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OAR Box 1830 

Prepped by Ollie Stewart 

Document Number: 

1) IV-A-8 

Docket Number: 

A-87-11 

Printed 11/13/2008 7:20:50 AM Sheet 1 of 232 
Unfteo StilM 

Environment- Protection Agency 

Office 01 Air tna rtuiuon 

Wi_ilno_n.D.C.2)4«) 

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Itotjeriwi A-m-n 

Alr_idl___flon JVrA-3 

&EPA ENFORCEMENT GUIDANCE 

FOR STAGE II VEHICLE 

REFUELING CONTROL 

PROGRAMS 

OFFICE OF MOBILE SOURCES 
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ENFORCEMENT GUTOANCE 

FOR 

STAGEH 

VEmCI_ERFflTTFT;iNG CONTROL PROGRAMS 

December 1991 
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TABLE OF CONTENTS 

SECTION TITLE 

1.0 Introduction 

1.1 History and Purpose of Stage II 

1_2 Synopsis of Guidance 

2.0 Stage II -mpJetnentaHon Requirements 

2.1 General Implementation Requirements 

3.0 Specific Implementation Requirements 

3.1 Facilities Regulated under CAAReqnirements 

3_2 Determination of Regulated Facilities 

.3-3 ., ..Compli__ice Requirements for Installation of Stage II Systems 

4.0 Program Emission Reduction Design Requirements 

4.1 Control System Design Requirements 

4_2 System Certification Requirements 

5.0 Enforcement Program Minimum Criteria 

5.1 General Criteria 

5-2 General Criteria Defined 

(a) Training and Public Education Requirements 

(b) A Method to Determine Which Facilities 

Comprise the Regulated Universe 

(c) Data Collection and Review to Monitor Compliance among the 

Regulated Facilities 

(d) Periodic Inspection of Regulated Facilities to Insure Compliance 

with Program Requirements 

(e) A Method to Assure Regulated Facility Compliance with 

Program Requirements Through Enforcement Mechanisms 
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SPECIFIC PROGRAM CRITERIA 

6.0 ~ Training and Public Education 

6.1 Program Oversight Agency (POA) Training and Testing Requirements 

for POA Inspectors 

6_2 Facility Owner/OperatorTraining on Stage II Equipment 

63 POA Education of Regulated Parities 

6.4 General Public Education 

7.0 Determination of the Regulated Universe 

8.0 Compliance Monitoring 

8.1 Verification of Facility Compliance Through Record Keeping 

8.1.1 Requirements for Regulated Facilities 

8.1.2 'POA Record Keeping Requirements 

8-2 Facility Equipment Requirements for Installation and Testing 

8-2.1 Infrastructure System Equipment 

8.2-2 Above Ground System Equipment 

8.3 POA Equipment Requirements 

8.4 Regulated Facility Inspections/General Requirements 

8.4.1 Requirements for Inspections of Facility Infrastructure 

8.4-2 Requirements for Inspections of Facility Above Gnmnd Equipment 

(a) Visual Inspection Requirements for Compliance Inspections 

(b) Functional Testing Requirements for Compliance Inspections 

9.0 Penalties 
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w _•):<« M I DM GUIDANCE FOR STAGE n VEHICLE 

RFFfTET ING rnNTROL PROGRAMS 

1.0 INTRODUCTION 

1.1 HISTORY AND PURPOSE OF STAGE H VAPOR CONTROLS 

Gasoline dispensing pump vapor control devices, commonly referred to as Stage H Vapor 

Recovery Control (Stage H), are systems that were developed to control volatile organic 

compound (VOC) vapor releases during the refueling process of motor vehicles. This 

process takes the vapors normally emitted directly into the atmosphere during refueling and 

recycles them back into the fuel storage tanks, thereby preventing their escape into the 

atmosphere. The Stage H system controls the release of VOCs, benzene and toxics emitted 

from gasoline. 

Provisions for providing for control of gasoline vapors during the fueling of motor vehicles 

first appeared in an October 1975 Federal Register notice and several other subsequent 

notices, which discussed Stage H implementation as a control strategy in the nations worst 

nonattainment areas. In the Clean Air Act Amendments (CAAA) of 1977, Section 

202(a)(5)(A) stated that if regulations were promulgated by the Adnunistrator, provisions 

for vapor control were to require specific vehicle fill area specifications for adaptability for 

Stage II controls. A detennination of the feasibility and desirability of vehicle based 

• jyflie ling vapor, control .systems, commonly referred 4o>*as onboard controls, -was also 

provided in the 1977 Amendments. Regulations were never promulgated under the 1977 

CAAA. 

Stage II technology was first introduced in San Diego, California in 1974. Since the 

implementation of this program, sixteen others areas that were classified as nonattainment 

for ozone in California implemented Stage U control programs. Most of these programs 

have been in operation for approximately ten years. California recently implemented control 

programs statewide in an effort to control benzene emissions. 

There are other areas in the country that have implemented Stage H programs. The District 

of Columbia implemented a control program in the early 1980's. St. Louis, Missouri 

implemented a Stage H program in the mid 1980's. The New York City metropolitan area 

and the State of New Jersey phased in programs in the late 1980's. Massachusetts, 

Pennsylvania, Dade County, Florida and some other state and local agencies have, or are in 

the process of, adopting provisions for Stage H programs. 

On November 15,1990, Congress passed the Clean Air Act Amendments of 1990, Pub. L. 

101 - 549 (codified at 42 U.S.C. §§7401-7601q) which contain provisions that require 

additional control programs. Section 182(b)(3) of the Act requires that all areas which are 

classified as moderate to extreme for ozone nonattainment implement a Stage U. vapor 

recovery program as a control measure. Section 202(a)(6) of the amended Act requires 

the Environmental Protection Agency (EPA), "after consultation with the Secretary of 

Transportation regarding the safety of vehicle-based ('onboard') systems for the control of 

vehicle refueling emissions, promulgate standards under this section requiring that new 

light-duty vehicles manufactured beginning in the fourth model year after the model year 
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which the standards are promulgated and thereafter shall be equipped with such systems." 

Each of these sections and the provisions contained within them may affect the status of a 

state's requirement to implement a program and every state should consider each situation 

independently in preparing their state plan submittal. 

In Section 182, the Act mandates the issuance of "guidance as appropriate, as to the 

effectiveness of such (Stage II) system." Two documents were prepared to respond to this 

mandate. A report detailing technical information on Stage H systems was prepared by 

EPA's Office of Air Quality Planning and Standards. That report is entitled Technical 

fil^T* - Stay H Vapor Recovery Syftft-ig for Control of Vehicle Rcfofftng Fmko^nc _t 

Gaso-me Dfrpp^g FTM*81^ (Technical Guidance). This document, ffnforrf'ff'it 

figjdfl'flr f y Stage n Vehicle Refueling Control Programs has been developed to assure 

these programs attain the emissions reductions they are designed to achieve. 

The minimum criteria and specific requirements in this document have been modified to 

take into account comments received on the May 29,1991 preliminary draft. 

1_2 SYNOPSIS OF STAGED GUIDANCE 

This guidance establishes the minimum requirements for program enforcement and 

oversight. The guidance is divided into five areas. Each Stage II program should contain 

provisions for meeting or exceeding these criteria. 

A successful Stage H program begins by providing information for public awareness and 

effective training for the regulated industry and the program oversight personnel. 

Successful implementation and oversight also entails identification of the regulated parties 

as well as ongoing monitoring of the all program operations through data analysis and other 

compliance monitoring mechanisms. The most important criterion for effective 

implementation and oversight of a Stage H program is establishment of an effective 

enforcement program to deter or eliminate violations which compromise the program. This 

guidance provides for specific implementation criteria in each of these areas. 

This document provides EPA's guidance to states regarding oversight and enforcement of 

Stage II gasoline vapor refueling control programs at refueling facilities. This guidance is 

a general statement of policy. It does not establish a binding norm and is not finally 

determinative of the issues addressed. Agency decisions in any particular case will be made 

applying the law, applicable regulations and guidelines on the basis of specific facts and 

actual action. 

