## 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

BACKGR OUND ..................................................................................................................5

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

LPG Transfer and Dispensing ................................................................................................... .............. 7 LPG Fugitive Emissions ........................................................................................................ .................. 8 LPG Fire and Safety Considerations ............................................................................................ ........... 8



### Affected Industry ............................................................................................................. ........... 9 Sales Dist ribution ............................................................................................................ ........................ 9



### EMISSION CONTROL TECH NOLOGY ASSESSMENT .............................................10
Fixed Liquid Level Gauge (FLLG) ......................................................................................... 10

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

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



### SUMMARY OF PROP OSED RULE 1177 ......................................................................11
Purpose ....................................................................................................................... ............... 11
Applicability ................................................................................................................. ............. 11

Definitions ................................................................................................................... ............... 11
Equipment and Operati on Requirements .............................................................................. 11
Operator Leak Detection Program Requirements ................................................................ 12
Recordkeeping Re quirements .................................................................................................. 1 3
Reporting Re quirements ........................................................................................................ .. 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 Re ductions ........................................................................................................... ...... 18



### COST AND COST -EFFECTIVENESS ...........................................................................19
Capital and Installation Costs ................................................................................................ . 20

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

### Forklift Cylinders ............................................................................................................ ......... 20
Barbecue Cy linders ............................................................................................................ ....... 21
Operation and Maintenance Costs .......................................................................................... 24

Overall Cost-E ffectiveness .................................................................................................... ... 24



### INCREMENTAL COST EFFECTIVEN ESS ..................................................................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 Formsiii 

## LIST OF TABLES AND FIGURES

PAGE

Table 1. Summary of Propos ed Rule 1177 Requirements .......................................................................... .... 4 Table 2. NPGA LPG Sales Cate gories ........................................................................................... ................ 7 Figure1. California 2009 LP G 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 Ca pital and Insta llation Costs. .................................................................. .. 23 Table 7. Summary of Operational, Ma intenance 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) emi ssions associated with the transfer and dispensing of liquefied petroleum gas (LPG) are currently not accounted for or regulated by the South Coast Air Quality Ma nagement 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 Refi neries 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 bene fits, 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 fee dback through multiple proposed rule language iterations.

The proposed rule will reduce fugitive emi ssions 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 fo r cylinder refueling. The proposed rule applies to the transfer of LPG to and fr om 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 cy linders. 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 us e of LPG low emission connectors for transfer and dispensing of LP G 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 F LLG (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 ta nk manufactured on or after July 1, 2013; and

- For all other cargo tanks by July 1, 2013 or as soon thereafter at the next servi ce 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 facilitie s 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 in spection 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 th at 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 i nventories 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 le ss than 4 gallons into which LPG is transferred

- LPG cylinders that are specifically dedi cated 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 Dispens ing 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 techni que or technology that monitors the maximum fill level to prevent overfilling without use of the FLLG. † Effective July 1, 2013 cargo tanks sha ll be retrofitted exclusively with low em ission FLLGs following any service that requires evacuation, but no later than July 1, 2017. ‡ Tanks that cannot be retrofitted without relocation shall be re trofitted 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 sa le 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 tran sfer and dispensing industry is being evaluated for VOC emissions reductions and c ontrols in this proposed rule. Staff will continue to study other industry processe s 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. Th e environmental analysis in the Draft EA concluded that Proposed Rule 1177 woul d not generate any significant adverse environmental impacts. The Draft EA wa s released for a 30-day public review and comment period from April 3, 2012 to Ma y 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 SCAQM D Governing Board must review and certify the Final EA as providing adequa te 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 Calif ornia. 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 Pr opane 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 a nd 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 th e retrofit of an estimated 25 percent of the inventory of LPG low emission connectors a nd “bleeder” valves within the District that are eligible to be retrofitted. In or der to qualify for the PERC rebate program, an owner/operator is required to retrofit an ex isting connector with one that meets the maximum design limit of four cubic cen timeter (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 comple ted, 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 reco mmended methods to reduce fugitive VOC emissions from FLLGs during LPG tank f illing operations. The Adept Group is a consulting company based in Westwood, Calif ornia 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 gall ons 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 projectwith 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 Fi re Protection Association (NFPA) and local fire agencies to fully evaluate the LPG transfer and dispensing process, as well as existing applicable local and federal fi re code requirements and practices. There have also been direct (teleconference) communications with FLLG and LPG low emission connector manufacturers, includi ng Marshall Excelsior and RegO Products.

In June 2011, a report authored by Life Cy cle Associates, LLC, and prepared for WPGA, estimated the quantity of LPG fugitive emissions in California by examining the distribution chain of LPG, the associ ated activities and the potential VOC fugitive emissions events at each stage of the dist ribution process. LPG quantities transferred and dispensed as well as the emissions resu lting 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 pr edominantly 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 ga soline, which is a liquid under normal or

### Final Staff Report

Proposed Rule 1177 7 June 2012 

### standard conditions, LPG is a vapor under si milar conditions, and must be stored and transported in closed containers under pressu re 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 fi re and safety precaution, to warn users of its presence in the event of leaks. Orga nosulfur compounds are usually used for this purpose with the most common odorant being et hyl mercaptan. Most states require a minimum of 1 pound of odorant to be inject ed 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 consump tion 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, cr op drying, tobacco curing and flame cultivation

Sales to Retail Cylinder filling and exchange

Industrial Standby fuel for manufacturi ng plants, space heating, flame cutting, metallurgical furnaces



### LPG Transfer and Dispensing

When material is transferred from st orage 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 liqui d state when transferred, it is important that delivery occurs within a closed system wh ere 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 a nd 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 f act 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 or der 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, N FPA 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 qua ntities 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 fr om 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 Summa ry. During transfer of LPG there are fugitive emissions associated with each exchange.

LPG fugitive emissions from transfer a nd dispensing operations result from three main areas: volatilization of entrapped product during disconnection of LPG supply and transfer lines, leaks in the equipmen t used for transfer and dispensing, and venting through FLLGs used as a safety de vice to ensure that pressurized receiving containers, including cylinders and tanks are not overfilled.

The FLLG is attached to a dip tube that ex tends into the LPG storage container and is usually found on bobtail truck tanks, stationa ry 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 cont ainer 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 indica tion 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 st orage is subject to regulation under both the Department of Transportation (DOT) a nd 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, tran sfer 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 Classifi cation System (NAICS) 454312] and 4925 - Mixed, Manufactured, or LPG Producti on and/or Distribution (no NAICS equivalent). However, processes not re presented 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 cons umes approximately 40 percent of the total LPG sales in California followed by the chem ical 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 emissi on connectors, PR 1177 requires facility operators to: 1) replace existing FLLG valv es with a smaller orifice (0.025 inch) No. 72 fixed liquid level gauge that reduces f ugitive LPG vapors or use an alternative technique or technology that does not requi re 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 va lve 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 ta nk 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 manuf acturers 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 bringi ng 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 ar e 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 toda y 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 tanke r/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 em ission connectors and FLLGs. There are numerous companies that manufacture a nd distribute FLLGs and low emission connectors. LPG marketers have had the cost s of retrofits subsidized through a rebate program that is sponsored by the Wester n Propane Education and Research Council (WPERC). The program provides a 75 per cent rebate on new LPG connectors and FLLGs on a first-come, first-serve basis a nd 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 LP G from any cargo tank, stationary storage tank or cylinder into another cargo tank, stati onary storage tank, cylinder or portable storage tank.

Definitions
Key definitions are listed in the proposed ru le for clarity, and utilize standard industry terms wherever applicable. The proposed de finitions incorporate extensive feedback from the LPG industry.

