Air Rules: Requirements and Information

Common definitions used when discussing GDFs:

  • An Existing Facility is one built before November 9, 2006. A New facility is any GDF built after that date.
  • Gasoline includes fuels such as E-85 and similar gasoline/alcohol blends. It does not include diesel or aviation gasoline.
  • A Gasoline Dispensing Facility (GDF) is any stationary facility that pumps gasoline into the fuel tank of a car, truck, boat, or other gasoline-fueled engines and equipment. The facility can be either a commercial store or a private pump.
  • AMT - Average monthly throughput is the amount of gasoline pumped (in most cases, sold) from a facility during a month. It can also mean how much gasoline is delivered to a facility in a month. Either method can be used. The monthly throughput determines what specific requirements a facility must meet.
  • Stage I vapor control systems reduce air emissions when a tanker puts gas in the storage tank. 
  • Stage II vapor control systems reduce air emissions when a car fuels up at the pump. Must be decommissioned by July 14, 2019.
  • ​Submerged fill means the bottom opening of the fill pipe is covered by the gasoline in the tank. The bottom opening is either at a specific distance from the bottom of the tank or can be shown to always be below the level of gasoline in the tank.

Federal Rules Affecting Gasoline Dispensing Facilities

The Federal GDF rule is the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Category: Gasoline Dispensing Facilities (40 CFR 63 Subpart CCCCCC) or 6C. On July 14, 2016, the State of TN rule 1200-3-18-.24 was revised to be similar to the Federal GDF rule. For most existing facilities, there will be no change in their requirements. GDF within certain counties will still be required to install and maintain Stage I vapor recovery systems when they have an AMT of 10,000 gallons/month or greater. See the listing of what counties are affected by location and throughput in the Air Rules by Location and Throughput section. Also see the section Stage I rules from TN Air Pollution Control below.

To see the entire current Federal GDF rule, please follow this link.

Based on the monthly throughput of a facility, different control requirements must be met for the following levels:

  • Less than 10,000 gallons/month.
  • Equal to or greater than 10,000 gallons/month.
  • Equal to or greater than 100,000 gallons/month.

See the brochure from EPA explaining the GDF rule for a summary of the control requirements for each level.

Existing sources should currently be in compliance. If the throughput of the existing facility increases to a new level, it should meet the requirements for that level within three years. If your facility is a new source (constructed or reconstructed after November 9, 2006), it must comply with the rule upon start up.

Gasoline Distribution NESHAP 6C Video from EPA

EPA’s Air Pollution Training Institute has a video describing Stage I and GDF requirements. The video explains what the 6C rule is, why it exists, and the general requirements of the rule. It is very informative and may help answer questions about the rule in an easy to understand method.

Information relating to 6C

Stage I rules from TN Air Pollution Control

On July 14, 2016, the State of TN rule 1200-3-18-.24 was revised to be similar to the Federal GDF rule. For most existing facilities, there will be no change in their requirements. The revised State rule continues to affect facilities located within 29 TN counties. GDF located in the 29 counties are required to install and maintain Stage I vapor recovery systems when they have an AMT of 10,000 gallons/month or greater. This is the same as the 2006 State of TN Stage I and II Vapor Recovery rule.

The TN Stage I Vapor Recovery rules required the installation of Stage I Vapor Recovery systems for sources within the 29 counties that have a monthly throughput of greater than 10,000 gallons per month. Please note that this is more stringent than the Federal 6C rule described above. The Tennessee Stage I Vapor Recovery Fact Sheet gives information about which counties are affected by the State rule.

For a look at the regulations governing Stage I and II in Tennessee go to page 57 of the document that opens up by going here: 1200-3-18-.24 Volatile Organic Compounds.

Stage II rules and testing from TN Air Pollution Control

On July 14, 2016, the State of TN rule requiring Stage II vapor recovery changed. Following this date, GDFs are required to decommission their Stage II vapor recovery system by July 14, 2019. Existing Stage II systems should be decommissioned by July 14, 2019, using the Petroleum Equipment Institute (PEI) guidance, “Recommended Practices for Installation and Testing of Vapor Recovery Systems at Vehicle Fueling Sites, PEI/RP300-09”. No new Stage II vapor recovery systems should be installed.

Until a GDF decommissions their Stage II vapor recovery system, they will have to continue to operate, maintain, and test their system as previously. Stage II rules and testing apply to GDFs with a throughput greater than 10,000 gallons per month of gasoline within Davidson, Rutherford, Sumner, Williamson, and Wilson Counties. Information about requirements for Stage II systems that have not been decommissioned yet is below.

Stage II Fact Sheet

Stage II systems are required to be tested every five years. This test should be performed according to one of three methods:

(a) Unless otherwise specified in this rule, use the test method found in Rule 1200-3-18-.85 (page 197) to determine compliance with the vapor-tight requirements for lines, piping, caps, couplers, adapters, and fittings;

(b) The test methods found in Appendix J, Technical Guidance - Stage II Vapor Recovery Systems for Control of Vehicle Refueling Emissions at Gasoline Dispensing Facilities, Volume II, EPA - 450/3-91-022b (November 1991) (a scanned copy of Appendix J can be viewed through this link), to determine compliance with applicable requirements; and/or 

(c) Other methods necessary for demonstration of compliance approved by the Technical Secretary and the EPA.