SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

Final Staff Report 

Proposed Rule 1177 – Liquefied Petroleum Gas Transfer and Dispensing 

June 2012 

Deputy Executive Officer 

Planning, Rule Development, & Area Sources 

Elaine Chang, DrPH 

Assistant Deputy Executive Officer 

Planning, Rule Development, & Area Sources 

Laki Tisopulos, Ph.D., P.E. 

Planning and Rules Manager 

Planning, Rule Development, & Area Sources 

Naveen Berry 

AUTHOR: KEN ELLIS – AIR QUALITY SPECIALIST 

REVIEWED BY: DAVID ONO – PROGRAM SUPERVISOR 

 WILLIAM WONG – PRINCIPAL DEPUTY DISTRICT COUNSEL 

CONTRIBUTORS: BARBARA RADLEIN – AIR QUALITY SPECIALIST 

 SHAH DABIRIAN – AIR QUALITY SPECIALIST 

 SUE LIEU – PROGRAM SUPERVISOR 
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

GOVERNING BOARD 

Chairman: DR. WILLIAM A. BURKE

Speaker of the Assembly Appointee 

Vice Chairman: DENNIS YATES 

 Mayor, Chino 

 Cities of San Bernardino County 

MEMBERS:

MICHAEL D. ANTONOVICH

Supervisor, Fifth District 

County of Los Angeles 

JOHN J. BENOIT 

Supervisor, Fourth District 

County of Riverside 

MICHAEL A. CACCIOTTI 

Mayor, South Pasadena 

Cities of Los Angeles County/Eastern Region 

JANE W. CARNEY 

Senate Rules Appointee 

JOSIE GONZALES 

Supervisor, Fifth District 

County of San Bernardino 

RONALD O. LOVERIDGE 

Mayor, Riverside 

Cities of Riverside County 

JOSEPH K. LYOU, Ph.D. 

Governor’s Appointee 

JUDITH MITCHELL 

Councilmember, Rolling Hills Estates 

Cities of Los Angeles County/Western Region 

SHAWN NELSON 

Supervisor, Fourth District 

County of Orange 

JAN PERRY 

Councilwoman, Ninth District 

City of Los Angeles 

MIGUEL A. PULIDO 

Mayor, Santa Ana 

Cities of Orange County 

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env. 
i

TABLE OF CONTENTS 

SECTION PAGE

EXECUTIVE SUMMARY ..................................................................................................1

BACKGROUND ..................................................................................................................5

Introduction ................................................................................................................................. 6

LPG Transfer and Dispensing ................................................................................................................. 7

LPG Fugitive Emissions .......................................................................................................................... 8

LPG Fire and Safety Considerations ....................................................................................................... 8

Affected Industry ........................................................................................................................ 9

Sales Distribution .................................................................................................................................... 9

EMISSION CONTROL TECHNOLOGY ASSESSMENT .............................................10

Fixed Liquid Level Gauge (FLLG) ......................................................................................... 10

LPG Low Emission Connectors ............................................................................................... 10

PERC Rebate Program ............................................................................................................ 11

SUMMARY OF PROPOSED RULE 1177 ......................................................................11

Purpose ...................................................................................................................................... 11

Applicability .............................................................................................................................. 11

Definitions .................................................................................................................................. 11

Equipment and Operation Requirements .............................................................................. 11

Operator Leak Detection Program Requirements ................................................................ 12

Recordkeeping Requirements .................................................................................................. 13

Reporting Requirements .......................................................................................................... 14

Leak Detection Method ............................................................................................................ 14

Confidentiality ........................................................................................................................... 15

Exemption .................................................................................................................................. 15

EMISSION INVENTORY ................................................................................................15

EMISSIONS ESTIMATION METHODOLOGY ............................................................15

Liquefied Petroleum Gas (LPG) Sales .................................................................................... 16

LPG Emission Factor Determination ...................................................................................... 17

Emission Reductions ................................................................................................................. 18

COST AND COST-EFFECTIVENESS ...........................................................................19

Capital and Installation Costs ................................................................................................. 20

Residential and Commercial Tanks ........................................................................................ 20
ii

Forklift Cylinders ..................................................................................................................... 20

Barbecue Cylinders ................................................................................................................... 21

Operation and Maintenance Costs .......................................................................................... 24

Overall Cost-Effectiveness ....................................................................................................... 24

INCREMENTAL COST EFFECTIVENESS ..................................................................25

COMPARATIVE ANALYSIS ...........................................................................................26

COMMENTS AND RESPONSES ...................................................................................30

Comments from Public ............................................................................................................. 30

SOCIOECONOMIC ASSESSMENT ...............................................................................43

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) .....................................43

DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE 

SECTION 40727 ...............................................................................................................44

REFERENCES .................................................................................................................46

Appendix A – LPG Industry Summary 

Appendix B – Emission Inventory Calculations 

Appendix C - Recordkeeping and Reporting Sample Forms 
iii

LIST OF TABLES AND FIGURES 

PAGE

Table 1. Summary of Proposed Rule 1177 Requirements .............................................................................. 4

Table 2. NPGA LPG Sales Categories ........................................................................................................... 7

Figure1. California 2009 LPG Sales Distribution .......................................................................................... 9

Table 3. Historical California LPG Sales (mgal), API sales data provided by Western Propane Gas 

Association .................................................................................................................................................... 16

Figure 2. California 2009 LPG Sales Distribution ....................................................................................... 17

Table 4. LPG Test Data ................................................................................................................................ 17

Table 5. SCAQMD VOC Emissions Reductions (tons per day) .................................................................. 19

Table 6. Summary of PR 1177 Capital and Installation Costs. .................................................................... 23

Table 7. Summary of Operational, Maintenance and Administrative Costs. ............................................... 24

Table 8. Comparison of Incremental VOC Reduction Alternatives and Costs ............................................ 26

Table 9. Proposed Rule 1177 Comparative Analysis ................................................................................... 27
Final Staff Report

Proposed Rule 1177 1 June 2012 

EXECUTIVE SUMMARY 

Fugitive Volatile Organic Compound (VOC) emissions associated with the transfer 

and dispensing of liquefied petroleum gas (LPG) are currently not accounted for or 

regulated by the South Coast Air Quality Management District (District) or the 

California Air Resources Board (CARB), with the exception of facilities covered 

under the scope of Rule 1173 – Control of Volatile Organic Compound Leaks and 

releases from components at Petroleum Refineries and Chemical Plants. The fugitive 

VOC emissions inventory from the transfer of LPG has been conservatively estimated 

to be 8.6 tons per day (tpd). Because LPG, which is a gas at atmospheric conditions, 

is stored under pressure to maintain its liquid state, reducing fugitive VOC emissions 

during the transfer and dispensing of LPG equates to reducing product loss and 

therefore, in addition to the air quality benefits, it would also result in potential costsavings and increased safety for industry and the consumer. 

The District initiated development of Proposed Rule (PR) 1177 - Liquefied Petroleum 

Gas Transfer and Dispensing in August 2010 and has worked extensively with 

industry in order to address their comments and concerns and arrive at a workable 

rule. Staff has conducted seven working group meetings and participated in thirteen 

site visits and incorporated overall feedback through multiple proposed rule language 

iterations. 

The proposed rule will reduce fugitive emissions of VOCs from the transfer and 

dispensing of LPG at facilities not subject to Rule 1173 by an estimated 6.1 tons per 

day, at a cost-effectiveness of $1,700 per ton. The processes contributing to these 

emissions include delivery and transfer of LPG to residential, industrial and 

commercial users, fueling stations and for cylinder refueling. The proposed rule 

applies to the transfer of LPG to and from stationary storage tanks, cylinders and 

cargo tanks, including bobtail trucks, tanker or transport trucks and railroad tank cars, 

as well as into portable tanks and cylinders. PR 1177 includes the following 

requirements, as further summarized in Table 1: 

 Installation of low emission connectors and valves 

- Effective July 1, 2013, require the use of LPG low emission connectors 

for transfer and dispensing of LPG to limit the discharge of LPG upon 

disconnection to four cubic centimeters or less; 

- Require that LPG-receiving containers that are filled using a fixed liquid 

level gauge (FLLG) or “bleeder valve” as an overfill prevention device be 

equipped with a low emission FLLG (number 72 size orifice or 

equivalent) according to the following schedule: 

 For owned or leased stationary storage tanks: 

- For new or re-serviced owned or leased stationary storage 

tanks effective July 1, 2013 ; 
Final Staff Report

Proposed Rule 1177 2 June 2012 

- For owned or leased stationary storage tanks that can be 

retrofitted in the field effective July 1, 2015; and 

- For all other owned or leased stationary storage tanks by 

July 1, 2017; 

 For cargo tanks: 

- Immediately, for any cargo tank manufactured on or after 

July 1, 2013; and 

- For all other cargo tanks by July 1, 2013 or as soon 

thereafter at the next service in which the cargo tank is 

evacuated, but no later than July 1, 2017; and 

 For portable tanks and cylinders by July 1, 2017 

 Implementation of a Leak Detection and Repair Program 

- Require daily physical inspections for leaks at LPG bulk loading facilities 

and LPG transfer and dispensing facilities that offer LPG for sale to an 

end user; 

- Require proper maintenance of vapor recovery or equalization systems at 

bulk loading facilities; 

- Require a quarterly leak check inspection of LPG connectors using a 

bubble test at LPG bulk loading facilities and LPG transfer and dispensing 

facilities that offer LPG for sale to an end user; and 

- Require removal from service and repair of leaking connectors prior to 

returning to service at LPG bulk loading facilities and LPG transfer and 

dispensing facilities that offer LPG for sale to an end user; 

 Recordkeeping 

- Require recordkeeping of all low emission FLLGs and LPG low emission 

connectors installed;

- Require records of leak repairs; and

- Require vapor recovery or equalization system maintenance records;

 Reporting

- Require annual reports of monthly purchase and dispensing volumes for 

calendar years 2013, 2014, and 2015 for LPG bulk loading facilities and 

LPG transfer and dispensing facilities that offer LPG for sale to an end 

user, by July 1, of the following year; and 
Final Staff Report

Proposed Rule 1177 3 June 2012 

- Require reporting of end of year inventories of all containers and 

associated low emission FLLGs for calendar years 2013 through 2017 and 

low emission connectors installed for calendar year 2013.

 Exemptions 

- Containers with a water capacity of less than 4 gallons into which LPG is 

transferred 

- LPG cylinders that are specifically dedicated for and installed for use with 

recreational vehicles 

- Facilities that are subject to the requirements of Rule 1173 
Final Staff Report

Proposed Rule 1177 4 June 2012 

Table 1. Summary of Proposed Rule 1177 Requirements 

Requirement Bulk Loading 

Facility 

Transfer and Dispensing Facility 

Offers LPG for Sale to 

End User Other 

LPG Low Emission Connectors By Jul 1, 2013 

Low Emission FLLG*

Cargo Tanks New 7/1/13 

Following Tank Evacuation† 7/1/17 N/A 

 Owned or Leased Stationary Storage Tanks 

New or Reserviced: 7/1/13 

In Field Retrofit‡: 7/1/15 

Other Retrofit‡: 7/1/17 

N/A 

Portable Tanks By Jul 1, 2017 

Vapor Recovery or Equalization System 

Maintain System: 

- Liquid and Vapor Tight During Transfer 

- Maintain Transfer Hose Assembly in 

Accordance with Vendor Specifications 

Beginning 

January 1, 

2013 

N/A 

Daily Inspection for Leaks Upon Rule Adoption N/A 

Quarterly Inspection for Leaks Beginning January 1, 2013 N/A 

Recordkeeping

- Low Emission FLLG Installations 

- LPG Low Emission Connector Installations By Jan 1, 2013 

- Leak Repairs Effective Jan 1, 2013 N/A 

- Vapor Recovery or Equalization System 

Maintenance Records By Jan 1, 2013 N/A 

Reporting (Annual)

- LPG Purchase and Dispensing Month-to-Month By Jul 1, 2014, 2015, 2016§ N/A 

- Inventory of LPG Containers and Associated 

FLLGs 

By Jul 1, 2014, 

2015, 2016, 

2017, 2018 

N/A N/A 

- End of Year Inventory of LPG Low Emission 

Connectors and Associated Equipment By Jul 1, 2014 N/A N/A 

* Alternatively, an owner/operator may transfer or dispense LPG with the FLLG closed during transfer using a fill by 

weight technique or alternative technique or technology that monitors the maximum fill level to prevent overfilling 

without use of the FLLG. 

† Effective July 1, 2013 cargo tanks shall be retrofitted exclusively with low emission FLLGs following any service that 

requires evacuation, but no later than July 1, 2017. 

‡ Tanks that cannot be retrofitted without relocation shall be retrofitted after it is taken out of service, prior to being 

returned to service, but no later than July 1, 2017. 

§ LPG transfer and dispensing facilities that offer LPG for sale to an end user may satisfy the reporting requirement by 

arranging to have their LPG suppliers identify and include their facility’s LPG purchases with the supplier’s annual 

report. The supplier shall also notify the facility and the District by March 1 of the reporting year in order to satisfy the 

reporting requirement. 

The estimated emission reduction is 6.1 tons per day of fugitive VOC emissions upon 

full implementation. PR 1177 will partially implement Control Measure CM #2007 

MCS-07 – Application of All Feasible Measures from the 2007 Air Quality 

Management Plan (AQMP). 

Currently, only a subset of the LPG transfer and dispensing industry is being 

evaluated for VOC emissions reductions and controls in this proposed rule. Staff will 

continue to study other industry processes and potential control technology, and may 
Final Staff Report

Proposed Rule 1177 5 June 2012 

pursue future amendments in an effort to procure greater emission reductions from 

this source category, including a review of exempted and out of scope operations and 

contributions from leak detection and repair. 

Pursuant to California Environmental Quality Act (CEQA) Guidelines §15252 and 

§15162 and AQMD Rule 110, the AQMD has prepared an Environmental 

Assessment (EA) for Proposed Rule 1177. The environmental analysis in the Draft 

EA concluded that Proposed Rule 1177 would not generate any significant adverse 

environmental impacts. The Draft EA was released for a 30-day public review and 

comment period from April 3, 2012 to May 2, 2012. Any comments received during 

the public comment period on the analysis presented in the Draft EA will be 

responded to and included in the Final EA. Prior to making a decision on the 

proposed adoption of Rule 1177, the SCAQMD Governing Board must review and 

certify the Final EA as providing adequate information on the potential adverse 

environmental impacts of the proposed project. 

Staff has prepared a separate report on socioeconomic analysis with a summary of the 

overall cost-effectiveness of PR 1177 and that report is available to the public at least 

30 days prior to the public hearing. 

BACKGROUND 

In May 1992, the California Air Resources Board (CARB) conducted a study to 

determine the usage patterns of LPG and to estimate emissions resulting from the 

transfer operations for the entire state of California. This effort was the first attempt 

to quantify LPG transfer emissions in California and the study found that total 

emissions were estimated to be 1,131 tons per year (3.11 tons per day) or the 

equivalent of 464,000 gallons of LPG emitted as fugitive VOCs annually. These 

emissions were based on 722 million gallons of LPG transferred in California and 

relied upon data provided by the National Propane Gas Association (NPGA). The 

report also concluded that emissions from the FLLG emissions were just as 

significant as emissions from filling line disconnections. 

Starting in 2005, the Propane Education and Research Council (PERC), a non-profit 

organization created to enhance consumer and employee safety and also to provide 

research and development for clean and efficient propane utilization equipment, 

initiated a rebate program, subsidizing 75 percent of the cost of retrofitting LPG 

transfer and dispensing equipment with LPG low emission connector and “bleeder” 

valve (FLLG) technology. Based on data presented by the Western Propane Gas 

Association (WPGA), the program has funded approximately $500,000 to date. 

These funds have been used to complete the retrofit of an estimated 25 percent of the 

inventory of LPG low emission connectors and “bleeder” valves within the District 

that are eligible to be retrofitted. In order to qualify for the PERC rebate program, an 

owner/operator is required to retrofit an existing connector with one that meets the 

maximum design limit of four cubic centimeter (4 cc) emission release upon 

disconnection. However, in a few cases, although the design limit may exceed the 4 

cc limit, the emission reduction benefit was considered significant enough to warrant 
Final Staff Report

Proposed Rule 1177 6 June 2012 

consideration. Based on 2010 and 2011 PERC data for LPG low emission 

technology retrofits that have been completed, there are a few cases where connectors 

have achieved VOC reductions of greater than 95 percent, although the release 

amounts are as much as 24.9 cc per disconnection. 

In 2006, under CARB’s Innovative Clean Air Technologies (ICAT) grant program, 

the Adept Group Inc. evaluated and recommended methods to reduce fugitive VOC 

emissions from FLLGs during LPG tank filling operations. The Adept Group is a 

consulting company based in Westwood, California that provides services, including 

commercialization of technologies as well as engineering and technology advisory. 

In the past, The Adept Group received PERC grants for a subsonic Continuous Level 

Gauge (CLG) development for horizontal LPG storage tanks and an acoustic StopFill Instrument (SFI) for Liquefied Propane Gas tanks. Both of these technologies 

were designed to non-invasively facilitate the filling of LPG containers with the 

FLLG valve closed, thereby limiting the amount of LPG vented to atmosphere. 

Based on most recent information obtained from the Adept Group, there are now over 

100 tanks (predominantly bulk tanks 1,000 gallons and greater) in both Europe and 

the United States that are monitored with CLGs. Although the only SFIs that have 

been sold have been through a project with the Texas Railroad Commission, the 

product is now commercially available. 

The District rule development process was initiated in August 2010 and has consisted 

of meetings with industry, including the WPGA and its membership. There have 

been a total of seven working group meetings and 13 field visits to bulk loading and 

dispensing facilities. Staff has had numerous telephone and electronic mail 

communications with CARB, the National Fire Protection Association (NFPA) and 

local fire agencies to fully evaluate the LPG transfer and dispensing process, as well 

as existing applicable local and federal fire code requirements and practices. There 

have also been direct (teleconference) communications with FLLG and LPG low 

emission connector manufacturers, including Marshall Excelsior and RegO Products. 

In June 2011, a report authored by Life Cycle Associates, LLC, and prepared for 

WPGA, estimated the quantity of LPG fugitive emissions in California by examining 

the distribution chain of LPG, the associated activities and the potential VOC fugitive 

emissions events at each stage of the distribution process. LPG quantities transferred 

and dispensed as well as the emissions resulting from these processes were prorated 

for the District based on population data in the absence of region-specific data. The 

report also included potential strategies for VOC reductions, including the use of 

LPG low emission connectors and smaller orifice FLLGs or “bleeder” valves. 

Introduction 

LPG is a petroleum product composed predominantly of any of the following 

hydrocarbons or mixtures thereof: propane, propylene, butanes (normal or isobutane) 

and to a lesser extent butylenes, and is classified as a VOC. Although consisting 

mainly of propane and butane, in some parts of the country, propane itself is 

commonly referred to as LPG. Unlike gasoline, which is a liquid under normal or 
Final Staff Report

Proposed Rule 1177 7 June 2012 

standard conditions, LPG is a vapor under similar conditions, and must be stored and 

transported in closed containers under pressure to retain its liquefied state and may 

also be refrigerated to reduce the pressure at which it is stored. 

LPG is colorless and odorless and about 1.5 times as heavy as air in the vapor state. 

Therefore, it is generally necessary, as a fire and safety precaution, to warn users of 

its presence in the event of leaks. Organosulfur compounds are usually used for this 

purpose with the most common odorant being ethyl mercaptan. Most states require a 

minimum of 1 pound of odorant to be injected into 10,000 gallons of LPG loaded. 

Appendix A – LPG Industry Summary contains additional details on LPG properties, 

transfer methods and uses. 

Table 2 below indicates the LPG consumption categories and the specific uses in 

each NPGA identified category. 

Table 2. NPGA LPG Sales Categories 

Category Description 

Residential Private homes (heating and cooking), recreational 

vehicles 

Commercial Motels (space heating and cooking), restaurants 

(space heating & cooking), laundries 

Chemical Raw material for chemical processing industry 

I.C.E. Fuel Highway vehicles, forklifts, oil field drilling production 

equipment 

Agricultural 

Tractor fuel, irrigation equipment engine fuel, building 

space heating, cooking, crop drying, tobacco curing 

and flame cultivation 

Sales to 

Retail Cylinder filling and exchange 

Industrial Standby fuel for manufacturing plants, space heating, 

flame cutting, metallurgical furnaces 

LPG Transfer and Dispensing 

When material is transferred from storage containers, it is done under normal 

atmospheric conditions, but typically at operating pressures which are higher than 

atmospheric through the use of pumps or vapor compressors in a closed system. In 

order for the material to remain in its liquid state when transferred, it is important that 

delivery occurs within a closed system where pressure is not compromised. Another 

important reason for maintaining a closed system under compression is because LPG 

is sold as a liquid and therefore metered and typically paid for on a per volume basis. 

Maintaining a closed system ensures that the customer is paying for product that is 

actually transferred rather than paying for lost product - a requirement of the Bureau 

of Weights and Measures. 

The main value of LPG products lies in the fact that they can be stored in a liquid 

state and used in their gaseous state. The advantage obtained from reduced 
Final Staff Report

Proposed Rule 1177 8 June 2012 

transportation cost is sufficient to offset the cost of liquefying and maintaining these 

products in a liquid state. Also, in order to use LPG in most commercial and 

industrial applications, it must eventually be converted back to a gaseous state which 

can be accomplished by returning it to atmospheric conditions. 

