nonattainment area must abide by Missouri Air Conservation Commission regulation 10 CSR 10-5.220, "Control of Petroleum Liquid - Storage, Loading and Transfer." To access the regulation, click here and go to page 7. Under this regulation, all gasoline storage tanks with a capacity greater than 500 gallons and less than or equal to 1,000 gallons in the St. Louis area must install approved pressure/vacuum (P/V) valves on all tank vents. In addition, gasoline underground storage tanks (USTs) 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. These facilities are also subject to a permitting program. In order to obtain an operating permit, gasoline dispensing facilities must conduct and pass a static leak decay test and a bench test of the pressure/vacuum valve(s). For more information regarding facility compliance, visit the Gasoline Dispensing Facilities webpage.
In previous years, gasoline dispensing facilities in the St. Louis ozone nonattainment area had to install and operate Stage II vapor recovery . Recent revisions to 10 CSR 10-5.220 "Control of Petroleum Liquid - Storage, Loading and Transfer" removed the requirement for Stage II vapor recovery. All affected gas stations were required to remove Stage II vapor recovery equipment by Dec. 31, 2015. For more information about the removal of Stage II vapor recovery equipment, please visit the department’s Widespread Use Rule webpage.
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
Gas stations in the Kansas City ozone maintenance area are required to use pressure/vacuum valves that are CARB certified and MOPETP approved, or are otherwise approved for use in the area by the Air Pollution Control Program. Following is a list of the pressure/vacuum valves that are approved for use in the area:
Pressure/Vacuum Vents +
St. Louis Area:
Gas stations in the St. Louis ozone nonattainment area that have gasoline underground 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 following list gives Stage I vapor recovery components that have demonstrated 98 percent collection efficiency; the components have received approval for use in the area.
Ball Float +
Bladder Plug +
Drain Valve Kit +
Drop Tube (components) +
Drop Tube with Device to Prevent Overfill +
Extractor Valve +
Face Seal Adaptor +
Fuel Lock +
Jack Screw Kit +
Pressure Vacuum Vent +
Product Adaptor +
Riser Components +
Spill Container +
Tank Bottom Protector +
Tank Gauge (in tank probe cap and adaptor) +
Vapor Adaptor +
Vapor/Product Dust Cap +
Note: Missouri performance evaluation testing procedures (MOPETP) is a collection of individual test procedures applied to manufacturers of vapor recovery systems and components to ensure the efficiency and overall performance of equipment installed in Missouri. Since Dec. 1, 2014, MOPETP has not been applicable to gasoline dispensing facilities in the St Louis nonattainment area. MOPETP is still applicable to the Kansas City maintenance area.
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.
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.
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.
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.
Facilities in St. Louis must conduct a pressure leak decay test (CARB TP 201.3) and P/V valve bench test (CARB TP 201.1E) 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 of testing to allow for observation.
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.
Reid Vapor Pressure, or RVP
Missouri stipulates that from June 1 through September 15 in the Kansas City ozone maintenance area, no one may sell, dispense or transport gasoline exceeding the stated limit for reid vapor pressure. To access regulation 10 CSR 10-2.330, click here and go to page 22 for "Control of Gasoline 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. The Missouri Department of Agriculture’s Fuel Quality Program tests gasoline samples and refers violations to the Missouri Department of Natural Resources' Air Pollution Control Program for enforcement.
Gasoline facilities in the St. Louis area must sell reformulated gasoline, which is part of a federally regulated program.
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. In the St. Louis area, the inspectors also will 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.
Equipment found in severe noncompliance 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 equipment, but they must replace the tag immediately when finished.
As soon as equipment is repaired, the inspector should be notified to return and reinspect the equipment. At that time, if repairs are sufficient, the inspector will remove the tag, returning the equipment to service. Any equipment that has been tagged out must be reinspected and approved by a department inspector before it can return to service. Failing to follow this procedure will result in a notice of violation and referral to the air program for enforcement, which includes monetary penalties.
All facilities located in the St. Louis non-attainment area are required to have either a valid operating permit, construction permit, or construction permit notification 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 the relevant application below and submit it to the appropriate office along with payment. You may apply and pay for a construction permit or construction permit notification 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 St. Louis City:
St. Louis Regional Office Vapor Recovery Permit Application
Facilities located in St. Louis County:
St. Louis County Department of Health Vapor Recovery Permit Application
Your operating permit for vapor recovery 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 three years, and it must be posted at all times. If you apply for a construction permit or construction permit notification, your current operating permit becomes invalid, and you must apply for a new one post-construction.
In order to renew your operating permit for vapor recovery, your facility must pass a pressure leak decay test and p/v valve bench test. Department or county staff must be notified at least seven days prior to scheduled testing to allow for observation of the tests.