Equipment and Operation Requirements
Effective July 1, 2013, PR 1177 will allow di spensing of LPG via liquid and vapor tight LPG low emission connectors or disp ensers, and allow venting only through a low emission FLLG in accordance with a pr escribed 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 le vel 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 centimeter s of LPG when disconnected, and a low emission FLLG is a fixed liquid level ga uge 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 specifica tions. The vapor return lines and liquid lines, including the hose, fittings and gasket s 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 th at 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. Sec ondly, for an owner/operator that chooses to use the FLLG during filling, any newly inst alled 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 emi ssion 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 retr ofitted 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 th e 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 le vel to prevent overf illing 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 ru le will require the implementation of a Leak Detection and Repair (LDAR) progr am 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 ex isting systems, but staff believes that implementing a minimum level of due d iligence through monitoring and repair can provide additional air quality benefits. The reduction of LPG emitted to the atmosphere also benefits the LPG indus try 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 w ill 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 conducte d 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 detecti ng 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 a nd 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 violati on 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 conducti ng 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 sche dule training dates and a written record of the training dates provided for each employ ee. 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 fac ility to provide the owner/operator with the following information after service is comp leted: 1) records of all low emission FLLGs and LPG low emission connectors insta lled; 2) service or sales receipts; 3) repair logs that include the date and tim e of each repair and a description of the service performed; 4) employer inform ation such as name, address and phone number; and 5) some form of identificati on 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 truc ks that have an LPG vapor recovery or equalization system, PR 1177 will require th e owner/operator to maintain records which demonstrate that the system is ma intained 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 pa rt 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 em ission 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, provi ded 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 ow ned containers and FLLGs associated with LPG storage or transfer for calendar years 2013 through 2017. The inventory must identify containers by type (residentia l 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 leas ed containers in each type and size category. In addition, the inventory must in clude 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 Sa mple 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 requireme nts 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 with in 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 l eaks 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 require d to maintain records or logs of leaks that are identified and subsequently repaired.

EMISSIONS ESTIMATION METHODOLOGY

The proposed rule will address fugitive emi ssions released from each transfer as detailed in Appendix A – LPG Industry Su mmary. Appendix B – Emission Inventory Calculations contains details on th e 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 Califor nia is voluntarily submitted by businesses involved in the transfer and dispensing of LPG to the American Petroleum Institute (API). Therefore, the data shown in Ta ble 3 below represents only a rough estimate of LPG sales for California.

Historical API sales data combined re sidential and commercial sales until 2002, but as of 2003 sales data for these two categor ies 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 sa les data for the District, a proportionality factor of 0.455, based on the District’s popula tion compared to total California state population, was used to estimate the sa les 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 approximate ly 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

Res

ide

nti

a l Ch e mical

C om

m

er cia

l

IC Engi n es

Sal es

to

R et

a il Agricultural

In d ustri a l2009LPGSales(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 grav ity 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 Adep t 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 dete rmine if there exists a susceptibility to blocked flow from potential particle obstr uction or freeze-up. The Battelle source test was evaluated by District source te sting 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 conducte d 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 testi ng to date. Emission rates and potential emission reductions in this staff report ar e 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 LP G 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 filli ng tanks by weight or through the use of alternative techniques or technologies woul d not require the FLLG to be open, thus completely eliminating emissions from FLLG s. 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 observa tions in the field, there appears to be a significant difference in the practice of ve nting 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 ope n 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 mee tings, and during site visits conducted by staff. Additional details are provide d 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 Facilitie s 0.05 0.04 0.07 0.07

Total: 2.1 1.1 8.6 6.1

68 ‡
* Primarily differences include varia tion 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 grav ity fill activities. A significant increase in estimated

fugitive LPG emissions and subsequent reductions within the IC Engine sect or 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 emissi ons 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 connect ors. Additionally, reports by Battelle, Life Cycle Associates, CARB, and WPGA pr ovide further support to verify control efficiencies of the low emission F LLGs and LPG low emission connectors.

It should be noted that while the residen tial 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 exte nded filling times (roughly seven minutes compared to less than a minute for pump-a ssisted 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-effectiven ess 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 administ er 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 pr opose rule also requires use of LPG low emission connectors.

Based on data supplied by the WPGA, an es timate 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 transpor t 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. Th ese are 1) retrofit of stationary storage tanks and forklift cylinders with low em ission No. 72 orifice drill size FLLGs; 2) retrofit of existing connectors with ne w LPG low emission c onnectors; and 3) upgrading existing facilities to decrease filli ng 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 emissi on FLLGs. Of the total ASME tanks, the majority (or 39,712) of these tanks are f ound in the residential sector, while the remaining 5,643 are used in the commercial s ector. 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 st orage tanks be either filled using a fill by weight technique or an alternative t echnique or technology that monitors the

### Final Staff Report

Proposed Rule 1177 21 June 2012 

### maximum fill level without the use of an F LLG 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 f illed by volume will be retrofitted with low emission FLLGs that will have identical cap ital and installation costs as residential and commercial tanks.

Results obtained from field tests indicate th at it would take an operator five to six times as long to gravity fill a 33-pound fork lift cylinder with a No. 72 low emission FLLG compared to the same size cylinder f itted with a No. 54 orifice drill size FLLG. Based on these observations, it is expected th at 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 fork lift 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 filli ng 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 moto r. In each of th ese cases there will be product and time savings which have not b een 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 estimat es that half of these cylinders are filled by weight at facilities equipped with au tomated (carousel) systems such as Blue Rhino and Amerigas and subsequently distribut ed as part of an exchange program to locations such as Home Depot, retail fac ilities 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 th at 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 servi ce of refilling barbecue cylinders, it is assumed for cost-effectiveness calculation pur poses that a majority (~80 percent, or 2,640 facilities) will offer the option of c ontinuing 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 au tomatic 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 equipm ent replacement or retrofit upgrades expected to occur as part of PR 1177 impl ementation. A cross-reference to add itional 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 Option 6 415 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 Option 7 196 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 exchang e 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 suita ble 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 rac k 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 e ngineering 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 hundr ed bulk loading facilities which will be responsible for inspections, recordkeepi ng and reporting data to the District. Employee training is already being implem ented at LPG bulk loading facilities and therefore there will be minimal cost associ ated when the training requirements of PR 1177.

The LPG transfer and dispensing indus try 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 a ny 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 emi ssion reductions, assumptions, capital and installation costs and operational and main tenance 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 

#     10 365 tpd 1

. 6 940

, 248

, 17 ) 000

, 301

, 21 ($

  



≈ $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 adop ting 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 de termine incremental costs, the AQMD must “calculate the difference in the dollar cost s 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 unde r the California Clean Air Act, an incremental cost analysis is required and is presented below.

Staff evaluated several alternatives base d on current operating practices, focusing on emission control options at the s upply 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 conn ectors, but not the low emission FLLG requirement. The additional control opti ons 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 woul d result in additional emission reductions, the PR 1177 requirement to use a tank fitted with a low emission FL LG 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 f ill 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 incrementa l 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

($/year) IncrementalCostEffectiveness ($/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-w eight or an alternative te chnique or technology that monitors the maximum fill level to prevent overfilling wi thout use of the FLLG; fill by weight is considered an alternative technique. The lowest cost alternativ e 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 fo r cost-effectiveness evaluation.

*** Overall cost-effectiveness includes the BBQ tank f illing control requirements and the remaining control requirements of PR 1177.



### COMPARATIVE ANALYSIS



### Pursuant to Health and Safety Code, Secti on 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 w ith regards to the public workshop conducted on August 25, 2011.

Applicability

Comment #1



### The LPG transfer and dispen sing 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, stat e 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, de veloped with significant input from the LPG industry, leverages current traini ng and inspection procedures wherever possible, and minimizes any duplication of existing recordkeeping or reporting requirements.

Comment #2



### Does the proposed rule apply to emergenc y 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 tr ansfers into the storage tank, but not any subsequent transfers from the tank to the ge nerators. The proposed rule is focused on transfers that involve emissions from eith er disconnections or venting from fixed liquid level gauges, rather than transfers a ssociated 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 LP G 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 speci fications in the definition for stationary storage tank. However, the container defi nition 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 fo r 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 mi nimize leakage of a valuable product in addition to the safety requirements from other agencies authorities, including NFPA, DOT, WPGA, CHP, etc. As su ch, 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 pr oposed 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 propos ed rule is limited to the definition of “LPG Vapor Recovery or Equa lization System.” The purpose of the definition is to clarify that entrained liquid that is rec overed by these systems would be considered when determining proper operating effici ency of the LPG vapor recovery or equalization system. The addition of the last sentence referring to the quantity of emissions released appears to be edito rial and staff believes the staff report adequately addresses the descriptive nature of the comment.