EPA has assumed that Stage H programs which comply with these criteria will be 95% 

effective. States implementing Stage H programs which do not meet the criteria as set forth 

in this document must demonstrate why a less effective program was selected and whether 

a lesser level of effectiveness would be appropriate. However, since many areas have 

demonstrated that a program achieving 95% recovery is economically and technically 

feasible, the Agency does not anticipate approval of programs that are not 95% effective. 
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2.0 STAGE H IMTf EMFOTATIONR^UIR-EMENTS 

2.1 GENERAL 

All States having areas that are designated under the National Ambient Air Quality 

Standards (NAAQS) as nonattainment for ozone and further are classified moderate to 

extreme, in accordance with the CAAA requirennents of 1990 section 182(b)(3)(a), are 

required to implement a Stage H vapor control program. However, section 202(a)(6) 

requires that: "Within 1 year after the date tf the enactment of the Clean Air Act 

Amendments of 1990, the Ad-oinistrator shall, after consultation with the Secretary of 

Transportation regarding the safety of vehicle-based ('onboard') systems for the control of 

vehicle refueling emissions, promulgate standards under this section requiring that new 

light-duty vehicles manufactured beginning in the fourth model year after the model year 

which the standards are promulgated and thereafter shall be equipped with such systems." 

In addition, section 202(a)(6) states: "The requirements of section 182(b)(3) [relating to 

stage II gasoline vapor recovery] for areas classified under section 181 as moderate for 

ozone shall not apply after promulgation of such standards and the Adniinistrator may, by 

rule, revise or waive the application of the requirements of such section 182(b)(3) for areas 

classified under section 181 as Serious, Severe, or Extreme for ozone, as appropriate, after 

such time as the Administrator determines that onboard emissions control systems required 

under this paragraph are in widespread use throughout the motor vehicle fleet." 

3.0 SPECIFICS 

3.1 PARTIESREGULATED UNDERTHECAVGASOIJNE VAPORRECOVERY 

GENERAL RULE OF SECTION 182 (B)(3) 

All gasoline dispensing facilities that dispense greater than 10,000 gallons per month 

(50,000 gallons per month in the case of an independent small business marketer) are 

subject to Stage H requirements. An independent small business marketer is defined in 

section 324 of the Clean Air Act. There are four exemptions mentioned in the section 

concerning independent small business marketers. EPA will be issuing policy statements 

interpreting the four exemptions. Until EPA issues a formal interpretation, states should 

realize that Congress intended that those small businesses that are refiners, controlled by 

refiners, or affiliated with refiners (by more than just a trademark or symbol) not be exempt 

from the Stage H program. 

3-2 DETERMINATION OF REGULATED FACnjTTES 

A gasoline dispensing facility's responsibility for installing Stage H is based on the average 

volume of product dispensed per month. A facility that dispenses more than 10,000 gallons 

per month must install Stage H controls. If a gasoline dispensing facility is classified as an 

independent small business marketer, the State may establish a cut-point as high as 50,000 

gallons per month. The criteria which mandates the installation of Stage H equipment 

under the CAA is determined by calculating the average volume of product dispensed per 

month for the 2 year period preceding the adoption date of the requirement by the state. 
However, each state may establish different cut-points so long as they are as stringent or 

more stringent than those required by the statute. If a gasoline dispensing facility was 

inactive for any period during the 2 year calculation period, the period should be extended 

to include a total of twenty four months of activity, or the state should use the months of 

actual operation to calculate the facility's average gallons per month. 

3 3 DATES FOR INSTALLATIONOF STAGED CONTROLS ATREGULATED 

FACILITIES 

Section 182(b)(3)(B) of The Act establishes three deadlines for installation and use of Stage 

H controls, once the state adopts the Stage H requirement: . 

(a) Facilities1 which begin construction after November 15,1990 must comply 

with Stage H requirements within 6 months after the state adopts Stage II. 

(b) Facilities which dispense 100,000 gallons or more of gasoline per month must 

comply within 1 year after state adoption. 

(c) All other facilities must comply, in accordance with the Acts requirements, 

within 2 years after adoption. 

These are statutorily required dates for installation of Stage H controls. However,the state 

has discretion io alter these dates so long as the deadlines are not less stringent. 

In addition, for independent small business marketers (ISBMs) states can also choose 

to opt for a three-year phase in period. The ISBMs schedule, according to section 324 is: 

(1) 33 percent of such outlets must be in 

compliance at the end of the first year 

after state adoption, 

(2) 66 percent at the end of the second year 

after state adoption, and 

(3) 100 percent by the end of the third year 

after state adoption. 

For ISBMs, the State may elect to follow the general schedule in Section 182(b)(3)(B), the 

optional schedule in Section 324, or any schedule that is not less stringent. 

1

 Facility (facilities) - Hereinafter the term facility will be used to refer to a gasoline 

dispensing facility (facilities). 
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4.0 PROGRAM EMISSION REDUCTION DESIGN REQUIREMENTS 

4.1 CONTROL SYSTEM DESIGN REQIJIREMENTS 

The control system minimum efficiency design requirements are contained as part of the 

General Preamble of Title I. The states that have installed and are operating Stage H 

controls have demonstrated that 95 percent control of VOC emissions is practicable. 

Therefore, EPA does not anticipate approval of a state requirement that would achieve less 

than 95 percent control. As an alternative to testing each facility for 95 percent control 

effectiveness, states may require installed Stage H systems to be certified to achieve at least 

95 percent control by either the California Air Resources Board (CARB), or by using CARB 

test procedures and methods or equivalent test procedures and methods developed by the 

state and submitted as part of the SIP. 

4_! SYSTEM CERTIFTCATIONREQUIREMENTS 

(a) An approved system should be tested and certified as meeting a minimum of 

95% emission reduction efficiency by one of the three criteria established in 

section 4.2 (b). In addition to requiring installation of an approved certified 

system, the installation and operations of each facility's systems should be 

tested in accordance with the requirements specified in Sections 8.2.1 and 

8.2.2. 

(b) ForEPA to accept a Stage H Program in ihe SIP submittal process, the 

approved systein(s) must demonstrate 95% minimum efficiency either by: 

(1) being tested and approved by California's Air 

Resources Board (CARB) past, current or future 

recognized testing methods, or 

(2) be an equivalent testing program adopted by 

the state, conducted by the Program Oversight 

Agency (POA)2 or by a third party recognized by 

the POA and submitted and recognized by EPA in 

the SIP, or 

(3) be an approved CARB system. 

2

 Program Oversight Agency (POA) - The POA is the state agency, or an agency or 

other representative that has been delegated the responsibility by the state, to oversee 

implementation and operation of the program and to enforce the requirements of the 

program. If the program is delegated to some other authority, the state has the 

responsibility of assuring the other authority is effectively overseeing and enforcing the 

program. 
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5.0 -ENFORCEMENT PROGRAM MINIMUM CRITERIA 

5.1 GENERAL 

Each Stage H program should meet or exceed the criteria established in this guidance 

document. The five areas of program guidance are noted and defined below. The Stage H 

Program should contain provision for: 

(a) TRAINING AND PUBLIC EDUCATION PROGRAMS. 

(b) A METHOD TO DETERMINE WHICH FACILITIES COMPRISE THE 

REGULATED UNIVERSE. 

(c) DATA COLLECTION AND REVIEW TO MONITOR COMPLIANCE 

AMONG REGUIAT1-DFACIUTIES. 

(d) PERIODIC INSPECTION OF REGULATED FACnJITES TO INSURE 

COMPLIANCE WITH PROGRAM REQUIREMENTS. 

(e) A METHOD TO ENSURE REGULATED FACILITYCOMPLIANCE WITH 

PROGRAM REQUIREMENTS THROUGH ENFORCEMENT 

MECHANISMS. 