Based on discussions with the working group and LPG operators and also through 

field observations, product transfer practices seem to vary relative to the period of 

time the FLLG is left open. Currently, NFPA 58; 7.3.1 (3) indicates that the venting 

of LPG gas, where necessary, shall be permitted by the use of FLLGs or bleeder 

valves. As such, per event activities are significantly different depending on the 

operator. Staff research indicates that NFPA 58 requires that the FLLG be used 

during LPG transfers mainly to address fire and safety concerns associated with 

overfills and possible release of large quantities of LPG. However, NFPA 58 does 

not specify the degree of opening the FLLG, which may also contribute to the 

different practices and hence the varying rates of fugitive LPG emissions. 

LPG Fugitive Emissions 

From the point of LPG production either from natural gas processing or crude oil 

refining to where the product reaches the end user, LPG is bought, sold, transported 

or distributed by wholesalers and refiners, retail bulk plants and other functions as 

detailed in Appendix A - LPG Industry Summary. During transfer of LPG there are 

fugitive emissions associated with each exchange. 

LPG fugitive emissions from transfer and dispensing operations result from three 

main areas: volatilization of entrapped product during disconnection of LPG supply 

and transfer lines, leaks in the equipment used for transfer and dispensing, and 

venting through FLLGs used as a safety device to ensure that pressurized receiving 

containers, including cylinders and tanks are not overfilled. 

The FLLG is attached to a dip tube that extends into the LPG storage container and is 

usually found on bobtail truck tanks, stationary storage tanks, and portable storage 

tanks and cylinders. The tube is inserted to be at the maximum level to which a 

receiving tank is to be filled and this level is typically set to 80 percent of the tank’s 

capacity with the remainder of the container left as vapor space to account for 

impacts of fluctuating temperature. The connection outside of the tank serves as a 

bleed valve. When the valve is opened during filling, LPG vapor is pushed through 

the FLLG and when the desired volume is reached, liquid LPG is ejected, thereby 

providing the operator with a visual indication that the tank has reached its capacity 

and filling is complete. 

LPG Fire and Safety Considerations 

Although transfer and dispensing of LPG has been relatively unregulated from an air 

quality perspective, proper handling and storage is subject to regulation under both 

the Department of Transportation (DOT) and the California Occupational Safety and 

Health Administration (Cal OSHA) as a hazardous material due to LPG’s 
Final Staff Report

Proposed Rule 1177 9 June 2012 

flammability. Moreover, because LPG is a saleable product, there is an inherent 

incentive to maintain closed storage, transfer and dispensing systems, which also 

serves to reduce fire and safety risks. A comparison of the DOT and Cal OSHA 

requirements to PR 1177 is included subsequently in the Comparative Analysis 

section of this report. 

Affected Industry 

The facilities and operations affected by PR 1177 are mainly represented by two 

Standard Industrial Classification (SIC) codes, 5984 - LPG (Bottled Gas) Dealers 

[North American Industry Classification System (NAICS) 454312] and 4925 - 

Mixed, Manufactured, or LPG Production and/or Distribution (no NAICS 

equivalent). However, processes not represented by either SIC code, but which 

include the transfer or dispensing of LPG will be evaluated on an individual basis to 

determine rule applicability. 

Sales Distribution 

Figure 1 below indicates the distribution of LPG sales in California according to 

market sector. The residential sector consumes approximately 40 percent of the total 

LPG sales in California followed by the chemical sector which uses approximately 20 

percent. The distribution in the District, in the absence of region specific data, is 

presumed to be similar to the statewide distribution. 

Chemical

20%

Commercial

12%

IC Engines

10%

Sales to Retail

7%

Agricultural

7%

Industrial

4%

Residential

40%

Figure1. California 2009 LPG Sales Distribution 
Final Staff Report

Proposed Rule 1177 10 June 2012 

EMISSION CONTROL TECHNOLOGY ASSESSMENT 

This section summarizes control techniques for reducing fugitive VOC emissions 

from LPG transfer and dispensing activities. In addition to a Leak Detection and 

Repair (LDAR) program for low emission connectors, PR 1177 requires facility 

operators to: 1) replace existing FLLG valves with a smaller orifice (0.025 inch) No. 

72 fixed liquid level gauge that reduces fugitive LPG vapors or use an alternative 

technique or technology that does not require the FLLG to be opened during filling, 

and 2) install LPG low emission connectors that result in reduced emissions upon 

disconnection. 

Fixed Liquid Level Gauge (FLLG) 

The FLLG, also referred to as the “bleeder” valve, is used as an indicator to 

determine the level of LPG in a tank. The valve is connected to what is called the dip 

tube which extends into the container. The dip tube is fixed and is typically set at a 

length equal to 80 percent liquid level tank capacity and filling level is dependent 

upon external conditions that would affect the expansion of LPG in the tank vapor 

space. The bleeder valve is designed so that during the filling process, when the LPG 

entering the tank reaches approximately the 80 percent mark, liquid will flow out of 

the opened valve as a visible mist. This lets the delivery operator know that the tank 

has reached its maximum filling capacity. 

Currently, No. 54 orifice drill size is used on most tanks and cylinders, although some 

tank owners have already retrofitted tanks with a smaller No. 72 orifice drill size, 

which results in a reduced amount of LPG emitted during the filling process. There 

are several companies that already manufacture and distribute these smaller orifice 

FLLGs. Staff’s research of FLLG manufacturers has determined that, although the 

No. 72 orifice drill size valve may not yet be available in commercial quantities for 

barbecue cylinders, they are available for storage tanks, forklift cylinders and cargo 

tanks. One manufacturer has indicated that the low emission FLLG is available in 

both brass and stainless steel for bobtail applications. Manufacturers further 

indicated that the lead time for bringing low emission FLLGs for barbecue cylinder 

applications to market is expected to range from a few weeks to a few months. They 

also anticipate little difficulty in meeting the expected demand that would result from 

the timelines established for compliance with the proposed rule. 

LPG Low Emission Connectors 

LPG low emission connectors are designed for various applications within the LPG 

transfer and dispensing industry. These products are designed to minimize the 

volume enclosed between two connection points, which limits the release of 

entrapped liquid upon disconnection. Relative to these specific applications, there is 

a manufacturer’s claim of up to a (6)99.6% reduction in fugitive emissions compared 

to standard connectors in use today and a minimum savings of $350 per 1,000 

transfers. Other low emission connectors are used for the dispensing of LPG into 

cylinders as well. 
Final Staff Report

Proposed Rule 1177 11 June 2012 

PERC Rebate Program 

FLLG component cost is usually less than $10 each, whereas LPG low emission 

connector equipment cost can range from less than $20 to as much as $2,250 for a 

loading arm system for a bobtail or tanker/transport truck. Based on information 

provided by WPGA, some LPG marketers have already retrofitted some tanks, 

cylinders, bobtails, tanker/transport trucks and lines that facilitate the transfer of LPG 

in the District with these LPG low emission connectors and FLLGs. There are 

numerous companies that manufacture and distribute FLLGs and low emission 

connectors. LPG marketers have had the costs of retrofits subsidized through a rebate 

program that is sponsored by the Western Propane Education and Research Council 

(WPERC). The program provides a 75 percent rebate on new LPG connectors and 

FLLGs on a first-come, first-serve basis and to date the WPGA has claimed that 25 

percent of existing inventory of LPG low emission connectors have been retrofitted 

as a result of the rebate program. 

SUMMARY OF PROPOSED RULE 1177 

Purpose 

PR 1177 will reduce fugitive VOC emissions from the transfer and dispensing of 

LPG. The processes contributing to these emissions include delivery to residential, 

industrial and commercial users, fueling stations and cylinder refueling. 

Applicability 

This rule applies to the transfer of LPG from any cargo tank, stationary storage tank 

or cylinder into another cargo tank, stationary storage tank, cylinder or portable 

storage tank. 

Definitions 

Key definitions are listed in the proposed rule for clarity, and utilize standard industry 

terms wherever applicable. The proposed definitions incorporate extensive feedback 

from the LPG industry. 

Equipment and Operation Requirements 

Effective July 1, 2013, PR 1177 will allow dispensing of LPG via liquid and vapor 

tight LPG low emission connectors or dispensers, and allow venting only through a 

low emission FLLG in accordance with a prescribed FLLG retrofit schedule, as 

further described below. In lieu of venting through a low emission FLLG during 

transfer or dispensing, the owner/operator may elect to use a filling technique or 

technology that monitors the maximum fill level to prevent overfilling without use of 

the FLLG. An LPG low emission connector is designed to result in a maximum 

emission release of four cubic centimeters of LPG when disconnected, and a low 

emission FLLG is a fixed liquid level gauge with a number 72 orifice size (0.025 
Final Staff Report

Proposed Rule 1177 12 June 2012 

inch) or physical configuration that results in an equivalent or lower emission rate 

that is tested and demonstrated using a method for which written approval of the 

Executive Officer has been obtained. 

PR 1177 will also require operators of railroad tank cars and transport trucks with 

vapor recovery or equalization systems to properly maintain and operate these 

systems according to manufacturer’s specifications. The vapor return lines and liquid 

lines, including the hose, fittings and gaskets which facilitate the movement of LPG 

must be properly connected between the cargo tank and the stationary storage tank 

and must also be maintained to ensure that the system remains liquid tight and vapor 

tight during the transfer process. 

Effective July 1, 2013, the owner/operator of a facility that transfers and dispenses 

LPG to stationary storage tanks, will be required to meet one of the following two 

conditions when transferring LPG. First, the owner/operator may choose to facilitate 

the LPG transfer with the FLLG in a closed position, while achieving the maximum 

fill level without overfilling the tank. Secondly, for an owner/operator that chooses 

to use the FLLG during filling, any newly installed stationary storage tank or one that 

is out of service or taken out of service must be equipped with a low emission FLLG 

prior to being put into or returned to service. In cases where a storage tank cannot be 

retrofitted with a low emission FLLG without relocation for evacuation or other 

services, the operator has until July 1, 2015 to demonstrate through documentation 

that the tank falls into this category. Stationary storage tanks for which such 

documentation is established must be retrofitted with a low emission FLLG by July 1, 

2017 prior to being filled. 

Effective July 1, 2017 any transfer of LPG into a portable storage tank or cylinder 

will be required to be done only when the portable storage tank or cylinder is 

equipped with a low emission FLLG or when applying a fill by weight technique or 

technology that monitors the maximum fill level to prevent overfilling with the FLLG 

closed. 

Operator Leak Detection Program Requirements 

In addition to retrofit of LPG low emission connectors and low emission FLLGs, to 

prevent potential emissions, the proposed rule will require the implementation of a 

Leak Detection and Repair (LDAR) program for LPG transfer and dispensing 

facilities that offer LPG for sale to end users. Based on feedback from the LPG 

industry, there are minimal leaks from existing systems, but staff believes that 

implementing a minimum level of due diligence through monitoring and repair can 

provide additional air quality benefits. The reduction of LPG emitted to the 

atmosphere also benefits the LPG industry by reducing product loss that leads to 

enhanced safety which may result in lower insurance costs. 

Effective January 1, 2013, the LDAR program will include daily physical checks for 

evidence of leaks. Owner/operators will be required to conduct inspections of 

connectors involved in the transfer of LPG to stationary storage tanks that are owned 
Final Staff Report

Proposed Rule 1177 13 June 2012 

or leased or to cargo tanks that are used to supply LPG to any other stationary storage 

tank or cargo tank. These inspections call for a bubble test to be conducted once 

every 90 days or in the case where the time between transfers is greater than 90 days, 

an inspection is required to be conducted upon the completion of the subsequent 

transfer operation. It should be noted that the proposed daily checks and the quarterly 

inspections requirement do not apply to portable storage tanks. 

For any equipment or connector that is found to be leaking, PR 1177 will require the 

operator to remove the equipment or connector from service, complete the repair and 

verify that the repair was completed by use of a bubble test or survey using an 

analyzer or test method used for detecting LPG vapor leaks. The operator will also 

be required to record any defect and repair activity prior to placing the equipment or 

connector back into service. Leaks and defects that are discovered during daily 

checks and inspections and repaired prior to placing the equipment or connector back 

into service would not constitute a violation of the PR 1177 vapor tight or liquid tight 

standards. However, leaks found by District staff may result in violation of these rule 

provisions. 

The proposed rule will also require owners to implement a training program for any 

employee that is responsible for conducting daily physical checks for evidence of 

leaks, such as the presence of odor, hissing noises, or staining, as well as quarterly 

inspections. The training program will also be required to include written training 

procedures, the training frequency and schedule training dates and a written record of 

the training dates provided for each employee. Based on discussions with the LPG 

industry, similar training is already conducted for all affected employees. 

Recordkeeping Requirements 

PR 1177 requires for persons performing the installation of low emission FLLGs and 

LPG low emission connectors, inspections or repairs at any LPG transfer and 

dispensing facility or at a bulk loading facility to provide the owner/operator with the 

following information after service is completed: 1) records of all low emission 

FLLGs and LPG low emission connectors installed; 2) service or sales receipts; 3) 

repair logs that include the date and time of each repair and a description of the 

service performed; 4) employer information such as name, address and phone 

number; and 5) some form of identification feature of the low emission FLLG or LPG 

low emission connector repaired, serviced or removed, including the manufacturer 

name. The owner/operator is subsequently required by PR 1177 to maintain these 

records for a minimum of two years. 

For railroad tank cars or tanker/transport trucks that have an LPG vapor recovery or 

equalization system, PR 1177 will require the owner/operator to maintain records 

which demonstrate that the system is maintained and operated according to the 

specifications of the vapor recovery and equalization system manufacturer. 
Final Staff Report

Proposed Rule 1177 14 June 2012 

Reporting Requirements 

PR 1177 requires owners/operators of LPG bulk loading facilities or LPG transfer 

and dispensing facilities that offer LPG for sale to an end user to submit monthly 

purchase and dispensing (sales) volumes as part of an annual report for calendar years 

2013, 2014 and 2015, respectively. These reports must be submitted no later than 

July 1 of 2014, 2015, and 2016, respectively. This data will assist staff in collecting 

and tracking LPG activity within the basin in order to assess any seasonal fluctuations 

in consumption and to improve upon staff emission estimates. It is expected that 

month-to-month variability may be present in facility records 

LPG transfer and dispensing facilities that offer LPG for sale to an end user may meet 

the annual reporting requirement for LPG purchase and sales volumes through an 

arrangement with their LPG suppliers, provided all suppliers notify the facility and 

the District by March 1 of the reporting year and include the name of the facility as 

part of the supplier’s annual report. 

The owner/operator of an LPG bulk loading facility will also be required to submit an 

end of year inventory of their facility’s LPG low emission connectors for calendar 

year 2013 by no later than July 1, 2014. The inventory must identify the equipment 

to which the LPG low emission connector is associated (e.g. bobtail, stationary 

storage tank, etc.) and must also include the LPG low emission connector 

manufacturer name and the part or identification number. 

The owner/operator of an LPG bulk loading facility will also be required to submit an 

end of year inventory of all leased or owned containers and FLLGs associated with 

LPG storage or transfer for calendar years 2013 through 2017. The inventory must 

identify containers by type (residential tank, commercial tank, portable forklift 

cylinder, bobtail, transport truck, etc.) and size (storage capacity in gallons) and must 

include the total number of owned or leased containers in each type and size 

category. In addition, the inventory must include the total number of FLLGs, as well 

as the number of low emission FLLGs installed in each container size category. The 

submittal schedules will be July 1, 2014, 2015, 2016, 2017 and 2018, respectively for 

each previous calendar year 2013, 2014, 2015, 2016 and 2017, respectively. 

Appendix C - Recordkeeping and Reporting Sample Forms contains sample reporting 

and recordkeeping forms for PR 1177. 

Leak Detection Method 

PR 1177 requires that leaks be determined through the use of a bubble test method or 

a survey that employs the use of an appropriate analyzer or another test method. 

Leak concentration measurements may also be conducted using EPA Reference 

Method 21 using an appropriate analyzer that must be calibrated with methane before 

an inspection is conducted. For the purposes of this rule any measurement of 10,000 

ppm or less would be considered a vapor-tight. 
Final Staff Report

Proposed Rule 1177 15 June 2012 

Confidentiality 

Purchase and dispensed volume information submitted to the District may be 

designated as exempt from disclosure and the owner/operator must clearly indicate 

this on any information or data for which the exempt from disclosure designation is 

sought. Appendix C - Recordkeeping and Reporting Sample Forms provides 

example report forms that can be used to identify how the exempt from disclosure 

designation can be designated. 

Exemption 

The proposed rule provides an exemption for LPG transfer into any container that has 

a water capacity of less than four gallons. There is also has an exemption for 

facilities that are subject to the requirements of Rule 1173 – Control of VOC Leaks 

and Releases from Components at Petroleum Facilities and Chemical Plants. 

Owner/operators that fill LPG cylinders that are specifically dedicated and installed 

in recreational vehicles are also exempt from the FLLG retrofit requirements of the 

rule. 

EMISSION INVENTORY 

The emissions inventory is comprised of fugitive VOC emissions released from the 

LPG transfer and dispensing operations within the District. The estimated fugitive 

emissions are categorized by the following actions: 

 Disconnection of liquid line 

 Disconnection of vapor line 

 Disconnection of the “jump line” that is used to connect truck and trailer 

cargo tanks. 

 Vapor released from the FLLG 

 Liquid released from the FLLG 

It should be noted that emissions from leaks are currently not quantifiable based on 

available data. However, the owner/operator of LPG bulk loading facilities and LPG 

transfer and dispensing facilities will be required to maintain records or logs of leaks 

that are identified and subsequently repaired. 

EMISSIONS ESTIMATION METHODOLOGY 

The proposed rule will address fugitive emissions released from each transfer as 

detailed in Appendix A – LPG Industry Summary. Appendix B – Emission Inventory 

Calculations contains details on the emissions estimation methodology and 

calculations, which estimate the level of transfer and dispensing related activities 

based on annual sales volumes. 
Final Staff Report

Proposed Rule 1177 16 June 2012 

Liquefied Petroleum Gas (LPG) Sales 

LPG sales data for the state of California is voluntarily submitted by businesses 

involved in the transfer and dispensing of LPG to the American Petroleum Institute 

(API). Therefore, the data shown in Table 3 below represents only a rough estimate 

of LPG sales for California. 

Historical API sales data combined residential and commercial sales until 2002, but 

as of 2003 sales data for these two categories were reported separately. Table 3 

below shows California LPG sales data from 1999 to 2009. Figure 2 provides the 

most recently available California sales data (2009) by distribution category.

Due to the lack of region-specific LPG sales data for the District, a proportionality 

factor of 0.455, based on the District’s population compared to total California state 

population, was used to estimate the sales data for the four-county region, ; forklift 

LPG consumption was estimated using CARB EMFAC and off-road vehicle 

inventories.and is reflected in Figure 2 which provides sales data by distribution 

category. The 2009 API sales data represents the most recent information and 

therefore is used to estimate baseline emissions.

Table 3. Historical California LPG Sales (mgal), API sales data provided by Western Propane Gas 

Association 

Category 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 

Residential 

and 

Commercial 

302,715 288,766 199,223 240,791 

Residential ------- ------- ------- ------- 204,167 246,420 252,807 259,285 287,581 283,711 275,256 

Commercial ------- ------- ------- ------- 109,912 146,220 104,266 88,015 101,518 108,513 86,639 

Sales to 

Retailers N/A N/A N/A N/A 64,663 61,665 65,854 56,938 56,905 65,358 51,941 

ICE Fuel 44,297 66,678 80,660 64,717 53,829 62,773 73,137 73,498 withheld 

withheld 67,077 

Chemical 89,212 180,861 135,075 N/A N/A N/A N/A N/A N/A N/A 135,576 

Industrial 37,950 36,791 37,813 45,300 33,331 22,994 44,788 46,512 withheld 

withheld 27,806 

Agricultural 25,421 17,255 39,874 65,056 30,373 49,588 55,509 66,216 74,321 59,409 50,466 

Total CA 

Sales 499,415 590,361 492,644 415,864 496,276 589,480 573,904 590,464 651,139 633,053 694,761 

SCAQMD 

Sales * 227,234 268,614 224,153 189,136 225,806 268,259 261,126 268,661 296,268 288,039 316,116 

(*) South Coast Air Basin sales is estimated at 45.5 percent of California sales based on population 

Although sales in California fluctuated during this period of time, there has been an 

overall increase in LPG sales of approximately 40 percent with LPG sales increasing 

from approximately 500 million gallons in 1999 to almost 695 million gallons in 

2009. 
Final Staff Report

Proposed Rule 1177 17 June 2012 

0

50

100

150

200

250

300

Residential

Chemical

Commercial

IC Engines

Sales to Retail

Agricultural

Industrial

2009 LPG Sales (mgal)

Figure 2. California 2009 LPG Sales Distribution 

LPG Emission Factor Determination 

In November 2008, the District conducted VOC testing at the Mutual Propane facility 

in Gardena, California. Thirty-three (33) pound LPG (propane) forklift storage tanks 

were filled using the gravity filling method with the objective of the test being to 

determine the rate at which propane is lost to the atmosphere during the filling 

process. The results obtained from the District tests were compared with the results 

obtained by the Adept Group which conducted their testing separately, but on the 

same day as the District. The tanks in both the District and the Adept Group tests 

were equipped with a No. 54 gauge (0.055-inch orifice) FLLG. The results of both 

sets of testing are summarized in Table 4. 

Table 4. LPG Test Data

Transfer Activity Test Reference Gaseous Propane 

Emissions Rate (g/s) 

Liquid Propane 

Emissions Rate (g/s) 

Gravity Fill *

SCAQMD (2008) 2.26 8.94 

Adept Group (2008) 2.5 N/A 

Pressure Fill (or Fill 

by Volume) *

SCAQMD (2011) 2.01 11.3 

Adept Group (2008) 3.0 10.9 

* Refer to page A-14 13 of Appendix A – LPG Industry Summary for gravity fill and fill by volume method 

discussions 

In addition to the District and the Adept Group’s testing, Battelle Laboratories had 

conducted source testing in September 2009 to compare the fluid flow rate through a 

No. 54 orifice drill size FLLG and a No. 72 orifice drill size (0.025 inch) FLLG, and 
Final Staff Report

Proposed Rule 1177 18 June 2012 

to evaluate the smaller gauge size to determine if there exists a susceptibility to 

blocked flow from potential particle obstruction or freeze-up. The Battelle source 

test was evaluated by District source testing staff and found to be conditionally 

acceptable. In an effort to further verify the emission rates of a No. 54 gauge and No. 