Comment #7



### We recommend deleting the definition of "Liqui d Tight." This is a reference to liquid fuels. When liquid propane is released in to 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 followi ng 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 m obile fueler to account for these various types of LPG transports.

Comment #9



### We suggest deleting the "performance test" de finition. 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 te st" definition was to provide an example of the criteria manufacturers may use in ensuring proper operation of an LPG Vapor Recovery or Equalization System. Howeve r, because manufacturer criteria may vary and are not the primary focus of the propos ed 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 isolat es 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 i ndustry requested bubble test, rather than Method 21.

Comment #12



### The inspection requirements should specify wh ether 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 update d to refer to connectors rather than components.

Comment #13



### How does the proposed rule distinguish betw een facilities that offer LPG for sale to an end user and those that transfer or di spense 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 contingenc y 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 clarif y the intended rule applicability. The inspection requirements are limited to owne rs 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 us e of LPG low emission connectors and low emission FLLGs would apply to all LPG tran sfer and dispensing facilities, and are the responsibility of the owner of the equipment.

Comment #14



### Facilities, such as refineries that are s ubject to Rule 1173, s hould 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 a ssess any additional controls that may be necessary for facilities currently subject to Rule 1173.

Cost-Effectiveness

Comment #15



### There are several issues associated with re trofitting 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 pe rcent, depending on the composition of the LPG supplier's tank inventory) that have e ither intentionally crimped (as a safety design) or damaged vent valves which re quire additional precautions up to removal from the field. Field rem oval 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 fu el service to the customer and any recertification or re-permitting for the upgr aded 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 aris e as noted. To accommodate these circumstances and address numerous comment s, 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 ar e 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 allowi ng retrofits to occur as part of existing out-of-service obligations such as tank requa lification, recertification, re-permitting, customer change-outs, etc., and the insp ection costs could be reduced by relying on more effective less costly physical inspec tions with bubble test verification rather than Method 21. With respect to retrofitti ng 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 co mpliance dates, removal of mandatory Method 21 requirements, and inspection ev ery 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 retrof itted 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, re trofitting 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 requalificati on cycles, primarily based on feedback from the industry. While low emissi on FLLGs are not currently commercially available for all applications, FLLG manuf acturers have indicated that availability should not be an issue with respect to the proposed compliance timeframes. Total costs and cost-effectiveness have been eval uated and included as part of the staff report and the overall cost effectiveness fo r 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 es timate the emission reduction potential from use of the low emission FLLGs?

Response



### A discussion on FLLG emissions is in cluded 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 openi ng, 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 re sults and is conservatively used for calculating emission estimates. The higher e nd of the tested results (Battelle, 2009), relied on indirect measurements of LPG lo ss (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 pr otocol that the District test employed.

Comment #19



### Although use of a low emission FLLG is e xpected to result in reduced emissions, consideration should be given to fill-by-wei ght operations as well as other alternative filling methods that do not utili ze the FLLG. Because of th e 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 ha s 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 Em ployee Training Program (CETP) courses for LPG equipment. If Method 21 is requi red, can the District offer training?

Response



### Based on comments from the LPG industry, th e proposed rule requires training of any employee that implements the leak det ection program, including the daily physical checks of connectors and quarterly insp ections, including administration of the bubble test. It is the District's understandi ng 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 cha nge the use of Method 21 as a requirement to an option.

Operator Inspection Program Requirements

Comment #22



### The District should require an epoxy affi xed bar code sticker for each tank to facilitate leak testing.

Response



### The proposed rule requires facilities to mainta in an inventory of affected connectors and FLLGs with information sufficient for identification, but does not specify how the facility would uniquely identify each ta nk or affected inspection unit. Staff believes the facilities would be best equi pped to identify the mechanism for tank identification and therefore prefers to defe r 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 constitu te 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 a nd 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 l eak 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 submitte d. 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 calenda r 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, sta ff 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 standardi zed conversions), accounting differences in sales by volume, by weight, or by se rvice 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 estimat e 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 entir e filling time, based on average fill rates

### Final Staff Report

Proposed Rule 1177 39 June 2012 

### estimated by an earlier CARB report, s upported by follow-up conversations with industry representatives and NFPA requireme nts). 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 per cent 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 th e emission estimates and emission reduction estimates of the proposed rule, based on the aforementioned methodology. The dispensing data is intended to validate the a ssumption that sales data is representative of the transfer and dispensing activity with in the District, on an aggregate basis.

It is not the intention of the proposed repor ting requirement to assign material balance based emission values to individual facilitie s or to the industry as a whole and the District recognizes that the reconciliati on of gross sales and dispensing values contains many variables and uncertainties, si milar 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 or der 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 Califor nia 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 fo r 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 trai ning documentation to the District?

### Final Staff Report

Proposed Rule 1177 40 June 2012 

### Response



### The proposed rule requires that training reco rds be maintained for employees that are engaged in the leak detection program. Training of personnel performing leak detection daily and quarterly checks en sure proper use of the techniques and understanding of the required frequencies required to identify leaks and verify repairs, and the records demonstrate co mpliance 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 da y timeframe for reporting. What is the purpose of the proposed rule for this requireme nt, and what efforts have been made to minimize this burden?

Response



### The proposed rule contains a phased retr ofit 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 inspecti on 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 inte nded to allow additional flexibility to owners and operators to provide unique iden tification information. The proposed rule language of sub clause (f)(1)(A)(ii)(IV) has b een updated as follows for clarification:

"Identification of the FLLG or connector th at 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 r ecords 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 ow ner 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 estima tion methodology, as outlined in Appendix B – Emission Inventory Calculations, relie s on the assumption that LPG sales are representative of dispensing related activitie s on an aggregate level. By tracking monthly and annual sales and dispensing r ecords, the District will be able to determine if there are any seasonality issu es associated with LPG transfer and dispensing and also confirm if sales is an appropriate surrogate for activity. In addition, the proposed rule has been revise d to limit this reporting obligation to three
years.

Comment #32



### What is the purpose for tracking monthl y disbursements? Can the monthly requirement be extended to an annual requi rement for smaller, infrequently used tanks?

Response



### The purpose for tracking monthl y 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 re ducing 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 t echnologies 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 fo r 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 pr ior to this rule development effort. The proposed rule leverages the LPG indus try’s voluntary effort s and accelerates the retrofit schedules for air quality benefits, estimated to be 6.1 tpd.

Rule Development Process

Comment #35



### The notification timeline for th e 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 (WP GA) in the development of the proposed rule, including the rule development schedul e. Because facilities subject to Rule 1173 were not part of the initially intended sc ope of the proposed rule, the District did not make a targeted notification of the propos al 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, in corporating 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 undere stimate 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 additiona l input from District staff referencing separate communications with industry representatives, as well as both internal and external source testing data. While indus try 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 associat ed with sales records and dispensing volumes. See also response to comment #25.

SOCIOECONOMIC ASSESSMENT



### A Socio e conomic Impact Analysis report for the proposed rule has been pr epared and will be released to the public no later than 30 days prior to the hearing. Proposed Rule 1177 would affect LPG dealer s/distributors (NAICS 454312), petroleum bulk stations and terminals (NAICS 424710), and retail f acilities, the latter including both gasoline stations (NAICS 447190) and general re ntal centers (NAI CS 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 d ealers/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 estimat ed 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 fo rgone 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 ENVIRONMENTA L QUALITY ACT (CEQA)



### Pursuant to California Environmental Quality Act (CEQA) Guidelines §15252 and §15162 and AQMD Rule 110, the AQMD ha s prepared an Environmental Assessment (EA) for Proposed Rule 1177. Th e environmental analysis in the Draft

### Final Staff Report

Proposed Rule 1177 44 June 2012 

### EA concluded that Proposed Rule 1177 woul d not generate any significant adverse environmental impacts. The Draft EA wa s released for a 30-day public review and comment period from Apr il 3, 2012 to May 2, 2012. Any comments received during the publ ic comment period on the analysis pr esented 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 SCAQM D Governing Board must review and certify the Final EA as providing a dequate 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 modificati ons alter any conclusions reached in the Draft EA, nor provide new info rmation 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. Th erefore, the Draft EA is now a Final EA and is included as an attachment to this Governing Board package.

