MEMORANDUM 

SUBJECT: Technical Support Document for the Revision to the Missouri State Implementation Plan 

(SIP) for Control of Petroleum Liquid Storage, Loading and Transfer-Stage II Removal O · Steven Brown ~I 1 Air Planning and Development Branch Sf Zt.(l 5""' 

TO: EPA-RO?-OAR-2015-0268 

THRU: Joshua Tapp, 

Branch Chief, A WMD/ APDB 

Michael Jay, 

Section Chief, A WMD/ APDB/ AtPS 

Missouri State Implementation Plan 

TABLE OF CONTENTS 

I. INTRODUCTION 

II. BACKGROUND 

III. DESCRIPTION OF REVISIONS 

• REMOVAL OF STAGE-II VAPOR RECOVERY SYSTEM REQUIREMENTS 

• REVISING CERTIFICATION AND TESTING PROCEDURES 

• PROHIBITING ABOVE GROUND STORAGE TANKS AT GDFs 

• REVISING PERMITTING PROVISIONS FOR STAGE-I SYSTEMS 

• GENERAL REVISIONS 

I. INTRODUCTION 

This Technical Support Document (TSD) addresses State Implementation Plan revisions submitted by 

the State ofMissouri that amend Missouri rule 10 CSR 10-5.220. This TSD provides EPA's analysis of 

the supporting evidence provided by Missouri as to why these revisions, in the aggregate, meet the 

minimum requirements of the Clean Air Act (CAA) and associated regulations, guidance and policy. 

Printed on Recycled Paper 
automobiles to capture the fuel vapors evacuated from the gasoline tank before they reach the nozzle. 

The fuel vapors captured in the carbon canisters are then combusted in the engine when the automobile 

is in operation. 

Stage II vapor recovery systems and vehicle ORVR systems were initially both required by the 1990 

Amendments to the Clean Air Act (CAA). Section 182(b)(3) ofthe CAA requires moderate and above 

ozone nonattainment areas to implement Stage II vapor recovery programs. CAA section 202(a)(6) 

required EPA to promulgate regulations for ORVR for light-duty vehicles (passenger cars). EPA 

adopted these requirements in 1994, at which point moderate ozone nonattainment areas were no longer 

subject to the CAA section 182(b )(3) Stage II vapor recovery requirements. ORVR equipment has been 

phased in for new passenger vehicles beginning with model year 1998, and starting with model year 

2001 for light-duty trucks and most heavy-duty gasoline powered vehicles. ORVR equipment has been 

installed on nearly all new gasoline powered light-duty vehicles, light-duty trucks, and heavy-duty 

vehicles since 2006. 

During the phase-in of OR VR controls, Stage II has provided volatile organic compound (VOC) 

reductions in ozone nonattainment areas. Congress recognized that ORVR systems and Stage II vapor 

recovery systems would eventually become largely redundant technologies, and provided authority to 

EPA to allow states to remove Stage II vapor recovery programs from their SIPs after EPA finds that 

ORVR is in "widespread use." Effective May 16, 2012, the date the final rule was published in the 

Federal Register (see 77 FR 28772), EPA determined that ORVR systems are in widespread use 

nationwide for control of gasoline emissions during refueling of vehicles at GDFs. Currently, more than 

75 percent of gasoline refueling nationwide occurs with ORVR-equipped vehicles, so Stage II vapor 

recovery programs have become largely redundant control systems and Stage II vapor recovery systems 

achieve an ever declining emissions benefit as more ORVR-equipped vehicles continue to enter the onroad motor vehicle fleet. In its May 16,2012 rulemaking, EPA also exercised its authority under CAA 

section 202(a)(6) to waive certain federal statutory requirements for Stage II vapor recovery systems at 

GDFs. This decision exempts all new ozone nonattainment areas classified serious or above from the 

requirement to adopt Stage II vapor recovery programs. Finally, EPA's May 16,2012 rulemaking also 

noted that any state currently implementing Stage II programs may submit State Implementation Plan 

(SIP) revisions that would allow for the phase-out of Stage II vapor recovery systems. 

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• REMOVAL OF STAGE-II VAPOR RECOVERY SYSTEM REQUIREMENTS 

On November 20,2014, the state ofMissouri submitted to EPA a revision to the SIP to remove 

the requirements of Stage II vapor recovery control systems at gasoline dispensing facilities in 

the St. Louis area, and a demonstration that such removal is consistent with EPA guidance and 

the Clean Air Act. 

The Stage II requirements of this state rule were promulgated in the late 1980s and were 

incorporated into Missouri's SIP as part of the control strategies for the one-hour ozone National 

Ambient Air Quality Standard (NAAQS). As stated above, pursuant to the May 16, 2012 

rulemaking (77 FR 28772), EPA determined that Onboard Refueling Vapor Recovery (ORVR) 

technology was in widespread use throughout the national motor vehicle fleet for purposes of 

controlling motor vehicle refueling emissions. This federal rule allows states to remove Stage II 

programs from their SIP if certain criteria are met through an emissions demonstration using 

EPA guidance entitled Guidance on Removing Stage II Gasoline Vapor Control Programs from 

State Implementation Plans and Assessing Comparable Measures, August 7, 2012. 

Because the Stage II controls in 10 CSR 10-5.220 are part ofMissouri's approved SIP, it 

submitted a SIP revision to EPA that includes revisions to the Stage II rule regulations and an 

analysis of the emissions impact of eliminating the Stage II controls as stated in EPA guidance. 

Included in the docket is Missouri's TSD which serves as the analysis of the emissions impact of 

eliminating Stage II requirements from the St. Louis area. 

