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Clarifying Stage I & Stage II Requirement Enforcement Guidelines

The memo states that all gasoline dispensing facilities (within the state of GA) subject to Stage I Vapor Recovery rules must maintain their Stage I Vapor Recovery Systems (VRS) in accordance with the Executive Order (EO), which was in effect at the time of the VRS’s installation. All new installations must use the most recent EO for the VRS, which is installed. If a major modification is made to the VRS then the governing EO becomes the EO in effect at the time of the major modification.

An Owner/Operator (O/O) may choose to voluntarily upgrade his/her vapor recovery system to standards specified in the most recent EO. This makes the VRS subject to the most recent EO. Installation of a newly certified vapor recovery equipment will be recognized by GAEPD as a voluntary upgrade of the VRS by the O/O to the EO which certifies the new equipment, and the VRS will now become subject to the regulations outlined in the applicable EO.

An O/O may install Stage I Enhanced Vapor Recovery (EVR) swivel adapters as a replacement part on an existing Stage I system. This is justified because the top section of a swivel adaptor rotates with the drop hose movements while the bottom section remains in place and maintains the integrity of the seal preventing venting of the tank in the atmosphere. Installation of a swivel adapter on an existing Stage I system will not require a torque test of the swivel adapter. In this case, the VRS shall remain a Stage I system and will not be considered as an upgrade to an EVR system. The VRS shall continue to be regulated by the applicable EO with the swivel adapter requirements. No other components of the EVR system will be allowed installed unless approved by California Air Resources Board (CARB ) or a third party.

All gasoline dispensing facilities subject to Stage II Vapor Recovery rules must maintain their Stage II VRS in accordance with the EO, which was in effect at the time of the VRS’s installation. All new installations must use the most recent EO for the VRS, which is installed. If a major modification is made to the VRS then the governing EO becomes the EO in effect at the time of the major modification. An O/O may chose to voluntarily upgrade his/her VRS to standards specified in the most recent EO, making it subject to that EO. Installation of newly certified vapor recovery equipment will be recognized by GA EPD as a voluntary upgrade of the VRS by the O/O to the EO which certifies the new equipment. This will result in the VRS being subject to the requirements outlined in the applicable EO.

Stage I & II EVR is optional, but if the O/O choose to install Stage I or II EVR, the entire approved system must be installed, and all tests and regulatory requirements outlined in the governing EO must be followed. It is recommended that O/O’s install Stage I EVR on all new installations and major modifications so that potential future rule changes will not require additional major modifications.

O/O or Companies Testing on behalf of O/O are required to submit accurate information to GA EPD regarding sites they are contracted to test. Failure to submit accurate information on Testing Notifications could result in a failure of the test in question. Submitting a test notification with the incorrect EO listed is considered by GA EPD to be inaccurate information and shall result in a failure of the test.