DRAFT FINDINGS UNDER CAL IFORNIA HEALTH AND SAFETY CODE SECTION 40727



### Health and Safety Code Section 40727 require s that prior to adopting, amending or repealing rules, the AQMD Governing Bo ard shall make findings of necessity, authority, clarity, consistency, non-duplica tion and reference, based on relevant information presented at the hearing. The draft findings are as follows:

Necessity: 

### The AQMD Governing Board has determ ined that a need exists to adopt Rule 1177 - Liquefied Petroleum Gas Tran sfer 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 AirQuality 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 a nd Safety Code Sections 39002, 39650, 40000, 40001, 40440, 40441, 40463, 40702, and 40725 through 40728, 41508, 41700, and 42300.

Clarity: 

### Rule 1177 – Liquefied Pe troleum 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 c onflict 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 S ections 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-effec tive and efficient), 40702 (rules to execute duties necessary to preserve original inte nt of rule), and 40910 et seq., (California Clean Air Act).

### Final Staff Report

Proposed Rule 1177 46 June 2012 

### REFERENCES



### 1. SCAQMD (2008) VOC Emissi ons During the Gravity Filling of a Forklift Propane Tank – Mutual Propane, Gardena, California, November 2008

2. Adept Group, Inc. (2008) LP Gas Em issions Through Outage Gauge During Cylinder Refilling – Mutual Propane, Gardena, California, November 2008

3. Battelle Laboratories (2009) Research Inve stigation on Testing and Evaluation of New Low Emission Fixed Ma ximum Liquid Level Gauges for Use in LP-Gas Containers, prepared for PERC, September 2009

4. CARB (1992) Determination of Usage Pa tterns and Emissions for Propane/LPG in California, May 1992

5. Life Cycle Associates, LL C (2011) Inventory of Fug itive Emissions from LPG Transfers in California, prepared for WPGA, June 2011 (CONFIDENTIAL)



### 6. Marshall Excelsior, Catalog (2010); Conf erence Call with Jim Zuck on January 13, 2012

7. REGO Conference Call with Dave Stainbr ook, V.P. of Engineering and Mark Hall, December 14, 2011.

8. SCAQMD (2011), “Propane Tank Filling Em ission Reduction Efficiency from Low Emissions #72-Drill Size Self-Cl eaning 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 base d 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, e ither 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 come s from any of three sources: crude oil wells, gas wells and condensate wells. Natura l gas that comes from crude oil wells is typically referred to as associated gas. Th is 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 cons ists 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 etha ne and butane. Before natural gas can be transported or used, the LPG (which is s lightly 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 pr ocessing is a source of approximately 60 percent of LPG produced, while crude oil refi ning is the source of the other estimated 40 percent of LPG supplies although the ra tio 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 i ndustry 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 pr edominantly 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 va lue of LPG is in the range of 22 to 26 percent less than that of natural gas. Al so, 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 pressu res significantly in excess of the vapor pressures of LPG within normal temperature ra nges. 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 sa fety precaution, to add an artificial odorant to warn users of its presence in the ev ent of leaks. Organosulfur compounds are usually used for this purpose with the mo st 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 c ontainers 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 liqui d and therefore metered and typically paid for on a per volume basis. Maintaining a clos ed 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 th e 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 sufficien t to offset the cost of liquefying these products. Also, in order to use LPG in mo st commercial and industrial applications it must be converted back to a gaseous st ate 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 Sy stem 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 applica tions ranging from cooking, heating, air conditioning and transportation, as well as i ndustrial uses where LPG can be used as a fuel in metallurgical plants or as a sta ndby 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 meas ured on a total fuel cycle 1 

### . However, there are many transfer points in the supply chain that ar e 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 ar e 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 tran sport 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, mo st 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 gall ons and the terminal has the equipment necessary to load and unload tanker truc ks which have a capacity of about 10,000 gallons. Typically, pumps are used to f acilitate the tanker truck loading process, while compressors are used during the tanker truck unloading process. In some cases terminals also facilitate the loading of bobt ail trucks which have a capacity in the range of 2,500 to 3,000 gallons.

1 Energetics, “Propane Reduces Greenhouse Gas Emi ssions – 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 distri bution center for retail type transactions. LPG is usually delivered to a retail bul k plant either directly from the LPG production/storage facility via rail and tanke r 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 sale s. 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 appr oximately 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 per cent of the retail sales sector (based on a 2005 Keatley report) to approximately 50 percen t of total retail sales currently. This approximation points to a shift in consum er 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 c ooking), 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, cr op 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 LP G is distributed in ar eas where there is a lack of natural gas distribution infrastruc ture. 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 cate gory 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, wate r 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 fu eling highway vehicles, forklifts, and oil field drilling and production equipment. Forklif ts in the District are widely used in warehouses because VOC emissions from propane combustion are much less than that from diesel or gasoline combustion. Th e majority of LPG in this category is used as forklift fuel. However, electric and hydr ogen 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 tractor s, irrigation engines, standby electric generators, space heating in buildings (inc luding farm houses), cooking, crop drying, tobacco curing, poultry, and other applications.

Sales to Retail


### LPG is sold to locations where 20 pound cy linder filling takes place and these include dispensing stations or hardware stores wh ich conduct LPG cylinder sales as part of exchange programs. Exchange program cyli nders 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 incl udes fuel for standby equipment, space heating, and flame cutting and metallurgical furnaces.

LPG SALES



### Table A-3 below shows Ca lifornia 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 da ta 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 sa les data for the District, a proportionality factor of 0.455, based on the District’s popul ation 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 ar e based on 2009 API reported sales, which is the most recent year for which sales da ta has been compiled. A breakdown of LPG sales data for the District according to mark et sector also shown in Table A-3 below, and the distribution by sector for the Di strict 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) base d 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 plan t 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 em ptied in 45 minutes to an hour with the use of a compressor or pump.

The typical LPG rail tank car only has openi ngs on the top and none on the bottom. Unloading racks or stations have a ladde r and platform that provide access to a manway on the railroad tank car. There ar e 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 wh ich connect to the plant piping system to allow the transfer of LPG from the rail ta nk 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 associ ated 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 w ith a 4-way valve system is used to facilitate the transfer of LPG from the rail ta nk 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 allo w 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 ex cessive 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 sli ghtly and discharge them into the liquid section of the storage tank. The storag e 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 unl oaded 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 formi ng 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 comp ressor 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, commercia l 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 ga llons, 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 Transfer 2 Figure A-3. LPG Vapor Recovery 2

### Final Staff Report

Appendix A - LPG Industry Summary A - 12 June 2012 

### Also unlike a transport truck, when a bobta il 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 sa fe level during filling and overfilling is prevented. The bobtail truck’s cargo tank usua lly 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 th at 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 manufactur ed according to the Department of Transportation (DOT) specifications. Tw enty (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 ga s grills, but are also used to fuel the type of space heaters that can be found at out door 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 s ite. According to the Western Propane Gas Association (WPGA), over the last few years there has b een 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 fo rklifts use 40 pounds LPG cylinders. These cylinders can be used either indoors or outdoor s. LPG for forklift usage is usually in liquid form and cylinders are mounted horizont ally on the back of the forklift. The tank gauge for this application may be de signed 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 ope rator will open the FLLG of the tank or cylinder receiving LPG to allow for va por expansion during the process.

Fill by Gravity

The gravity fill method is an additional appr oach 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 av erage (delivery) frequency that can range from once every two weeks to once every f our weeks. The company will then use this supply to fill their fo rklift 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 fr om 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 (L PG) 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 c onnects 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 fr om bulk loading facility storage tanks to transport trucks, transfers are typically co mpleted at rates of 100 gallons per minute (gpm) or higher. When these transport tr ucks 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 desi gned to withstand high pressures and specifications regarding operating pressures that the system must be capable of withstanding have been developed by the Am erican Society of Mechanical Engineers (ASME) Pressure Vessel Code, Section 8 a nd 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 sma ll amounts of vapor that are produced and must also be equipped with pressure re lief 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 cer tain circumstances. The vapor port also allows for volumetric testing or system calibration.