The following section generally defines these criteri-. 

5_2 STAGE H ENFORCEMENT GUIDANCE PROGRAM CRITERIA 

(a) TRAINING AND PUBLIC EDUCATION 

1. The Program Oversight Agency (POA) should develop and implement an effective 

training program for its inspectors. The training should include, at minimum, instruction 

in all program requirements and inspection procedures (visual and functional inspection 

practices and testing methods) and a written and practical test to verify proficiency with the 

information and procedures. 

2. The POA should require that all manufacturers of equipment used in a Stage H 

system provide training on the operation and maintenance requirements for that equipment 

or the POA should provide training or authorize an educational institution to provide 

training on the equipment. A facility representative (an owner, facility manager or 

designated employee) should attend this training for the Stage H equipment that they select 

for installation on their facility premises. Verification, such as a certificate of attendance 

of the training, should be obtained by the attendee within three months of the initiation of 

operations of the facility equipment and be maintained on the facility premises. The facility 

representative that completed the training is then responsible for informing all facility 

employees about the equipment operation and maintenance. 
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3. The POA should develop and distribute to all regulated facilities written 

information regarding the purpose and benefits of a Stage H program. The information 

should also include enforcement consequences for non-compliance with program 

requirements. The information should be conveyed in terms easily understood by the owners 

and operators of the regulated facilities, their employees and by the general public. 

4. The POA should develop information on the Stage H program purpose, benefits 

and requirements and make that information available for public distribution. 

(b) A METHOD TO DETERMINE WHICH FACnJTIES COMPRISE THE 

REGULATEDUNIVERSE 

The Clean Air Act, as amended in 1990, sets out the sources which, at a minimum, 

must be subject to the Stage fl requirements. However,the States have authority to change 

those requirements as long as the statutorily required gasoline dispensing facilities are 

covered. Hence, the POA must establish a method to accurately determine which facilities 

must comply with the Stage H program requirements. 

(c) DATA COIiECTION TO MONITOR (X>MPLIANCT AMONG REGULATED 

FACnJTTES 

The POA should verify compliance by regulated facilities by insuring through data 

^niii^nn, „« WH ^ equipmem, 

that the equipment has been tested and proved to be functional and that the equipment is 

properly maintained and updated in accordance with the program requirements. This can 

be accomplished through collection of data such as applications, permits or other documents 

and through inspections. 

(d) PERIODIC INSPECTIONS OF REGULATED FACnJTIES TO INSURE 

COMPLIANCE WTraraOGRAMREQlJIREMENTS 

The POA should verify compliance among regulated facilities by conducting a 

minimum of 1 compliance inspection per facility per year with mandatory follow-up at 

stations with violations. The compliance inspection should consist of visual verification of 

all necessary paperwork, labels, public information and Stage I and H equipment. Stage I 

equipment is interrelated with the operational effectiveness of the Stage H systems. If the 

Stage I equipment on the facility premises is disabled or malfunctioning, emissions captured 

through the Stage H equipment may be released. Inspection of the Stage I seals and covers 

should be included as part of the Stage H inspection process. Therefore, verification of the 

presence of the Stage I equipment at the facility is a vital part of the inspection. A visual 

inspection for all mandatory labels and Stage II system parts should be conducted on all 

gasoline dispensing pumps. The compliance inspection should also consist of a 

determination of whether each facility's Stage H system is operating properly. Functional 

tests should be conducted at regulated facilities in accordance with the schedule for testing 

facility equipment as established in this document. If inspection results indicate a potential 

problem, more intensive system analysis should be initiated for problem identification. If 
there is a problem with the equipment, it should be corrected before operation can be 

continued. 

(e) A METHOD TO ASSURE REGULATED FACILITY COMPLIANCE WITH 

PROGRAMREQUDUEMENTSTHROUGHENFORCEMENTMECHANISM^ 

The POA should develop a penalty schedule which establishes appropriate penalties 

for facilities violating the Stage H requirements. These penalties may include 

administrative, civil and criminal penalties that will deter or eliminate non-compliance with 

the Stage H requirements. The enforcement process should include provisions for warnings, 

notices of violations, cease and desist orders, monetary penalties, and revocation or 

suspension of a facility's license to operate. The penalty schedule should account for 

severity of the violation, intent, frequency of violations, and other aspects affecting the 

penalty. The penalties that are established should ensure recovery of any economic benefit 

associated with the violation, phis recoup an additional amount which serves as a deterrent 

to regulated parties. The policy should also recognize that penalty assessment should 

provide for fair and equitable treatment of the regulated community and for swift resolution 

of environmental problems. 

SPECIFIC PROGRAM CRITERIA 

-6.0 TRAINING AND PUBLIC EDUCATION 

GENERAL 

As established in section 5.1(a), the POA should develop and implement an effective training 

and testing program for its inspectors which will provide for and demonstrate knowledge 

and proficiency of all Stage H program requirements and procedures. Also, the owners and 

operators of the equipment should be trained in the operation and maintenance of their 

facility's Stage H equipment. The owners and operators should be held responsible for the 

proper operation and maintenance of the facility equipment by all parties authorized to 

operate the equipment, including the general public. 

6.1 POA TRAINING AND TESTING ILEQUIREMENTS FOR POA INSPECTORS 

The training of POA personnel is vital to an effective control program. All POA inspectors 

should be able to understand and implement all programmatic requirements. A thorough 

training program should be designed and implemented. The training program should cover, 

at a minimum, the following subject areas: 

(a) Purposes and effects of Stage H vapor control programs, 

(b) System types, parts, operations and functions, 

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(c) . Inspection requirements, both procedures and practices, 

(d) Identification techniques of system, and equipment failures, both visual and 

functional, 

(e) Record review and recording procedures, 

(f) Enforcement procedures including issuance of warnings, NOVs, hearing 

testimony, and other enforcement procedures. 

All POA inspectors should attend training sessions and demonstrate their knowledge and 

proficiency with all areas required in this section. The training program should consist of 

at least 40 hours of training that includes both classroom and practical field training. A 

written and practical test should be developed and administered during the training process. 

The POA should ensure that the established passing score accurately demonstrates that the 

trainee has the knowledge and proficiency to be an effective inspector. The criteria for this 

training and testing should be specified in the state SIP submittal. If substantial advances 

in system/equipment technology is made, periodic retraining of all POA inspectors should 

be conducted in order to educate the POA personnel on any new inspection practices, 

policies and procedures. Training institutions can be utilized for trainmg purposes, however 

training should be developed and approved under the POA's guidance. The POA may also 

elect to conduct the training "in-house". 

6-2 FACH_nrYOWNER/OP_a_ATORSTI-AINlNGON STAGED EQUIPMENT 

At least one owner/operator from each facility should receive training in the categories 

listed in this section. For each person who receives training, a certificate or other proof 

of training must be required. Training should include, but need not be limited to, the 

following areas: 

(a) Purposes and effects of the Stage H vapor control program, 

(b) Equipment operation and function specific to their facility's system, 

(c) Maintenance schedules and requirements for the facility's equipment, 

(d) Equipment warranties, 

(e) Equipment manufacturer contacts (names, addresses and phone numbers) 

for parts and service. 

Acceptable forms of training can include either equipment manufacturer's seminars, POA 

training sessions or other arrangements determined to be effective. The POA should either 

develop and provide this training or accept equipment manufacturer seminar/training with 

proof of attendance or completion. If manufacturer provided training is accepted, it should 

be evaluated and confirmed to include the minimum training requirements specified in the 
SIP. The POA should monitor any and all training t® .evaluate its effectiveness and require 

updated training when significant changes in equipment or program requirements occur. 