72 gauge FLLG, District engineers conducted additional analysis in the fall of 2011, 

and issued a final report in December 2011, focusing on pressure filling. Blockage or 

freeze-up has not been observed in any testing to date. Emission rates and potential 

emission reductions in this staff report are based on the 2011 final report results listed 

in Table 4 (see additional details in Appendix B – Emission Inventory Calculations). 

Emission Reductions 

Table 5 below lists the emissions associated with each market sector and also the 

reductions resulting from the use of control technology. The current estimated 

emissions inventory from the transfer of LPG is 8.6 tons per day (tpd). In contrast, 

the WPGA estimated daily VOC emissions of 2.1 tpd. Lastly, based on the Adept 

Group’s estimates, the daily VOC emissions inventory may be as high as 68 tpd. 

It is also important to note that filling tanks by weight or through the use of 

alternative techniques or technologies would not require the FLLG to be open, thus 

completely eliminating emissions from FLLGs. However, because the rule provides 

an option to the LPG industry on the use of low emission FLLGs or an alternative 

approach, the emission reductions represented in this staff report, which are based on 

emissions from the low emission FLLG, are conservative because shifting to 

alternative techniques or technologies is not considered in the calculation. 

Based on discussions with industry and observations in the field, there appears to be a 

significant difference in the practice of venting LPG from the receiving tank’s FLLG 

during transfer. In some cases the FLLG is left open for approximately one minute, 

while in other cases the FLLG is left open for as long as the entire duration of the 

filling process, which can vary between a few minutes for a 5 gallon container to over 

half an hour for a bobtail truck tank or large residential or commercial storage tank. 

Table 5 summarizes emissions and potential emission reductions data collected by the 

WPGA, as well as estimates based on staff research, including feedback provided by 

stakeholders during the working group meetings, and during site visits conducted by 

staff. Additional details are provided in Appendix B – Emission Inventory 

Calculations. 
Final Staff Report

Proposed Rule 1177 19 June 2012 

Table 5. SCAQMD VOC Emissions Reductions (tons per day)

Sector 

WPGA Criteria District Criteria* 

Emissions 

(tons/day) 

Reductions 

(tons/day) 

Emissions 

(tons/day) 

Reductions 

(tons/day) 

Residential 0.17 0.10 1.47 0.79 

Commercial 0.05 0.03 0.47 0.25 

Sales to Retail (Cylinder 

Filling and Exchange) 1.18 0.38 2.03 1.31 

IC Engines (Forklifts) 0.63 0.55 4.35† 3.62†

Industrial, Chemical, 

Agricultural 0.02 0.02 0.18 0.10 

Distribution Facilities 0.05 0.04 0.07 0.07 

Total: 2.1 1.1 8.6 6.1 

 68 ‡

* Primarily differences include variation of FLLG use from 60-90 seconds up to 100% of LPG transfer time, and 

difference between industry referenced emission rate of 0.8 g/s compared to recent SCAQMD tested result of 2.01 

g/s. Worse case criteria do not adjust WPGA assumed market distribution of fill by weight transfers. 

†

 Initial WPGA criteria does not account for forklift tank gravity fill activities. A significant increase in estimated 

fugitive LPG emissions and subsequent reductions within the IC Engine sector is due primarily to the extended 

filling and concurrent venting time associated with gravity filling. 

‡ Adept Group Estimate, 2009. 

PR 1177 will reduce the overall VOC emissions by 6.1 tpd based on results obtained 

from the District staff’s FLLG source test report and the control efficiency 

requirements for LPG low emissions connectors. Additionally, reports by Battelle, 

Life Cycle Associates, CARB, and WPGA provide further support to verify control 

efficiencies of the low emission FLLGs and LPG low emission connectors. 

It should be noted that while the residential sector represents roughly 40 percent of 

the sales volume, the largest contributors to the estimated baseline emissions are 

represented by sales to retail (primarily smaller five gallon barbecue cylinders) due to 

the greater frequency of filling, the accompanying disconnections from such 

transfers, and to the practice of gravity filling for forklift cylinders (internal 

combustion engines), due to the extended filling times (roughly seven minutes 

compared to less than a minute for pump-assisted filling) and concurrent venting 

through an open FLLG. 

COST AND COST-EFFECTIVENESS 

This section presents the cost and cost-effectiveness associated with the PR 1177, 

including underlying evaluation assumptions. 

In order to calculate the cost-effectiveness for implementing PR 1177, the net present 

value of the capital cost and operating cost of any requirements can be calculated 

using the following formula: 

PV = C + A x PVF, where: 
Final Staff Report

Proposed Rule 1177 20 June 2012 

PV = Present Value of the control equipment 

C = Capital costs associated with implementing PR 1177 

A = Annual costs incurred to administer the retrofit program, such as 

inspection and component repair 

PVF = Present Value Factor, which is 8.11 for an assumed 10 years equipment 

life and 4% real rate of inflation. 

Fugitive VOC emission reductions resulting from the implementation of PR 1177 are 

estimated at 6.1 tons per day (see Appendix B – Emission Inventory Calculations). 

Capital and Installation Costs 

The proposed rule requires owner/operators to transfer or dispense LPG only to 

containers that are either fitted with low emission FLLG or make use of an equivalent 

alternative technique or technology. The propose rule also requires use of LPG low 

emission connectors. 

Based on data supplied by the WPGA, an estimate of the number of affected LPG 

containers and the cost of components were categorized by container type and 

expected equipment upgrade. The estimated costs ranged from as low as $2 for a 

self-cleaning, No. 72 orifice drill size FLLG to as much as $2,250 for the retrofit of a 

loading arm system for bobtail and transport trucks. Staff relied upon upper end cost 

estimates as a conservative approach to determine overall cost-effectiveness. For 

example, rather than rely on the cost to retrofit an existing barbecue cylinder with a 

low emission FLLG, the cost for a new cylinder (~$30) was used. 

The total capital costs associated with PR 1177 is approximately $21 million. This 

cost is distributed among 3 major areas. These are 1) retrofit of stationary storage 

tanks and forklift cylinders with low emission No. 72 orifice drill size FLLGs; 2) 

retrofit of existing connectors with new LPG low emission connectors; and 3) 

upgrading existing facilities to decrease filling times associated with gravity filling 

(forklift cylinders) or to accommodate fill-by-weight (barbecue cylinders). 

Residential and Commercial Tanks 

PR 1177 will require that tanks that meet American Society of Mechanical Engineers 

(ASME) Code be retrofitted with low emission FLLGs. Of the total ASME tanks, the 

majority (or 39,712) of these tanks are found in the residential sector, while the 

remaining 5,643 are used in the commercial sector. The individual FLLG cost is $10, 

while the installation which is relatively straightforward can be completed by an LPG 

operator. For this report the installation cost is conservatively estimated at $50, or 

roughly an hour’s worth of labor. 

Forklift Cylinders 

PR 1177 requires that cylinders and portable storage tanks be either filled using a fill 

by weight technique or an alternative technique or technology that monitors the 
Final Staff Report

Proposed Rule 1177 21 June 2012 

maximum fill level without the use of an FLLG or retrofitting the container “bleeder” 

valve or FLLG with a low emission FLLG. 

According to a data provided by the WPGA, approximately 70 percent of this market 

employs the fill by volume method using a pump and motor. For the remaining 30 

percent of this market, forklift cylinders are filled by gravity. Based on feedback of 

the working group, the cylinders that are filled by volume will be retrofitted with low 

emission FLLGs that will have identical capital and installation costs as residential 

and commercial tanks. 

Results obtained from field tests indicate that it would take an operator five to six 

times as long to gravity fill a 33-pound forklift cylinder with a No. 72 low emission 

FLLG compared to the same size cylinder fitted with a No. 54 orifice drill size FLLG. 

Based on these observations, it is expected that an operator will likely consider one or 

more of three possible options. These options are: 1) in situations where the 

stationary tanks used to fill the forklift tank range in capacity from “200 DOT” 

storage tank (or ~46 gallons) to 125 gallons, a customer is likely to opt for removing 

these stationary storage tanks and replacing them with new cylinders and rack(s) and 

have the LPG supplier fill them directly; 2) remove existing storage tanks that range 

in capacity from 172 gallons to 288 gallons and replace them with a larger tank (~ 

500 gallons) equipped with a pump and motor to speed up the filling of the forklift 

cylinder by volume; and 3) for stationary tanks that range in capacity from 499 

gallons to 1,150 gallons, to add a pump and motor. In each of these cases there will 

be product and time savings which have not been factored into the cost-effectiveness 

calculations. 

Barbecue Cylinders 

According to data provided by WPGA, the current 20 pound barbecue cylinder 

inventory is approximately 142,000. WPGA estimates that half of these cylinders are 

filled by weight at facilities equipped with automated (carousel) systems such as Blue 

Rhino and Amerigas and subsequently distributed as part of an exchange program to 

locations such as Home Depot, retail facilities and gasoline service stations. The 

remaining cylinders are filled by volume at gasoline service stations as well as at 

other retail facilities. It is estimated that there are approximately 3,300 facilities that 

currently provide barbecue cylinder filling as part of their services. Based on 

information from the Life Cycle Associates, LLC report, historically these cylinders 

have been refilled (by volume) at a local retailer, but cylinder exchange programs 

have become much more common in recent years. 

Of the 3,300 facilities that offer the service of refilling barbecue cylinders, it is 

assumed for cost-effectiveness calculation purposes that a majority (~80 percent, or 

2,640 facilities) will offer the option of continuing to fill by volume or exchange 

empty barbecue cylinders for full ones. It is also assumed for calculation purposes 

that for the remaining facilities (~660) a fill by weight, on-site option that would 

require a scale and may also include an automatic shut-off valve installation would be 

considered. Table 6 summarizes the various capital and associated installation labor 
Final Staff Report

Proposed Rule 1177 22 June 2012 

costs for each of the equipment replacement or retrofit upgrades expected to occur as 

part of PR 1177 implementation. A cross-reference to additional evaluation 

parameters are cross-referenced within the table. 
Final Staff Report

Proposed Rule 1177 23 June 2012 

Table 6. Summary of PR 1177 Capital and Installation Costs. 

Retrofit 

Activity No. of Units Cost per Part 

Total Cost 

of Parts 

Labor 

Cost 

Total Labor 

Cost 

Total Retrofit 

Cost 

FLLGs on Residential 

Tanks 39,712(1) $10 $397,120 $50 $1,985,600 $2,382,720 

FLLGs on Commercial 

Tanks 5,643(1) $10 $56,430 $50 $282,150 $338,580 

New Barbecue 

Cylinders (OPD Unit) 71,000(2) $30 $2,130,000 $10 $710,000 $2,840,000 

Scales to Allow for Fill 

by Weight Process 660 $1,000 $660,000 ----- ------ $660,000 

FLLGs on Bobtail 

Trucks 250 $10 $2,500 $50 $12,500 $15,000

Bobtail Trucks 

(Dispenser Vapor Tight 

Seals) 

250 $370 $92,500 $200 $50,000 $142,500 

LPG Low Emission 

Connectors on Tanker 

Trucks 

100 $2,000 $200,000 $200 $20,000 $220,000 

Forklift Tank FLLG 

Retrofits 60,000(1) $10 $600,000 $50 $3,000,000 $3,600,000 

Forklift Cylinders 

(Gravity Fill) 

Convert to Cylinder 

Exchange Option with 

Direct Fill 5

2,038 Tanks 

(1,530 

customers) 

See 

footnote 

(5) 

$3,204,400 $200 $407,600 $3,612,000 

Trucks (for Cylinder 

Exchange Program)5 6 $120,000 $720,000 ------- ------ $720,000 

Forklift Cylinders 

(Gravity Fill) 

Convert to Fill by 

Volume Option6

415 customers 

(with 415 tanks) $3,000 $1,245,000 $2,000 $830,000 $2,075,000 

Forklift Cylinders 

(Gravity Fill) 

Replace Existing Tank 

with Larger Tank and 

Add Pump/Motor to 

Allow Fill by Volume 

Option7

196 tanks 

(196 

customers) 

$1,000 

$3,000 

$196,000 

$588,000 

$200 

$2,000 

$5,000 

$39,200 

$392,000 

$980,000 

$235,200 

$980,000 

$980,000 

Service (Hose End) 

Dispensers 5,000 $400 $2,000,000 $100 $500,000 $2,500,000 

Total Cost: $12,091,950 $9,209,050 $21,301,000 

(1) Obtained from LPG Tank Inventory provided by Western Propane Gas Association (WPGA) (See Appendix A – LPG Industry Summary)

(2) Obtained from WPGA data provided. Industry estimates that 50 percent of barbecue tank inventory is included in the exchange program that 

employs the fill by weight process which is carried out with the “bleeder” valve closed 

(3) Industry estimates that approximately 2,141 facilities (with 2,649 tanks) that fill by gravity could possibly change to any of three (3) alternative 

options which include fill by volume using a pump, a cylinder exchange program/direct bobtail fill of cylinders and where suitable replacing a 

smaller tank with a larger one and adding a pump and motor. 

(4) Based on WPGA survey data 

(5) Based on addition of 1 - 6 cylinder rack and 6 new cylinders to replace 200 DOT and 50 gallon tanks, and 1 -12 cylinder rack and 12 new 

cylinders to replace 420 DOT and 125 gallon tanks 

(6) Based on addition of a pump/motor at $3,000 each and electrical for which labor cost is $2,000 

(7) Tank replacement cost used is $1,000 with the associated labor cost being $200 per tank; $2,000 for wiring and $5,000 for engineering design, 

site preparation and permitting 
Final Staff Report

Proposed Rule 1177 24 June 2012 

Operation and Maintenance Costs 

It is estimated that there are two hundred bulk loading facilities which will be 

responsible for inspections, recordkeeping and reporting data to the District. 

Employee training is already being implemented at LPG bulk loading facilities and 

therefore there will be minimal cost associated when the training requirements of PR 

1177. 

The LPG transfer and dispensing industry has expressed the importance of 

minimizing leaks that may occur in their operations since product loss is directly 

related to company profits. As such, a leak detection and repair program is already in 

place and therefore, PR 1177 will not add any cost associated with leaks at LPG bulk 

loading facilities or customer locations. 

Annual operations and maintenance costs will be mainly due to the costs associated 

with inspections, reporting and recordkeeping. 

Table 7. Summary of Operational, Maintenance and Administrative Costs. 

Activity No. of 

Facilities 

Activity 

Frequency 

(or Period) 

Unit 

Cost 

Annual 

Cost 

(P/A) 

Factor 

(Annual Cost)x 

(P/A) Factor 

Quarterly Inspections 

(>10,000 gal. tanks) 

200 

(4 per 

year) 

Quarterly $200 $160,000 8.11 $1,297,600 

Reporting (1) 200 3 years $2,000 $400,000 2.7751 $1,110,040 

Recordkeeping (2) 200 Annually $4,800 $960,000 8.11 $7,785,600 

Truck Driver (3) 6 Annually $70,000 $420,000 8.11 $3,406,2000 

Tank Maintenance 

Employee (3) 6 Annually $70,000 $420,000 8.11 $3,406,200 

Truck Maintenance(3) 6 Annually $5,000 $30,000 8.11 $243,300 

Total Cost: $17,248,940 

(1): Time dedicated to reporting is assumed to be one week per year (at $50 per hour) 

(2): Time dedicated to recordkeeping is assumed to be 1 day per month (at $50 per hour) 

(3): For forklift cylinder exchange program

Staff has reviewed in detail the emission reductions, assumptions, capital and 

installation costs and operational and maintenance costs with the WPGA and other 

members of the industry, reaching consensus on costs included in this staff report. 

Overall Cost-Effectiveness 

Based on a 10 year useful component life: 

Total Capital Cost + (Total Annual O & M Cost x 8.11)

Total Annual Emissions reductions (tpy) x 10 years 
Final Staff Report

Proposed Rule 1177 25 June 2012 

 

6.1  tpd 365 10

($21,301,000) 17,248,940

 

 

≈ $1,700/ton VOC reduced 

INCREMENTAL COST EFFECTIVENESS 

Health and Safety Code Section 40920.6 requires the AQMD to perform an 

incremental cost analysis when adopting a Best Available Retrofit Control 

Technology (BARCT) rule or feasible measure required by the California Clean Air 

Act. To perform this analysis, the AQMD must (1) identify one or more control 

options achieving the emission reduction objectives for the proposed rule, (2) 

determine the cost effectiveness for each option, and (3) calculate the incremental 

cost effectiveness for each option. To determine incremental costs, the AQMD must 

“calculate the difference in the dollar costs divided by the difference in the emission 

reduction potential between each progressively more stringent potential control 

option as compared to the next less expensive control option.” 

Proposed Rule 1177 partially implements Control Measure MCS-07 from the 2007 

Air Quality Management Plan. Because Control Measure MCS-07 is intended to 

meet feasible measure requirements under the California Clean Air Act, an 

incremental cost analysis is required and is presented below. 

Staff evaluated several alternatives based on current operating practices, focusing on 

emission control options at the supply and receiving container for BBQ 

tanks/cylinders, while preserving the proposed control requirements for all other LPG 

transfer and dispensing applications. The first alternative was based on PR 1177, and 

requires the use of LPG low emission connectors, but not the low emission FLLG 

requirement. The additional control options included all PR 1177 requirements for 

barbecue tanks/cylinders as well as a final option that replaced the low emission 

FLLG requirement with a mandatory fill by weight requirement. The mandatory fill 

by weight requirement would eliminate the fugitive emissions from FLLG during the 

filling process. 

Although the fill by weight alternative would result in additional emission reductions, 

the PR 1177 requirement to use a tank fitted with a low emission FLLG or equivalent 

alternative would still allow fill by weight as a compliance option, and require at 

most a one-time nominal cost for a newly fitted or retrofitted tank, whereas the 

mandated fill by weight alternative would require the installation and maintenance of 

a scale at each retail facility that supplies LPG for BBQ tank/cylinder customers. 

The analysis indicates that the overall cost-effectiveness is reduced by the low 

incremental cost impact from the PR 1177 requirements associated with barbecue 

tank filling, whereas the more stringent fill by weight requirement for this category 

represents an order of magnitude higher impact, or approximately $2 million annual 

increase, as compared to the proposed rule. 
Final Staff Report

Proposed Rule 1177 26 June 2012 

Table 8 summarizes the total and incremental cost-effectiveness of each of the three 

alternatives analyzed. 

Table 8. Comparison of Incremental VOC Reduction Alternatives and Costs 

Control Alternative for 

BBQ Tank Filling 

Incremental 

VOC 

Reduction 

(tpd) 

Annual Cost 

Increase 

($/year) 

Incremental 

Annual Cost

($/year) 

Incremental 

CostEffectiveness 

($/ton) 

Overall CostEffectiveness 

($/ton)*** 

LPG Low Emission Connectors 0.0 $0 $0 $0 $2,000 

PR 1177 Requirements: 

 LPG Low Emission 

Connectors 

 Low Emission FLLG* 

1.2** $213,000 $213,000 $500 $1,700 

 LPG Low Emission 

Connectors 

 Mandatory Fill By Weight 

1.2 $2,003,100 $1,790,100 $4,200 $2,100 

* PR 1177 requires use of a low emission FLLG, fill-by-weight or an alternative technique or technology that 

monitors the maximum fill level to prevent overfilling without use of the FLLG; fill by weight is considered an 

alternative technique. The lowest cost alternative is expected to be implemented by owner/operators as 

identified. 

** District and industry sponsored source test data indicate a reduction range of 50% - 70%, the low end of the 

range is conservatively used for cost-effectiveness evaluation. 

*** Overall cost-effectiveness includes the BBQ tank filling control requirements and the remaining control 

requirements of PR 1177. 

COMPARATIVE ANALYSIS 

Pursuant to Health and Safety Code, Section 40727.7 staff has prepared an analysis of 

the proposed AQMD rules and regulations, requirements and federal air pollution 

control measures that apply to the same source type. While there are no current 

federal or District air pollution control requirements for this source, there are 

requirements imposed by Cal OSHA and DOT, which staff has examined. Table 9 

below summarizes this analysis. 
Final Staff Report

Proposed Rule 1177 27 June 2012 

Table 9. Proposed Rule 1177 Comparative Analysis 

Section AQMD Cal OSHA* DOT 

Purpose Reduce VOC emissions 

associated with transfer and 

dispensing of LPG 

[PR 1177 (a)] 

 Establishes minimum 

safety standards in 

places of employment 

[8 CCR 450, NFPA 58 

by adoption] 

Prescribes requirements applicable to 

the acceptance and transportation of 

hazardous materials by private, common, 

or contract carriers on highways 

[49 CFR 177.800] 

Applicability Transfer of LPG from a cargo 

tank, stationary tank or cylinder 

to other cargo, stationary or 

portable tank or cylinder 

[PR 1177(b)] 

The design, 

construction, and 

installation of LPG 

containers, including the 

storage and handling of 

LPG 

[8 CCR 450(a)] 

Transport of LPG by motor carriers on 

highway 

[49 CFR 177.800] 

Requirements  LPG transfer from cargo tank 

to stationary tank and vice 

versa at bulk loading 

facilities: 

o A rail tank or tanker truck 

equipped with vapor 

recovery or equalization 

lines must be maintained 

and operated according to 

manufacturer’s 

specifications; 

o All vapor and liquid return 

lines must be in vapor and 

liquid tight condition; 

o The transfer hose 

assembly must be 

properly maintained. 

