Enforcement Guidance for Stage II Vehicle Refueling Control Programs


United SIM*	Office of Air unci Mutton
Envtrorvnwtf*! ProtKScr AgiOOf	WMNngtofi, D.C, ZHSO
Air and ft«dl«fion
EPA ENFORCEMENT GUIDANCE
FOR STAGE II VEHICLE
REFUELING CONTROL
PROGRAMS
GASOUNE
OFFICE OF MOBILE SOURCES

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FNFORC FMFNT GUIDANCE
FOR
STAGE II
VEHICLE REFUELING CONTROL PROGRAMS
December 1991

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ISM J Of CONTENTS
SECTION TITLE
'•
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SPECIFIC PROGRAM CRITERIA
Training and Public Education
Program Oversight Agency (POA) Training and Testing Requirement*
for POA Inspectors
Facility Owner/Operator Training on Stage II Equipment
POA Education of Regulated Facilities
General Public Education
Determination of the Regulated Universe
Compliance Monitoring
Verification of Facility Compliance Through Record Keeping
Requirements far Regulated Facilities
POA Record Keeping Requirements
Facility Equipment Requirements for Installation and Testing
Infrastructure System Equipment
Above Ground System Equipment
i
POA Equipment Requirements
Regulated Facility Inspections/General Requirements
Requirements for Inspections of Facility Infrastructure
Requirements for Inspections of Facility Above Ground Equipment
Visual Inspection Requirements for Compliance Inspections
Functional Testing Requirements for Compliance Inspections
Penalties
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ENFORCEMENT GUIDANCE FOB STAGE n VEHICLE
BKFtna wr. rnNTROL PROGRAMS
k'MUiJilUNlKlK
1.0
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 ID, are systems that were developed to control volatile organic
compound (VOQ vapor releases during the refueling process of motor vehicles. This
proees takes the vapors normally emitted directly into the atmosphere during refueling and
recycles them back into the fuel storage tanks, thereby preventing their ggcapg 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 n 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 Administrator, provisions
for vapor control were to require specific vehicle fill area specifications for adaptability for
Stage H controls. A determination of the feasibility and desirability of vehicle based
refueling vapor control systems, commonly referred to as onboard controls, was
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 H 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 II program in the mid 198
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wbfch tic 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 ID system." Two documents were prepared to respond to this
mandate. A report detailing technical information on Stage Q systems was prepared by
EPA^s Office of AirJJuality Planning and Standards. That report b entitled
GaaoBnc Dispensing FucSMita (Technical *Guidanreh°
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.
O SYNOPSIS OF STAGE II GUIDANCE
This guidance establishes the minimum requirements for program enforcement and
oversight. The guidance is divided into five areas. Each Stage n program should contain
provisions for meeting or exceeding these criteria.
A successful Stage II 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 11 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 IT 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 E programs which comply with these criteria will be 95%
effective. States implementing Stage IT 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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20 STAGE n IMPLEMENT A TION REOIITRFMKN^S
2.1 GENERAL
All State having areas that are designated under tie National Ambient Air Qualitj
Standards (NAAQS) as nonattainment for ozone and further are r.la«rf*iA«jj moderate to
extreme. In accordance with the CAAA requirements 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 tie date of lie enactment of the Clean Air Act
Amendments of 1990, the Administrator 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."
m 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 lit as irnglmte for
ozone shall not apply after promulgation of sue! standards and the Administrator may, by
rule, revise or waive the application of the requirements of such section 182(b)(3) for areas
classified under section 181 at Serious, Severe, or Extreme for ozone, as appropriate, after
such time as the Administrator determines that onboard emissions control systems required
tinier this paragraph are in widespread use throughout the motor vehicle fleet."
S3iX3HGS
3.1 PARTIES KEGUIATEDUNDER THE CAA GASOIJNE VAPOR RECOVERY
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 EL 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 n program.
3JS DEXERMINA1HONOFREGIJIATEDFAC3UXIES
A gasoline dispensing facility's responsibility for installing Stage n 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 II 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 0 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.
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However, each slate may establish different cut-points s® long as they are is stringent or
mom stringent Ham those required by lie statute. If i 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 J DATES FOR INSTALLATION OF STAGE H CONTROLS AT REGULATED
FACILITIES
Section 182(b)(3)(B) of The Act establishes three deadlines for installation and use of Stage
II controls, once the state adopts the Stage II 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 to 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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4M BBQ(aAMEMlSSHlHL.BEDiyCT«ON DESIGN KEOP1REMENTS
4,1 CONTROL SYSTEM DESIGN REQUIREMENTS
He control system minimum efficiency design requirements are contained as part of tie
General Preamble of Title I. He states that have installed and are operating Stage II
controls lave demonstrated that 95 percent control of VOC emissions 'm practicable.
Therefore, EPA does not anticipate approval of a slate 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 J SYSTEM CERTinCATXONREQUIREMENTS
(a) An approved system should be tested and certified as meeting a minimum 0f
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) For EPA to accept a Stage H Program in the SIP submittal process, the
approved system(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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'•® ENFORCEMENT ffiOGMMMINIMlIM CRl'iMIA
5,1 GENERAL
Each Stage II program should meet or exceed lie 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 REGULATED FACILITIES.