It is the responsibility of the facility owner/6perat«rto ensure that at least one facility 

representative attendthis training and to make every current and future facility employee 

aware of the purposes of the equipment and the correct operating procedures. The facility 

representative should attend the required training within three months of the initiation of 

operation of the facility equipment. However,it is suggested that the facility representative 

obtain the training prior to the initiation of operation of the system. If the facility 

representative whoreceivedthe initial training/cert_5cateleaves that facility, another facility 

representative must take and successfully complete the training and maintain the certificate 

on the facility premises. 

6 3 POA EDUCATION OF REGUIATEDFAOTLmES 

The POA should prepare --formation on the purposes and benefits of Stage H vapor 

controls and distribute this information to all regnteted facilities. The information should 

include, but is not limited to: 

(a) The general purposes and benefits (environmental, health, safety,and potential 

costs savings) of the Stage H vapor control program, 

(b) The specific program requirements, 

(c) Potential enforcement consequences for non-compliance, 

(d) Information on the program oversight agency including office address, phone 

number and other pertinent infora__tion. 

Posters, signs, pamphlets and other information, tools, if properly developed, distributed 

and displayed, have been found to be very effective tools in educating gasoline dispensing 

facility employees as well as the public. 

6.4 GENERAL PUBLIC EDUCATION 

The POA should prepare, and make available to the general public, information on the 

Stage n vapor control program. The information should be easily understood by the general 

public and include, but need not be limited to the following: 

i 

I 

(a) The purposes and benefits (environmental, health, safety, and potential cost 

savings) of the Stage H vapor control program. 

(b) A general explanation of how Stage H systems function. 

(c) The correct procedures for operation of Stage H equipment. 

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(d) Information on the program oversight agency, including office address, phone 

number and other pertinent information for public inquiry, comments and 

complaints. 

Provisions for other public education should also be considered. Television, radio, 

newspapers and other media sources have been effective in providing basic program 

information to the public, especially during initial program implementation. 

7.0 DETERMINATION OF THE REGULATED UNIVERSE 

The POA must, in accordance with the Clean Air Act Amendment requirements, which are 

generally noted in sections 3.1 through 3.4, accurately determine which gasoline dispensing 

facilities must comply with the Stage H program requirements. Several methods have been 

utilized to make the determination of which gasoline dispensing facilities may be required 

to comply with Stage H vapor control program requirements. Each area should determine 

the most accurate method fordetennining what comprises the potentially regulated universe. 

If a regulated facility disagrees with the POAs determination, documentation noting the 

dispute can be submitted to the POA. The regulated facility should be required to submit 

information verifying the proposed exempt status. - The POA should verify the accuracy of 

the documents before any final determination is made. 

Once all potential facilities are identified, a determination of. which facilities meet all of the 

. requirements for mandatory compliance m be made, 

at a minimum, in accordance with the size and throughput calculations required in section 

3.1 of this document. However, more stringent throughput calculations can be used. 

Once this determination is made, a program to accurately track facilities in the regulated 

universe must be developed and maintained. A facility required to be regulated is a facility 

that meets all of the requirements, at a minimum, established by section 182(b)(3) of the 

CAAA of 1990. Once a facility is part of the regulated universe, the facility should be 

required to maintain the Stage H equipment. 

States may choose to require that all facilities dispensing gasoline install and operate Stage 

H controls. A provision for states to adopt and enforce more stringent requirements with 

respect to independent small business marketers of gasoline is included in section 324(b) 

of the CAA. This section provides that the Administrator may approve state Stage H 

programs which require compliance by gasoline dispensing facilities with monthly sales 

volumes less than what the Clean Air Act stipulates. The state should closely evaluate not 

only the environmental consequences of adopting more stringent controls but should also 

consider the potential impact on the regulated industry and the POA oversight capabilities. 

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8.0 PROGRAM COMPLIANCE MONITORING 

8.1 VERTFICATTONOF FACTLTTY COMPLIANCE THROUGH RECORD KEEPING 

8.1.1 REQUIREMENTS FOR REGULATED FACTLTnES 

The POA should track facility compliance by requiring that regulated facilities maintain 

various types of records. The POA is responsible for developing and distributing these 

forms prior to the facility coming under the program's oversight and updating these record 

keeping forms. All regulated facilities should be required to apply for all necessary permits, 

licenses, or records required to be maintained by the POA. The records should be requireto be kept on the facility premises in an easily accessible location for review by the POA 

officials. The records should be accurate and up to date and be maintained in accordance 

with the following criteria: 

(a) PERMITTING RECORDS 

Any and all permits to operate a facility or a specific system at a facility should be required 

to be current and be available for review at the facility during a facility inspection. 

(b) STATION OPERATING LICENSE 

Any and all licenses to operate a facility or a specific system at a facility should be required 

to be current and available for review at the facility during a facility inspection. 

(c) SYSTEM INSTALIATION AND TESTING RESULTS 

All facilities should be required to verify that the Stage H system meets or exceeds the 

requirements of a Liquid Blockage Test or Leakage Test, as discussed in section 8.2.1 and 

8.2.2 and as described in section 8.4*2 (b), or other applicable tests specific to a Stage H 

system. The test results should be dated and should note the installing and test companies' 

names, addresses and phone numbers. 

(d) STAGED SYSTEMMAINTENANCERECORDS 

Any maintenance conducted on any part of a regulated facility's system should be required 

to be logged on a maintenance record. This record should be maintained on the facility 

premises. This maintenance record should include a general part description, the date 

repaired or replaced, the replacement part manufacturer'sinf ormation, a general description 

of the part location in the system (i.e. pump number etc.) and a description of the problem. 

The POA should develop and make available to all regulated facilities, maintenance 

recording forms for tracking this information. 

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(e) INSPECTION RECORDS 

The regulated facility should be required to maintain on the facility premises, a file of all 

inspection reports issued by the POA. The file should be organized chronologically. 

(D COMPLIANCE RECORDS 

The regulated facility should be required to maintain on the facility premises a file of all 

compliance records including warnings, notices of violations, and other compliance records 

issued by the POA to the regulated facility. The file should be maintained separate from 

the inspection file and be organized chronologically. 

(g) TRAINING CERTIFICATION 

The regulated facility should be required to maintain on the facility premises proof of 

attendance and completion of the training specified in the SIP (in accordance with section 

6-2). 

8.1.2 POA RECORD KEEPING REQUIREMENTS 

The POA should develop and update as required, accurate, up-to-date records and files of 

all facility and program related information including, but not limited to: 

(a) AGeneral Station File which should include the following information; 

the facility name, address, phone number, owner and operator names, a POA assigned 

reference number, the date of initial compliance with implementation requirements and 

the Stage H system type information. Other station specific information, such as the 

number of pumps, could be included at the POA's discretion. 

(b) A Station Inspection Report File which should be filed by assigned 

reference number and/or alphabetically. The reports should be maintained in chronological 

order. Each inspection report must include the date of the inspection, the POA inspectors' 

name, number and signature, any findings such as equipment failures, follow-up action to 

be performed, a notation of any violations, and a signature from the facility owner or 

operator. Other information may be included at the discretion of the POA. 

(c) A Station Enforcement File which includes any related documents issued 

to the regulated facility such as warnings, NOVs, hearing summaries, suspensions and 

revocations of permits to operate and/or construct, and penalties assessed and collected. 

The reports should be maintained in chronological order. 

File information can be computerized if the POA chooses to use such a system. This will 

enable the POA to reference material quickly and expedite their procedures. Hard copy files 

should also be maintained for original, signed forms and for other information which is 

unable to be stored in the computer filing system. 

13 
P.19 

8-2 FACHJTYEQUIPMENT REQUIREMENTS FOR INSTAIJ^ 

TESTING 

8.2.1 INFRASTRUCTURE SYSTEM EQUIPMENT 

All underground plumbing, pumps, vents and other underground equipment specific to a 

vapor recovery system must comply with any and all system-related certification 

requirements, all other state, local and federal guidelines pertaining to Stage H and any 

other regulations, guidelines or requirements which affect the regulated facility's business 

operations,, including Stage I requirements. 