 LPG transfer and dispensing 

facilities: 

o Cargo tanks, stationary 

tanks and cylinders used 

to transfer or dispense 

LPG must be fitted with 

vapor tight LPG low 

emission connectors by 

7/1/2013; 

o Cargo trucks and 

stationary storage tanks 

are equipped with low 

emission FLLG or use 

alternative technique or 

technology by 7/1/2017; 

o New or reserviced cargo 

tanks and stationary tanks 

shall be fitted with low 

emission FLLGs. 

o Portable tanks filled by 

volume must have a low 

emission FLLG by 

7/1/2017 

[PR 1177 (d)] 

 LPG tanks used for 

storage, transport or 

mobile fuel tanks 

>125 gal require 

permit, renewable 

every 5 years 

 Permits to operate 

dispensing units, trap 

tanks, and skid tanks 

are renewable every 

3 years 

 Tanks have to be reinspected by an 

authorized inspector 

upon permit renewal 

 Permits are valid for 

a specific tank at a 

specific location. If 

the tank is replaced, 

the permit is invalid 

 LPG product has to 

be odorized 

 Tanks > 125 gal 

have to be equipped 

with level gages and 

thermometers 

 Air pressure cannot 

be used to displace 

LP-Gas during the 

transfer operation 

 All filling connections 

shall be kept 

effectively plugged or 

capped when not in 

use 

[8CCR 470-494] 

Cargo tanks must be: 

 Seamless or welded construction or 

combination of both 

 Compliant with ASME Code Section 

VIII 

 Have a design pressure between 100 

– 500 psig 

 Equipped with a pressure relief valve 

on top of the tank 

 Painted white, aluminum or similar 

reflecting color on the upper two-thirds 

of area of the cargo tank 

 The burst pressure of all piping, pipe 

fittings, hose and other pressure 

parts, except for pump seals and 

pressure relief devices, must be at 

least 4 times the design pressure of 

the cargo tank 

 Each cargo tank must be provided 

with a pressure gauge 

 The cargo tank motor vehicle 

manufacturer must supply a certificate 

stating that the completed cargo tank 

motor vehicle conforms in all respects 

to Specification MC 331 and the 

ASME Code 

 Before unloading from a cargo tank 

motor vehicle containing a liquefied 

compressed gas, the qualified person 

performing the function must check 

those components of the discharge 

system, including delivery hose 

assemblies and piping, that are 

readily observed during the normal 

course of unloading to assure that 

they are of sound quality, without 

obvious defects detectable through 

visual observation and audio 

awareness, and that connections are 

secure 

 If there is an unintentional release of 

product to the environment during 

unloading of a liquefied compressed 

gas, the qualified person unloading 

the cargo tank motor vehicle must 

promptly shut the internal self-closing 

stop valve or other primary means of 

closure and shut down all motive and 

auxiliary power equipment 

[49 CFR 177] 
Final Staff Report

Proposed Rule 1177 28 June 2012 

Section AQMD Cal OSHA* DOT 

Leak detection and 

repair requirements 

 Daily physical check for 

evidence of leaks (visual, 

audible, odor) 

 Quarterly inspection of 

connectors on stationary 

tanks or cargo tanks that 

supply LPG 

 Daily and Quarterly checks 

and inspections not required 

for portable tanks (e.g., 

forklift, barbeque tanks) 

 Conduct bubble test of 

connectors at stationary 

tanks receiving LPG during 

or immediately following the 

transfer 

 Any connector identified as 

leaking or defective must be 

removed from service, 

repaired and tested before 

returned to service and the 

repair recorded in a repair 

log 

[PR 1177(e)] 

 Repair or alteration 

affecting the safety of 

any container or 

cylinder has to be 

authorized by a 

qualified inspector. 

The owner or user of 

the LP-Gas container 

shall ensure that the 

repair or alteration is 

performed by a 

company with a valid 

ASME “U” or a 

National Board “R” 

Certificate of 

Authorization 

 A container or 

cylinder that has 

been subjected to a 

fire shall not be 

returned to service 

until it has been 

inspected by a 

qualified inspector 

and found to be safe 

and cannot be 

recharged until it has 

been retested in 

accordance with the 

requirements for its 

original hydrostatic 

test and found to be 

suitable for continued 

service [8CCR 494] 

Inspection and test intervals for cargo 

tanks: 

 1 year for external visual inspection 

and leakage 

 5 years for internal and pressure test 

 Inspection must be performed by 

DOT registered inspectors 

 All required tests and inspections 

must be documented and certified by 

the inspector 

 A cargo tank that fails inspection must 

be either repaired and retested, or 

must be removed from service 

 Repairs to DOT cylinders shall be 

made under DOT regulations and 

control in accordance with the 

requirements of 49 CFR Section 

173.34 

Training LPG bulk loading or LPG 

transfer and dispensing facilities 

must have a training program in 

place consisting of: 

 Written training procedures; 

 Training frequency and 

scheduled training dates; 

 Written record of dates 

training was provided; 

 Record of upcoming training 

schedule 

[PR 1177(e)] 

 Emergency response 

training 

 Initial 24 hrs training 

8 hrs annual 

refresher annually [8 

CCR 5192 

(Hazwoper)] 

 New employees must complete 

hazmat training within 90 days from 

hiring and every 3 years thereafter 

 Employer must maintain records of 

employee training, such as the 

hazmat employee's name, the most 

recent training completion date of the 

hazmat employee's training, a 

description, copy, or the location of 

the training materials used, the name 

and address of the person providing 

the training; and certification that the 

hazmat employee has been trained 

and tested 
Final Staff Report

Proposed Rule 1177 29 June 2012 

Section AQMD Cal OSHA* DOT 

Recordkeeping 

requirements 

LPG bulk loading or LPG 

transfer and dispensing facilities 

must maintain: 

 Records of all FLLG and 

connectors installed or 

repaired of FLLG and 

connectors during daily 

inspections 

 Repair logs with date and 

time of repair, name of 

person performing the repair 

and employer phone and 

address, description of 

service performed and 

identification of each 

component repaired 

 Maintenance records for 

vapor recovery or 

equalization systems 

 Documentation that installed 

low emission FLLG or LPG 

low emission connectors 

used to comply with rule 

meet applicable rule 

definition 

[PR 1177(f)] 

 Retain shipping records for one year 

Reporting 

requirement 

 LPG bulk loading and LPG 

transfer and dispensing 

facilities that offer LPG for 

sale to an end user must 

submit annual reports of the 

LPG purchased and 

dispensed volume for each 

calendar years 2013, 2014 

and 2015 no later than July 1 

of the subsequent calendar 

year; 

 LPG bulk loading facilities 

must submit an end of year 

inventory of installed LPG 

low emission connectors by 

July 1, 2014 for calendar 

year 2013. 

 LPG bulk loading facilities 

must submit annual 

inventory of containers and 

associated FLLGs for 

calendar years 2013 through 

2017 no later than July 1 of 

the subsequent calendar 

year 

[PR 1177(g)] 

The owner or user of a 

LPG container has to 

report all repairs or 

alterations affecting the 

safety of LPG tanks to 

the DIR within 21 days 

by the ASME “U” or 

National Board “R” 

certificate holder making 

such repairs or 

alterations using the 

appropriate National 

Board Form, “R-1”, 

Report of Welded 

Repair, or “R-2”, Report 

of Alteration [8CCR 

494(e)] 

Submit incident reports within 30 days 

Leak detection 

methods 

Daily physical checks and 

bubble test or Method 21 

[1177(h)] 

 

Confidentiality of 

information 

Information submitted to the 

Executive Officer may be 

designated as exempt from 

disclosure per Govt. Code 

§6250-6276.48 [1177(i)] 

 

*Department of Industrial Relations 
Final Staff Report

Proposed Rule 1177 30 June 2012 

COMMENTS AND RESPONSES 

Comments from Public 

The following comments were received with regards to the public workshop 

conducted on August 25, 2011. 

Applicability 

Comment #1 

The LPG transfer and dispensing industry is subject to regulations from multiple 

agencies. The District should ensure that the proposed rule does not conflict with 

existing regulations and should also take steps to remove any unnecessary 

duplication. 

Response 

The District has reviewed the federal, state and local requirements, especially those 

for fire protection, and has developed the proposed rule that is complementary in 

nature to existing regulations, while providing additional benefits centered on 

improving air quality. The proposed rule, developed with significant input from the 

LPG industry, leverages current training and inspection procedures wherever 

possible, and minimizes any duplication of existing recordkeeping or reporting 

requirements. 

Comment #2 

Does the proposed rule apply to emergency LPG fuel tanks that service emergency 

equipment? LPG fuel is transferred to emergency internal combustion engines for 

backup power from the LPG storage tank. 

Response 

The proposed rule would apply to the LPG transfers into the storage tank, but not any 

subsequent transfers from the tank to the generators. The proposed rule is focused on 

transfers that involve emissions from either disconnections or venting from fixed 

liquid level gauges, rather than transfers associated with feeding of fuel into the 

combustion equipment itself. The proposed rule language has also been updated to 

limit the inspection and reporting requirements to LPG Bulk Loading facilities and 

LPG Transfer and Dispensing facilities that offer LPG for sale to an end user. 

Therefore, specifically with respect to LPG stored as emergency fuel, the LPG low 

emission connector requirement would apply to the LPG fuel provider, but not to the 

emergency engine operator. 
Final Staff Report

Proposed Rule 1177 31 June 2012 

Definitions 

Comment #3 

The definition of container should reference the ASME specifications. 

Response 

Staff has included a reference to ASME specifications in the definition for stationary 

storage tank. However, the container definition is intended, for the purpose of this 

proposed rule, to be a generic reference that includes both cylinders and tanks, the 

former being more specifically covered by DOT rather than ASME standards. 

Comment #4 

The definition of dry-break coupling or dry disconnect coupling is unnecessary 

because the proposed rule only requires LPG low emission connectors. 

Response 

The terms and associated definitions for dry-break coupling and dry disconnect 

couplings have been removed from the proposed rule. 

Comment #5 

The inspection requirements should rely on a physical examination and use of a 

bubble test rather than the expensive Method 21 that can result in false positives. The 

LPG industry has a built in incentive to minimize leakage of a valuable product in 

addition to the safety requirements from other agencies authorities, including NFPA, 

DOT, WPGA, CHP, etc. As such, leaks should not be considered to be a significant 

issue. 

Response 

The self-inspection requirement has been updated to rely on physical examination 

and use of a bubble test rather than Method 21. Staff believes that the Leak Detection 

and Repair (LDAR) program included in this proposed rule is vital to further evaluate 

the potential leaks as a source of additional VOC emissions. 

Comment #6 

We recommend amending the definition of LPG Vapors to read: “LPG VAPORS are 

organic compounds occurring in vapor form as well as entrained liquid within the 

container. Small quantities are released to atmosphere upon completion of the LPG 

transfer and dispensing operations.” 
Final Staff Report

Proposed Rule 1177 32 June 2012 

Response 

Use of the term “LPG Vapors” in the proposed rule is limited to the definition of 

“LPG Vapor Recovery or Equalization System.” The purpose of the definition is to 

clarify that entrained liquid that is recovered by these systems would be considered 

when determining proper operating efficiency of the LPG vapor recovery or 

equalization system. The addition of the last sentence referring to the quantity of 

emissions released appears to be editorial and staff believes the staff report 

adequately addresses the descriptive nature of the comment. 

Comment #7 

We recommend deleting the definition of "Liquid Tight." This is a reference to liquid 

fuels. When liquid propane is released into the atmosphere, it vaporizes. Further, 

emission rates for propane are measured in cubic centimeters for the rate of emission 

and size of cavity from which emissions come. 

Response 

A LPG leak of sufficient volume can be observed in liquid form, although it's 

presence as a liquid would be limited following its release due to volatilization. The 

District would view a connector that is not liquid tight as resulting in greater loss than 

a connector that is not vapor tight. 

Comment #8 

Why is there a separate definition for "mobile fueler" in addition to "bobtail?" 

Response 

District staff believes that the denotative meaning of bobtail would not include trailer 

tanks, and have included the definition for mobile fueler to account for these various 

types of LPG transports. 

Comment #9 

We suggest deleting the "performance test" definition. This appears to be a provision 

taken from the gasoline vapor recovery regulation. The propane industry does not 

have a standard vapor recovery system other than for offloading railcars and 

transports. 

Response 

The intent of including the "performance test" definition was to provide an example 

of the criteria manufacturers may use in ensuring proper operation of an LPG Vapor 

Recovery or Equalization System. However, because manufacturer criteria may vary 

and are not the primary focus of the proposed rule, the term "performance test" has 

been removed, and the language associated with demonstrating proper maintenance 
Final Staff Report

Proposed Rule 1177 33 June 2012 

of LPG Vapor Recovery or Equalization Systems updated to allow facilities to confer 

with manufacturers in determining the appropriate form of documentation. 

Comment #10 

We suggest amending the definition of “valve” to read: 

“VALVE is a device that regulates or isolates the fluid flow in a pipe, tube, tank, 

or conduit by means of an external actuator.” 

Response 

Agree. The word "tank" has been added to the definition for valve. 

Comment #11 

Analyzers should not be required to be calibrated with methane. 

Response 

The calibration standard is based on methane for consistency with a leak threshold of 

10,000 ppm and Rule 1173. In addition, the inspection procedure section has been 

updated in the proposal to rely on the industry requested bubble test, rather than 

Method 21. 

Comment #12 

The inspection requirements should specify whether the leak being checked for is a 

vapor or liquid leak and the criteria used to establish the presence or absence thereof. 

In addition, the types of components subject to the inspection requirements should be 

further clarified to distinguish between connectors and components such as pumps 

and sight glasses, flanges and threaded connections. 

Response 

The inspection requirements have been updated to refer to connectors rather than 

components. 

Comment #13 

How does the proposed rule distinguish between facilities that offer LPG for sale to 

an end user and those that transfer or dispense LPG only as a support function? An 

example of the latter would be a facility that maintains a smaller LPG tank to fill 

forklift propane tanks as a contingency for supply disruption normally covered 

through a cylinder exchange program with a LPG supplier. Should there be a 

threshold on the requirements based on tank size, throughput, or categorization as a 

primary business? 
Final Staff Report

Proposed Rule 1177 34 June 2012 

Response 

The proposal has been updated to clarify the intended rule applicability. The 

inspection requirements are limited to owners and operators of Bulk Loading and 

Dispensing facilities and LPG transfer and dispensing facilities that offer LPG for 

sale to an end user. However, the use of LPG low emission connectors and low 

emission FLLGs would apply to all LPG transfer and dispensing facilities, and are the 

responsibility of the owner of the equipment. 

Comment #14 

Facilities, such as refineries that are subject to Rule 1173, should be excluded from 

the proposed rule. 

Response 

The proposed rule has been updated to exclude facilities subject to Rule 1173. Staff 

plans to further evaluate both rules to assess any additional controls that may be 

necessary for facilities currently subject to Rule 1173. 

Cost-Effectiveness 

Comment #15 

There are several issues associated with retrofitting stationary storage tanks with low 

emission FLLGs in the field. While many can be retrofitted fairly readily, there are a 

percentage of tanks (between 5 and 50 percent, depending on the composition of the 

LPG supplier's tank inventory) that have either intentionally crimped (as a safety 

design) or damaged vent valves which require additional precautions up to removal 

from the field. Field removal would result in additional emission from trucks used 

for removal, and also result in other additional costs and business disruption, 

including providing continuation of LPG fuel service to the customer and any 

recertification or re-permitting for the upgraded tank, which may included servicing 

at a DOT certified facility. It should also be noted that residential tanks subject to 

retrofitting are often located at lower income areas that are more sensitive to cost. 

Response 

Although staff understands that based on feedback from the LPG industry, most tanks 

can be readily retrofitted with low emission FLLGs in the field, it is not uncommon to 

encounter tanks where difficulties arise as noted. To accommodate these 

circumstances and address numerous comments, the proposed rule has been updated 

to extend the compliance deadlines over a five year period, aligning retrofit schedules 

to customer change-outs and similar maintenance activities. 

Comment #16 

The costs to implement the proposed rule are prohibitive. Major contributors to cost 

include the tight time schedule for retrofits, use of Method 21 and requirement to test 
Final Staff Report

Proposed Rule 1177 35 June 2012 

field tanks that are infrequently filled. The additional costs associated with 

scheduling which could be mitigated by allowing retrofits to occur as part of existing 

out-of-service obligations such as tank requalification, recertification, re-permitting, 

customer change-outs, etc., and the inspection costs could be reduced by relying on 

more effective less costly physical inspections with bubble test verification rather 

than Method 21. With respect to retrofitting of FLLGs, it should be noted that an 

analogous effort to retrofit cylinders with an overfill protection device (OPD) 

occurred over a 5 year period, with retrofits still occurring as older tanks are refilled. 

Response 

PR 1177 has been revised with extended compliance dates, removal of mandatory 

Method 21 requirements, and inspection every 90 days or during a subsequent 

transfer where the time between transfers is greater than 90 days. Total costs and 

cost-effectiveness of the proposed rule have been evaluated and included as part of 

the staff report. 

See also response to comment #15 and response to comment #5 for additional 

discussion. 

Equipment and Operation Requirements 

Comment #17 

There are several issues associated with retrofitting portable storage tanks. From a 

cost perspective, the tight schedule imposes additional costs which could be avoided 

if the DOT cylinders would be retrofitted in conjunction with the 5 year 

requalification schedule (12 year for new cylinders). In addition, commercial 

availability of the low emission FLLG is uncertain, and because of the space 

availability on the smaller cylinders, retrofitting of the cylinder would require 

replacement of the entire valve assembly. While cost estimates for the low emission 

FLLG is $7 per unit, for the valve assembly the cost is about $20 per unit and would 

need to be passed on to the customer. 

Response 

The compliance deadlines in the proposed rule have been extended to up to five years 

to better accommodate cylinder requalification cycles, primarily based on feedback 

from the industry. While low emission FLLGs are not currently commercially 

available for all applications, FLLG manufacturers have indicated that availability 

should not be an issue with respect to the proposed compliance timeframes. Total 

costs and cost-effectiveness have been evaluated and included as part of the staff 

report and the overall cost effectiveness for this proposed rule is approximately 

$1,700 per ton of VOC emissions reduced, which is well below the acceptable limit 

for VOC-related rules. It should be noted that additional cost savings resulting from 

lowered LPG product lost to emissions should help mitigate some of the retrofit costs. 
Final Staff Report

Proposed Rule 1177 36 June 2012 

Comment #18 

What testing has been performed to estimate the emission reduction potential from 

use of the low emission FLLGs? 

Response 

A discussion on FLLG emissions is included in the LPG Emission Factor 

Determination section of this staff report. FLLGs with number 72 size orifices were 

tested, including the self-cleaning design that incorporates a drill bit insert designed 

to represent an equivalent orifice opening, with emission reduction results ranging 

from 50% to 70%. The most recent test by the District in December 2011 represents 

the low end of the emission reduction results and is conservatively used for 

calculating emission estimates. The higher end of the tested results (Battelle, 2009), 

relied on indirect measurements of LPG loss (using air flow as a surrogate) and may 

be more representative of the potential reductions from a controlled environment 

rather than the more direct weight loss protocol that the District test employed. 

Comment #19 

Although use of a low emission FLLG is expected to result in reduced emissions, 

consideration should be given to fill-by-weight operations as well as other alternative 

filling methods that do not utilize the FLLG. Because of the open-ended nature of the 

cylinder exchange model, such providers would be disproportionately burdened with 

the responsibility of retrofitting thousands of cylinders while filing in a manner that 

does not rely on the FLLG. 

Response 

The proposed rule has been updated to account for fill by weight techniques or other 

technology, providing a mechanism for alternatives to retrofit and use of the low 

emission FLLG. 

LPG transfer at LPG Bulk Loading Facilities 

Comment #20 

Vapor tight caps are not currently being used. Vapor tightness is ensured by the shutoff valve, while the caps only serve as dust caps. 

Response 

The requirement to use vapor-tight caps has been removed from the proposed rule. 

The condition of vapor tightness will rely on the shut-off valve. 
Final Staff Report

Proposed Rule 1177 37 June 2012 

Inspections 

Comment #21 

Would DOT required training be sufficient to meet the training obligations of the 

proposed rule? The industry is also subject to other training requirements such as 

HM126 every three years, and Certified Employee Training Program (CETP) courses 

for LPG equipment. If Method 21 is required, can the District offer training? 

Response 

Based on comments from the LPG industry, the proposed rule requires training of any 

employee that implements the leak detection program, including the daily physical 

checks of connectors and quarterly inspections, including administration of the 

bubble test. It is the District's understanding that the DOT training generally covers 

these aspects, however, the facility owner or operator should review their specifically 

implemented training program to ensure consistency with the proposed rule. 

The proposed rule has been updated to change the use of Method 21 as a requirement 

to an option. 

Operator Inspection Program Requirements 

Comment #22 

The District should require an epoxy affixed bar code sticker for each tank to 

facilitate leak testing. 

Response 

The proposed rule requires facilities to maintain an inventory of affected connectors 

and FLLGs with information sufficient for identification, but does not specify how 

the facility would uniquely identify each tank or affected inspection unit. Staff 

believes the facilities would be best equipped to identify the mechanism for tank 

identification and therefore prefers to defer the specification to affected owners and 

operators. The affixed bar code sticker may be one of the available options. 

Comment #23 

Leaks detected and repaired under the daily inspection program would not be 

considered violations. What would constitute a violation with respect to leaks? 

Would leaks detected under the quarterly inspection or components taken out of 

service in lieu of repair be handled differently? 

