RE: Stage II Decertification

Shepard, Dave to

:

Glenn Passavant, Jones, Christian

Cc

:

Lynn Dail, "lrector@nescaum.org"

Glenn,

As a first step I’ll answer the questions you posed in your email as best as I can. It sounds like these 

issues may be the topic of a conference call with NESCAUM. If you’d like to schedule a separate phone 

call just let me know.

(1) how many GDFs in VT have Stage II.? I realize that it only applies to stations exceeding 400,000 

gal/yr.

In Vermont approximately 394 GDFs were equipped with Stage II before we started phasing out 

the program. The number that currently have Stage II is probably around 340.

(2) for a typical GDF, say 1.2 1.4 million gal/yr what are the estimated costs for 

decommissioning Stage II? 

We haven’t made an attempt to estimate the cost of decommissioning Stage II and so far I 

haven’t seen any invoices or other information for any of the GDFs that have been 

decommissioned so far to provide any cost figures. 

(3) before decommissioning what were the average annual inspection,testing, and hardware 

maintenance costs for this typical station due to Stage II? 

We don’t have a good estimate of the annual cost of compliance as we have only anecdotal 

knowledge of the hardware maintenance costs for GDFs. The Stage II regulation was amended in 

2001 to require GDFs to perform specified maintenance of their tank top fittings annually 

(including replacement of the vapor adaptors) or to perform an annual pressure decay test. At 

that time we estimated the cost of the pressure decay test to range from $350 to $800 and the cost 

to replace vapor adaptors at $100 per adaptor (typically a GDF has between one and three 

adaptors). There wasn’t an estimate of the labor costs. In addition to the annual 

maintenance/pressure decay test requirement the Vermont Stage II regulations require Stage II 

testing every five years. The required tests include a pressure decay test for all GDFs equipped 
with Stage II and either an air to liquid ratio test (for vacuum-assist equipped GDFs) or a 

dynamic backpressure test (balance equipped GDFs). 

(4) Is it correct to assume that essentially all GDFs in VT are vacuum assist. 

In Vermont approximately 90% of the GDFs with Stage II are/were equipped with vacuum-assist 

systems.

Dave Shepard

Vermont Department of Environmental Conservation

Air Pollution Control Division

103 South Main Street

Waterbury, VT 05671-0402

Phone: (802) 241-3857

Fax: (802) 241-2590

From: Passavant.Glenn@epamail.epa.gov [mailto:Passavant.Glenn@epamail.epa.gov] 

Sent: Tuesday, April 26, 2011 12:38 PM

To: Jones, Christian; Shepard, Dave

Cc: Dail.Lynn@epamail.epa.gov; lrector@nescaum.org

Subject: Stage II Decertification

Hi Chris and Dave

I am Glenn Passavant of EPA's Office of Transportation and Air Quality. I have worked the ORVR/Stage 

II control areas for EPA for over 20 years. 

As you may be aware, EPA is now developing a rule to relieve the states of their legal obligation to 

maintain Stage II controls. We hope to propose that rule this Spring.

As we have been developing the rule, a few questions have come up which I hope you might be able to 

help us answer since VT has already acted to remove Stage II and you have a fairly rigorous process and 

checklist.

I will summarize below and perhaps we can have a follow-up teleconference.

(1) how many GDFs in VT have Stage II.? I realize that it only applies to stations exceeding 400,000 

gal/yr.
(2) for a typical GDF, say 1.2 1.4 million gal/yr what are the estimated costs for decommissioning Stage 

II?

(3) before decommissioning what were the average annual inspection,testing, and hardware maintenance 

costs for this typical station due to Stage II?

(4) Is it correct to assume that essentially all GDFs in VT are vacuum assist.

Thank you for your help.

GLENN W. PASSAVANT

CENTER DIRECTOR

ASSESSMENT & STANDARDS DIVISION

OFFICE OF TRANSPORTATION AND AIR QUALITY

US EPA ANN ARBOR, MI

734-214-4408