The regulated facility should also verify proper installation and function of the equipment. 

The POA should require that all installation and/or testing businesses meet certain 

minimum criteria to conduct any tests required for verification of equipment compliance. 

Verification of proper installation and function should be conducted by either the POA or 

an installation company or another business meeting the minimum criteria established by 

the POA to conduct such tests. The POA may elect, for verification purposes, to accept a 

registered professional engineer's seal of approval as one method of verifying proper 

installation and function. Mandatory Liquid Blockage testing and a Leak Test should be 

required on systems when applicable to such systems. Testing should be encouraged in 

order to verify proper installation of the infrastructure plumbing before the above ground 

equipment is installed. Testing should be required to be conducted once all of the 

.equipment is in operational condition at the gasoline, dispensing pumps,.verifying proper 

installation and function of the entire system. If the POA does not elect to conduct the 

initially required testing, the regulated facility should be required to notify the POA, at 

least two days in advance of the testing, when the testing will occur and what party will 

conduct the testing. 

In addition, each facility should be required to recertify the function of the Stage H 

equipment at least every five years or upon major system replacement or modification or 

which ever occurs first. This recertification requires a Leak Test (on applicable systems) 

as noted in section 8.4.2(b) or other tests necessary to assure compliance on other system 

types, and any and all other functional tests that are required for the initial system 

certification. A major system modification should be considered to be replacing, repairing 

or upgrading 75% or more of the facility's Stage H equipment. 

8.2.2 ABOVE GROUND SYSTEM EQUIPMENT 

All equipment must meet the requirements for a certified system. The above-ground 

equipment must be compatible with the infrastructure equipment and be tested for proper 

installation and function. Applicable tests should be conducted on each system verifying 

proper installation and operation of the equipment before licensing or permitting can occur. 

Test methods should include, but not be limited to, Leak Tests, Liquid Blockage testing 

and a test of nozzle auto shut-off mechanisms and flow prohibiting mechanisms (if 

equipment is designed with the device or devices) to determine if the mechanisms are 

14 
P.20 

operating properly. The testing on the above-ground equipment should only be conducted 

when the equipment is fully installed and ready for operation. 

All new programs should consult with any implementation information and guidance 

referenced in the Technical fiT'dfl"^ - Stage

 n Vaoor Recoverv Systems for Control of 

Vehicle Rfffffiiwg Fmfrjyinns, at Gasoline TMgpgnging Facilities and any other policy or 

guidance issued by the EPA regarding the implementation of Stage H programs. 

Because Stage H technology will continue to improve in the areas of efficiency, durability 

and ease of use, POA's should encourage existing facilities, conducting substantial repairs 

or replacements, to upgrade the facility equipment. Reducing life-cycle costs, increasing 

operational efficiency and increasing employee and customer satisfaction are incentives 

that should be considered for upgrading facility equipment. 

Retrofitting certified equipment with non-certified parts, rebuilt parts, or aftennarket nonoriginal equipment manufacturer (OEM) parts should be prohibited unless the aftennarket 

parts manufacturer or re-manufacturer demonstrates that the replacement part does not 

degrade the system's original efficiency or durability. The POA should establish a 

mechanism for testing and/or approving aftennarket or rebuilt replacement parts before 

substitutions of OEM parts can be approved. Certification or approval mechanisms should 

consider efficiency, durability and enforcement oversight implications. The POA could 

consider approval mechanisms that afford reasonable approval costs with assurance that 

the approved parts do not reduce or degrade the system efficiency or durability. CARB 

currently tests and approves T-fterniarket replacement parts and the TO A xan opt for 

accepting replacement parts approved by the CARB program. 

8.3 PROGRAM OVERSIGHT AGENCY EQUIPMENT 

The POA should possess and utilize the equipment necessary to verify compliance by 

regulated parties. The verification of the proper certified system and verification of proper 

function should be confirmed through the inspection process. The POA should possess, at 

a minimum, equipment to accomplish these tasks. The list of necessary equipment includes 

the following: 

Protective Clothing (gloves/eye protection) 

POA official identification/business cards 

All necessary forms (inspection/compliance) 

All testing apparatus (measuring tools and any other testing kit 

required to perform functional tests) 

15 
P.21 

8.4 REGU1_ATT_0FACILJTYINSPECTI0NS 

GENERAL REQUIREMENTS 

The POA must conduct a minimum of 1 compliance inspection, per facility per year, with 

mandatory follow-up at facilities that are found to be in violation. The compliance 

inspection should consist of the inspection of records, as required in section 8.1,and facility 

equipment, as required in section 8.2. Functional testing of equipment should also be 

performed. This section establishes the recommended minimum requirements for the 

compliance inspections. 

8.4.1 REQUIREMENTS FOR INSPECTION OF FACILITY INFRASTRUCTURE 

BY THE POA 

The POA.should reserve the right to conduct facility system testing. If the POA elects to 

conduct the testing, the requirements of section 8.2.1 will apply as the POA requirements 

and procedures. If the POA does not elect to conduct the initial testing for system 

certification, permitting or licensing, then the POA should verify that the facility has 

complied with all of the requirements of section 8.2.1 through record review of the testing 

results and through the process of issuing permits or licenses. 

8.4_2 REQUIREMENTS FX)R INSPECTIONS OF FACILITY ABOVE GROUND 

EQUIPMENT BY THE POA 

The POA should visually inspect all system equipment and verify that the system installed 

is the one licensed or permitted for that facility and, that the system in all respects 

maintains the specific certified configuration. The inspection should consist of a visual 

inspection of each pump, pump instruction label, nozzle, hose and any attached or related 

system parts and other Stage H system equipment listed, but not limited to, the equipment 

noted in section 8.4.2(a). Applicable functional tests should also be conducted on the Stage 

H equipment to verify compliance and assess program effectiveness. The testing should be 

conducted according to, but not limited to, the requirements noted in section 8.4.2 (b). 

(a) VISUAL INSPECTION REQUIREMENTS FOR COMPLIANCE 

i_M.fcoy_JI*J_N 

The visual inspection should include, but not be limited to: 

i 

(1) Verification that all equipment is present and maintains a certified system 

configuration and is in proper working order. The equipment includes, but is not limited 

to, nozzles and nozzle parts (faceplate or facecone, bellows, springs, latches, check values), 

hoses, hose hangers/retrartors,flow limners, swivels, collection units, control panels, system 

pumps, processing units, vent pipes and any and all other system-related parts. A list of 

general violations and equipment-related violations is noted in attachment 3. The list is not 

inclusive and should be expanded and coordinated with the POA's established penalty 

schedule. 

16 
P.22 

(2) Verification of the presence of all Stage H instruction labels and signs and program 

information required in section 5.2 (a) and (d). 

(3) Inspection of all files, permits and licenses and verification that the facility has 

complied with all recordkeeping requirements. Also, inspect files to ensure that the facility 

has complied- with maintenance requirements and any and all other requirements 

established in this document. 

(4) Observation of the use of the equipment by facility operators and the public to 

determine if the equipment is functioning properly and/or being operated correctly. These 

observations should include dispensing units, processors and handling units, and any other 

systems-related equipment. 

(5) Thorough preparation of all inspection report forms and compliance forms when a 

violation is identified. 

(6) All related equipment, such as Stage I equipment, must be checked according to 

established state, local and federal Stage I inspection procedures and requirements. 

(b) FUNCTIONAL TESTING REQUIREMENTS FOR COMPLIANCE 

INSPECTIONS 

Fnnctron-J testing should be conducted -by the i^ A _n'.iccni^nce with the following 

criteria: 

(1) A functional test of the required shut off or flow prohibiting mechanisms should be 

conducted on any nozzle which is believed to have a problem or if it is believed that the 

system equipment may not include the required system shut off or flow prohibiting 

mechanisms. When possible and applicable, close observation of vehicles during the 

refueling process is allowed to determine some of these functions. 