Response 

Any leak detected by an owner/operator and subsequently repaired prior to being 

returned to service, and documented appropriately would not be considered to be a 

violation of the proposed rule. However, if the District determines as part of a field 
Final Staff Report

Proposed Rule 1177 38 June 2012 

inspection that a connector exhibits a leak greater than 10,000 ppm using Method 21, 

or exhibits a visible mist, it would not be considered to be vapor tight or liquid tight 

respectively and therefore subject to violation. 

Reporting and Recordkeeping 

Comment #24 

The annual reporting deadline is too short and the requirement may overlap with API 

reporting that is already voluntarily submitted. Can the District explore opportunities 

to harmonize reporting of information to other entities and on concurrent schedules to 

minimize additional burdens? 

Response 

The proposed rule has been updated to extend the report submittal deadline from 

April 1 to July 1 of the following calendar year and limit the reporting to calendar 

years 2013, 2014 and 2015, based on comments from the industry. Facilities would 

be able to use information submitted to API in the report to the District. However, 

because the API reporting is voluntary, staff believes incorporation of the reporting 

requirement in the proposed rule is necessary to ensure consistency and completeness 

of the data. 

Comment #25 

It is unclear how the required reporting of annual sales is useful for determining air 

quality impacts. If sales data is to be used to assign emission values to individual 

facilities, it should be noted that there are a number of underlying variables that 

would make such correlations difficult. It is not uncommon for facilities to rule out 

one to five percent when reconciling sales and dispensing activities due to variations 

and uncertainties in correlating volume and weight from temperature and pressure 

dependent product densities (and standardized conversions), accounting differences 

in sales by volume, by weight, or by service provided (i.e., charge on a per 

container/cylinder rate, or other billing cycle not directly linked to real-time transfers 

or actual dispensing quantities). 

Response 

The WPGA commissioned a report to estimate emissions from LPG transfer and 

dispensing. This 2011 report uses annual sales data as the starting point for 

estimating the District-wide LPG transfer, dispensing and disconnect activities and 

correlates average FLLG release rates from test data and entrapment volumes for 

connectors to estimate overall LPG emissions. 

The District used the methodology of the WPGA report to evaluate emissions, with 

an adjustment for the amount of time the FLLG was used during the fill cycle (the 

WPGA report assumes 60 seconds independent of the fill time, whereas the District 

estimate assumes FLLG use during the entire filling time, based on average fill rates 
Final Staff Report

Proposed Rule 1177 39 June 2012 

estimated by an earlier CARB report, supported by follow-up conversations with 

industry representatives and NFPA requirements). An additional adjustment to the 

WPGA report methodology is the estimate of the fill capacity (the WPGA report 

assumes that all tanks are filled to 80 percent capacity from an empty starting point, 

whereas the District estimate assumes that bobtail trucks cargo tanks, and commercial 

and residential tanks are partially filled on average). Appendix B – Emission 

Inventory Calculations of this staff report contains further emission inventory 

calculation details. 

The purpose of obtaining the sales data is to confirm the estimated sales data 

attributed to the District to support the emission estimates and emission reduction 

estimates of the proposed rule, based on the aforementioned methodology. The 

dispensing data is intended to validate the assumption that sales data is representative 

of the transfer and dispensing activity within the District, on an aggregate basis. 

It is not the intention of the proposed reporting requirement to assign material balance 

based emission values to individual facilities or to the industry as a whole and the 

District recognizes that the reconciliation of gross sales and dispensing values 

contains many variables and uncertainties, similar to other area (non point) sources of 

emissions. It should also be noted that the proposed rule is only requiring purchase 

and sales data reporting for three years in order to compare to the API data and to be 

able to interpret possible usage and seasonal trends that may exist in the District. 

Comment #26 

What protections are provided for the reporting of sensitive confidential sales data 

required under the proposed rule? 

Response 

The proposed rule has been updated with the following provision (subdivision (i)): 

“Subject to the provisions of the California Public Records Act (Govt. Code § 

6250-6276.48) information submitted to the Executive Officer may be designated 

as confidential. The designation must be clearly indicated on the reporting form, 

identifying exactly which information is deemed confidential. District guidelines 

require a detailed and complete basis for such claim in the event of a public 

records request.” 

Similar language exists in other District rules that require reporting of confidential 

information. 

Comment #27 

What is the purpose of supplying training documentation to the District? 
Final Staff Report

Proposed Rule 1177 40 June 2012 

Response 

The proposed rule requires that training records be maintained for employees that are 

engaged in the leak detection program. Training of personnel performing leak 

detection daily and quarterly checks ensure proper use of the techniques and 

understanding of the required frequencies required to identify leaks and verify 

repairs, and the records demonstrate compliance with the requirement. This 

documentation is not part of the reporting requirements. 

Comment #28 

The requirement to maintain and submit an inventory of facility components appears 

overly burdensome, especially the tight 30 day timeframe for reporting. What is the 

purpose of the proposed rule for this requirement, and what efforts have been made to 

minimize this burden? 

Response 

The proposed rule contains a phased retrofit schedule for the installation of low 

emission FLLGs. An inventory of affected containers and associated low emission 

FLLGs would be used to track implementation of this proposal. 

The proposed rule has been updated to extend the reporting deadline to July 1 

following the end of the calendar year. Staff has also developed sample 

recordkeeping and reporting forms (please see Attachment C) which industry has 

reviewed. Subsequent industry feedback has also been incorporated into these forms 

to simplify the proposed rule recordkeeping and reporting requirements. 

Comment #29 

The recordkeeping requirements for inspection and repair logs is not specific enough, 

especially with respect to the term "...but not limited to...". What format and what 

specific details are required by the proposed rule, and can a template be made 

available to minimize confusion? 

Response 

The term "...but not limited to..." was intended to allow additional flexibility to 

owners and operators to provide unique identification information. The proposed rule 

language of sub clause (f)(1)(A)(ii)(IV) has been updated as follows for clarification: 

"Identification of the FLLG or connector that was installed, repaired, serviced or 

removed, such as FLLG or connector identification information or FLLG or 

connector manufacturer name." 
Final Staff Report

Proposed Rule 1177 41 June 2012 

Comment #30 

If LPG suppliers are allowed to keep records for inspections or reports, will the 

facility owner that receives LPG be able to delegate recordkeeping requirements for 

District inspections? 

Response 

The inspection requirement in the proposed rule has been updated to apply only to 

LPG suppliers. Therefore, the facility owner that receives LPG for consumption and 

does not offer LPG for sale to an end user is not obligated to inspect or keep 

associated records. 

Comment #31 

The required tracking of LPG transfers appears to double count sales volume. 

Response 

The purpose of tracking dispensing volumes in addition to sales volumes is to 

determine if the use of sales volume or dispensing volumes is a better proxy for 

emission estimation. The emission estimation methodology, as outlined in Appendix B 

– Emission Inventory Calculations, relies on the assumption that LPG sales are 

representative of dispensing related activities on an aggregate level. By tracking 

monthly and annual sales and dispensing records, the District will be able to 

determine if there are any seasonality issues associated with LPG transfer and 

dispensing and also confirm if sales is an appropriate surrogate for activity. In 

addition, the proposed rule has been revised to limit this reporting obligation to three 

years. 

Comment #32 

What is the purpose for tracking monthly disbursements? Can the monthly 

requirement be extended to an annual requirement for smaller, infrequently used 

tanks? 

Response 

The purpose for tracking monthly disbursements is to determine the extent of any 

seasonal variation in LPG consumption in order to evaluate impacts on air quality 

management planning emission inventories, which may be sensitive to summer or 

winter peaks. See also response to comment #31. 

Fire and Safety Hazards 

Comment #33 

It should be noted that reducing LPG emissions from FLLG, etc. should result in a 

concurrent reduction in fire safety hazards, which could translate into lower insurance 
Final Staff Report

Proposed Rule 1177 42 June 2012 

premiums, especially if techniques and technologies that do not rely on FLLGs are 

utilized. 

Response 

The draft staff report has been updated to acknowledge the concurrent reduction in 

fire and safety hazards and the potential for lowered insurance premiums with respect 

to lowered fugitive emissions. Staff will consider these benefits of reducing fugitive 

LPG release in the Socioeconomic Impact Assessment report. 

General 

Comment #34 

It should be emphasized that the LPG industry has been evolving to low emissions 

equipment through routine maintenance voluntarily without regulation. 

Response 

The draft staff report has been updated to further acknowledge the efforts from the 

LPG industry to voluntarily reduce emissions prior to this rule development effort. 

The proposed rule leverages the LPG industry’s voluntary efforts and accelerates the 

retrofit schedules for air quality benefits, estimated to be 6.1 tpd. 

Rule Development Process 

Comment #35 

The notification timeline for the public workshop was too short. It is also unclear 

how the proposed rule applies to facilities subject to Rule 1173. 

Response 

The District has been conducting working group meetings with industry, including 

the Western Propane Gas Association (WPGA) in the development of the proposed 

rule, including the rule development schedule. Because facilities subject to Rule 

1173 were not part of the initially intended scope of the proposed rule, the District did 

not make a targeted notification of the proposal to facilities such as refineries, and has 

subsequently added specific rule language to exclude Rule 1173 facilities from the 

proposal, pending further review of potential controls for facilities currently subject 

to Rule 1173. Staff conducted a total of seven working group meetings and 

participated in thirteen site visits, incorporating feedback though multiple proposed 

rule language iterations. 
Final Staff Report

Proposed Rule 1177 43 June 2012 

Emissions Inventory 

Comment #36 

The estimated emissions appear to underestimate the inventory relative to a one 

percent loss assumption based on sales. 

Response 

The methodology used to estimate emissions is outlined in Appendix B – Emission 

Inventory Calculations, and is based on an industry sponsored study, the California 

Air Resources Board’s report, and additional input from District staff referencing 

separate communications with industry representatives, as well as both internal and 

external source testing data. While industry has also indicated that it is not 

uncommon for accounting differences between sales and dispensing records to be in 

the one percent range, the District is not currently correlating this difference as 

representative of fugitive emissions, either as an average or worse case correlation 

due to a number of uncertainties associated with sales records and dispensing 

volumes. See also response to comment #25. 

SOCIOECONOMIC ASSESSMENT 

A Socioeconomic Impact Analysis report for the proposed rule has been prepared and 

will be released to the public no later than 30 days prior to the hearing.Proposed Rule 

1177 would affect LPG dealers/distributors (NAICS 454312), petroleum bulk stations 

and terminals (NAICS 424710), and retail facilities, the latter including both gasoline 

stations (NAICS 447190) and general rental centers (NAICS 532310) of roughly 

equal distribution. The majority of the affected facilities are small businesses.

The total average annual cost of PR 1177 is estimated to be $4.28 million from 2013 

to 2025. Out of $4.28 million cost, LPG dealers/distributors would incur about $3 

million (70 percent of the total cost) at $120,000 per dealer/distributor. The average 

annual cost of petroleum bulk stations & terminals, including those involved in 

gravity filling forklift cylinders is estimated to be $1.21 million (or about $6,060 per 

facility). The average annual cost of gasoline stations and general rental centers is 

estimated to be $0.07 million (or about $106 per facility).

PR 1177 is projected to have 21 jobs forgone annually in the entire four-county 

economy between 2012 and 2025, which is 0.0002 percent of the baseline jobs in the 

four-county area and are considered to be within the noise of the economic model 

employed for this analysis.

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) 

Pursuant to California Environmental Quality Act (CEQA) Guidelines §15252 and 

§15162 and AQMD Rule 110, the AQMD has prepared an Environmental 

Assessment (EA) for Proposed Rule 1177. The environmental analysis in the Draft 
Final Staff Report

Proposed Rule 1177 44 June 2012 

EA concluded that Proposed Rule 1177 would not generate any significant adverse 

environmental impacts. The Draft EA was released for a 30-day public review and 

comment period from April 3, 2012 to May 2, 2012. Any comments received during 

the public comment period on the analysis presented in the Draft EA will be 

responded to and included in the Final EA. Prior to making a decision on the 

proposed adoption of Rule 1177, the SCAQMD Governing Board must review and 

certify the Final EA as providing adequate information on the potential adverse 

environmental impacts of the proposed project. and one comment letter was received 

from the public regarding the Draft EA. Responses to the comments received have 

been prepared and the comment letter and its responses are included as Appendix C 

of the EA.

Since the release of the Draft EA, minor modifications have been made to the 

document. However, none of the modifications alter any conclusions reached in the 

Draft EA, nor provide new information of substantial importance relative to the draft 

document. As a result, these minor revisions do not require recirculation of the Draft 

EA pursuant to CEQA Guidelines §15073.5. Therefore, the Draft EA is now a Final 

EA and is included as an attachment to this Governing Board package.

DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE 

SECTION 40727 

Health and Safety Code Section 40727 requires that prior to adopting, amending or 

repealing rules, the AQMD Governing Board shall make findings of necessity, 

authority, clarity, consistency, non-duplication and reference, based on relevant 

information presented at the hearing. The draft findings are as follows: 

Necessity: The AQMD Governing Board has determined that a need exists to adopt 

Rule 1177 - Liquefied Petroleum Gas Transfer and Dispensing, to partially 

implement Control Measure CM #2007 MCS-07 – Application of All Feasible 

Measures from the 2007 AQMP and help AQMD attain the National Ambient Air 

Quality Standard for ozone for which AQMD is classified as an Extreme NonAttainment Area. 

Authority: The District obtains its authority to adopt, amend or repeal rules and 

regulations from California Health and Safety Code Sections 39002, 39650, 40000, 

40001, 40440, 40441, 40463, 40702, and 40725 through 40728, 41508, 41700, and 

42300. 

Clarity: Rule 1177 – Liquefied Petroleum Gas Transfer and Dispensing as proposed 

to be adopted, is written or displayed so that its meaning can be easily understood by 

the persons directly affected by it. 

Consistency: Proposed Rule 1177 – Liquefied Petroleum Gas Transfer and 

Dispensing is in harmony with, and not in conflict with or contradictory to, existing 

statutes, court decisions, or federal or state regulations. 
Final Staff Report

Proposed Rule 1177 45 June 2012 

Non Duplication: Rule 1177 – Liquefied Petroleum Gas Transfer and Dispensing, as 

proposed to be adopted, does not impose the same requirements as any existing state 

or federal regulations, and the amendments are necessary and proper to execute the 

powers and duties granted to, and imposed upon, the District. 

Reference: This regulation would implement, interpret or make specific the 

provisions of: Health and Safety Code Sections 40001 (rules to achieve ambient air 

quality standards), 40440(a) and (c) (rules to carry out the Air Quality Management 

Plan and rules which are also cost-effective and efficient), 40702 (rules to execute 

duties necessary to preserve original intent of rule), and 40910 et seq., (California 

Clean Air Act). 
Final Staff Report

Proposed Rule 1177 46 June 2012 

REFERENCES 

1. SCAQMD (2008) VOC Emissions During the Gravity Filling of a Forklift 

Propane Tank – Mutual Propane, Gardena, California, November 2008 

2. Adept Group, Inc. (2008) LP Gas Emissions Through Outage Gauge During 

Cylinder Refilling – Mutual Propane, Gardena, California, November 2008 

3. Battelle Laboratories (2009) Research Investigation on Testing and Evaluation of 

New Low Emission Fixed Maximum Liquid Level Gauges for Use in LP-Gas 

Containers, prepared for PERC, September 2009 

4. CARB (1992) Determination of Usage Patterns and Emissions for Propane/LPG 

in California, May 1992 

5. Life Cycle Associates, LLC (2011) Inventory of Fugitive Emissions from LPG 

Transfers in California, prepared for WPGA, June 2011 (CONFIDENTIAL)

6. Marshall Excelsior, Catalog (2010); Conference Call with Jim Zuck on January 

13, 2012 

7. REGO Conference Call with Dave Stainbrook, V.P. of Engineering and Mark 

Hall, December 14, 2011. 

8. SCAQMD (2011), “Propane Tank Filling Emission Reduction Efficiency from 

Low Emissions #72-Drill Size Self-Cleaning Fixed Maximum Liquid Level 

Gauges (FMLLGs),” Source Test Report – 11-300, 2011 
APPENDIX A. LPG INDUSTRY SUMMARY 

LPG PROPERTIES

LPG TRANSFER AND MODES OF DISTRIBUTION 

LPG USAGE 

LPG SALES 

LPG TRANSPORT METHODS, STORAGE AND 

DISPENSING 
Final Staff Report

Appendix A - LPG Industry Summary A - 2 June 2012 

The information in this appendix is based on the June 2011 Life Cycle Associates, 

Inc. report that was prepared for the WPGA and supplemented by District staff 

research. 

Liquefied Petroleum Gas (LPG) is derived from two large energy industries: natural 

gas processing and crude oil refining use. LPG is an organic compound having a 

vapor pressure not exceeding that allowed for commercial propane and is composed 

predominantly of the following hydrocarbons, either by themselves or as mixtures: 

propane, propylene, butane (normal butane or isobutane) and to a lesser extent 

butylenes, and is stored and transported under pressure in a liquid state. 

Raw natural gas from wells primarily comes from any of three sources: crude oil 

wells, gas wells and condensate wells. Natural gas that comes from crude oil wells is 

typically referred to as associated gas. This gas could have existed as a gas cap above 

the crude oil in the underground formation or could have dissolved in the crude oil. 

Natural gas that comes from gas wells and from condensate wells, in which there is 

little or no crude oil is termed non-associated gas. 

When natural gas is drawn from the earth, it is a mixture of several gases and liquids. 

Natural gas which is sold by gas utilities consists of about 90 percent methane. Of 

the remaining 10 percent, approximately 5 percent is propane and the remaining 5 

percent consists of other gases such as ethane and butane. Before natural gas can be 

transported or used, the LPG (which is slightly heavier than methane, the major 

component of natural gas) is separated out. 

Some LPG is also present in crude oil and is referred to as “associated gas”. In order 

to stabilize crude oil for pipeline or tanker transport, the associated gas is further 

processed into LPG. Worldwide, gas processing is a source of approximately 60 

percent of LPG produced, while crude oil refining is the source of the other estimated 

40 percent of LPG supplies although the ratio between gas processing and refining 

varies depending on geographic location. 

During the crude oil refining process LPG is produced on the way to making the 

heavier fuels such as diesel, jet fuel, fuel oil, and gasoline. It is estimated that 

approximately 37 percent of propane consumed in the United States is consumed as 

raw material in the petrochemical industry with demand being regional and 

concentrated in the Gulf Coast region. Propane is also one of many possible raw 

material options utilized by the petrochemical industry. 

LPG PROPERTIES 

LPG is a petroleum product composed predominantly of any of the following 

hydrocarbons or mixtures thereof: propane, propylene, butanes (normal or isobutane) 

and to a lesser extent butylenes. Although consisting mainly of propane and butane, 

in some parts of the country, propane itself is commonly referred to as LPG. Propane 

and butane have vapor pressures (at 60 degrees F) of 107 psia and 26 psia, 
Final Staff Report

Appendix A - LPG Industry Summary A - 3 June 2012 

respectively compared to gasoline which ranges from approximately 3.5 psia to 7 psia 

at the same temperature (see Table A-1). 

Unlike gasoline, which is a liquid under normal or standard conditions, LPG is a 

vapor under similar conditions. The heating value of LPG is in the range of 22 to 26 

percent less than that of natural gas. Also, the temperatures required to liquefy LPG 

products can be produced by refrigeration or by use of storage containers that are 

designed to securely hold vapors at pressures significantly in excess of the vapor 

pressures of LPG within normal temperature ranges. It is mainly for this reason that 

LPG is stored and transported in closed containers under pressure. 

LPG is colorless and odorless and about 1.5 times as heavy as air in the vapor state. 

Therefore, it is necessary, as a fire and safety precaution, to add an artificial odorant 

to warn users of its presence in the event of leaks. Organosulfur compounds are 

usually used for this purpose with the most common odorant being ethyl mercaptan. 

Most states require a minimum of 1 pound of odorant to be injected into 10,000 

gallons of LPG loaded. 

When LPG is transferred from storage containers it is done under normal atmospheric 

conditions, but at operating pressures that are much higher than atmospheric using 

pumps. In order for the material to remain in its liquid state when transferred, it is 

important that delivery occur within a closed system where pressure is not 

compromised. Another important reason for maintaining a closed system under 

pressure is because LPG is sold as a liquid and therefore metered and typically paid 

for on a per volume basis. Maintaining a closed system ensures that the customer is 

paying for product that is actually transferred rather than paying for lost product. 

An important value of LPG products lies in the fact that they can be stored in liquid 

state and used in their gaseous state. Hence the advantage obtained from reduced 

transportation cost is thought to be sufficient to offset the cost of liquefying these 

products. Also, in order to use LPG in most commercial and industrial applications it 

must be converted back to a gaseous state which can be accomplished by returning it 

to atmospheric temperature and pressure. 

Table A-1. Fuel Properties Comparison 

Property Vapor Pressure (psia) Boiling Point 

(

°

F) BTUs per gallon @ 60 °

F @ 100 °F 

Propane 107 172 -44 85,000 – 92,000 

Butane 26 38 32 102,032 

Gasoline 

(CARB Phase 3) 

(2)6.4 - 7.2 (1)114,000 – 125,000 

Natural Gas 91,000 

(1): Alternate Energy System Inc.; www.aspenycap.org 

 (2): CARB Gasoline Specifications; RVP varies depending on blend of gasoline 
Final Staff Report

Appendix A - LPG Industry Summary A - 4 June 2012 

(3): BTU content depends on the grade and blend of the gasoline 

LPG has multiple uses in numerous applications ranging from cooking, heating, air 

conditioning and transportation, as well as industrial uses where LPG can be used as 

a fuel in metallurgical plants or as a standby fuel. In some cases LPG is used as a 

chemical feedstock at manufacturing plants, and is also available for use in motor 

vehicles, where it is commonly referred to as autogas, although its introduction to the 

motor vehicle fuel market has thus far been limited. 

