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EPA Vapor Recovery Regulations

The Environmental Protection Agency (EPA) is tasked with maintaining and creating good air quality. The Clean Air Act (CAA) promulgated numerous regulations to prevent public health risks from air pollutants. One such regulatory program, Title I of the Act, National Ambient Air Quality Standards (NAAQS), identified areas that did not meet specific standards for criteria air pollutants. These non-attainment areas have more stringent air quality regulations designed to improve public health and welfare. Certain types of filling stations located within non-attainment areas are required to install vapor recovery systems to reduce releases of volatile organic compounds (VOC) and relevant ozone problems.

  1. Air Quality Regulations 40 CFR 50

    • The EPA requires states to adopt federally approved control strategies for air pollution. As such, state agencies are tasked with preparing state implementation plans (SIP) that show how all permits will meet minimum federal standards. For those states that do not meet NAAQS standards for criteria pollutants, such as particulate matter (40 CFR 50.6), ozone (40 CFR 50.9 and 50.10) and soluble acids (40 CFR 50.11) in certain "non-attainment" areas, more stringent regulations are required. Any state that does not meet minimum federal air quality regulations, has to institute vapor recovery systems for gasoline filling stations when granting underground storage tank permits.

    VOC Recovery at Gas stations--State Regulations

    • Similar to air quality regulations, the EPA has granted states oversight on the granting of underground storage tank (UST) permits. All gasoline stations have the potential to emit VOCs that increase on-the-ground ozone, causing significant lung ailments for surrounding populations. Any filling station within a non-attainment area must meet state requirements to reduce VOCs and ozone problems by installing vapor recovery systems. For example, Illinois' vapor recovery regulations are contained in the Illinois Administrative Code Title 35 Sections 215, 218 and 219.

      Not all filling stations in non-attainment areas must install vapor recovery systems. Only stations that sell more than 10,000 gallons of gasoline per month or stations that sell more than 50,000 gallons of gasoline and are classified as an independent small business marketer are required to to install systems. An independent small marketer is an owner of tanks and other dispensing equipment. Gasoline refineries are not regulated under this program. The owner of the tanks and pumps is responsible for paying for the vapor recovery systems and site-specific details are included in the underground storage tank (UST) permit for the station.

    Vapor Recovery Systems--State Regulations

    • A vapor recovery system reduces volatile organic compounds and other hazardous air pollutants during gasoline refueling. A recovery systems collects vapors at the fill pipe and returns them to the underground storage tank. Stage I vapor recovery systems connect tubes from the storage tank to the cargo tanker to capture harmful vapors. Stage II recovery systems capture vapors through the pump hose, when vehicles are refueled, and transfer them back to the storage tank. Both system stages conserve gasoline by decreasing evaporation rates. Without vapor recovery chemical, equilibrium in the storage tanks would be lost because air would be introduced into the system; gasoline would be lost to evaporation. Most importantly, harmful air pollutants are not released into the atmosphere, improving air quality which in turn protects public health. Illinois regulates vapor recovery systems under Title 35 of the Administrative Code, but each state's vapor recovery regulations may contain different nuances so check each code for detailed regulatory compliance information.

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