The pump provides pressure to move produc t from the storage tank to the receiving tank and its design and operating characteristic s 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 Emi ssions 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 th e 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 meteri ng 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 produ ced 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 th e 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 sy stem 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 causi ng 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 bot h 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 a ppears to be quite similar to a gasoline filling station. LPG filling stations/dispe nsers 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 co llection 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 Inventor y Calculations B - 1 June 2012 

## APPENDIX B. EMISSION INVENTORY CALCULATIONS

### Final Staff Report

Appendix B – Emissions Inventor y 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 vol atilization of entrapped product from the housing of various hoses, dispen sing nozzles and interconnections during disconnection, and are based on estimated en trapment volumes a nd the LPG liquid or vapor state physical propertie s during disconnection, as well as an estimated number of disconnections based on an industry s ponsored study of the LPG transfer and dispensing profile 1



### .

2. FLLG Venting . VOC emissions result from ven ting of LPG through FLLGs used as a safety device to ensure that pressurized receiving containers, cylinders and tanks are not overfilled. These emissions are ba sed on source test emission rate data 2 

### 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 onl y minimum due diligence associated with leaks, emissions and reductions have not been estimated.

The methodology used to estimate emissions a nd reductions associated with PR 1177 are based on the industry sponsored study, with so me adjustments to assumptions as noted individually and as summarized in a subse quent 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 di spensing 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 Petroleu m 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 reduc tion from vented VOC emissions of roughly 70% from the use of low emi ssion 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 Test 2 

### is accurate and representative and demonstrates an improvement over the industry study 3 

### because the

### Final Staff Report

Appendix B – Emissions Inventor y Calculations B - 3 June 2012 

### sampling involves losses from the entire cont ainer 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 us ed during 100% of the transfer time when filling by volume. This represents an ad justment from the industry-sponsored study which relied on an assumption that the FLLG ve nt 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 repres entative 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 t ypical 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 Inventor y 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 distributi on data, estimated based on a roughly 45.5% share as indicated by population is accura te 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 th e 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 Inventor y 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 asso ciated with LPG transfer and dispensing is based on the average size of the receivi ng 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 Inventor y Calculations B - 6 June 2012 

### cylinders. The estimated number of filling ev ents 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 estimate 4 

### , an appropriate average fill capacity of 60% is used to determine the number of filling events for bobtails, small storage tanks a nd 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 e stimates 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 Inventor y 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 betw een the tank and the trailer cargo tanks. “HiEff” is a high e fficiency connection.

### Final Staff Report

Appendix B – Emissions Inventor y 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 di scussions 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 a ssociated with use of FLLGs and the disconnections of transfer and dispensing c onnectors is based on the following calculation: 

#    

i i s Disconnect FLLG Emissions Emissions Emissions 

### (1)

Where:
i = Industry Sector FLLG = Fixed Liquid Level Gauge



### Reductions associated with the proposed ru le are based on a 50% reduction from FLLG related emissions and the difference between th e 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 Inventor y Calculations B - 9 June 2012 

#   

   

i i i s Disconnect LE s Disconnect FLLG Emissions Emissions Emissions Reductions % 100 / % 50 

### (2)

Where: LE = Low Emission



### Emissions Calculation Breakdown

FLLG Emissions


### FLLG venting releases LPG emissi ons in both vapor and liquid form: 

#     

i i i Liquid FLLG, Vapor FLLG, FLLG Emissions Emissions Emissions 

### (3)

Using the estimated LPG vapor a nd 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: 

#         
j i j i i
i i

, , ( ( Events) Vent No. 2 (g/s) 11.3 Time) Vent (g/s) 2.01 Emissions FLLG 

### (4) 

#  

k i k i

, , ( Events) Vent No. (g/s) 11.3

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: 

#        
j i j i i

i i

, , ( ( Events) Vent No. (lb/min) 2.99 Time) Vent (lb/min) 0.266 Emissions FLLG 

### (5) 

#  

k i k i

, , ( Events) Vent No. (lb/min) 1.49



### 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 di spensing options. The annual emissions is proportional to the number of disconnect even ts, 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
l i l

i Events) Disconnect (No. Vol.) Entrapped (Connector Emissions s Disconnect    

#   

, 

### (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 Inventor y Calculations B - 10 June 2012 

### As indicated in (2), the reductions from FLLG related emissions are estimated to be 50%:

% 100 / % 50   

# 

i FLLG FLLG Emissions Reductions 

### (7)

Disconnect Emission Reductions


### As indicated in (2), the reductions from disconnects is based on the difference between existing connector configurations and th e LPG low emission connector assemblies: 

#  

 

i i Disconnect LE Disconnect Disconnect Emissions Emissions Reductions 

### (8)

Incorporating the emission estimation calculation of (6) into (8) results in the following:

l l
l i l

i Events) Disconnect (No. mL] Vol.) Entrapped r [(Connecto Reductions Disconnect  

  

#    4

, 

### (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 Facilitie s 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 Lo w Emissions #72-Drill Size Self-Cleaning

Fixed Maximum Liquid Leve l Gauges (FMLLGs),” 2011.