LPG burns relatively cleanly, resulting in lower greenhouse gas emissions than most 

other fossil fuels when measured on a total fuel cycle1

. However, there are many 

transfer points in the supply chain that are inefficient, resulting in product loss, the 

correction of which could translate directly into cost savings. 

LPG TRANSFER AND MODES OF DISTRIBUTION 

The following description and categories are highlights from the industry-sponsored 

analysis. 

LPG Transfer 

Figure A-1 is a network flow diagram that is representative of the movement of LPG 

from the point of production, either from natural gas or from crude oil refining to 

where the product reaches the end user. The diagram depicts the purchase and sale of 

LPG, the various methods used to transport and distribute LPG by wholesalers, 

refiners and retail bulk plant operators. During each transfer or dispensing activity 

there are potential fugitive emissions associated with each exchange. 

Terminals 

After production, LPG is typically held in storage at its production facility and then 

transported to a terminal via rail tank cars or tanker trucks, but LPG may also be sent 

directly to a retail bulk plant. However, most of the LPG produced within the state is 

sent to terminals which do not sell directly to the public, but caters predominantly to 

high volume transfers. At a terminal, LPG is transferred from rail tank cars which 

have an approximate capacity of 33,000 gallons and the terminal has the equipment 

necessary to load and unload tanker trucks which have a capacity of about 10,000 

gallons. Typically, pumps are used to facilitate the tanker truck loading process, 

while compressors are used during the tanker truck unloading process. In some cases 

terminals also facilitate the loading of bobtail trucks which have a capacity in the 

range of 2,500 to 3,000 gallons. 

 

1

 Energetics, “Propane Reduces Greenhouse Gas Emissions – A Comparative Analysis,” pg. 3, 2009. 
Final Staff Report

Appendix A - LPG Industry Summary A - 5 June 2012 

Retail Bulk Plants 

A retail bulk plant can be viewed as a distribution center for retail type transactions. 

LPG is usually delivered to a retail bulk plant either directly from the LPG 

production/storage facility via rail and tanker trucks or from terminals via tanker 

trucks. Bulk storage tanks have a much greater water capacity than most customer 

tanks. They typically range in size from 6,000 to 60,000 gallons, but may be as large 

as 120,000 gallons. 

Bobtail trucks usually fill up at bulk plants and then distribute LPG to multiple users, 

including retail sales facilities, residential and commercial customers and fueling 

stations. The residential sector consumes approximately 40 percent of the LPG sold 

in the District followed by the chemical sector and the commercial sector which 

consume 20 percent and 12 percent, respectively. 

Another significant sector includes usage in internal combustion engines (I.C.Es.) 

which accounts for 10 percent of total LPG sales. Of this 10 percent, the majority (94 

percent) of LPG in this category is used in the operation of forklifts while the 

remaining 6 percent is used in on-road vehicles. 

The retail sales sector accounts for approximately 7 percent of the overall LPG 

market and consists of both onsite cylinder refilling operations, as well as a (20-

pound) cylinder exchange program. Although no statistical data have been collected, 

the Western Propane Gas Association (WPGA) estimated that the cylinder exchange 

program has grown from approximately 7 percent of the retail sales sector (based on a 

2005 Keatley report) to approximately 50 percent of total retail sales currently. This 

approximation points to a shift in consumer habits from refilling 20 pound barbecue 

tanks at a retail filling station to participation in the more convenient tank exchange 

programs which can be done at hardware stores like Home Depot. 
Final Staff Report

Appendix A - LPG Industry Summary A - 6 June 2012 

Figure A-1. Value Chain of LPG Distribution (Life Cycle Associates, LLC, 2011) 

LPG USAGE 

LPG sales are divided into seven (7) categories as shown in Table A-2 below. 

Table A-2. LPG Sales Categories 

Category Description 

Residential Private homes (heating and cooking), recreational 

vehicles 

Commercial Motels (space heating and cooking), restaurants (space 

heating & cooking), laundries 

Chemical Raw material for chemical processing industry 

I.C.E. Fuel Highway vehicles, forklifts, oil field drilling production 

equipment 

Agricultural 

Tractor fuel, irrigation equipment engine fuel, building 

space heating, cooking, crop drying, tobacco curing and 

flame cultivation 

Sales to 

Retail Cylinder filling and exchange 

Industrial Standby fuel for mfg. plants, space heating, flame cutting, 

metallurgical furnaces 
Final Staff Report

Appendix A - LPG Industry Summary A - 7 June 2012 

Residential 

In California and the District, residential LPG usage accounted for the largest market 

share of LPG sales. Typically, residential LPG is distributed in areas where there is a 

lack of natural gas distribution infrastructure. Residential customers use LPG for 

space heating, indoor and outdoor cooking, water heating, swimming pool heating, 

clothes drying, lighting and cooling. Recreational vehicle (RV) fueling is also 

included in the residential market category and LPG is used in RVs for power 

generation, heating and refrigeration. 

Commercial 

LPG is used commercially at facilities such as motels and restaurants. These 

facilities utilize LPG for space heating, water heating, cooking and for laundering. 

This category also includes sales to bottle fillers, campgrounds, and hardware stores. 

Chemical 

The chemical market segment in the District accounts for only 20 percent of total 

LPG sales. LPG is sold to the petrochemical industry where it is used as raw material 

in chemical processes. Some typical products manufactured include ethylene, 

benzene, toluene, xylene, and methanol which are the starting points for many 

polymers and specialty chemicals. 

Internal Combustion Fuel 

In this category propane is utilized for fueling highway vehicles, forklifts, and oil 

field drilling and production equipment. Forklifts in the District are widely used in 

warehouses because VOC emissions from propane combustion are much less than 

that from diesel or gasoline combustion. The majority of LPG in this category is used 

as forklift fuel. However, electric and hydrogen fuel cell forklifts have recently been 

replacing LPG-fueled forklifts. 

Agricultural 

Farm use accounts for about 7 percent of total sales in the District. LPG is used in 

the farming industry for fueling tractors, irrigation engines, standby electric 

generators, space heating in buildings (including farm houses), cooking, crop drying, 

tobacco curing, poultry, and other applications. 

Sales to Retail 

LPG is sold to locations where 20 pound cylinder filling takes place and these include 

dispensing stations or hardware stores which conduct LPG cylinder sales as part of 

exchange programs. Exchange program cylinders are filled by weight or mass at bulk 

loading facilities using an automated system and then delivered by trucks to exchange 

sites. 
Final Staff Report

Appendix A - LPG Industry Summary A - 8 June 2012 

Industrial Uses 

LPG usage in manufacturing plants includes fuel for standby equipment, space 

heating, and flame cutting and metallurgical furnaces. 

LPG SALES 

Table A-3 below shows California LPG sales data from 1999 to 2009. Although 

sales in California have fluctuated during this period of time, there has been an 

overall increase in LPG sales of almost 40 percent with LPG sales increasing from 

almost 500 million gallons in 1999 to almost 695 million gallons in 2009. Prior to 

2003, American Petroleum Institute (API) sales data combined residential and 

commercial sales, but as of 2003, sales data for these two categories were reported 

separately. LPG sales data reported to API is voluntary and as such the sales volumes 

reported are not entirely indicative of the total industry sales transactions. 

Due to the lack of region-specific LPG sales data for the District, a proportionality 

factor of 0.455, based on the District’s population compared to total California state 

population was used to estimate the sales data for the four-county region. Baseline 

VOC emissions estimations for PR 1177 are based on 2009 API reported sales, which 

is the most recent year for which sales data has been compiled. A breakdown of LPG 

sales data for the District according to market sector also shown in Table A-3 below, 

and the distribution by sector for the District is highlighted in Table A-4. 
Final Staff Report

Appendix A - LPG Industry Summary A - 9 June 2012 

Table A-3. Historical California LPG Sales (mgal) based on API sales data provided by Western Propane 

Gas Association 

Category 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 

Residential 

and 

Commercial 

302,715 288,766 199,223 240,791 

Residential ------- ------- ------- ------- 204,167 246,420 252,807 259,285 287,581 283,711 275,256 

Commercial ------- ------- ------- ------- 109,912 146,220 104,266 88,015 101,518 108,513 86,639 

Sales to 

Retailers N/A N/A N/A N/A 64,663 61,665 65,854 56,938 56,905 65,358 51,941 

ICE Fuel 44,297 66,678 80,660 64,717 53,829 62,773 73,137 73,498 withheld 

withheld 67,077 

Chemical 89,212 180,861 135,075 N/A N/A N/A N/A N/A N/A N/A 135,576 

Industrial 37,950 36,791 37,813 45,300 33,331 22,994 44,788 46,512 withheld 

withheld 27,806 

Agricultural 25,421 17,255 39,874 65,056 30,373 49,588 55,509 66,216 74,321 59,409 50,466 

Total CA 

Sales 499,415 590,361 492,644 415,864 496,276 589,480 573,904 590,464 651,139 633,053 694,761 

SCAQMD 

Sales * 227,234 268,614 224,153 189,136 225,806 268,259 261,126 268,661 296,268 288,039 316,116 

(*) South Coast Air Basin sales is estimated at 45.5 percent of California sales based on population 

Table A-4. 2009 SCAQMD LPG Sales 

Market Sector Market Subsector Volume 

(mgal) 

Percent Share 

(%) 

Residential Heating 122.01 97.36 

RVs 3.31 2.64 

Subtotal: 125.32 

 

Commercial --- 39.45 

Sales to Retail Exchange 11.82 50 

On-site Refill 11.82 50 

Subtotal: 23.64 

 

IC Engines Forklift 28.76 94.17 

On-road Vehicles 1.78 5.83 

Subtotal: 30.54 

 

Industrial --- 12.66 

Chemical --- 61.73 

Agricultural --- 22.98 

Total: 316.27 
Final Staff Report

Appendix A - LPG Industry Summary A - 10 June 2012 

LPG TRANSPORT METHODS, STORAGE AND DISPENSING 

Liquefied Petroleum Gas (LPG) Transport Methods 

Railroad Tank Cars 

Railroad tank cars deliver propane to bulk plant unloading stations in large quantities. 

Railroad tank cars are by far the largest DOT tanks that transport LPG, ranging in 

size from 4,000 – 45,000 gallons water capacity and equipped with fittings and valves 

enclosed in a protective dome that is located on the top of the cargo tank (see 

Figure A-2). The railroad tank cars observed in the District are in the range of 30,000 

– 34,000 gallons water capacity and can be emptied in 45 minutes to an hour with the 

use of a compressor or pump.

The typical LPG rail tank car only has openings on the top and none on the bottom. 

Unloading racks or stations have a ladder and platform that provide access to a 

manway on the railroad tank car. There are valves, including the emergency shut-off 

valve housed in the dome on the top of the rail tank car. Also included in the dome 

area are liquid and vapor hose connections which connect to the plant piping system 

to allow the transfer of LPG from the rail tank car to different locations of the plant. 

Multiple tank cars may be loaded or unloaded without moving the cars.

LPG Transfer 

In the absence of a vapor compressor, a railroad tank car will always have a small 

amount of residual liquid remaining even when a pump is used to transfer the product 

(LPG). Because of the limitations associated with the use of pumps in this 

application, vapor compressors are more suited for unloading LPG from rail tank 

cars. 

A compressor shown below in Figure A-2 with a 4-way valve system is used to 

facilitate the transfer of LPG from the rail tank car to the bulk plant storage. In order 

to move liquid LPG product from the railcar to the storage tank, the compressor 

draws vapor from the vapor portion of the storage tank into the compressor where it is 

compressed slightly. The slightly compressed vapors enter the top of the rail tank 

car, thereby increasing the tank car pressure and reducing the storage tank pressure. 

This difference in pressure will then cause the liquid to move through the liquid line 

from the railcar to the storage tank. 

Vapor Recovery 

Once all the liquid has been removed from the tank car, the compressor 4-way valve 

system setting is rotated 90 degrees to allow the vapor flow to change direction, 

thereby pulling vapors from the top of the tank car and discharging them into the 

storage tank’s liquid section to prevent excessive pressure build up (in the storage 

tank) as shown below in Figure A-3. The liquid line valve is placed in the closed 

position. Once these adjustments are made the compressor can withdraw vapor from 
Final Staff Report

Appendix A - LPG Industry Summary A - 11 June 2012 

the top of the railcar, compress them slightly and discharge them into the liquid 

section of the storage tank. The storage tank liquid will condense these vapors back 

to liquid. The key to this process is to facilitate the movement of the vapors and 

condense them, but to do so in such a way that the changes in pressure in the two 

vessels are gradual. 

Transport/Tanker Truck 

Transport trucks or tanker trucks have a water capacity of approximately 10,000 

gallons. When a transport truck is being unloaded its liquid line is connected to that 

of the storage tank liquid line. Similarly, vapor lines from the transport truck and the 

storage tank are connected, thereby forming a closed loop vapor return/equalization 

system that promotes the transfer of LPG.

Transport trucks are also equipped with either a pump or a compressor that is used 

during the offloading process. Using a compressor is more effective in facilitating a 

more complete transfer of liquid LPG from the transport truck and the transfer lines, 

while when a pump is used the hose of the liquid line may still have residual liquid.

Bobtail Truck 

A bobtail truck has a water capacity in the range of 2,500 – 3,000 gallons and is used 

to transport LPG to residential, commercial and retail sales facilities. These facilities 

will usually store relatively smaller amounts (less than 10,000 gallons) of LPG. On a 

typical delivery route a bobtail truck can make multiple deliveries since most 

residential tanks are commonly 150 – 300 gallons, and a commercial tank, which can 

be as large as 1,000 gallons are typically also smaller than a bobtail.

Unlike a transport truck, a bobtail truck does not have a vapor return/equalization 

line. However, a bobtail truck has a hose which is extended to the customer’s storage 

tank, in addition to a pump which helps to transfer LPG. Upon completion of the 

transfer process, the hose is rolled back onto a spool and the driver makes the 

necessary preparation for another delivery.

 

2

 Courtesy of Blackmer®, a Dover Company.

Figure A-2. Liquid LPG Transfer2 Figure A-3. LPG Vapor Recovery2
Final Staff Report

Appendix A - LPG Industry Summary A - 12 June 2012 

Also unlike a transport truck, when a bobtail truck is filled it utilizes a fixed liquid 

level gauge (FLLG) which may be opened to varying degrees either intermittently or 

continuously, depending on operator practice. Opening of the FLLG ensures that the 

product (LPG) in the tank remains at a safe level during filling and overfilling is 

prevented. The bobtail truck’s cargo tank usually has a separate gauge that indicates 

the LPG volume, and an operator will usually determine that a tank is filled when 

liquid level is somewhere in the range of 80 to 87 percent capacity depending on 

season, temperature or the period of time that the LPG is allowed to remain in the 

cargo tank before delivery.

Liquefied Petroleum Gas (LPG) Storage Vessels 

Propane cylinders are the most common type of LPG storage vessels. All cylinders 

used for LPG services are manufactured according to the Department of 

Transportation (DOT) specifications. Twenty (20) pound barbecue cylinders are by 

far the most common cylinders followed by forklift cylinders which are used 

predominantly at industrial facilities. In addition to cylinders, LPG storage 

containers also include storage tanks that are used at residential and commercial 

facilities.

Barbecue Cylinders 

The 20-pound cylinders are typically used in gas grills, but are also used to fuel the 

type of space heaters that can be found at outdoor restaurants. These cylinders have a 

water capacity of 4.7 gallons and can be refilled at a local retailer or exchanged at a 

cylinder exchange station. Cylinders are usually filled at a bulk plant and then 

delivered to the exchange site. According to the Western Propane Gas Association 

(WPGA), over the last few years there has been a shift from refilling these tanks at a 

retail station to replacing an empty cylinder by going through an exchange program.

Forklift Cylinders 

Thirty-three pound LPG cylinders are usually used to power most of the forklifts used 

at industrial sites, however, larger forklifts use 40 pounds LPG cylinders. These 

cylinders can be used either indoors or outdoors. LPG for forklift usage is usually in 

liquid form and cylinders are mounted horizontally on the back of the forklift. The 

tank gauge for this application may be designed to accurately indicate LPG levels 

when the tank is in either a horizontal or a vertical position.

LPG forklift cylinder delivery service is offered by many companies, but some 

companies also fill their forklift tanks onsite. Cylinders that are filled offsite and are 

transported are required to be filled by weight according to DOT regulations.

Forklift cylinders can be filled by three (3) different methods, which are by weight, 

by volume or by gravity. 
Final Staff Report

Appendix A - LPG Industry Summary A - 13 June 2012 

Fill by Weight

The fill by weight method employs the use of a pump to facilitate the transfer of LPG 

with the FLLG closed during the transfer. The completion of the filling process is 

determined by a weight setting using a scale. 

Fill by Volume (or Pressure Fill)

The fill by volume method is the most common approach used across all segments of 

the LPG transfer industry. Like the fill by weight method, a pump is used to move 

the product (LPG), but in this case the operator will open the FLLG of the tank or 

cylinder receiving LPG to allow for vapor expansion during the process. 

Fill by Gravity

The gravity fill method is an additional approach currently used for forklift cylinder 

filling. Use of this method is seen in some companies that have a very small forklift 

operation. LPG delivered by a supplier to the small operation is stored in a tank that 

can range from 50 to 400 gallons with an average (delivery) frequency that can range 

from once every two weeks to once every four weeks. The company will then use 

this supply to fill their forklift tanks. Unlike the fill by weight and fill by volume 

methods, there is no pump used to move the LPG and the transfer is facilitated by the 

pressure difference between the two containers. It should be noted that in this case 

the FLLG is left open during the entire transfer process. 

Residential and Commercial Storage Tanks 

Residential storage tanks can range from 150 – 500 gallons and commercial tanks 

from 250 – 1,100 gallons. These tanks are filled by bobtail trucks and may be filled 

up to levels ranging from 80 – 87 percent of total capacity depending on the ambient 

temperature. Some tanks have more than one (1) FLLG to facilitate the different fill 

levels. During the summer months operators are more likely to fill these tanks to the 

80 percent level to allow for expansion at higher temperatures. 

Liquefied Petroleum Gas (LPG) Fuel Dispensing/Delivery 

Figure A-4 below represents a simplified version of an LPG dispensing system. 

There are four (4) essential functional components which make up the system and 

they are: 1) a storage tank; 2) a pump; 3) a metering unit and 4) the piping (including 

valves and other control elements) that connects these components and leads from the 

metering unit to the dispensing nozzle or connector. 

The design of the system must also reflect its use in a specific delivery application. 

In situations where transfers are made from bulk loading facility storage tanks to 

transport trucks, transfers are typically completed at rates of 100 gallons per minute 

(gpm) or higher. When these transport trucks make deliveries to retail facilities, 
Final Staff Report

Appendix A - LPG Industry Summary A - 14 June 2012 

transfer rates are approximately 50 to 60 gpm. Residential deliveries are made at 

transfer rates which are even lower and typically at about 30 gpm.3

The system is closed and must not allow the leak of either liquid or vapor. In 

addition, the system is usually designed to withstand high pressures and 

specifications regarding operating pressures that the system must be capable of 

withstanding have been developed by the American Society of Mechanical Engineers 

(ASME) Pressure Vessel Code, Section 8 and have been adopted by the State Fire 

and Safety Codes. The system must be capable of minimizing the production of 

vapor within the system, eliminate small amounts of vapor that are produced and 

must also be equipped with pressure relief valves, which are designed to permit a 

controlled venting of the product to the atmosphere when internal pressures exceed 

safe limits. 

Figure A-4. Basic Components of an LPG Delivery System 

Storage Tank and Pump 

As shown in the Figure A-4 above an LPG storage tank is designed with a liquid fill 

inlet for supplying product and a discharge line with an outlet for delivery. A storage 

tank also has a vapor port that accommodates the insertion of a pressure equalization 

line to increase delivery efficiency under certain circumstances. The vapor port also 

allows for volumetric testing or system calibration. 

The pump provides pressure to move product from the storage tank to the receiving 

tank and its design and operating characteristics are based on its application. Also, 

the discharge rate and pressure of the dispensing system have to be appropriate for 

the system to which it delivers product. 

 

3

 CARB “Determination of Usage Patterns and Emissions for Propane/LPG in California,” May 1992. 
Final Staff Report

Appendix A - LPG Industry Summary A - 15 June 2012 

Metering Unit 

Liquid LPG is measured as it passes through the metering unit. There is also an 

indicating unit which is designed to register the quantity of liquid as it passes through 

the meter. Measuring and registration occur simultaneously, thereby allowing the 

system operator and customer to monitor the amount of liquid that is being delivered 

continuously throughout the delivery. 

Vapor Eliminator and Differential Pressure Valve 

As shown in Figure A-3, above, the metering unit includes the vapor eliminator and 

the differential pressure valve. The function of these devices is to prevent vapor from 

entering the meter and being measured along with liquid product. The vapor 

eliminator separates any vapor that is produced from the liquid flow before it reaches 

the meter and returns it to the vapor space of the storage tank. The differential 

pressure valve maintains the product in its liquid state as it passes through the meter 

by restricting flow on the discharge side of the meter and thus maintaining a uniform 

pressure in the piping and metering element upstream that is at or above the product 

vapor pressure. 

As liquid is drawn from the storage tank the liquid pressure drops causing some of the 

liquid product to boil since its boiling point is -44 degrees Fahrenheit and increasing 

vapor in the tank vapor space. This is typical of any liquid LPG delivery system. 

Receiving Vessels 

Both the receiving vessel and the delivery system contain a combination of vapor and 

liquid at all times. As the liquid is pumped into the receiving tank and the level rises 

the vapor becomes compressed thereby causing the pressure and temperature in the 

receiving vessel to rise. When equilibrium is eventually established and vapor 

condenses and returns to the liquid phase. 