A construction permit or construction permit notification 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 department office for clarification. On the back of the permit application is a list of supplemental information required when submitting a construction permit application or construction permit notification. Read this list carefully to ensure a smooth application process.
The construction permit or construction permit notification is valid for one year, and it must be posted at all times. You are only approved for construction listed on this permit or notification. If at any time you find additional work that needs to be done, contact your local department office immediately to amend your permit or notification.
Your construction permit or construction permit notification acts as your operating permit during construction. However, within 30 days of the completion of construction, 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 department office about progress and requirements.
On May 16, 2012, EPA issued a rule allowing states to phase out their Stage II vapor recovery programs. The department began the process on Mar. 15, 2013. All stations previously subject to the Stage II program in the St. Louis area were required to be fully decommissioned by Dec. 31, 2015. The department’s full policy can be found here PDF Document. 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.
While inspections are conducted by your local office, most enforcement action will be initiated by the department’s Air Pollution Control Program. Enforcement action will not be initiated for simple defective equipment; however, there are a few violations that trigger automatic enforcement action:
- Unapproved equipment
- Illegal gasoline deliveries
- Construction without a permit or permit notification
In addition, prolonged, excessive or repeated deficiencies of any type may result in further action.
- As noted in the Vapor Recovery Equipment section, all Stage I equipment at the facility must be state 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 construction permit notification, or construction activities are beyond the scope of your current permit or notification, you will be issued a notice of violation and referred to the air program for enforcement. If you have applied for a construction 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 of the Missouri Air Pollution Control Program. If it is determined that a monetary penalty is appropriate, you will be contacted by someone in the compliance/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, or the air program may evaluate issuing an administrative penalty order.
Both Kansas City and St. Louis area regulations require Stage I vapor recovery on large capacity gasoline storage tanks and gasoline loading racks. In addition, all delivery vessels loading or unloading at the facility 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.
If a bulk plant has an average monthly throughput of less than 120,000 gallons, the plant may apply for a low throughput exemption from specific requirements of Stage I vapor recovery regulations on its loading rack and outgoing delivery vessels.
The Request for Exemption application must arrive at the department by February 1 of each year. Although the exemption is granted yearly, once a facility exceeds the 120,000 monthly average, the facility must install Stage I vapor recovery and will not be eligible for the exemption again.
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 ozone nonattainment area or Kansas City ozone maintenance area, it must be equipped with proper Stage I vapor recovery . In addition, 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 .
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 keep a copy of the passing test in the cab of the vessel at all times. As of September 2010, it is no longer necessary to submit these test results to the department.
Illegal Loading/Unloading and Enforcement Actions
Missouri State regulations require delivery vessels to utilize vapor recovery equipment when loading the vessel at a bulk plant or terminal and unloading at a facility inside the St. Louis or Kansas City ozone 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 load 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.
The department will take enforcement action against gasoline delivery companies failing to properly use Stage I vapor recovery when unloading gasoline. Delivery vessel drivers and facility owners or operators may also be held responsible for illegal delivery violations.
On May 16, 2012, the Environmental Protection Agency released a final rule that determined onboard refueling vapor recovery technology is in widespread use throughout the motor vehicle fleet for purposes of controlling motor vehicle refueling emissions. As a result of this finding, the Air Pollution Control Program initiated the removal of Stage II vapor recovery requirements for gasoline dispensing facilities in the St. Louis ozone nonattainment area. EPA’s determination included a regulatory support document summarizing the financial benefits and costs of decommissioning Stage II vapor recovery systems.
The Air Pollution Control Program held stakeholder meetings in the St. Louis area to discuss EPA’s widespread use rule and the revision to and implementation of Missouri Air Regulation 10 CSR 10-5.220 “Control of Petroleum Liquid Storage, Loading and Transfer.”
Aug. 6, 2015 -- Vapor Recovery Stakeholder Meeting Presentation
March 22, 2013 - Vapor Recovery Stakeholder Meeting Presentation
Jan. 8, 2013 - Policy Memo 2013-01 – Stage II vapor recovery – Phase Out
Jan. 8, 2013 - Draft Technical Support Document for Removal of Stage II Aug. 7, 2012 - EPA Guidance on removing Stage II programs from State Implementation Plans
July 31, 2012 - Policy Memo 2012-01 - Stage II vapor recovery Enforcement Discretion
June 28, 2012 - Vapor Recovery/Stage II– Widespread Use Meeting Notes
- California Air Resources Board - Vapor Recovery
- The California Air Pollution Control Officers Associations
- Missouri Department of Agriculture - Division of Weights and Measures
- Missouri Department of Natural Resources' Hazardous Waste Program - Tanks Section
- Missouri Petroleum Marketers and Convenience Store Association
- UST Operator Training
- Petroleum Storage Tank Insurance Fund