(2) The POA should verify that each facility has complied with the Leak Test (LT) 

requirements specified in section 8.2.1. Functional Leak Test testing by the POA is not 

required during the normal annual inspections. The POA retains the option of conducting 

or requiring the facility to conduct the LT as part of compliance assurance activities. 

(3) A Dynamic Backpressure test (DBT) should be conducted at each facility (where 

the test is applicable to the system), during the annual compliance inspection. The DBT is 

not required during follow-up inspections unless the test is required to verify that violations 

have been corrected. 

(4) The POA should verify facility compliance with the Liquid Blockage Test (LBT) 

requirements as specified in section 8.2.1 by reviewing the station records or testing files. 

Functional LBT testing by the POA is not required but the POA retains the option of 

conducting the LBT as part of the compliance assurance activities. 

17 
P.23 

X* 

The following is a list of functional tests proven effective in the analysis of Stage H systems 

operation and in determining equipment-related problems. 

DYNAMICBACKPRESSURETEST 

The Dynamic "Backpressure test (DBT) is used to quantify the dynamic backpressure in 

the vapor path from the nozzle to the storage tank. (For a draft example test procedure 

derived from CARB test procedure specifies, refer to attachment 1). The DBT simulates 

backpressure created during the vehicle refueling process by passing nitrogen through the 

system at a constant rate. The system is designed to have a minimum and mavimnm 

backpressure and any drop in the pressure indicates a leak in the path while exceeding the 

maximum indicates a blockage. This test is applicable for all balance orHirt vacuum assist 

systems. 

LEAK TEST 

The Leak Test (LT) procedure is conducted to quantify the vapor tightness of a system. 

A leak in the system may cause excessive vapor emissions or reduce the system's efficiency. 

The check requires pressurizing the system to 10 inches water column and allowing the 

system to decay for several minutes. (For a draft example test procedure derived from 

CARB test procedure specifics, refer to attachment 2.) This test procedure is applicable to 

the balance and vacuum assist systems. 

LIQUID BLOCKAGE TEST 

The Liquid Blockage Test (LBT) is virtually the same test as the DBT except a liquid 

blockage is introduced into the system. The procedure attempts to create a blockage in 

the vapor piping by introducing gasoline into the system at the dispenser. After the gasoline 

has been introduced (enough to create a blockage if the system has any low points) gaseous 

nitrogen is then introduced at specified flow rate. If sufficient resistance to flow is 

encountered and the pressure drop exceeds established limits, the conclusion is that there 

is an unacceptable low point in the piping. If the pressure is measured within the allowable 

limits, then the system is operating effectively. 

9.0 PENALTIES 

9.1 GENERAL REQUIREMENTS FOR PROGRAM PENALTIES 

As required in section 5.2 (e), the POA should invoke penalties that, at a minimum, ensure 

compliance with all program requirements. A penalty schedule should be developed to 

assure this. This schedule of penalties for violations of program requirements should 

include, but need not be limited to: 

(a) Notices of Violations 

(b) Warnings 

18 
P.24 

(c) Cease and Desist Orders 

(d) Suspension of license or permit to operate 

•(e) Revocation of license or permit to operate 

(f) Monetary fines 

(g) "Red Tagging" Equipment (Prohibiting equipment operation until 

repair is completed) 

Provisions for civil and criminal penalties should also be considered as possible deterrence 

mechanisms. V the penalties available to the POA do not sufficiently deter violations and 

non-compliance continues, alternative penalties must be pursued. The state must assure 

compliance in order to continue to receive the SIP credits provided for by the program. 

The Penalty Schedule should arrount for severity of the violation, intent, frequency of 

violations, and other factors. 

The penalties that are established should ensure recovery of any economic benefit associated 

with the violation, plus imposition of an additional amount that will serve as a deterrent to 

regulated parties. The policy should also recognize that penalty assessment should provide 

JorJair ___d equitable,treatment_)f the.regulated community _u_d.for.swift.resolution of 

environmental problems. 

Penalties should be established for, but not be limited to, violations listed in attachment 

3. This list is in no way inclusive of all possible violations. 

19 
P.25 

ATTACHMENT 1 
P.26 

Of4ft Autbll 

SOURCE TEST PROCEDURE ST-27 

GASOLINE DISPENSING FACILITY 

DYNAMIC BACK PRESSURE 

REF: Regulation 8-7-302 

1. Applicability 

1.1 This procedure is used to quantify the dynamic back pressure in the vapor ] 

leading from the dispensing nozzle to the underground tank, inclusively. It is applicabi 

all cases where vapor balance or Hirt vacuum assist Phase II systems are utilized. 

2. Principle 

2.1 The dynamic back pressure during refueling is simulated by passing nitre 

through the Phase II recovery system at a constant rate. The resultant dynamic t 

pressure is measured using a pressure gauge. Alternate Methods 1 and 2 are also inclu 

for those Phase II systems which utilize a remote vapor check valve. 

3. Range 

•:: , ;3.1 The mirrimurrrand maximum dynamic back pressures that can be measured 

dependent upon available pressure gauges. Recommended gauge ranges are Oo inc 

rbO and 0-2 inches rbO for Alternate Methods 1 and J. Recommended ranges 

Alternate Method 2 are (T-.50 inches H2O and 0-1 inch H2O. 

4. Interferences 

4.1 Any leaks in the nozzle vapor path, vapor hose, or underground vapor rei 

piping will result in erroneously low dynamic back pressure measurements. 

5. Apparatus 

5.1 Nitrogen High Pressure Cylinder with Pressure Regulator. Use a high press 

nitrogen cylinder capable of maintaining a pressure of 2000 psig and equipped wit 

compatible two-stage pressure regulator. 

52 Rotameter. Use a calibrated rotameter capable of accurately measur 

nitrogen flowrates of 20,60, and 100 CFH and equipped with a flow control valve. 

5 J Pressure gauges. Use two Magnehelic differential pressure gauges, or equivah 

with appropriate ranges , and equipped with toggle valves connected to the high press 

inlets. 

5.4 Automobile fill pipe. Use a fill neck known to be compatible with all vaj 

recovery nozzles and equipped with a pressure tap. 

5.5 Nitrogen. Use commercial grade nitrogen. 

5.6 Hand Pump, Use a gasoline compatible hand pump to drain condensate pots. 
P.27 

6. Pre-Test Procedures 

6.1 For those Phase II systems which do not utilize a remote vapor check valve. 

assemble the apparatus as shown in Figure 27-1. ensuring that the riser shut-otf valve on the 

test equipment is closed. If a Hirt Phase II system is used, the vacuum producing device 

should be turned off during this test. 

6.2 The test equipment must be leak-checked prior to use. Plug the nozzle end ol 

the auto fill pipe, open the nitrogen cylinder and the toggle valves on the magneheiic 

gauges. Adjust the flow meter control valve until a pressure of 50 percent of full scale is 

indicated on the high range pressure gauge. Close the nitrogen cylinder valve and toggle 

valves. A pressure decay of0._ inches mO, in five minutes, is considered acceptable. 

6.3 Perform an initial visual examination for vapor leaks at the nozzle and hose or 

the Phase II system to be tested. 

6.4 Disconnect and drain the vapor hose for all dispensers to be tested. Pour two (2) 

gallons of gasoline into each vapor return riser. Reconnect vapor hose. Allow fifteen (15) 

minutes for liquid in the vapor return piping to drain. For Phase II systems which do not 

employ a remote vapor check valve, the 2 gallons of gasoline may be introduced through the 

vapor passage in the nozzle. 

6.5 Completely drain all gasoline from the spout and bellows. 

6.6 For those vapor piping configurations which utilize a condensate pot, drain the 

pot prior to testing. 

6.7 For Alternate Methods 1, 2, and 3 the Phase 1 vapor poppet shall be propped open 

in such a manner that the valve is not damaged. 