Previously, older vapor return systems were designed to alleviate the pressure buildup problem by connecting a vapor line between the vapor spaces of the two tanks. 

This would allow for equilibrium in both the delivery and the receiving tanks. 

However, this is not beneficial to the purchaser because product that was being 

purchased was being returned to the seller in the form of vapor. 
Final Staff Report

Appendix A - LPG Industry Summary A - 16 June 2012 

 Delivery of Product Spray Fill Method 

Figure A-4. Delivery of Product and Spray Fill Method 

Spray Fill 

Delivery systems now consist of a pipe from the receiving tank that is extended into 

the vapor space and is designed in such as way that the incoming liquid product is 

sprayed upward toward the top of the tank as shown in Figure A-4. As cooler liquid 

droplets descend they condense the vapor, thereby lowering the pressure in the 

receiving tank and allowing the system to pump to deliver liquid product more 

efficiently. 

LPG Motor Fuel Dispensing 

The construction of an LPG filling station appears to be quite similar to a gasoline 

filling station. LPG filling stations/dispensers offer services depending on customer 

demand. A dispenser can be a simple unit consisting of basic elements of pumping 

and metering or a state-of-the-art data collection and processing module equivalent to 

that used at gasoline dispensing stations. A typical fill rate of a motor vehicle using 

LPG is about 10 gallons per minute. 
Appendix B – Emissions Inventory Calculations B - 1 June 2012 

APPENDIX B. EMISSION INVENTORY CALCULATIONS 
Final Staff Report 

Appendix B – Emissions Inventory Calculations B - 2 June 2012 

METHODOLOGY 

VOC fugitive emissions from LPG transfer and dispensing operations result from three main 

areas: 

1. Line Disconnects. VOC emissions result from volatilization of entrapped product 

from the housing of various hoses, dispensing nozzles and interconnections during 

disconnection, and are based on estimated entrapment volumes and the LPG liquid or 

vapor state physical properties during disconnection, as well as an estimated number 

of disconnections based on an industry sponsored study of the LPG transfer and 

dispensing profile1

. 

2. FLLG Venting. VOC emissions result from venting of LPG through FLLGs used as 

a safety device to ensure that pressurized receiving containers, cylinders and tanks are 

not overfilled. These emissions are based on source test emission rate data2

 and an 

estimation of venting time associated with the filling of cylinders and tanks. 

3. Leaks. VOC emissions can result from leaks in the equipment used for transfer and 

dispensing. Because PR 1177 addresses only minimum due diligence associated with 

leaks, emissions and reductions have not been estimated. 

The methodology used to estimate emissions and reductions associated with PR 1177 are 

based on the industry sponsored study, with some adjustments to assumptions as noted 

individually and as summarized in a subsequent section in this appendix labeled 

“Assumption Differences”. 

ASSUMPTIONS 

The following assumptions are used to assist in the estimation of fugitive VOC emissions 

from LPG transfer and dispensing: 

1. The overall level of LPG transfer and dispensing activity by industry sector, as 

evaluated by industry, is accurate and representative, including the estimated 

proportion of activity within the District. The industry study correlation between 

sales reported through the American Petroleum Institute (API) and LPG transfer and 

dispensing activity is appropriate and representative. 

2. The industry study estimated FLLG emission vent rate from conventional (number 54 

orifice size) valves is accurate and representative. 

3. The industry study estimated emission reduction from vented VOC emissions of 

roughly 70% from the use of low emission FLLG (number 72 orifice size or 

equivalent) is accurate and representative of the maximum reduction achievable. 

4. The emission reduction percentage of 50% from replacing a number 54 to a number 

72 orifice size in the FLLG as evaluated by District Source Test2

 is accurate and 

representative and demonstrates an improvement over the industry study3

 because the 
Final Staff Report

Appendix B – Emissions Inventory Calculations B - 3 June 2012 

sampling involves losses from the entire container rather than focusing on releases 

from only the orifice. 

5. The FLLG venting cycle is concurrent with the filling cycle for stationary tanks and 

portable cylinders and the FLLG vent is used during 100% of the transfer time when 

filling by volume. This represents an adjustment from the industry-sponsored study 

which relied on an assumption that the FLLG vent cycle is independent of the transfer 

time and equal to one minute per transfer. 

6. The District Source Test (2011) estimates for FLLG LPG vapor release rates of 2.01 

g/s (#54 size orifice) and 0.98 g/s (#72 size orifice) and LPG liquid release rate of 

11.3 g/s (#54 size orifice) and 4.6 g/s (#72 size orifice) is accurate and representative 

of pump fill operations. The District results, based on a quarter to half turn opening 

of the FLLG, 74.9 degree Fahrenheit tank temperature, 49% tank fill level, show a 

standard deviation of 10% – 20%, is representative of typical transfer and dispensing 

activities that utilize the FLLG. The District Source Test (2008) estimates for gravity 

fill operations of 2.26 g/s (#54 size orifice) and LPG liquid release rate of 8.94 g/s 

(#54 size orifice) is accurate and representative. 

7. Liquid phase LPG released through the FLLG occurs only during the final moments 

of a transfer or dispensing activity, and is roughly one second for stationary tanks and 

portable cylinders and two seconds for cargo tanks. 

8. The filling cycle for stationary tanks and portable cylinders varies by pumping rate 

and receiving vessel size. The estimated typical filling cycles for typical receiving 

vessels based on staff literature review and communications with industry are 

representative and accurate. 
Final Staff Report

Appendix B – Emissions Inventory Calculations B - 4 June 2012 

9. The 2009 sales distribution data by sector as provided by industry for CA and the 

associated District-wide sales distribution data, estimated based on a roughly 45.5% 

share as indicated by population is accurate and representative. The relative 

proportion of District-wide LPG sales for use in internal combustion (i.c.) engines is 

represented by ARB EMFAC and off-road vehicle inventories, as obtained by 

industry and is approximately 55.5% of the state-wide total. The following table 

summarizes the District-wide distribution of LPG sales: 

Market Sector 

CA Volume 

Share 

(%) 

CA 

Volume 

(mmgal/year) 

District 

Volume 

(mmgal/year) 

Residential 275.26 125.32 

Heating 97.74% 269.04 122.01 

RVs 2.26% 6.22 2.83 

Commercial 86.64 39.45 

Sales to Retail 51.94 23.65 

Exchange 50.00% 25.97 11.82 

On-site Refill 50.00% 25.97 11.82 

IC Engines 67.08 30.54 

Forklifts 77.20% 51.78 28.76* 

Highway Vehicles 22.80% 15.30 1.78 

Industrial 27.81 12.66 

Chemical 135.58 61.73 

Agricultural 50.47 22.98 

Total 694.66 316.07 

* - Fill by gravity represents approximately 30% of the volume, or 8.63 mmgal per year, per 

WPGA working group membership. 
Final Staff Report

Appendix B – Emissions Inventory Calculations B - 5 June 2012 

10. The industry provided breakdown of sector related sales and transfer/dispensing 

breakdown is accurate and representative. The following table summarizes the 

industry estimated percentages: 

Source Destination Method Operation Share (%) 

LPG Production/ 

Storage* 

Terminal 

Rail Offload 30.0% 

Transport (1 tank, comp) Offload 31.5% 

Transport (tank & trailer, comp) Offload 31.5% 

Transport (1 tank, pump) Offload 3.5% 

Transport (tank & trailer, pump) Offload 3.5% 

Chemical 

Rail Offload 90.0% 

Transport (1 tank, comp) Offload 4.5% 

Transport (tank & trailer, comp) Offload 4.5% 

Transport (1 tank, pump) Offload 0.5% 

Transport (tank & trailer, pump) Offload 0.5% 

Terminal* Retail Bulk Plant 

Transport (1 tank, comp) Fill 45% 

Transport (tank & trailer, comp) Fill 45% 

Transport (1 tank, pump) Fill 5% 

Transport (tank & trailer, pump) Fill 5% 

Retail Bulk Plant 

Residential, Heating Bobtail Fill 97.7% 

Residential, RV RV Cylinders Fill 2.3% 

Commercial Bobtail Fill 100% 

Sales to Retail, 

Exchange 

Transport (1 tank, comp) Fill 45% 

Transport (tank & trailer, comp) Fill 45% 

Transport (1 tank, pump) Fill 5% 

Transport (tank & trailer, pump) Fill 5% 

20# Cylinder Fill 100% 

Sales to Retail, Onsite Fill Bobtail Fill 100% 

IC Engines, Forklifts Forklift Cylinder (40 lb.) Fill 77.20% 

IC Engines, Highway 

Vehicles Highway Vehicle Fill 22.80% 

Industrial 

Transport (1 tank, comp) Fill 45% 

Transport (tank & trailer, comp) Fill 45% 

Transport (1 tank, pump) Fill 5% 

Transport (tank & trailer, pump) Fill 5% 

Agricultural 

Bobtail Fill 90.00% 

Transport (1 tank, comp) Fill 4.50% 

Transport (tank & trailer, comp) Fill 4.50% 

Transport (1 tank, pump) Fill 0.50% 

Transport (tank & trailer, pump) Fill 0.50% 

* - Includes facilities subject to Rule 1173 and exempt from the proposed rule. 

11. The estimated number of filling events associated with LPG transfer and dispensing 

is based on the average size of the receiving vessel and fill capacity. Because of the 

safety factor generally applied to LPG tanks and cylinders, the average fill capacity of 

80% is used to determine the number of filling events for stationary tanks and 
Final Staff Report

Appendix B – Emissions Inventory Calculations B - 6 June 2012 

cylinders. The estimated number of filling events associated with LPG transfer and 

dispensing to bobtails and smaller tanks is expected to be higher because they may 

contain residual LPG prior to topping off. Based on the CARB study estimate4

, an 

appropriate average fill capacity of 60% is used to determine the number of filling 

events for bobtails, small storage tanks and vehicles. The following table summarizes 

the filling times for various representative cargo tanks and stationary tanks based on 

the CARB parameters and industry estimates: 

Transfer Type Fill Time 

(sec) 

Tank 

Volume 

(gal) 

Fill 

Capacity 

Tank Fill 

Volume 

(gal) 

Fill Rate 

(gpm) 

Bobtail 1,350 3,000 0.6 1,800 80.0 

Commercial Tank 240 400 0.6 240 60.0 

Residential Tank 180 300 0.6 180 60.0 

Transport (1 tank, comp) 6,000 10,000 0.8 8,000 80.0 

Transport (1 tank, pump) 6,000 10,000 0.8 8,000 80.0 

Transport (tank & trailer, comp) 6,000 10,000 0.8 8,000 80.0 

Transport (tank & trailer, pump) 6,000 10,000 0.8 8,000 80.0 

20# Cylinder 60 5 0.8 4 Variable 

Forklift Cylinder (40 lb) 60 10 0.8 8 Variable 

Forklift Cylinder (40 lb) - Gravity Fill 420* 10 0.8 8 Variable 

* Field observation of gravity fill time of approximately seven minutes with a No. 54 size orifice. Observed gravity fill time with a No. 72 size 

orifice exceeded half an hour, and is projected to result in the use of pump fed or cylinder exchange alternatives. Industry estimates range up 

to ten minutes. 

This represents an adjustment to the industry-sponsored study which relied on an 

assumption that all containers were empty on filling and filled up to 80 percent. 
Final Staff Report

Appendix B – Emissions Inventory Calculations B - 7 June 2012 

12. The following estimated connector entrapment volumes as determined by the industry 

sponsored study is representative and accurate: 

Transfer Type Operation Equipment Estimated Volume 

(L) 

20# Cylinder 

Disconnect Vapor Line 0.0200 

Fill Liquid Line HiEff 0.0400 

Fill Liquid Line 0.1070 

Bobtail 

Fill Vapor Line 0.6510 

Fill Liquid Line 0.6826 

Offload Liquid Line 0.0200 

Commercial Tank 

Fill Liquid Line 0.0260 

Offload Liquid Line 0.0200 

Forklift Cylinder (40 lb) 

Disconnect Vapor Line 0.0200 

Fill Liquid Line 0.0260 

Highway Vehicle Fill Liquid Line 0.0200 

Residential Tank Fill Liquid Line 0.0260 

Transport (tank & trailer, pump) Offload “Jump Line” (Liquid) 6.4715 

Offload Liquid Line 7.3006 

"Jump Line" is the interconnecting line between the tank and the trailer cargo tanks. 

“HiEff” is a high efficiency connection. 
Final Staff Report

Appendix B – Emissions Inventory Calculations B - 8 June 2012 

ASSUMPTION DIFFERENCES 

The following is a summary of the District’s adjustments to the industry sponsored study 

methodology, and are based on follow-up staff discussions as well as literature and field 

review: 

Parameter Industry Study Methodology 

Parameter 

District Methodology 

Parameter 

1. FLLG Emission 

Rates 

#54 Orifice (Pump Fill): 

 0.8 g/s Vapor 

 9.3 g/s Liquid 

SCAQMD Source Test Results 

#54 Orifice: 

Pump-Fill Gravity-Fill

 2.01 g/s Vapor • 2.26 g/s Vapor 

 11.3 g/s Liquid • 8.94 g/s Liquid 

#72 Orifice (Pump Fill): 

 0.98 g/s Vapor 

 4.6 g/s Liquid 

2. FLLG Emission 

Reduction 

70% Overall 50% Overall for Pump Fill 

>50% For Gravity Fill Switching to Pump 

Fill or Exchange 

3. FLLG Vent Time All vent times are 60 seconds, independent 

of fill time. 

Vent time is based on fill time. 

4. Tank fill events  Fill events are based on the total sales 

volume for the sector and targeted 

receiving vessel. 

 The number of events is equal to the total 

sales volume divided by the fill volume. 

 Fill volume is 80% of the tank size 

 Fill events are based on the total sales 

volume for the sector and targeted 

receiving vessel. 

 The number of events is equal to the total 

sales volume divided by the fill volume. 

 Fill volume is 80% of the tank size for 

cylinders and large cargo tanks; 60% for 

smaller tanks and bobtails. 

EMISSION CALCULATIONS 

The annual mass amount of LPG emissions associated with use of FLLGs and the 

disconnections of transfer and dispensing connectors is based on the following calculation: 

 

i i

Emissions EmissionsFLLG EmissionsDisconnects (1) 

Where: 

i = Industry Sector 

FLLG = Fixed Liquid Level Gauge 

Reductions associated with the proposed rule are based on a 50% reduction from FLLG 

related emissions and the difference between the existing connector entrapment volumes and 

the LPG low emission connector design value of four cubic centimeters per disconnect, as 

follows: 
Final Staff Report

Appendix B – Emissions Inventory Calculations B - 9 June 2012 

    

i i i

Reductions EmissionsFLLG % EmissionsDisconnects EmissionsLEDisconnects 50% /100 (2) 

Where: 

LE = Low Emission 

Emissions Calculation Breakdown 

FLLG Emissions 

FLLG venting releases LPG emissions in both vapor and liquid form: 

  

i i i

EmissionsFLLG EmissionsFLLG,Vapor EmissionsFLLG,Liquid (3) 

Using the estimated LPG vapor and liquid release rates of 2.01 g/s and 11.3 g/s respectively, 

as well as the estimated one to two second liquid release per event estimate: 

       

i j

i i j

i i ,

, Emissions 2.01(g/s) (Vent Time) 11.3 (g/s) 2 (No. Vent Events) FLLG (4) 

 

i k

i k

,

, 11.3 (g/s) (No. VentEvents)

Where: 

j = Cargo Tank Type j

k = Individual Stationary or Portable Tank Type k

Converting grams per second to pounds per minute yields the following: 

      

i j

i i j

i i ,

, Emissions 0.266 (lb/min) (Vent Time) 2.99 (lb/min) (No. VentEvents) FLLG (5) 

 

i k

i k

,

, 1.49 (lb/min) (No. Vent Events)

Disconnect Emissions 

Emissions associated with the disconnection of transfer and dispensing equipment and the 

release of the entrapped LPG is dependent upon the size of the entrapment space, which 

varies between different transfer and dispensing options. The annual emissions is 

proportional to the number of disconnect events, and the mass emissions is dependent on 

whether the disconnection occurred while LPG was in the vapor or liquid phase, and the 

associated density at the event temperature and pressure, as follows: 

l l

i l

l

i

Emissions (ConnectorEntrappedVol.) (No.DisconnectEvents)  Disconnects    

,

 (6) 

Where: 

l = Connector Type l (LPG State, Vessels Connected)

ρ = Density (Vapor or Liquid) 

Emission Reduction Calculation Breakdown 

FLLG Emission Reductions 
Final Staff Report

Appendix B – Emissions Inventory Calculations B - 10 June 2012 

As indicated in (2), the reductions from FLLG related emissions are estimated to be 50%: 

   50% /100%

i

ReductionsFLLG EmissionsFLLG (7) 

Disconnect Emission Reductions 

As indicated in (2), the reductions from disconnects is based on the difference between 

existing connector configurations and the LPG low emission connector assemblies: 

 

i i

ReductionsDisconnect EmissionsDisconnect EmissionsLEDisconnect (8) 

Incorporating the emission estimation calculation of (6) into (8) results in the following: 

l l

i l

l

i

ReductionsDisconnect [(Connector EntrappedVol.)  4 mL]  (No.DisconnectEvents)

,

 (9) 

EMISSION CALCULATION SUMMARIES 

Below is an overall summary of the estimated emissions and reductions using the 

methodology outlined in this appendix: 

Sector 

WPGA Criteria District Criteria 

Emissions 

(tons/day) 

Reductions 

(tons/day) 

Emissions 

(tons/day) 

Reductions 

(tons/day) 

Residential 0.17 0.10 1.47 0.79 

Commercial 0.05 0.03 0.47 0.25 

Sales to Retail 1.18 0.38 2.03 1.31 

IC Engines 0.63 0.55 4.35 3.62 

Industrial, Chemical, 

Agricultural 0.02 0.02 0.18 0.10 

Distribution Facilities 0.05 0.04 0.07 0.07 

Total: 2.1 1.1 8.6 6.1 

The following pages summarize the emission calculations and reduction estimates for 

California using the methodology outlined in this appendix. 

 

1

 Life Cycle Associates, LLC (2011), “Inventory of Fugitive Emissions from LPG Transfers in California, prepared for 

WPGA,,” June 2011 (CONFIDENTIAL). 2

 SCAQMD (2011), “Propane Tank Filling Emissions Reduction Efficiency from Low Emissions #72-Drill Size Self-Cleaning 

Fixed Maximum Liquid Level Gauges (FMLLGs),” 2011. 3

 Battelle (2009) “Research Investigation on Testing and Evaluation of New Low Emission Fixed Maximum Liquid Level 

Gauges for Use in LP-Gas Containers, prepared for PERC,” September 2009. 4

 CARB (1992) “Determination of Usage Patterns and Emissions for Propane/LPG in California,” May 1992. 
Final Staff Report 

Appendix B – Emissions Inventory Calculations B - 11 

Summary of California LPG Transfer and Dispensing VOC Emissions and Reduction Estima

Activity Fugitive Emissio

Source Destination Method Operation Share (%) Volume (gal x1000) Volume Per (gal x1000) Number Type Mass Per (g) Mas

LPG Production/Storage Terminal Rail Offload 30.0% 150,953 24 6,290 Tower Liquid Line 279 LPG Production/Storage Terminal Rail Offload Tower Vapor Line 274 LPG Production/Storage Terminal Transport (1 tank, comp) Offload 31.5% 158,500 8 19,813 Liquid Line 337 LPG Production/Storage Terminal Transport (1 tank, comp) Offload Vapor Line 10 

LPG Production/Storage Terminal Transport (tank & trailer, comp) Offload 31.5% 158,500 8 19,813 Liquid Line 337 LPG Production/Storage Terminal Transport (tank & trailer, comp) Offload Vapor Line 10 

LPG Production/Storage Terminal Transport (tank & trailer, comp) Offload Jump Line 99 

LPG Production/Storage Terminal Transport (1 tank, pump) Offload 3.5% 17,611 8 2,201 Liquid Line 3,599 LPG Production/Storage Terminal Transport (1 tank, pump) Offload Vapor Line 10 

LPG Production/Storage Terminal Transport (tank & trailer, pump) Offload 3.5% 17,611 8 2,201 Liquid Line 3,599 LPG Production/Storage Terminal Transport (tank & trailer, pump) Offload Vapor Line 10 

LPG Production/Storage Terminal Transport (tank & trailer, pump) Offload Jump Line 99 

LPG Production/Storage Chemical Rail Offload 90.0% 122,018 24 5,084 Tower Liquid Line 279 LPG Production/Storage Chemical Rail Offload Tower Vapor Line 274 LPG Production/Storage Chemical Transport (1 tank, comp) Offload 4.5% 6,101 8 763 Liquid Line 337 LPG Production/Storage Chemical Transport (1 tank, comp) Offload Vapor Line 10 

LPG Production/Storage Chemical Transport (tank & trailer, comp) Offload 4.5% 6,101 8 763 Liquid Line 337 LPG Production/Storage Chemical Transport (tank & trailer, comp) Offload Vapor Line 10 

LPG Production/Storage Chemical Transport (tank & trailer, comp) Offload Jump Line 99 

LPG Production/Storage Chemical Transport (1 tank, pump) Offload 0.5% 678 8 85 Liquid Line 3,599 LPG Production/Storage Chemical Transport (1 tank, pump) Offload Vapor Line 10 

LPG Production/Storage Chemical Transport (tank & trailer, pump) Offload 0.5% 678 8 85 Liquid Line 3,599 LPG Production/Storage Chemical Transport (tank & trailer, pump) Offload Vapor Line 10 

LPG Production/Storage Chemical Transport (tank & trailer, pump) Offload Jump Line 99 