3 Battelle (2009) “Research Investigation on Testing and Ev aluation 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 Em issions for Propane/LPG in California,” May 1992.Final Staff ReportAppendix B – Emissions Inventory Calculations B - 11 June 2012Summary of California LPG Transfer and Dispensing VOC Emissions and Reduction EstimatesActivityFugitive Emissions Potential ReductionsSource Destination Method Operation Share (%)Volume (gal x1000)Volume Per (gal x1000) NumberType Mass Per (g) Mass (kg) Mass Per (g) Mass (kg)LPG Production/Storage Terminal Rail Offload 30.0% 150,953 24 6,290 Tower Liquid Line 279 1,758 279.42 1,757LPG Production/Storage Terminal Rail OffloadTower Vapor Line 274 1,726 274.35 1,726LPG Production/Storage Terminal Transport (1 tank, comp) Offload 31.5% 158,500 8 19,813 Liquid Line 337 6,667 334.55 6,628LPG Production/Storage TerminalTransport (1 tank, comp) OffloadVapor Line 10 198 9.94 197LPG Production/Storage Terminal Transport(tank & trailer, comp) Offload 31.5% 158,500 8 19,813 Liquid Line 337 6,667 334.55 6,628LPG Production/Storage Terminal Transport (tank & trailer, comp) OffloadVapor Line 10 198 9.94 197LPG Production/Storage Terminal Transport (tank & trailer, comp) OffloadJump Line 99 1,969 99.32 1,968LPG Production/Storage Terminal Transport(1 tank, pump) Offload 3.5% 17,611 8 2,201 Liquid Line 3,599 7,923 3,597.22 7,919LPG Production/Storage TerminalTransport (1 tank, pump) OffloadVapor Line 10 22 9.94 22LPG Production/Storage Terminal Transport (tank & trailer, pump) Offload 3.5% 17,611 8 2,201 Liquid Line 3,599 7,923 3,597.22 7,919LPG Production/Storage Terminal Transport (tank & trailer, pump) OffloadVapor Line 10 22 9.94 22LPG Production/Storage Terminal Transport (tank & trailer, pump) OffloadJump Line 99 219 99.32 219LPG Production/Storage Chemical Rail Offload 90.0%122,018 24 5,084 Tower Liquid Line 279 1,421 279.42 1,421LPG Production/Storage Chemical Rail OffloadTower Vapor Line 274 1,395 274.35 1,395LPG Production/Storage Chemical Transport (1 tank, comp) Offload 4.5% 6,101 8 763 Liquid Line 337 257 334.55 255LPG Production/Storage ChemicalTransport (1 tank, comp) OffloadVapor Line 10 8 9.94 8LPG Production/Storage Chemical Transport (tank & trailer, comp) Offload 4.5% 6,101 8 763 Liquid Line 337 257 334.55 255LPG Production/Storage Chemical Transport (tank & trailer, comp) OffloadVapor Line 10 8 9.94 8LPG Production/Storage Chemical Transport (tank & trailer, comp) OffloadJump Line 99 76 99.32 76LPG Production/Storage Chemical Transport (1 tank, pump) Offload 0.5% 678 8 85 Liquid Line 3,599 305 3,597.22 305LPG Production/Storage ChemicalTransport (1 tank, pump) OffloadVapor Line 10 1 9.94 1LPG Production/Storage Chemical Transport (tank & trailer, pump) Offload 0.5% 678 8 85 Liquid Line 3,599 305 3,597.22 305LPG Production/Storage Chemical Transport (tank & trailer, pump) OffloadVapor Line 10 1 9.94 1LPG Production/Storage Chemical Transport (tank & trailer, pump) OffloadJump Line 99 8 99.32 8Terminal Retail Bulk Plant Transport (1 tank, comp) Fill45% 251,588 8 31,448 Liquid Line 337 10,583 334.55 10,521Terminal Retail Bulk Plant Transport (1 tank, comp) FillVapor Line 10 314 9.94 312Terminal Retail Bulk Plant Transport (1 tank, comp) FillFLLG Vapor 12,060 379,269 6,030.00 189,634Terminal Retail Bulk Plant Transport (1 tank, comp) FillFLLG Liquid 23 711 11.30 355Terminal Retail Bulk Plant Transport (1 tank, comp) OffloadLiquid Line 337 10,583 334.55 10,521Terminal Retail Bulk Plant Transport (1 tank, comp) OffloadVapor Line 10 314 9.94 312Terminal Retail Bulk Plant Transport (tank& trailer, comp) Fill 45% 251,588 8 31,448 Liquid Line 337 10,583 334.55 10,521Terminal Retail Bulk Plant Transport (tank & trailer, comp) FillVapor Line 10 314 9.94 312Terminal Retail Bulk Plant Transport (tank & trailer, comp) FillFLLG Vapor 12,060 379,269 6,030.00 189,634Terminal Retail Bulk Plant Transport (tank & trailer, comp) FillFLLG Liquid 23 711 11.30 355Terminal Retail Bulk Plant Transport (tank & trailer, comp) OffloadLiquid Line 337 10,583 334.55 10,521Terminal Retail Bulk Plant Transport (tank & trailer, comp) OffloadVapor Line 10 314 9.94 312Terminal Retail Bulk Plant Transport (tank & trailer, comp) OffloadJump Line 99 3,125 99.32 3,124Terminal Retail Bulk Plant Transport(1 tank, pump) Fill 5% 27,954 8 3,494 Liquid Line 337 1,176 334.55 1,169Terminal Retail Bulk Plant Transport (1 tank, pump) FillVapor Line 10 35 9.94 35Terminal Retail Bulk Plant Transport (1 tank, pump) FillFLLG Vapor 12,060 42,141 6,030.00 21,070Terminal Retail Bulk Plant Transport (1 tank, pump) FillFLLG Liquid 23 79 11.30 39Terminal Retail Bulk Plant Transport (1 tank, pump) OffloadLiquid Line 3,599 12,577 3,597.22 12,570Terminal Retail Bulk Plant Transport (1 tank, pump) OffloadVapor Line 10 35 9.94 35Terminal Retail Bulk Plant Transport (tank & trailer, pump) Fill 5% 27,954 8 3,494 Liquid Line 337 1,176 334.55 1,169Terminal Retail Bulk Plant Transport (tank & trailer, pump) FillVapor Line 10 35 9.94 35Terminal Retail Bulk Plant Transport (tank & trailer, pump) FillFLLG Vapor 12,060 42,141 6,030.00 21,070Terminal Retail Bulk Plant Transport (tank & trailer, pump) FillFLLG Liquid 23 79 11.30 39Terminal Retail Bulk Plant Transport (tank & trailer, pump) OffloadLiquid Line 3,599 12,577 3,597.22 12,570Terminal Retail Bulk Plant Transport (tank & trailer, pump) OffloadVapor Line 10 35 9.94 35Terminal Retail Bulk Plant Transport (tank & trailer, pump) OffloadJump Line 99 347 99.32 347Retail Bulk Plant Residential, Heating Bobtail Fill 97.7% 269,041 1.8 149,467 Liquid Line 337 50,299 334.55 50,004Retail Bulk Plant Residential, Heating Bobtail FillVapor Line 10 1,494 9.94 1,485Retail Bulk Plant Residential, Heating Bobtail FillFLLG Vapor 2,714 405,579 1,356.75 202,790Retail Bulk Plant Residential, Heating Bobtail FillFLLG Liquid 23 3,378 11.30 1,689Retail Bulk Plant Residential, Heating Bobtail Offload 269,041 0.18 1,494,671 Liquid Line 10 14,737 7.89 11,790Retail Bulk Plant Residential, Heating Residential Tank FillLiquid Line 13 19,159 10.85 16,211Retail Bulk Plant Residential, Heating Residential Tank FillFLLG Vapor 362 540,772 180.90 270,386Retail Bulk Plant Residential, Heating Residential Tank FillFLLG Liquid 11 16,890 5.65 8,445Retail Bulk Plant Residential, RV RV Cylinders Fill 2.3% 6,215 0.048 129,483 Liquid Line 13 1,660 10.85 1,404Retail Bulk Plant Residential, RV RV Cylinders FillFLLG Vapor 121 15,616 60.30 7,808Retail Bulk Plant Residential, RV RV Cylinders FillFLLG Liquid 11 1,463 5.65 732Retail Bulk Plant Residential, RV RV Cylinders DisconnectVapor Line 0 40 0.25 32Retail Bulk Plant Commercial Bobtail Fill 100% 86,639 1.8 48,133 Liquid Line 337 16,198 334.55 16,103Retail Bulk Plant Commercial Bobtail FillVapor Line 10 481 9.94 478Retail Bulk Plant Commercial Bobtail FillFLLG Vapor 2,714 130,608 1,356.75 65,304Retail Bulk Plant Commercial Bobtail FillFLLG Liquid 23 1,088 11.30 544Retail Bulk Plant Commercial Bobtail Offload 86,639 0.18 481,328 Liquid Line 10 4,746 7.89 3,797Retail Bulk Plant Commercial Commercial Tank FillLiquid Line 13 6,170 10.85 5,220Retail Bulk Plant Commercial Commercial Tank FillFLLG Vapor 362 174,144 180.90 87,072Retail Bulk Plant Commercial Commercial Tank FillFLLG Liquid 11 5,439 5.65 2,720Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, comp) Fill 45% 11,687 8 1,461 Liquid Line 337 492 334.55 489Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, comp) FillVapor Line 10 15 9.94 15Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, comp) FillFLLG Vapor 12,060 17,618 6,030.00 8,809Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, comp) FillFLLG Liquid 23 33 11.30 17Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, comp) OffloadLiquid Line 337 492 334.55 489Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, comp) OffloadVapor Line 10 15 9.94 15Retail Bulk Plant Sales to Retail, ExchangeTransport (tank & trailer, comp) Fill 45% 11,687 8 1,461 Liquid Line 337 492 334.55489Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, comp) FillVapor Line 10 15 9.94 15Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, comp) FillFLLG Vapor 12,060 17,618 6,030.00 8,809Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, comp) FillFLLG Liquid 23 33 11.30 17Retail Bulk Plant Sales to Retail, ExchangeTransport (tank & trailer, comp) OffloadLiquid Line 337 492 334.55 489Retail Bulk Plant Sales to Retail, ExchangeTransport (tank & trailer, comp) OffloadVapor Line 10 15 9.94 15Retail Bulk Plant Sales to Retail, ExchangeTransport (tank & trailer, comp) OffloadJump Line 99 145 99.32 145Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, pump) Fill 5% 1,299 8 162 Liquid Line 337 55 334.55 54Retail Bulk Plant Sales to Retail,Exchange Transport (1 tank, pump) FillVapor Line 10 2 9.94 2Retail Bulk Plant Sales to Retail,Exchange Transport (1 tank, pump) FillFLLG Vapor 12,060 1,958 6,030.00 979Retail Bulk Plant Sales to Retail,Exchange Transport (1 tank, pump) FillFLLG