7. Testing 

7.1 Alternate Method 1. Phase II systems which do not utilize a remote vapor check 

valve may be tested using the following methodology. Insert the nozzle into the fill pipe ot 

the pressure drop test unit, ensuring that a tight seal at the fillpipe/nozzle interface is 

achieved. Ensure that the riser shut-otf valve on the test equipment is closed. 

7.2 Close both toggle valves and connect the nitrogen supply. 

7.3 Open the nitrogen supply, set the delivery pressure to 10 psig, and use the 

flowmeter control valve to adjust the flowrate to 20 CFH. 

7.4 Open the toggle valve on the 0-.5 inches H->0 gauge. If the pressure is 

.5 inches H2O, close this valve and use the 0-2 incnes H2O gauge. 

greater 

than 0.5 

7.5 A pulsating gauge needle indicates nitrogen passing through a liquid obstruction 

in the vapor return system. If this occurs, close the flowmeter control valve, disengage the 

nozzle and redrain the nozzle and hose assembly. Re-engage the nozzle, open the 

flowmeter control valve and repeat the test. 

7.6 Repeat Sections 7.3 through 7.5 for nitrogen flowrates of 60 and 100 CFH. 
1' l&MIC __/ - I 

PRESSURE DROP TEST UNIT 

CONTROL 

VALVE 

HUJPIPE 

RISER -

SIIUT-OFF VALVE 

PRESSURE GAUGES 

PHASE II 

RISER 

ROIAMEIER 

NITROGEN 
P.29 

7.7 The following information should be recorded on the field data sheet shown 

Figure 27-2. 

Pump Number and Product Grade 

Nozzle make and model 

Nitrogen flowrate, CFH 

Dynamic back pressure, inches H2O 

7.8 Close and replace the dust cover on the Phase I poppet. 

7.9 Alternate Method 2. Phase II systems which utilize a remote vapor check vai 

may be tested using the following methodology. 

7.9.1 Disconnect the vapor recovery hose from the remote vapor valve. Test t 

nozzle/hose assembly pursuant to Sections 7.1 through 7.8 and record the results. 

1.92 Disconnect the vapor check valve from the riser and connect a compatit 

pipe fitting to the riser as shown in Figure 27-1. 

7.9.3 Plug the nozzle end of the fill pipe on ^\c pressure drop test unit and opt 

the riser shut-off valve on the test equipment 

7.9.4 Repeat Sections 7.2 through 7.8. In addition to the information required 

Section 7.7, record the make and model of the remote vapor check valve. 

7.9.5 Record on the field data sheet the pressure drop across the remote vap 

•check valve.:rThis data liavailable from tne manutacturer. 

7.9.6 Add the dynamic back pressures, for each nitrogen flowrate, obtained fro 

Sections 7.9.1, 7.9.4 and 7.9.5. 

7.10 Alternate Method 3. Phase II balance and Hirt systems which use those modi 

of remote vapor check varves which can be disabled by removing the poppet on the fuel si/ 

may be tested using the following methodology. The Emco-Wheaton A-228 remote vap 

check valve cannot be tested using this method. 

7.10.1 Carefully open the fuel side of the remote vapor check valve and remo 

the fuel poppet Replace the threaded plug on the fuel side of the valve. 

7.10.2 Test the Phase II system pursuant to Sections 7.1 through 7.8, recordi: 

the data on the field data sheet shown in Figure 27-3. 

7.10.3 Carefully reassemble the remote vapor check valve by removing the pit 

on the fuel side and reinserting the fuel poppet Replace the threaded fuel plug. 

8. Reporting 

8.1 Results from Alternate Methods 1 or 3 shall be reported as shown in Figure 27-

Results from Alternate Method 2 shall be reported as shown in Figure 27-3. 
P.30 

SUMMARY OF 

SOURCE TEST RESULTS 

rr.i \nme tnj Ajjre.ss Tcsnng Comp»n\ Name and Addreu 

PIMP GASOLINE NOZZLE MFG.& DYNAMIC BACK PRESSURE, INS. W.C 

; # £&__£ MOPE- M'MPER _!_____ ____FJ_ IOOCFH COMMENTS 

Ten Conducted By Da«« 

Figure 27 - 2 
Company M 

Test Date 

Address City 

Test Company Address 

Phone 

City 

SUMMARY OF SOURCE TEST RESULTS 

PUMP# 

• 

i 

GAS 

GRADE 

\ 

NUZZLE 

MODEL 

NITROGEN 

ILOW.CH 1 

VAPOR VALVli 

MODEL 

DYNAMIC: HACK PRESSURI:. INCHES O I WATER COLUMN 

NOZZLE/IIOSE 

ASSEMBLE 

RISER TO 

U.G. TANK 

VAPOR 

VALVE1 

I I I 

TOTAL 

AP.INII20 

WT'« 0m s% 

to 
P.32 

ATTACHMENT 2 
P.33 

3MJT-J0-W 

Source Test Procedure ST-30 

GASOLINE DISPENSING FACILITY 

LEAK TEST PROCEDURE 

REF: Regulation 8-7-301, 302 

1. Applicability 

1.1 This Test Procedure is used to quantify the vapor tightness of any vapc 

recovery system installed at a gasoline dispensing facility (GDF). Leaks in a balanc 

system may cause excessive vapor emissions. Leaks in a vacuum assist system m: 

decrease the efficiency of the vapor collection or processing system. 

2. Principle 

2.1 The entire vapor recovery system is pressurized to ten (10) inches of watt 

column and then allowed to decay for five (5) minutes. The acceptability of the fin; 

pressure is based upon the vapor system volume or ullage space. 

3. Range 

3.1 The minimum and maximum full-scale ranges of the pressure gauge are 0-1 

and 0-20 inches of water column, respectively. Maximum incremental graduations of th 

pressure gauge shall be one-tenth, of an inch water column. 

.4. Interferences 

4.1 On vacuum assist systems the processor must be isolated and the vapor systei 

capped. On a balance system the vent pipes must be capped or plugged. Any leakage : 

these points will show up as a system component leak. 

5. Apparatus 

5.1 Nitrogen. Use commercial grade nitrogen in a high pressure cylinder, equippe 

with a two-stage pressure regulator and a one psig pressure relief valve. 

. 5.2 Pressure Gauge or Water Manometer. Use a 0-10 inch water column pressur 

gauge, or water manometer, to measure the pressure decay in the vapor recovery systen 

The pressure gauge shall be readable to the nearest tenth of an inch (0.1) water column. 

5.3 Vent Cap Assembly. See Figure 1 for example. 

5.4 T Connector Assembly. See Figure 2 for example. 

5.5 Stopwatch. Use a stopwatch accurate to within 0.2 seconds. 

6. Pre-Test Procedures 

6.1 Dispensing shall not take place during the test. There shall have been no Iml 

drops into the storage tanks within the three hours prior to the test. 

6.2 Measure the gasoline gallonage in each underground storage tank. Determin 

the actual capacity of each storage tank. Calculate the ullage space for each tank b 

subtracting the gasoline gallonage present from the actual tank capacity. The minimun 

ullage during the test shall be 30 percent of the tank capacity or 500 gallons, whichever i 

greater. The vent pipes may be manifolded during the test to achieve the required ullage. 
P.34 

6.3 Insure that all Phase I couplers are equipped with a locking dust cap. Replace 

the manhole covers as a safety precaution. 

6.4 Disconnect the dispenser end of one vapor recovery hose and install the "T" 

connector assembly (see Figure 2). Connect the nitrogen gas supply (do not use air), and 

the pressure gauge to "T connector. 

6.4.1 For those Phase II systems utilizing a remote vapor check valve, the T 

connector assembly shall be installed on the vapor nser side of the check valve unless the 

remote check valve is disabled by removing the poppet on the fuel side. 

6.5 Install the vent cap assembly(s) (see Figure 1). For manifolded systems ail 

storage tank vent pipes shall be capped during the test. 