EPA reviewed Missouri's TSD analysis and found that it follows the EPA guidance document 

cited above, demonstrates that removal of Stage II controls will not adversely affect the air 

quality in the St. Louis area, and satisfies all CAA requirements for removal of control measures 

from a SIP. Specifically, the requirements of section 110(1) ofthe CAA, which prohibits revision 

of a SIP that would interfere with attainment of a NAAQS or reasonable further progress toward 

attainment of a NAAQS, have been met. In addition, the requirements of section 193 ofthe 

CAA, which prohibits modification of any control requirement in effect before 1990 in a current 

nonattainment area unless the modification insures equivalent or greater emissions reductions, 

are satisfied. 

As shown in section III.C. of Missouri's TSD, the emissions reduction benefits from ORVR 

systems in the motor vehicle fleet are greater than the emissions reduction benefits from Stage II 

vapor recovery systems for all years of interest in the demonstration. Therefore, the requirements 

of section 193 of the CAA are satisfied for any year analyzed in the demonstration. 

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for any year analyzed in the demonstration. 

Missouri's analysis was conducted in accordance with EPA guidance and covers the years 2012 

through 2020 and demonstrates that removal of Stage II controls may begin as early as 2013 

without negatively impacting the St. Louis air quality or violating the Clean Air Act prohibition 

on backsliding. 

For further information, see Missouri's submittal that includes the redline strikeout revision to 

the rule and TSD, "Technical Support Document for the Amendment to 10 CSR 10-5.220 

Control ofPetroleum Liquid Storage, Loading and Transfer Removal of Stage II Vapor 

Recovery Requirements (Prepared January 9, 2013 for 10 CSR 10-5.220, rulemaking effective 

date is November 30, 2014)" which is part of this docket. 

• REVISING CERTIFICATION AND TESTING PROCEDURES 

Certification and testing procedures for Stage I systems will use the California Air Resources 

Board (CARB) vapor recovery program instead of the Missouri Performance Evaluation and 

Test Procedures (MOPETP). The CARB is the state of California's clean air regulatory board. 

Because California established CARB before the federal government adopted its current 

regulatory policies, it is the only state permitted to oversee a state-run air resources board. Under 

the CAA the CARB may also adopt and enforce its own emissions standards. 

See Missouri's redline strikeout submittalSections: 

(3) General Provisions 

(5) Test Methods 

• PROHIBITING ABOVE GROUND STORAGE TANKS AT GDFs 

The prohibition of aboveground storage tanks (ASTs) at GDFs will be codified. The existing rule 

never allowed ASTs because MOPETP never certified ASTs. The elimination ofMOPETP 

requires adding language to the rule to clarify that ASTs will continue to be prohibited greater 

than a capacity of one thousand gallons. 

See Missouri's redline strikeout submittalSections: 

(3) General Provisions, (C) Gasoline Transfer at GDFs. 

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for any year analyzed in the demonstration. 

Missouri's analysis was conducted in accordance with EPA guidance and covers the years 2012 

through 2020 and demonstrates that removal of Stage II controls may begin as early as 2013 

without negatively impacting the St. Louis air quality or violating the Clean Air Act prohibition 

on backsliding. 

For further information, see Missouri's submittal that includes the redline strikeout revision to 

the rule and TSD, "Technical Support Document for the Amendment to 10 CSR 10-5.220 

Control ofPetroleum Liquid Storage, Loading and Transfer Removal of Stage II Vapor 

Recovery Requirements (Prepared January 9, 2013 for 10 CSR 10-5.220, rulemaking effective 

date is November 30, 2014)" which is part ofthis docket. 

• REVISING CERTIFICATION AND TESTING PROCEDURES 

Certification and testing procedures for Stage I systems will use the California Air Resources 

Board (CARB) vapor recovery program instead of the Missouri Performance Evaluation and 

Test Procedures (MOPETP). The CARB is the state of California's clean air regulatory board. 

Because California established CARB before the federal government adopted its current 

regulatory policies, it is the only state permitted to oversee a state-run air resources board. Under 

the CAA the CARB may also adopt and enforce its own emissions standards. 

See Missouri's redline strikeout submittalSections: 

(3) General Provisions 

(5) Test Methods 

• PROHIBITING ABOVE GROUND STORAGE TANKS AT GDFs 

The prohibition of aboveground storage tanks (ASTs) at GDFs will be codified. The existing rule 

never allowed ASTs because MOPETP never certified ASTs. The elimination ofMOPETP 

requires adding language to the rule to clarify that ASTs will continue to be prohibited greater 

than a capacity of one thousand gallons. 

See Missouri's redline strikeout submittalSections: 

(3) General Provisions, 

(C) Gasoline Transfer at GDFs. 

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Sections: 

(3) General Provisions 

(F) Permits Required 

• GENERAL REVISIONS 

There are general clerical revisions such as the addition of definitions, formatting and or text 

changes that add clarity to the rule throughout the document. See the redline strikeout version in the 

state submittal that is part of this docket. 

CONCLUSION 

After reviewing Missouri's SIP submittal, the evidence shows that Missouri's TSD demonstration 

follows the EPA guidance document, Guidance on Removing Stage II Gasoline Vapor Control 

Programs from State Implementation Plans and Assessing Comparable Measures, August 7, 2012, and 

demonstrates that these SIP revisions will not have an adverse impact on air quality by removing Stage 

II Vapor Recovery Systems in the St. Louis area. The associated SIP revisions to the General Provisions 

section of the rule complement the removal of Stage II Vapor Recovery Systems in the St. Louis area. 

They do not have a negative impact on air quality and are approvable. These SIP revisions are in 

accordance with the Clean Air Act and do not interfere with any applicable requirement concerning 

attainment, reasonable further progress or any other applicable requirements for the St. Louis area. 

Therefore, th~ EPA supports approving these SIP revisions that amend Missouri Rule 10 CSR 10-5.220. 

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