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Gasoline Dispensing Facilities (GDFs)

The gasoline marketing industry includes many components that move gasoline from the point of production (the refinery) through bulk distribution and storage facilities (bulk terminals or bulk plants) and on to gasoline service stations. A retail service station or private facility where gasoline is dispensed into vehicle fuel tanks is commonly referred to as a Gasoline Dispensing Facility (GDF). The wholesale operations of storing and transporting gasoline, including delivery to and storage in a service station underground storage tank, are commonly called Stage I operations. Vehicle refueling operations are commonly termed Stage II. Click on the following link to view the emission factors used to calculate volatile organic compound (VOC) emissions from Stage I and Stage II operations at GDFs.

Stage I

Stage I Emission Controls

When Stage I emission controls are used, displaced gasoline vapors are collected and routed back into the delivery truck using a combination of pipes and hoses (see Stage I diagram). Submerged loading, consisting of a tube installed to within 6 inches of the bottom of the tank, significantly reduces emissions because turbulence caused by the splashing of the delivery product in the underground tank is minimized.

Stage I Compliance Schedules

In accordance with Chapter 3745-21 of the Ohio Administrative Code (OAC), which became effective March 31, 1993, all gasoline dispensing facilities located in Ashtabula, Butler, Clark, Clermont, Cuyahoga, Delaware, Franklin, Geauga, Greene, Hamilton, Lake, Licking, Lorain, Lucas, Mahoning, Medina, Miami, Montgomery, Portage, Stark, Summit, Trumbull, Warren and Wood counties are subject to the provisions of OAC rule 3745-21-09(R), which pertains to Stage I vapor control systems. Within the counties not mentioned above, the requirements of OAC rule 3745-21-09(R) apply to all existing GDFs: (1) for which construction or modification commenced on or after Oct. 19, 1979 or (2) which are located at a facility (plant) having the potential to emit a total of 100 tons or more of VOC per calendar year. The deadlines for final compliance with the Stage I requirements are specified in OAC rule 3745-21-04(C)(19).

In accordance with Ohio EPA Engineering Guide 12, Stage I emission controls are specified as "Best Available Technology" (BAT) for most new gasoline dispensing facilities in both urban and rural areas throughout Ohio with an annual gasoline throughput greater than 6,000 gallons (OAC rule 3745-31-01(NN) defines a new source).

Stage II

Stage II Emission Controls

Gasoline vapor VOC emissions occur when liquid from the underground tank is dispensed into the vehicle fuel tank. Vapors contained in the fuel tank are displaced back through the vehicle fillneck and are emitted to the atmosphere. With the installation of Stage II vapor recovery equipment, displaced vapors are captured at the vehicle fillneck and routed back to the underground tank (see Stage II diagram). VOC emissions from vehicle refueling operations also result from gasoline spitback/spillage at the vehicle fillpipe and breathing/emptying losses through the underground storage tank vent.

Stage II Compliance Schedules

In accordance with Chapter 3745-21 of the Ohio Administrative Code (OAC), which became effective March 31, 1993, all gasoline dispensing facilities located in Ashtabula, Butler, Clark, Clermont, Cuyahoga, Geauga, Greene, Hamilton, Lake, Lorain, Medina, Miami, Montgomery, Portage, Summit and Warren counties are subject to the provisions of OAC rule 3745-21-09(DDD), which pertain to Stage II vapor control systems. The deadlines for final compliance with the Stage II requirements are specified under OAC rule 3745-21-04(C)(64). However, the deadlines specified in OAC rule 3745-21-04(C)(64) have been extended for certain GDFs in the Cincinnati and Dayton areas based on separate Director's Final Findings and Orders issued on March 30, 1995, and March 21, 1996, which temporarily suspended and subsequently revoked the suspension of the Stage II programs in these areas. The following tables specify the Stage II compliance deadlines for Independent Small Business Marketers (ISBMs) of gasoline and non-ISBMs of gasoline in the Cleveland-Akron Area (Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage and Summit counties), the Cincinnati Area (Butler, Clermont, Hamilton and Warren counties) and the Dayton Area (Clark, Greene, Miami and Montgomery counties).

Stage II Training Requirements

Questions have arose regarding who is required to attend Stage II training. Stage II training is required for the GDF owner/operator or local manager under OAC rule 3745-21-09 (DDD)(3)(a)(vi). Proof of attendance and completion of the training is essentially required for the individual who is responsible for inspecting, maintaining, or otherwise ensuring ongoing compliance of the Stage II system at the particular site. The GDF owner/operator or local manager may be the trained individual for a number of sites for which he or she has direct oversight responsibilities. A maintenance or testing company employee may not serve as the trained individual. However, the responsible (trained) official may have oversight responsibilities of a maintenance or testing company employee assigned to duties at one or more GDFs. Persons interested in developing a Stage II training course should contact Ohio EPA, the Division of Air Pollution Control (DAPC) to obtain a copy of the Stage II course approval criteria.