6.6 If the storage tank vent pipe is open, and easily accessible, a modified version 

of the "T connector may be installed at the vent pipe (see Figure 3). This will allow the 

test to be conducted without any dispenser modifications. This is advantageous at certain 

facilities using coaxial Phase II systems. 

7. Testing 

7.1 Open the nitrogen gas supply valve, regulate the delivery pressure to 5 psig, 

and pressurize the vapor system (or subsystem for individual vapor return line systems) to 

or slightly above 10 inches rfoO initial pressure. It is critical to maintain the nitrogen flow 

until both flow and pressure stabilize, indicating temperature and vapor pressure 

stabilization in the tanks. Check the vent cap assembiy(s) and T connector assembly 

using leak detecting solution to verify that the test equipment is leak tight. 

"7.2 Close the nitrogen supply valve and start the stopwatch when the pressure 

decreases to the initial starting pressure of 10 inches of water column. 

7.3 After each minute record the system pressure.After five minutes, record the 

final system pressure. See Table I to determine the acceptability of the final system 

pressure results. 

7.4 If the system failed to meet the criteria set forth in Table I repressurize the 

system and check all accessible vapor connections using leak detector solution or a 

combustible gas detector. If vapor leaks in the system are encountered, repair or replace 

the defective component and repeat the test. 

7.5 Carefully remove the vent cap assembly(s). Allow any remaining pressure to be 

relieved through, vent pipe(s). Keep all potential ignition sources away from the vent 

pipe(s). 

7.6 After the pressure is relieved, remove the T connector assembly and 

reconnect the vapor recovery hose. If the fuel poppet was removed from a remote vapor 

check valve to conduct this test, carefully replace the poppet and reconnect the vapor 

hose. 

7.7 If the vapor recovery system utilizes individual vapor return lines, repeat the 

leak test for each of the other gasoline grades. Avoid leaving any vapor return line open 

longer than is necessary to install or remove the "T connector assembly. 

8. Reporting 

8.1 The calculated ullage and system pressures for each five minute vapor recovery 

system test shall be reported as shown in Figure 4. 
P.35 

TABLE I 

GASOLINE DISPENSING FACILITY 

LEAK RATE CRITERIA 

INITIAL PRESSURE -10 INCHES WATER COLUMN 

ULLAGE SPACE MINIMUM PRESSURE 

,,-», , ^ _,o AFTER FIVE MINUTES 

(GALLONS! (Inches of Water) 

500 3.7 

600 4.5 

700 5.2 

800 5.8 

900 6.2 

I^OOC •• • •yy,y;:6.5 

1,500 7.6 

2,000 8.2 

2,500 8.5 

3,000 8.7 

3,500 8.9 

4,000 9.1 

4,500 9.2 

5,000 9.3 

7,500 9.5 

10,000 9.6 

15,000 9.7 

30,000 9.8 

Use linear interpolation for intermediate values of ullage space. 
EIGIIREI 

P.36 

VENT CAP ASSEMBLY 

HOSE 

PLUG 

HOSE CLAM 

VENT PIPE 
FTGURE 2 

P.37 

T CONNECTOR 

ASSEMBLY 

FROM NITROGEN SUPPLY 

REGULATED TO 5 PSIG 

TO RISER 

3/4" X 1/2W X 3/4 

GALVANIZED OR BRASS T" 

PRESSURE GAUGE 

0-10" H20 

TOSWT 

3/4" GALVANIZED 

OR BRASS NIPPLE 
P.38 

FIGURE 3 

ALTERNATE VENT CAP 

ASSEMBLY 

PRESSURE GAUGE 

0-10" H20 

PLUG 

HOSE 

,^^^N\\\\\\>\\\\\\\\\^ 

k_^<^s> 

FROM N2 S 

AT 5 PSIG 

HOSE CLAM 

VENT PIPE 
P.39 

1 

• FIGURE 4 | 

SUMMARY OF 

SOURCE TEST RESU 

SOURCE INFORMATION 

Firm Nama and Addraaa 

Pat mil CondMooa 

Firm Rapraaanu-va and TMa 

Pnono No. 

Sourer. 

Vapor Racovary Systtm 

Pl4_Ht NO* PQf&lIt NOb 

Oparataa hr/day 4 369 daya/yr 

LTS 

«»OOrt No. 

Ttat Oata: 

TaatTlnwa: 

Run A: 

Run 8: 

RunC: 

FACILITY PARAMETERS 

PHASE U SYSTEM TYPE 

(Check One) 

Balance 

Hirt 

Red Jacket 

. Hasitech 

Healy 

Manifolded?(YorN) _ 

Opaiattng Paramatara: 

I_n___ 

1 

2 

3 

£__•___ Galloni Praam 

Applicable Regulation*: VN Racommended: 

Source Test Raaulta and Commanta: 

Tank #: 

Product Grade: _ 

Actual Tank Capacity, gallons 

Gasoline Volume, gallons 

Ullage, gallons 

Initial Pressure, inches H2 0 

Pressure After 1 Minute, inches H2 0 

Pressure After 2 Minutes, inches H2 0 

Pressure After 3 Minutes, inches H20 

Pressure After 4 Minutes, inches H20 

Final Pressure After 5 Minutes, inches H20. 

NO COMMERCIAL USE OP THESE RESULTS IS AUTHORIZED 

"Mt Conouctao oy Taat Company OataoiTaat 

~WTS: «: u 
P.40 

ATTACHMENT 3 
P.41 

VIOLATIONS 

The folloviag is a general list of violations. This list is aot 

conclusive aad should bs treated as a reference for what eaa 

constitute a violation. 

GENERAL VIOLATIONS 

- Required labels not prsssnt or unreadable 

- Licenses, permits and system tasting results which are not 

current, valid, or do not meet any of ths othar program 

requirements 

- Required records or filss which are not updated or available 

or are not kept according to program requirements 

EQUIPMENT RELATED VIOLATIONS 

NOZZLE BOOTS 

Nossls boots are considsrsd to bs dsfaetivs if thsy have a slit 

greater than one inch in length, have a triangular tsar greater 

than 1/2 inch par side,are improperly installed/ or are uncertified 

or missing. 

FACEPLATES 

Faceplates are considsrsd to ba dsfaetivs if thsy ars damaged such 

that less than 3/4 of ths faesplats contacts ths fill inlet area 

hole, ars improperly installed, or are uncertified or missing. 

PACECONES 

Faceeones ars considsrsd to bs dsfsotive if they are damaged such 

that less than 3/4 of the faoecone is prsssnt, are improperly 

installed, or are uncertified or missing. 
P.42 

-2-

CHECK VALVES 

Chsck valves are considsrsd to bs defective for a balance system 

if they are frozen in the open position (impaired from motion by 

the boot), or improperly installed or missing. Chsck valvss ars 

defective in a Hirt system when they are frosen in the open or 

closed positions or missing. Check valves ars not required for 

aspirator assist systems. 

Any auto shut off/flov limitsr meohanisms not operating properly 

or is missing is also considsrsd to be a violation. 

HOSES 

Hoses ars considered to be defective if they are flattened or 

kinked in any manner that will constrict ths flov of vapors in the 

vapor return line, improperly installed, torn such that vapors can 

escape, or are uncertified or missing. 

PROCESS UNITS 

Process units are considsrsd to be defective when they do not 

process the vapors as thsy were designed to. Any process unit 

which is not operational or not operating or is missing is 

considsrsd dsfactive. Defects of the process unit include but are 

not limited to: leaking return lines, intermittent process 

interruptions and lov return pressures. 

VACUUM DEVICES 

Vacuum devices on assist systems are considsrsd to bs dsfsctive 

when they are not operating, have been removed from service or are 

missing. Defective devices inelude leaking return lines, lov 

prsssure returns or intermittent processing. 

NOTE: some of this information was derived from the California Air 

Resources Board Compliance Division Compliance Assistance Program 

Gasoline Marketing and Distribution Gasoline Facilities Phase I * 

II inspsction nots book.