Liquid 23 4 11.30 2Final Staff ReportAppendix B – Emissions Inventory Calculations B - 12 June 2012ActivityFugitive Emissions Potential ReductionsSource Destination Method Operation Share (%)Volume (gal x1000)Volume Per (gal x1000) NumberType Mass Per (g) Mass (kg) Mass Per (g) Mass (kg)Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, pump) OffloadLiquid Line 3,599 584 3,597.22 584Retail Bulk Plant Sales to Retail, Exchange Transport (1 tank, pump) OffloadVapor Line 10 2 9.94 2Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, pump) Fill 5% 1,299 8 162 Liquid Line 337 55 334.55 54Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, pump) FillVapor Line 10 2 9.94 2Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, pump) FillFLLG Vapor 12,060 1,958 6,030.00 979Retail Bulk Plant Sales to Retail, Exchange Transport (tank & trailer, pump) FillFLLG Liquid 23 4 11.30 2Retail Bulk Plant Sales to Retail, ExchangeTransport (tank & trailer, pump) OffloadLiquid Line 3,599 584 3,597.22 584Retail Bulk Plant Sales to Retail, ExchangeTransport (tank & trailer, pump) OffloadVapor Line 10 2 9.94 2Retail Bulk Plant Sales to Retail, ExchangeTransport (tank & trailer, pump) OffloadJump Line 99 16 99.32 16Retail Bulk Plant Sales to Retail, Exchange 20# Cylinder Fill 100% 25,971 0.004 6,492,625 Liquid Line HiEff 20 128,035 17.75 115,231Retail Bulk Plant Sales to Retail, Exchange 20# Cylinder DisconnectVapor Line 0 1,994 0.25 1,595Retail Bulk Plant Sales to Retail, On-site Fill Bobtail Fill 100% 25,971 1.8 14,428 Liquid Line 337 4,855 334.55 4,827Retail Bulk Plant Sales to Retail, On-site Fill Bobtail FillVapor Line 10 144 9.94 143Retail Bulk Plant Sales to Retail, On-site Fill Bobtail FillFLLG Vapor 2,714 39,151 1,356.75 19,575Retail Bulk Plant Sales to Retail, On-site Fill Bobtail FillFLLG Liquid 23 326 11.30 163Retail Bulk Plant Sales to Retail, On-site Fill Bobtail Offload 25,971 0.18 144,281 Liquid Line 10 1,423 7.89 1,138Retail Bulk Plant Sales to Retail, On-site Fill Commercial Tank FillLiquid Line 13 1,849 10.85 1,565Retail Bulk Plant Sales to Retail, On-site Fill Commercial Tank FillFLLG Vapor 362 52,201 180.90 26,100Retail Bulk Plant Sales to Retail, On-site Fill Commercial Tank FillFLLG Liquid 11 1,630 5.65 815Retail Bulk Plant Sales to Retail, On-site Fill 20# Cylinder Fill 25,971 0.004 6,492,625 Liquid Line 53 342,492 50.78 329,689Retail Bulk Plant Sales to Retail, On-site Fill 20# Cylinder FillFLLG Vapor 121 783,011 60.30 391,505Retail Bulk Plant Sales to Retail, On-site Fill 20# Cylinder FillFLLG Liquid 11 73,367 5.65 36,683Retail Bulk Plant Sales to Retail, On-site Fill 20# Cylinder DisconnectVapor Line 0 1,994 0.25 1,595Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb)-Gravity Fill 15,535 0.008 1,941,819 Liquid Line 13 24,890 10.85 21,061Retail Bulk Plant IC Engines, ForkliftsForklift Cylinder (40 lb)-Gravity FillFLLG Vapor 972 1,887,059 911.50 1,769,968Retail Bulk Plant IC Engines, ForkliftsForklift Cylinder (40 lb)-Gravity FillFLLG Liquid 9 17,360 4.47 8,680Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb)-Gravity DisconnectVapor Line 0 596 0.25 477Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb) Fill 77.20% 36,247 0.008 4,530,910 Liquid Line 13 58,077 10.85 49,142Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb) FillFLLG Vapor 121 546,428 60.30 273,214Retail Bulk Plant IC Engines, Forklifts Forklift Cylinder (40 lb) FillFLLG Liquid 11 51,199 5.65 25,600Retail Bulk Plant IC Engines, ForkliftsForklift Cylinder (40 lb) DisconnectVapor Line 0 1,392 0.25 1,113Retail Bulk Plant IC Engines, Highway Vehicles Highway Vehicle Fill 22.80% 15,295 0.018 849,732 Liquid Line 10 8,378 7.89 6,703Retail Bulk Plant Industrial Transport (1 tank, comp) Fill 45% 12,513 8 1,564 Liquid Line 337 526 334.55 523Retail Bulk Plant Industrial Transport (1 tank, comp) FillVapor Line 10 16 9.94 16Retail Bulk Plant Industrial Transport (1 tank, comp) FillFLLG Vapor 12,060 18,863 6,030.00 9,431Retail Bulk Plant Industrial Transport (1 tank, comp) FillFLLG Liquid 23 35 11.30 18Retail Bulk Plant Industrial Transport (1 tank, comp) OffloadLiquid Line 337 526 334.55 523Retail Bulk Plant Industrial Transport (1 tank, comp) OffloadVapor Line 10 16 9.94 16Retail Bulk Plant Industrial Transport (tank & trailer, comp) Fill 45% 12,513 8 1,564 Liquid Line 337 526 334.55 523Retail Bulk Plant Industrial Transport (tank & trailer, comp) FillVapor Line 10 16 9.94 16Retail Bulk Plant Industrial Transport (tank & trailer, comp) FillFLLG Vapor 12,060 18,863 6,030.00 9,431Retail Bulk Plant Industrial Transport (tank & trailer, comp) FillFLLG Liquid 23 35 11.30 18Retail Bulk Plant Industrial Transport (tank & trailer, comp) OffloadLiquid Line 337 526 334.55 523Retail Bulk Plant Industrial Transport (tank & trailer, comp) OffloadVapor Line 10 16 9.94 16Retail Bulk Plant Industrial Transport (tank & trailer, comp) OffloadJump Line 99 155 99.32 155Retail Bulk Plant Industrial Transport (1 tank, pump)Fill 5% 1,390 8 174 Liquid Line 337 58 334.55 58Retail Bulk Plant Industrial Transport (1 tank, pump) FillVapor Line 10 2 9.94 2Retail Bulk Plant Industrial Transport (1 tank, pump) FillFLLG Vapor 12,060 2,096 6,030.00 1,048Retail Bulk Plant Industrial Transport (1 tank, pump) FillFLLG Liquid 23 4 11.30 2Retail Bulk Plant Industrial Transport (1 tank, pump) OffloadLiquid Line 3,599 625 3,597.22 625Retail Bulk Plant Industrial Transport (1 tank, pump) OffloadVapor Line 10 2 9.94 2Retail Bulk Plant Industrial Transport (tank & trailer,pump) Fill 5% 1,390 8 174 Liquid Line 337 58 334.55 58Retail Bulk Plant Industrial Transport (tank & trailer, pump) FillVapor Line 10 2 9.94 2Retail Bulk Plant Industrial Transport (tank & trailer, pump) FillFLLG Vapor 12,060 2,096 6,030.00 1,048Retail Bulk Plant Industrial Transport (tank & trailer, pump) FillFLLG Liquid 23 4 11.30 2Retail Bulk Plant Industrial Transport (tank & trailer, pump) OffloadLiquid Line 3,599 625 3,597.22 625Retail Bulk Plant Industrial Transport (tank & trailer, pump) OffloadVapor Line 10 2 9.94 2Retail Bulk Plant Industrial Transport (tank & trailer, pump) OffloadJump Line 99 17 99.32 17Retail Bulk Plant Agricultural Bobtail Fill 90.00% 45,419 1.8 25,233 Liquid Line 337 8,491 334.55 8,442Retail Bulk Plant Agricultural Bobtail FillVapor Line 10 252 9.94 251Retail Bulk Plant Agricultural Bobtail FillFLLG Vapor 2,714 68,470 1,356.75 34,235Retail Bulk Plant Agricultural Bobtail FillFLLG Liquid 23 570 11.30 285Retail Bulk Plant Agricultural Bobtail OffloadLiquid Line 10 249 7.89 199Retail Bulk Plant Agricultural Transport (1 tank, comp) Fill 4.50% 2,271 8 284 Liquid Line 337 96 334.55 95Retail Bulk Plant Agricultural Transport (1 tank, comp) FillVapor Line 10 3 9.94 3Retail Bulk Plant Agricultural Transport (1 tank, comp) FillFLLG Vapor 12,060 3,423 6,030.00 1,712Retail Bulk Plant Agricultural Transport (1 tank, comp) FillFLLG Liquid 23 6 11.30 3Retail Bulk Plant Agricultural Transport (1 tank, comp) OffloadLiquid Line 337 96 334.55 95Retail Bulk Plant Agricultural Transport (1 tank, comp) OffloadVapor Line 10 3 9.94 3Retail Bulk Plant Agricultural Transport (tank & trailer, comp) Fill 4.50% 2,271 8 284 Liquid Line 337 96 334.55 95Retail Bulk Plant Agricultural Transport (tank & trailer, comp) FillVapor Line 10 3 9.94 3Retail Bulk Plant Agricultural Transport (tank & trailer, comp) FillFLLG Vapor 12,060 3,423 6,030.00 1,712Retail Bulk Plant Agricultural Transport (tank & trailer, comp) FillFLLG Liquid 23 6 11.30 3Retail Bulk Plant Agricultural Transport (tank & trailer, comp) OffloadLiquid Line 337 96 334.55 95Retail Bulk Plant Agricultural Transport (tank & trailer, comp) OffloadVapor Line 10 3 9.94 3Retail Bulk Plant Agricultural Transport (tank & trailer, comp) OffloadJump Line 99 28 99.32 28Retail Bulk Plant Agricultural Transport (1 tank, pump) Fill 0.50% 252 8 32 Liquid Line 337 11 334.55 11Retail Bulk Plant AgriculturalTransport (1 tank, pump) FillVapor Line 10 0 9.94 0Retail Bulk Plant AgriculturalTransport (1 tank, pump) FillFLLG Vapor 12,060 380 6,030.00 190Retail Bulk Plant AgriculturalTransport (1 tank, pump) FillFLLG Liquid 23 1 11.30 0Retail Bulk Plant AgriculturalTransport (1 tank, pump) OffloadLiquid Line 3,599 114 3,597.22 113Retail Bulk Plant AgriculturalTransport (1 tank, pump) OffloadVapor Line 10 0 9.94 0Retail Bulk Plant Agricultural Transport (tank & trailer, pump) Fill 0.50% 252 8 32 Liquid Line 337 11 334.55 11Retail Bulk Plant Agricultural Transport (tank & trailer, pump) FillVapor Line 10 0 9.94 0Retail Bulk Plant Agricultural Transport (tank & trailer, pump) FillFLLG Vapor 12,060 380 6,030.00 190Retail Bulk Plant Agricultural Transport (tank & trailer, pump) FillFLLG Liquid 23 1 11.30 0Retail Bulk Plant Agricultural Transport (tank & trailer, pump) OffloadLiquid Line 3,599 114 3,597.22 113Retail Bulk Plant Agricultural Transport (tank & trailer, pump) OffloadVapor Line 10 0 9.94 0Retail Bulk Plant Agricultural Transport (tank & trailer, pump) OffloadJump Line 99 3 99.32 3