(d) PERIODIC INSPECTION OF REGULATED FACILITIES TO INSURE
COMPLIANCE WITH PROGRAM REQUIREMENTS.
ft) A METHOD TO ENSURE REGULATED FACILITY COMPLIANCE WITH
PROGRAM REQUIREMENTS THROUGH ENFORCEMENT
MECHANISMS.
The following section generally defines these criteria.
5,i sriAiaiii mmmiSMxm. mmmm:mxmm^Mrn€XTrmiM
(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 II
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 n 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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nic POA should develop and distribute I® ai regulated facilities written
information regarding tie 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
mi 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.
0>) A METHOD TO DETERMINE WHICH FACILITIES COMPRISE THE
me Clean Air Act, as amended in 1990, sets out the sources which, at a minimum,
must be subject to the Stage H 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
roust comply with the Stage H program requirements.
(c) DATA COlJLECIfON TO MONITOR COMPLIANCE AMONG REGULA11D
FACILITIES
The POA should verify compliance by regulated facilities by insuring through data
collection, as well as inspections, that the facilities have installed the required equipment,
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 FACUITIES TO W5UME
COMPLIANCE WITH PROGRAM REQUIREMENTS
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 II 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 II equipment may be released. Inspection of the Stage I seals and covers
should be included as part of the Stage II 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 11 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
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Here Is a problem with the equipment, it should be corrected before operation can be
continued.
Ce) A MEfflOD TO ASSUME REGULATED FACILITYCXIMMJANCE WITH
PROC3UMRBQUIREMENTS THROUGHINFORGEMENTMECBANISMS
He POA should develop a penalty schedule which establishes appropriate penalties
for facilities violating lie Stage H requirements. These penalties may include
administrative, civil and criminal penalties that will deter or eliminate non-compliance with
the Stage U 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, plus recoup an additional amount which serves as a deterrent
to regulated parties. The policy should also recognize that penalty should
provide for fair and equitable treatment of the regulated community and for swift resolution
of environmental problems.
SPECIFIC PROGRAM CRITERIA
« TRAINING AND PUBLIC EDUCATION
GBfHIAL
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 II program requirements and procedures. Abo, the owners and
operators of the equipment should be trained in the operation and m»lntoni»nr«> of their
facility's Stage II 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 REQUIREMENTS 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 n vapor control programs,
(b) System types, parts, operations and functions,
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(c) Inspection requirements, both procedures and practice.
(d) Identification techniques of system and equipment failures, both visual and
functional,
(e) Record review and recording procedures,
(f) Enforcement procedures including issuance of #arnings, NOVs, bearing
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 SEP 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 training purposes, however
training should be developed and approved under the POA's guidance. The POA may also
elect to conduct the training "in-house".
O FACILITY OWNER/OPERATORS TRAINING ON STAGE M EQCiMENT
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
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SIP» The POA should monitor any and all training to evaluate Its effectiveness and require
updated training when significant changes In equipment or program requirements occur.
It is the responsibility of lie facility owner/operator to ensure that at least one facility
representative attend'this 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 who received the initial training/certificate leaves that facility, another facility
representative must take and successfully complete the training and maintain the certificate
on the facility premises.
O POA EDUCATION OF REGULATED FACILITIES
The POA should prepare information on the purposes and benefits of Stage H vapor
controls and distribute this information to all regulated facilities. The information should
include, but far not limited to:
(a) The general purposes and benefits (environmental, health, safety,and potential
costs savings) of the Stage II 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 information.
Posters, signs, pamphlets and other information tools, if properly developed, distributed
ni displayed, have been found to be very effective tools in educating gasoline dispensing
facility employees **s weil as the public.
6.4 GENERAL PUBLIC EDUCATION
The POA should prepare, and make available to the general public, Information on the
Stage II vapor control program. The information should be easily understood by the general
public and include, but need not be limited to the following:
(a) The purposes and benefits (environmental, health, safety, and potential cost
savings) of the Stage II vapor control program.
(to) A general explanation of how Stage H systems function.
(c) The correct procedures for operation of Stage II equipment.
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(d) Information on tie 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 PETOMWATOM OF THE REGTOLATB1 UNIVERSE
The POA most, la 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 II program requirements. Several methods have been
utilized to make the determination of which gasoline dispensing facilities may be required
to comply with Stage II vapor control program requirements. Each area should determine
the most accurate method for determining 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 ail potential facilities are Identified, a determination of which facilities meet all of the
requirements for mandatory compliance must be made. This determination must 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 II equipment.
States may choose to require that all facilities dispensing gasoline install and operate Stage
11 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 II
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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fl.§

