Vapor Recovery Information and Compliance Requirements
Requirements on this page have been updated to reflect the requirements in the amendments to 10 CSR 10-2.260, effective Feb. 28, 2019 and 10 CSR 10-5.220, effective March 30, 2019.The department will allow those affected by the permitting changes in the amendment to 10 CSR 10-5.220, effective March 30, 2019, to start complying with the new requirements on Feb. 1, 2019, unless a permit is specifically requested.
Beginning Feb. 1, 2019, St. Louis County will no longer oversee the requirements of 10 CSR 10-5.220. Thereafter, all inquiries regarding 5.220 should be directed to the department.
Please see the vapor recovery equipment webpage below for details regarding the Enhanced Vapor Recovery implementation schedule.
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. Only Stage I vapor recovery is used in Missouri.
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.
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 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 at Gasoline Dispensing Facilities
Clay, Jackson and Platte counties
Unless otherwise exempt, owners/operators of gasoline storage tanks in the Kansas City area are regulated by the Missouri Air Conservation Commission. The Missouri Air Conservation Commission voted to adopt an amendment 10 CSR 10-2.260 “Control of Emissions During Petroleum Liquid Storage, Loading and Transfer” on Sept. 27, 2018. The requirements in the amendment will be effective Feb. 28, 2018. To view the amended language click here. Under the amended regulation:
- All gasoline storage tanks greater than 550 gallons and less than 40,000 gallons in the Kansas City area are required to install California Air Resources Board or department approved pressure/vacuum valves on all tank vents,
- 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.
- Gasoline storage tanks between 250 gallons and 550 gallons are no longer subject to the regulation.
See the Gasoline Dispensing Facilities webpage for more information regarding the amendment.
St. Louis Area - Stage I and II Vapor Recovery at Gasoline Dispensing Facilities
Franklin, Jefferson, St. Charles and St. Louis counties and the City of St. Louis
Unless otherwise exempt, owners/operators of gasoline storage tanks in the St. Louis ozone nonattainment area are regulated by the Missouri Air Conservation Commission. The Missouri Air Conservation Commission voted to adopt an amendment to 10 CSR 10-5.220, "Control of Emissions During Petroleum Liquid Storage, Loading and Transfer" on Nov. 29, 2018. The requirements of the amendment will be effective March 30, 2019. The department will allow those affected by the amendment to 10 CSR 10-5.220, if they so choose, to start complying with the new permitting requirements on Feb. 1, 2019. A link to access the amendment will be available soon.
Under the amended regulation:
- Owners/operators of gasoline storage tanks with a capacity greater than 550 gallons and less than or equal to 1,000 gallons must install California Air Resources Board or department approved pressure/vacuum valves on all tank vents.
- Underground 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.
- Vapor recovery construction permits are not required. In place of construction permits, owners/operators must submit a notification.
- Vapor recovery operating permits are not required. Owners/operators must continue to 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
Unless otherwise exempt, under the amendment to 10 CSR 10-2.260, effective Feb. 28, 2019, 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 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 +
St. Louis Area:
Unless otherwise exempt, owners/operators 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 underground storage tank must be equipped with Enhanced Vapor Recovery (EVR) components that are approved by a California Air Resources Board (CARB) Executive Order or that are approved by the Air Pollution Control Program as having a collection efficiency of 98%. Click here to view the most recent CARB Executive Orders. 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, for example 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.
Under the amendment to 10 CSR 10-5.220, effective March 30, 2018, owners/operators of underground storage tanks in the St. Louis nonattainment 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 ozone nonattainment 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. Effective Feb. 28, 2019, MOPETP will no longer be applicable in the Kansas City 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.
The amendment to 10 CSR 10-2.260, effective Feb. 28, 2019 includes some changes to the testing requirements.
The amendment requires owners/operators of underground gasoline storage tanks with capacities greater than 2,000 gallons that are not otherwise exempt and are located in Kansas City, 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.
The amendment also changes the allowed pressure decay and pressure/vacuum valve test methods. The 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.
The amendment to 10 CSR 10-5.220, effective March 30, 2019 includes some changes to the testing requirements. The department will allow those affected by the amendment to 10 CSR 10-5.220, if they so choose, to start complying with the requirements on Feb. 1, 2019.
Unless otherwise exempt, the amendment requires owners/operators of underground 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. Owner/operators must continue to 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.
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 and Reformulated Gasoline
Gasoline in the Kansas City area is regulated by the Missouri Air Conservation Commission. 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 and search for 10 CSR 10-2.330. The Missouri Department of Agriculture’s Fuel Quality Program tests gasoline samples and shares the results with the Missouri Department of Natural Resources' Air Pollution Control Program.
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. When finished, the inspector should discuss their findings with you and give you a copy of the inspection report.
The amendment to 10 CSR 10-5.220, effective March 30, 2019, includes some procedural changes related to the permitting/notification processes. Beginning Feb. 1, 2019, unless requested by an owner/operator, the department will stop issuing vapor recovery operating permits and vapor recovery construction permits in the St. Louis non-attainment area as a result of an early implementation of the amendment. Under the amendment, 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.
The amendment to 10 CSR 10-5.220 also includes some changes to testing requirements. Testing is not required following partial modifications to stage I vapor recovery systems. 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.
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.
The requirements for low throughput exemptions for bulk plants affected by the amendments to 10 CSR 10-5.220 “Control of Emissions During Petroleum Loading, Storage and Transfer”, effective March 30, 2019 and 10 CSR 10-2.260 “Control of Emissions During Petroleum Loading, Storage and Transfer” have changed. 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 still require tracking of the gasoline throughputs; however, an annual request to the department is no longer required. A department approved throughput tracking form is available here. The form must be available to the department upon request. Additionally, the amendments will no longer 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 ozone nonattainment area or Kansas City 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 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.
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.
Air Pollution Control Program
P.O. Box 176
Jefferson City, MO 65102-0176
St. Louis Regional Office
7545 S. Lindbergh, Suite 210
St. Louis, MO 63125
Kansas City Regional Office
500 NE Colbern Road
Lee’s Summit, MO 64086-4710
Kansas City Department of Health
Air Quality Program
2400 Troost Ave., Suite 3200
Kansas City, MO 64108
- 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