Terminal Retail Bulk Plant Transport (1 tank, comp) Fill 45% 251,588 8 31,448 Liquid Line 337 Terminal Retail Bulk Plant Transport (1 tank, comp) Fill Vapor Line 10 Terminal Retail Bulk Plant Transport (1 tank, comp) Fill FLLG Vapor 12,060 Terminal Retail Bulk Plant Transport (1 tank, comp) Fill FLLG Liquid 23 Terminal Retail Bulk Plant Transport (1 tank, comp) Offload Liquid Line 337 Terminal Retail Bulk Plant Transport (1 tank, comp) Offload Vapor Line 10 Terminal Retail Bulk Plant Transport (tank & trailer, comp) Fill 45% 251,588 8 31,448 Liquid Line 337 Terminal Retail Bulk Plant Transport (tank & trailer, comp) Fill Vapor Line 10 Terminal Retail Bulk Plant Transport (tank & trailer, comp) Fill FLLG Vapor 12,060 Terminal Retail Bulk Plant Transport (tank & trailer, comp) Fill FLLG Liquid 23 Terminal Retail Bulk Plant Transport (tank & trailer, comp) Offload Liquid Line 337 

Terminal Retail Bulk Plant Transport (tank & trailer, comp) Offload Vapor Line 10 

Terminal Retail Bulk Plant Transport (tank & trailer, comp) Offload Jump Line 99 

Terminal Retail Bulk Plant Transport (1 tank, pump) Fill 5% 27,954 8 3,494 Liquid Line 337 Terminal Retail Bulk Plant Transport (1 tank, pump) Fill Vapor Line 10 Terminal Retail Bulk Plant Transport (1 tank, pump) Fill FLLG Vapor 12,060 Terminal Retail Bulk Plant Transport (1 tank, pump) Fill FLLG Liquid 23 Terminal Retail Bulk Plant Transport (1 tank, pump) Offload Liquid Line 3,599 Terminal Retail Bulk Plant Transport (1 tank, pump) Offload Vapor Line 10 

Terminal Retail Bulk Plant Transport (tank & trailer, pump) Fill 5% 27,954 8 3,494 Liquid Line 337 Terminal Retail Bulk Plant Transport (tank & trailer, pump) Fill Vapor Line 10 

Terminal Retail Bulk Plant Transport (tank & trailer, pump) Fill FLLG Vapor 12,060 

Terminal Retail Bulk Plant Transport (tank & trailer, pump) Fill FLLG Liquid 23 

Terminal Retail Bulk Plant Transport (tank & trailer, pump) Offload Liquid Line 3,599 

Terminal Retail Bulk Plant Transport (tank & trailer, pump) Offload Vapor Line 10 

Terminal Retail Bulk Plant Transport (tank & trailer, pump) Offload Jump Line 99 

Retail Bulk Plant Residential, Heating Bobtail Fill 97.7% 269,041 1.8 149,467 Liquid Line 337 Retail Bulk Plant Residential, Heating Bobtail Fill Vapor Line 10 Retail Bulk Plant Residential, Heating Bobtail Fill FLLG Vapor 2,714 Retail Bulk Plant Residential, Heating Bobtail Fill FLLG Liquid 23 Retail Bulk Plant Residential, Heating Bobtail Offload 269,041 0.18 1,494,671 Liquid Line 10 Retail Bulk Plant Residential, Heating Residential Tank Fill Liquid Line 13 Retail Bulk Plant Residential, Heating Residential Tank Fill FLLG Vapor 362 Retail Bulk Plant Residential, Heating Residential Tank Fill FLLG Liquid 11 Retail Bulk Plant Residential, RV RV Cylinders Fill 2.3% 6,215 0.048 129,483 Liquid Line 13 Retail Bulk Plant Residential, RV RV Cylinders Fill FLLG Vapor 121 Retail Bulk Plant Residential, RV RV Cylinders Fill FLLG Liquid 11 Retail Bulk Plant Residential, RV RV Cylinders Disconnect Vapor Line 0 Retail Bulk Plant Commercial Bobtail Fill 100% 86,639 1.8 48,133 Liquid Line 337 Retail Bulk Plant Commercial Bobtail Fill Vapor Line 10 Retail Bulk Plant Commercial Bobtail Fill FLLG Vapor 2,714 Retail Bulk Plant Commercial Bobtail Fill FLLG Liquid 23 Retail Bulk Plant Commercial Bobtail Offload 86,639 0.18 481,328 Liquid Line 10 Retail Bulk Plant Commercial Commercial Tank Fill Liquid Line 13 Retail Bulk Plant Commercial Commercial Tank Fill FLLG Vapor 362 Retail Bulk Plant Commercial Commercial Tank Fill FLLG Liquid 11 Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, comp) Fill 45% 11,687 8 1,461 Liquid Line 337 Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, comp) Fill Vapor Line 10 Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, comp) Fill FLLG Vapor 12,060 Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, comp) Fill FLLG Liquid 23 Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, comp) Offload Liquid Line 337 

Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, comp) Offload Vapor Line 10 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, comp) Fill 45% 11,687 8 1,461 Liquid Line 337 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, comp) Fill Vapor Line 10 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, comp) Fill FLLG Vapor 12,060 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, comp) Fill FLLG Liquid 23 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, comp) Offload Liquid Line 337 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, comp) Offload Vapor Line 10 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, comp) Offload Jump Line 99 

Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, pump) Fill 5% 1,299 8 162 Liquid Line 337 Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, pump) Fill Vapor Line 10 Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, pump) Fill FLLG Vapor 12,060 Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, pump) Fill FLLG Liquid 23 
Final Staff Report

Appendix B – Emissions Inventory Calculations B - 12 

Activity Fugitive Emissio

Source Destination Method Operation Share (%) Volume (gal x1000) Volume Per (gal x1000) Number Type Mass Per (g) Mas

Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, pump) Offload Liquid Line 3,599 Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, pump) Offload Vapor Line 10 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, pump) Fill 5% 1,299 8 162 Liquid Line 337 Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, pump) Fill Vapor Line 10 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, pump) Fill FLLG Vapor 12,060 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, pump) Fill FLLG Liquid 23 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, pump) Offload Liquid Line 3,599 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, pump) Offload Vapor Line 10 

Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, pump) Offload Jump Line 99 

Retail Bulk Plant Sales to Retail, Exchange 20# Cylinder Fill 100% 25,971 0.004 6,492,625 Liquid Line HiEff 20 Retail Bulk Plant Sales to Retail, Exchange 20# Cylinder Disconnect Vapor Line 0 Retail Bulk Plant Sales to Retail, On-site Fill Bobtail Fill 100% 25,971 1.8 14,428 Liquid Line 337 Retail Bulk Plant Sales to Retail, On-site Fill Bobtail Fill Vapor Line 10 Retail Bulk Plant Sales to Retail, On-site Fill Bobtail Fill FLLG Vapor 2,714 Retail Bulk Plant Sales to Retail, On-site Fill Bobtail Fill FLLG Liquid 23 Retail Bulk Plant Sales to Retail, On-site Fill Bobtail Offload 25,971 0.18 144,281 Liquid Line 10 Retail Bulk Plant Sales to Retail, On-site Fill Commercial Tank Fill Liquid Line 13 Retail Bulk Plant Sales to Retail, On-site Fill Commercial Tank Fill FLLG Vapor 362 Retail Bulk Plant Sales to Retail, On-site Fill Commercial Tank Fill FLLG Liquid 11 Retail Bulk Plant Sales to Retail, On-site Fill 20# Cylinder Fill 25,971 0.004 6,492,625 Liquid Line 53 Retail Bulk Plant Sales to Retail, On-site Fill 20# Cylinder Fill FLLG Vapor 121 Retail Bulk Plant Sales to Retail, On-site Fill 20# Cylinder Fill FLLG Liquid 11 Retail Bulk Plant Sales to Retail, On-site Fill 20# Cylinder Disconnect Vapor Line 0 Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb)-Gravity Fill 15,535 0.008 1,941,819 Liquid Line 13 Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb)-Gravity Fill FLLG Vapor 972 Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb)-Gravity Fill FLLG Liquid 9 Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb)-Gravity Disconnect Vapor Line 0 

Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb) Fill 77.20% 36,247 0.008 4,530,910 Liquid Line 13 

Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb) Fill FLLG Vapor 121 

Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb) Fill FLLG Liquid 11 

Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb) Disconnect Vapor Line 0 Retail Bulk Plant IC Engines, Highway Vehicles Highway Vehicle Fill 22.80% 15,295 0.018 849,732 Liquid Line 10 

Retail Bulk Plant Industrial Transport (1 tank, comp) Fill 45% 12,513 8 1,564 Liquid Line 337 Retail Bulk Plant Industrial Transport (1 tank, comp) Fill Vapor Line 10 Retail Bulk Plant Industrial Transport (1 tank, comp) Fill FLLG Vapor 12,060 Retail Bulk Plant Industrial Transport (1 tank, comp) Fill FLLG Liquid 23 Retail Bulk Plant Industrial Transport (1 tank, comp) Offload Liquid Line 337 Retail Bulk Plant Industrial Transport (1 tank, comp) Offload Vapor Line 10 Retail Bulk Plant Industrial Transport (tank & trailer, comp) Fill 45% 12,513 8 1,564 Liquid Line 337 Retail Bulk Plant Industrial Transport (tank & trailer, comp) Fill Vapor Line 10 

Retail Bulk Plant Industrial Transport (tank & trailer, comp) Fill FLLG Vapor 12,060 

Retail Bulk Plant Industrial Transport (tank & trailer, comp) Fill FLLG Liquid 23 

Retail Bulk Plant Industrial Transport (tank & trailer, comp) Offload Liquid Line 337 

Retail Bulk Plant Industrial Transport (tank & trailer, comp) Offload Vapor Line 10 

Retail Bulk Plant Industrial Transport (tank & trailer, comp) Offload Jump Line 99 

Retail Bulk Plant Industrial Transport (1 tank, pump) Fill 5% 1,390 8 174 Liquid Line 337 Retail Bulk Plant Industrial Transport (1 tank, pump) Fill Vapor Line 10 Retail Bulk Plant Industrial Transport (1 tank, pump) Fill FLLG Vapor 12,060 Retail Bulk Plant Industrial Transport (1 tank, pump) Fill FLLG Liquid 23 Retail Bulk Plant Industrial Transport (1 tank, pump) Offload Liquid Line 3,599 Retail Bulk Plant Industrial Transport (1 tank, pump) Offload Vapor Line 10 Retail Bulk Plant Industrial Transport (tank & trailer, pump) Fill 5% 1,390 8 174 Liquid Line 337 Retail Bulk Plant Industrial Transport (tank & trailer, pump) Fill Vapor Line 10 

Retail Bulk Plant Industrial Transport (tank & trailer, pump) Fill FLLG Vapor 12,060 

Retail Bulk Plant Industrial Transport (tank & trailer, pump) Fill FLLG Liquid 23 

Retail Bulk Plant Industrial Transport (tank & trailer, pump) Offload Liquid Line 3,599 

Retail Bulk Plant Industrial Transport (tank & trailer, pump) Offload Vapor Line 10 

Retail Bulk Plant Industrial Transport (tank & trailer, pump) Offload Jump Line 99 

Retail Bulk Plant Agricultural Bobtail Fill 90.00% 45,419 1.8 25,233 Liquid Line 337 Retail Bulk Plant Agricultural Bobtail Fill Vapor Line 10 Retail Bulk Plant Agricultural Bobtail Fill FLLG Vapor 2,714 Retail Bulk Plant Agricultural Bobtail Fill FLLG Liquid 23 Retail Bulk Plant Agricultural Bobtail Offload Liquid Line 10 Retail Bulk Plant Agricultural Transport (1 tank, comp) Fill 4.50% 2,271 8 284 Liquid Line 337 Retail Bulk Plant Agricultural Transport (1 tank, comp) Fill Vapor Line 10 Retail Bulk Plant Agricultural Transport (1 tank, comp) Fill FLLG Vapor 12,060 Retail Bulk Plant Agricultural Transport (1 tank, comp) Fill FLLG Liquid 23 Retail Bulk Plant Agricultural Transport (1 tank, comp) Offload Liquid Line 337 Retail Bulk Plant Agricultural Transport (1 tank, comp) Offload Vapor Line 10 Retail Bulk Plant Agricultural Transport (tank & trailer, comp) Fill 4.50% 2,271 8 284 Liquid Line 337 Retail Bulk Plant Agricultural Transport (tank & trailer, comp) Fill Vapor Line 10 Retail Bulk Plant Agricultural Transport (tank & trailer, comp) Fill FLLG Vapor 12,060 Retail Bulk Plant Agricultural Transport (tank & trailer, comp) Fill FLLG Liquid 23 Retail Bulk Plant Agricultural Transport (tank & trailer, comp) Offload Liquid Line 337 

Retail Bulk Plant Agricultural Transport (tank & trailer, comp) Offload Vapor Line 10 

Retail Bulk Plant Agricultural Transport (tank & trailer, comp) Offload Jump Line 99 

Retail Bulk Plant Agricultural Transport (1 tank, pump) Fill 0.50% 252 8 32 Liquid Line 337 Retail Bulk Plant Agricultural Transport (1 tank, pump) Fill Vapor Line 10 

Retail Bulk Plant Agricultural Transport (1 tank, pump) Fill FLLG Vapor 12,060 

Retail Bulk Plant Agricultural Transport (1 tank, pump) Fill FLLG Liquid 23 

Retail Bulk Plant Agricultural Transport (1 tank, pump) Offload Liquid Line 3,599 

Retail Bulk Plant Agricultural Transport (1 tank, pump) Offload Vapor Line 10 

Retail Bulk Plant Agricultural Transport (tank & trailer, pump) Fill 0.50% 252 8 32 Liquid Line 337 

Retail Bulk Plant Agricultural Transport (tank & trailer, pump) Fill Vapor Line 10 

Retail Bulk Plant Agricultural Transport (tank & trailer, pump) Fill FLLG Vapor 12,060 Retail Bulk Plant Agricultural Transport (tank & trailer, pump) Fill FLLG Liquid 23 Retail Bulk Plant Agricultural Transport (tank & trailer, pump) Offload Liquid Line 3,599 

Retail Bulk Plant Agricultural Transport (tank & trailer, pump) Offload Vapor Line 10 

Retail Bulk Plant Agricultural Transport (tank & trailer, pump) Offload Jump Line 99 
APPENDIX C. RECORDKEEPING AND REPORTING 
Final Staff Report

Appendix C – Recordkeeping and Reporting C - 2 June 2012 

RECORDKEEPING AND REPORTING REQUIREMENTS 

Proposed Rule 1177 contains both recordkeeping and reporting requirements. This appendix 

summarizes the requirements and provides sample templates for affected facilities to use. 

Below is an excerpt from Table 1 of the Draft Staff Report that includes a breakdown of the 

recordkeeping and reporting requirements: 

Requirement Bulk Loading 

Facility 

Transfer and Dispensing Facility 

Offers LPG for Sale to End 

User Other 

Recordkeeping

- LE FLLG Installations 

- LPG LE Connector Installations By Jan 1, 2013 

- Leak Repairs Effective Jan 1, 2013 N/A 

- Vapor Recovery or Equalization System 

Maintenance Records By Jan 1, 2013 N/A 

Reporting (Annual)

- LPG Purchase and Dispensing Month-to-Month By Jul 1, 2014, 2015, 2016§ N/A 

- Inventory of LPG Containers and Associated FLLGs 

By Jul 1, 2014, 

2015, 2016, 

2017, 2018 

N/A N/A 

- End of Year Inventory of LPG Low Emission 

Connectors and Associated Equipment By Jul 1, 2014 N/A N/A 

§ LPG transfer and dispensing facilities that offer LPG for sale to an end user may satisfy the reporting requirement by arranging to 

have their LPG suppliers identify and include their facility’s LPG purchases with the supplier’s annual report. The supplier shall 

also notify the facility and the District by March 1 of the reporting year in order to satisfy the reporting requirement. 

SAMPLE TEMPLATES 

The following table summarizes the sample templates contained in this appendix. Facilities 

should use these templates, or an equivalent approved by the Executive Officer, for required 

submittals. Because the required submittals primarily contain information maintained for 

recordkeeping purposes, many of the report templates can also be used for record logs, as 

noted. 

Report 

Requirement 

Report Submittal Deadline 

July 1 

2014 

July 1 

2015 

July 1 

2016 

July 1 

2017 

July 1 

2018 

For Calendar Year 

2013 2014 2015 2016 2017 

(g)(1) - Purchase and Sales Volume* 

(g)(2) Supplier Customer List Report** √ √ √ 

(g)(23) - Connector End of Year Inventory* √ 

(g)(34) - FLLG End of Year Inventory* √ √ √ √ √

General Information √ √ √ √ √

Confidential Information Designation √ √ √ √ √

* The report form templates may also be used for recordkeeping. 

** LPG suppliers that are reporting on behalf of customers that would otherwise report per (g)(1) shall include a list of the 

covered customers as part of the annual report submittal. 
Final Staff Report

FORM R1177 - GI Appendix C – Recordkeeping and Reporting C - 3 

South Coast AQMD 21865 Copley Drive Diamond Bar, CA 91765 (909) 396‐2000

RULE 1177 ANNUAL REPORT

GENERAL INFORMATION

Calendar Year: SCAQMD Facility ID (If Applicable

Legal Company Name:

Facility Name:

Facility Location:

Company Mailing Address:

Contact Person: Title:

Phone: Fax:

Email:

Sign below to certify that all information submitted in the Annual Retrofit Report is true and correc

________________________________________________________________  ________________________________________________Printed Name of Responsible Party Signature of Responsible Party

________________________________________________

Date
Final Staff Report

FORM R1177 - EDD Appendix C – Recordkeeping and Reporting C - 4 

South Coast AQMD 21865 Copley Drive Diamond Bar, CA 91765 (909) 396‐2000

RULE 1177 ANNUAL LPG REPORT

EXEMPT FROM DISCLOSURE DESIGNATION

Calendar Year: SCAQMD Facility ID (If Applicable

Facility Name:Facility Location:

Report Form Please indicate which inform

EXEMPT FROM DISCLOSURE by check

Monthly LPG Purchase And Sales Volumes (Form R1177­1)

(Due July 1 2014, 2015, 2016)* 

LPG Supplier Customer Report List (Form R1177­1S)†

(Due July 1 2014, 2015, 2016)* 

Connector End of Year Inventory (Form R1177­2)

(Due July 1 2014)‡ 

Container and FLLG End of Year Inventory (Form R1177­3)

(Due July 1 2014, 2015, 2016, 2017, 2018)* 

*= For Prior Calendar Year †= Optional form for suppliers to list LPG customers for whom LPG sales to end users are included as part of the supplier’s submitted LPG purchase and sales vo‡ = For Calendar Year2013 Pursuant to the California Public Records Act, your information and data are public records and may be disclosed to a third party. Icertain limited information as exempt from disclosure because it qualifies as trade secret, production data, or other qualification, aDistrict’s Guidelines for Implementing the California Public Records Act, you must make such a claim at the time of submittal to the 
Final Staff Report

FORM R1177 - 1 Appendix C – Recordkeeping and Reporting C - 5 

SCAQMD Facility ID (If Applicable

Facility Name:

Calendar Year: Facility Location:

Month Purchase Volumes (gal) Sales Volumes (ga

January

February

March

April

May

June

July

August

September

October

November

December

South Coast AQMD 21865 Copley Drive Diamond Bar, CA 91765 (909) 396‐2000

RULE 1177 ANNUAL LPG REPORT

LPG PURCHASE AND SALES

Due by July 1 Following Each Calendar Year for 2013, 2014 an
Final Staff Report

FORM R1177 – 1S Appendix C – Recordkeeping and Reporting C - 6 

SCAQMD Facility ID (If Applicable

Facility Name:

Calendar Year: Facility Location:

# Facility Name, Address # Facility Name, Address

Use additional forms as needed.  

South Coast AQMD 21865 Copley Drive Diamond Bar, CA 91765 (909) 396‐2000

RULE 1177 ANNUAL LPG REPORT

LPG SUPPLIER CUSTOMER REPORT LIST

Due by July 1 Following Each Calendar Year for 2013, 2014 an
Final Staff Report

FORM R1177 - 2 Appendix C – Recordkeeping and Reporting C - 7 

SCAQMD Facility ID (If Applicable

Facility Name:

Calendar Year: Facility Location:

Identify Equipment Connected To

(Bobtail, Tanker Truck, Stationary Tank, etc.)

LPG Low Emission Connector De

Manufacturer

Part or

Identification

Number

South Coast AQMD 21865 Copley Drive Diamond Bar, CA 91765 (909) 396‐2000

RULE 1177 ANNUAL LPG REPORT

CONNECTOR END OF YEAR INVENTORY

Due by July 1, 2014 For Calendar Year 2013
Final Staff Report

FORM R1177 - 3 Appendix C – Recordkeeping and Reporting C - 8 

South Coast AQMD 21865 Copley Drive Diamond Bar, CA 91765 (909) 396‐2000

RULE 1177 ANNUAL REPORT

CONTAINER AND FLLG END OF YEAR INVENTO

Due by July 1 Following Each Calendar Year for 2013, 2014, 2015, 2

SCAQMD Facility ID (If Applicable

Facility Name:

Calendar Year: Facility Location:

Container Type Container Sizes (Gal) No. of Containers No. of Low Emission FLLGs Installed T

(If 

Residential

<250      

250 ‐ 500      

>500      

Commercial

<250      

250 ‐ 500      

>500 ‐ 1,000      

>1,000 ‐ 1,150      

>1,150      

Portable, Forklift

Portable, Non­Forklift

Bobtail/Tanker Truck

Other

Total No. of FLLGs:

_________

Total No. of Low Emission FLLGs:

_________