«.l VERIFICATION OF FACILITY COMPIXANCE THROUGH RECORD KEEPING
1X1 ISJlltEmNB 101 Jffi6!JMT0)F4CiIiniS
The POA should track facility compliance by requiring flat regulated facilities
various types of records. The POA is responsible for developing and distributing these
for* prior to the facility craning 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 worts required to be maintained by the POA. Hie records should be required
to be kept on the facility premises in an easily accessible location for review by the POA
officials. Hie 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 INSTALLATION AND TESTING KBOLT5
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 II
system. The test results should be dated and should note the installing and test companies'
names, addresses and phone numbers.
(d) STAGE M SYSTEM MAINTENANCE RECORDS
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'sinformation,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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(«) INSPECTION RECORDS
The regulated facility should he required to maintain on the farilitv , „
inspects reports issued by the TO A. The file should be orgauitd °f
C® COMPLIANCE RECORDS
issued by ^ ^ I"" M?er COmpltan,:e ««*
the inspection ffle and £ S£25 £!&££ " "* f™°
(f) training certification
Tie regulated facility should be required to maintain on tie facility nwmfapc «».««# #
attends and completion of the training specified in .he SIP * accordS^th^ioo
I-1-2 foa record keeping requirements
A®!M dmel0p Td update 85 mnindt accurate, ujMo-date records and files of
^ all facility and prognm related Monnatiai indnding, hmimrn limited t*
the facility ^ k wWch Si01jH lnclude tM lowing information;
ine iacutty name, address, phone number, owner and operator namw a poa
SeTtaH thf ^ f c®mPBa,lce with implementation requirements and
m.mh, r system typemfomuition. Other station specmc information, such as tic
number of pomp, could be included at the POA's discretion.
- J* A Station Inspection Rfpftit Fjft which should be filed by assi
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«J FAC3UTYEQUIPMENT REQUIREMENTS TOM INSTALLATION AND
TESTING
12.1 'W«ASmUCTimESYSTMEQIJ»^T
AM underground plumbing, pump, 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 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 recertiffcation 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 m^jor system modification should be considered to be replacing, repairing
or upgrading 75% or more of the facility's Stage H equipment.
Sii 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
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operating properly. He testing on the above-ground equipment should only be conducted
when lie equipment Is fulj installed and ready for operation.
AH new program should consult with any Implementation Information and guidance
referenced in lie Sstiam. for Control of
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 non-
original 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 aftennarket replacement parts and the POA can opt for
accepting replacement parts approved by the CARB program.
O FROGRAMOVERSfGBT 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)
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8.4 MGIttA^FACn^rYWS^rnOMS
G»imALXiQum»»fr5
He POA must conduct a minimum of I compliance inspection, per facility per year, wilt
mandatory follow-up at facilities that are found to be in violation. lie 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.
1.4.1 REQUIREMENTS FOR INSPECTION OF FACILITY INFRASTRUCTURE
lYOTEFOA
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.
SA2 REQUIREMENTS FOR INSPECTIONS OF FACILITY ABOVE GROUND
EQUMNT BY THE BOA
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 ail 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)
. msmsnms
The visual Inspection should include, but not be limited to:
(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/retractors,flow limiters, 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.
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(2) Verification of the presence of al 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 flat lie facility has
complied with all record keeping 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.

Functional testing should be conducted by the POA in accordance with the following
criteria:
(1) A functional test of tie required shut off or flow prohibiting mechanisms should be
conducted on any nozzle which is believed to have a problem or tf 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.
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Hit following is a list of functional tests proven effective Im tie analysis of Stage H systems
operation and In determining equipment-related problems.
DYNAMIC BACKPRESSURE TEST
me Dynamic Backpressure test (DBT) m used to quantify the dynamic backpressure im
the vapor path from tie nozzle to the storage tank, (For a draft ample test procedure
derived from CAM! 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 hare a minimum and maximum
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 or Hirt vacuum assist
systems.
LEAK TEST
The Leak Test (LT) procedure is conducted to quantify the vapor tiflhtnaw 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
C ARB 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 fa 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
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(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) "Med Tagging" Equipment (Prohibiting equipment operation until
repair fe completed)
Provisions for civil and criminal penalties should also be considered as possible deterrence
mechanisms. H the penalties available to tie POA do not sufficiently deter violations and
non-compliance continue, alternative penalties must be pursued. The slate must assure
compliance in order to continue to receive the SIP credits provided for by the program.
The Penalty Schedule should account 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 polky should also recognize that penalty assessment should provide
for fair and equitable treatment of the regulated community and for swill 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.
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EPA-420-B-91-101
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