Winding Down: Decommissioning Stage II Vapor Recovery Systems

Individual States Methodically Decide When (or If) to Phase Out Gas Vapor Recovery at the Fuel Nozzle

It’s been about five years since the U.S. Environmental Protection Agency (EPA) ruled that fuel marketers could begin removing and replacing Stage II vapor recovery systems because they were no longer cost-effective at reducing air pollution. Since then individual states have been deciding what to do. The result has been a stream of decisions that has amounted to a gradual phase out. Only a handful of jurisdictions, led most notably by California, still require gasoline vapor recovery systems at the fuel nozzle.

The EPA’s 2012 announcement that it would waive Stage II vapor recovery requirements affected approximately 40 ozone nonattainment areas and 13 ozone transport regions. The agency determined onboard refueling vapor recovery systems (ORVR) are widespread in the highway motor vehicle fleet and are effective at capturing vapors evacuated from the gasoline tank before reaching the pump nozzle. The widespread use designation was made after the EPA determined more than 75 percent of gasoline was dispensed into vehicles that have ORVR systems.

The agency estimated potential national cost savings for facilities that decommission Stage II systems at more than $91 million. That amounted to recurring savings of about $3,000 per year for 30,600 dispensing facilities outside California with Stage II equipment. “By waiving the Stage II requirement, EPA is reducing regulatory burdens on the gasoline service station industry,” the agency wrote in its fact sheet regarding the ruling in 2012.

Decommissioning Requirements

The EPA ruling did not mean all fuel marketers were free to eliminate their Stage II systems. States had to show the EPA that removing Stage II requirements would not interfere with applicable Clean Air Act (CAA) requirements. This factor led to what amounted to a gradual phase-out in the states that decided to act. The process of decommissioning the systems is either completed or in progress for the large majority of the affected regions. Some of the most recent actions involve these states:

·         Virginia: As of January 1, 2017, owners of Gasoline Dispensing Facilities (GDF) located in the Richmond area may decommission their Stage II equipment in accordance with the PEI RP300-09.

·         Tennessee: As of July 14, 2016, Stage II will no longer be required to be installed in new GDF.  Existing Stage II systems should be decommissioned by July 14, 2019.

·         New Jersey: Beginning October 12, 2016 new GDF can be constructed without Stage II Vapor recovery systems.

·         Kentucky: Louisville stopped Stage II requirement in May 2016 and requires GDF to decommission those systems within 3 years.

California plans to retain its Stage II program for the foreseeable future. The state Air Resources Board (CAB) believes the EPA’s guidance allowing Stage II removal does not apply because its Phase II Enhanced Vapor Recovery program includes more controls and achieves more emission reductions than federal Stage II. The CAB also believes Stage II elimination would likely increase the risk of benzene exposure. The District of Columbia and three other states with Stage II vapor recovery requirements – Nevada, Oregon and Washington – have not acted to change them.

Decommissioning involves properly shutting down the Stage II equipment that collected gas vapor and transferred it to the underground storage tank until it could be collected by delivery trucks. The procedure generally involves capping off and disconnecting various Stage II components but leaves the below grade Stage II vapor piping in place. Regulations generally require facilities to decommission their entire Stage II system rather than replacing equipment at individual dispensers. All the Stage II hanging hardware must be replaced with conventional hanging hardware.

Two types of Stage II systems had been in place across the United States. Vapor Balance systems are characterized by the large bellows attached to the fuel nozzle. The somewhat cumbersome Vapor Balance system assembly creates a slight vacuum that pulls gas vapors back into the underground storage tank. The other Stage II system, Vacuum Assist, has a smaller vapor collector on the nozzle paired with a vacuum pump that pulls gas vapor back to the underground storage tank.

Husky Corporation offers a preassembled and fully tested set of hanging hardware allowing fuel marketers to replace their Stage II equipment. The EZ Connect package includes an adapter (to plug the vapor recovery line at the dispenser), whip hose, break-away, fuel hose, swivel, and nozzle.

“All the fuel marketer has to do is disconnect their old dispenser hose assembly and attach the EZ Connect package,” Baker said. “Since Husky is the only company that manufactures all the components needed to decommission Stage II systems, customers asked us to develop this professionally assembled package to make the decommissioning project as easy as possible.”

Husky quality inspectors check thread connections to ensure compatibility and consistency. Husky technicians assemble the components with tools that apply the correct torque, pressure-test the connections, and conduct continuity tests against problems with static electricity.

The CAA also required many ozone non-attainment areas to adopt Stage I vapor recovery systems which apply to the gasoline distribution industry and Stage II systems which apply to service stations in the early 1990’s. The Stage I rules limiting emissions of hazardous air pollutants from gasoline distribution terminals in the United States remain in effect.