## 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 Draf t Staff Report that incl udes 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 Dispens ing 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 arrang ing to have their LPG suppliers identify and include their facility’s LPG purchases with t he supplier’s annual report. The supplier s hall also notify the facility and the District by March 1 of the reporting year in order to sa tisfy 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 pr imarily contain information maintained for recordkeeping purposes, many of the report templa tes 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)(2 3 ) - Connector End of Year Inventory* √

(g)(3 4 ) - 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 ReportFORM R1177 - GIAppendix C – Recordkeeping and Reporting C - 3 June 2012South Coast AQMD21865 Copley DriveDiamond Bar, CA 91765(909) 396‐2000RULE1177ANNUALREPORTGENERALINFORMATIONCalendarYear:SCAQMDFacilityID(IfApplicable):LegalCompanyName:FacilityName:FacilityLocation:CompanyMailingAddress:ContactPerson:Title:Phone:Fax:Email:SignbelowtocertifythatallinformationsubmittedintheAnnualRetrofitReportistrueandcorrect.________________________________________________________________  __________________________________________________________________PrintedNameofResponsiblePartySignatureofResponsibleParty__________________________________________________________________DateFinal Staff ReportFORM R1177 - EDDAppendix C – Recordkeeping and Reporting C - 4 June 2012South Coast AQMD21865 Copley DriveDiamond Bar, CA 91765(909) 396‐2000RULE1177ANNUALLPGREPORTEXEMPTFROMDISCLOSUREDESIGNATIONCalendarYear:SCAQMDFacilityID(IfApplicable):FacilityName:FacilityLocation:ReportFormPleaseindicatewhichinformationisEXEMPTFROMDISCLOSUREbycheckingtheboxbelowMonthlyLPGPurchaseAndSalesVolumes(FormR1177­1)(DueJuly12014,2015,2016)*LPGSupplierCustomerReportList(FormR1177­1S)†(DueJuly12014,2015,2016)*ConnectorEndofYearInventory(FormR1177­2)(DueJuly12014)‡ContainerandFLLGEndofYearInventory(FormR1177­3)(DueJuly12014,2015,2016,2017,2018)**= 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 volume report.‡= For Calendar Year2013PursuanttotheCaliforniaPublicRecordsAct,yourinformationanddataarepublicrecordsandmaybedisclosedtoathirdparty.Ifyouwishtoclaimcertainlimitedinformationasexemptfromdisclosurebecauseitqualifiesastradesecret,productiondata,orotherqualification,asdefinedintheDistrict’sGuidelinesforImplementingtheCaliforniaPublicRecordsAct,youmustmakesuchaclaimatthetimeofsubmittaltotheDistrict.Final Staff ReportFORM R1177 - 1Appendix C – Recordkeeping and Reporting C - 5 June 2012SCAQMDFacilityID(IfApplicable):FacilityName:CalendarYear:FacilityLocation:MonthPurchaseVolumes(gal)SalesVolumes(gal)JanuaryFebruaryMarchAprilMayJuneJulyAugustSeptemberOctoberNovemberDecemberSouth Coast AQMD21865 Copley DriveDiamond Bar, CA 91765(909) 396‐2000RULE1177ANNUALLPGREPORTLPGPURCHASEANDSALESDuebyJuly1FollowingEachCalendarYearfor2013,2014and2015Final Staff ReportFORM R1177 – 1SAppendix C – Recordkeeping and Reporting C - 6 June 2012SCAQMDFacilityID(IfApplicable):FacilityName:CalendarYear:FacilityLocation:#FacilityName,Address#FacilityName,AddressUse additional forms as needed.Page ___ of ___South Coast AQMD21865 Copley DriveDiamond Bar, CA 91765(909) 396‐2000RULE1177ANNUALLPGREPORTLPGSUPPLIERCUSTOMERREPORTLISTDuebyJuly1FollowingEachCalendarYearfor2013,2014and2015Final Staff ReportFORM R1177 - 2Appendix C – Recordkeeping and Reporting C - 7 June 2012SCAQMDFacilityID(IfApplicable):FacilityName:CalendarYear:FacilityLocation:IdentifyEquipmentConnectedTo(Bobtail,TankerTruck,StationaryTank,etc.)LPGLowEmissionConnectorDescriptionManufacturerPartorIdentificationNumberNumberofLPGLowEmissionConnectorsSouth Coast AQMD21865 Copley DriveDiamond Bar, CA 91765(909) 396‐2000RULE1177ANNUALLPGREPORTCONNECTORENDOFYEARINVENTORYDuebyJuly1,2014ForCalendarYear2013Final Staff ReportFORM R1177 - 3Appendix C – Recordkeeping and Reporting C - 8 June 2012South Coast AQMD21865 Copley DriveDiamond Bar, CA 91765(909) 396‐2000RULE1177ANNUALREPORTCONTAINERANDFLLGENDOFYEARINVENTORYDuebyJuly1FollowingEachCalendarYearfor2013,2014,2015,2016and2017SCAQMDFacilityID(IfApplicable):FacilityName:CalendarYear:FacilityLocation:ContainerTypeContainerSizes(Gal)No.ofContainersNo.ofLowEmissionFLLGsInstalledTotalNo.ofFLLGs(IfDifferentthanNo.Containers)Residential<250250 ‐ 500>500Commercial<250250 ‐ 500>500 ‐ 1,000>1,000 ‐ 1,150>1,150Portable,ForkliftPortable,Non­ForkliftBobtail/TankerTruckOtherTotalNo.ofFLLGs:_________TotalNo.ofLowEmissionFLLGs:_________