California Air Resources Board (CARB) requirements for Stage II installations

Ohio EPA, DAPC has recently started issuing operating permits to GDFs which cite the CARB requirements that apply to the specific Stage II system installed at the facility. You can obtain a copy of the CARB certification (Executive Order) for your Stage II system from the Stage II equipment manufacturer, your Ohio EPA field office, or from the CARB website at http://arbis.arb.ca.gov/vapor/vapor.htm. Contact your Ohio EPA field office with questions regarding the CARB requirements.

ISBM Eligibility

Ohio Stage II rules classify GDF owner/operators as either ISBM of gasoline, or non-ISBMs. The Stage II rules provided the ISBMs with a three year phased-in compliance schedule for the installation of Stage II (for multiple-GDFs owned by an ISBM within Stage II areas) and a 50,000 gallons of gasoline per month per site exemption. Non-ISBM sites were required to complete installation of Stage II at earlier dates and meet a lower exemption level of 10,000 gallons of gasoline per month. Stage II controls must be installed at an exempted site if it's gasoline throughput exceeds its exemption level in any one month.

The ISBM provisions were created to protect those owner/operators that are true independent gasoline marketers and whose livelihood is centered on the marketing of gasoline. As provided by rule, a ISBM may not be a refiner, controlled by a refiner or directly/indirectly affiliated with a refiner unless the sole affiliation is by means of a supply contract or trademark agreement. In addition to these qualifications, an owner/operator must obtain more than 50 percent of his or her gross annual income from the marketing or sale of gasoline in order to qualify as an ISBM. The U.S. EPA defines income from sales of gasoline to include income from gasoline refining and marketing activities including activities commonly referred to as jobbing (i.e., purchasing gasoline from a refiner and then reselling it to a gasoline retailer or other distributor). Income from other sales includes all non-gasoline sales including, but not limited to the following: kerosene, diesel, food and snacks, beverages, cigarettes, lottery and owner income from non-GDF related activities. For example, a person whose only business and source of income was a combination grocery store and gasoline station would not fall within the ISBM definition if the person received 50 percent or more of his income from the sale of non-gasoline products.

Guidelines for Stage II Compliance Schedules

Questions have arose regarding the allowable length of time for an exempt GDF to achieve compliance with Stage II requirements after the GDF exceeds its exemption level. The GDF owner/operator must immediately provide an expeditious schedule for compliance with the Stage II requirements to the appropriate Ohio EPA District Office/Local Air Agency if during any month the gasoline throughput exceeds the applicable exemption level (10,000 gallons per month for non-ISBMs or 50,000 gallons per month for ISBMs).

The Ohio EPA, DAPC believes that the following represents an acceptable time frame for an exempted GDF owner/operator to achieve final compliance with Stage II requirements after exceeding a monthly exemption level:

  • Report monthly throughput in excess of an applicable exemption level within 15 days after the end of the month during which the exceedance occurred (exceedance report).
  • Submit compliance schedule and final control plan within one month after exceedance report.
  • Achieve final compliance (successful completion of all Stage II testing) within six months after submission of compliance schedule. Exceptions to this will be reviewed on a case-by-case basis based on weather, contractor availability, loan approval needs, etc.

The company's proposed compliance schedule should include the following milestones along with associated completion dates:


Completion Date

(a) Submit final control plan by:


(b) Place orders for the purchase of Stage II equipment by:


(c) Award contract for installation of Stage II by:


(d) Initiate on-site construction for installation of Stage II by:


(e) Complete on-site installation of Stage II by:


(f) Pass performance testing of Stage II system by:


(g) Achieve final compliance by:


Permit and Fee Requirements

Gas dispensing facilities have two permitting options available to them:

1. Permit-By-Rule (PBR) where no permit document is issued and all requirements are based on the applicable rule. A facility with only a PBR requirement does not have to pay annual air emissions fees.

2. Permit-to-Install and Operate (PTIO) where a permit is issued with facility specific terms and conditions. A facility with a PTIO would be subject to non-Title V air emissions fees.

Contact your district office or local air agency if you are unsure which option would be best for your operations.

Underground Storage Tanks

In Ohio, the Bureau of Underground Storage Tank Regulation (BUSTR) regulates Ohio's underground storage tank (UST) program. You may contact the BUSTR at 614-752-8200 or visit their website.