UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District, Rule 1177, Liquefied Petroleum Gas 

Transfer and Dispensing

Prepared by: Nicole Law

August 2013
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RULE IDENTIFICATION -

Agency: South Coast Air Quality Management District

(SCAQMD)

SIP Approved Rule: There are no versions of SCAQMD Rule 1177 which 

have been SIP approved.

Subject of this TSD: Rule 1177- Liquefied Petroleum Gas Transfer and 

Dispensing

Adopted – June 1, 2012; Submitted – February 6, 

2013

BACKGROUND – SCAQMD Rule 1177 Liquefied Petroleum Gas Transfer and 

Dispensing was adopted in 2012 to regulate transfer of liquefied petroleum gas 

(LPG) not already covered in district rules. Before the adoption of this rule, there 

was no liquefied petroleum gas rule to regulate fugitive emissions from the transfer 

and dispensing of LPG. However, SCAQMD Rule 1173 Control of Volatile Organic 

Compound Leaks and Releases from Components at Petroleum Facilities and 

Chemical Plants does cover the emissions at petroleum facilities and chemical 

plants.

RULE SUMMARY SMAQMD Rule 1177, Liquefied Petroleum Gas Transfer and 

Dispensing, is a rule designed to limit fugitive emissions of volatile organic 

compounds (VOCs) from the transfer and dispensing of LPG. The rule describes 

related equipment and operation requirements, leak detection and repair program 

requirements, recordkeeping requirements, and reporting requirements. Major 

requirements of the rule are provided below:

1. Railroad tank cars and mobile fuelers must be equipped with LPG vapor 

recovery or equalization systems.
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2. Equipment is properly connected and maintained to be vapor and liquid tight 

conditions during LPG transfer.

3. Stationary storage tanks, cargo tanks, and portable storage tanks are either 

equipped with low emission fluid liquid level gauges (FLLG) or FLLGs are 

closed while another filling technique is used to prevent overfilling. 

4. Owners and operators of LPG bulk loading facilities and LPG transfer and 

dispensing facilities that offer LPG for sale are required to conduct daily 

checks, conduct quarterly inspections, conduct periodic training for 

employees who perform inspections, and remove, repair, and replace leaking 

connectors.

5. A person who performs installation of FLLG or connectors, inspections, and 

repairs must provide the owner/operator with applicable records, which the 

owner/operator shall maintain for at least two years.

6. Owners/operators of railroad tank cars and mobile fuelers equipped with 

LPG vapor recovery or equalization systems shall maintain records to 

demonstrate that the system is operating according to specifications of the 

manufacturer.

7. Owners/operators of LPG transfer and dispensing facilities shall maintain 

documentation that demonstrates connecters and FLLGs used to comply with 

the rule meet the definition of LPG low emission connector or low emission 

FLLG.

8. Owners/operators of LPG transfer and dispensing facilities shall submit or 

maintain annual purchase and dispensing volumes.

9. Owners/operators of LPG bulk loading facilities shall submit an inventory of 

LPG low emission connectors. This includes the specific storage or transfer 

equipment or operations involved and manufacturer and identification of part 

of number of all low emission connectors. Annually, they shall submit an 

end of year inventory of containers and mobile fuelers associated with the 

transfer or storage of LPG equipped with FLLGs.
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The rule established various equipment and operation requirements, leak detection 

and repair (LDAR) program requirements, recordkeeping requirements, reporting 

requirements, and test methods.

EPA EVALUATION - The following criteria were used to evaluate the submitted 

rule. 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation Cutpoints, 

Deficiencies, and Deviations, EPA, May 25, 1988) and the Little Bluebook 

(Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 

2. RACT – There are no applicable Control Techniques Guideline (CTG) or 

Alternative Control Technique (ACT) documents for this rule. Other districts

do not have similar rules. 

3. SIP Relaxation - Where previous versions of rules have been SIP approved, 

new submittals must comply with CAA §110(l) and §193 regarding SIP 

relaxations.

The recordkeeping, reporting and other requirements generally ensure that the 

submitted rule can be enforced. There are no CTGs, ACTs, other district rules, or 

national regulations for this category. However, the rule’s operation requirements and 

leak detection and repair requirements make the rule stringent enough to meet RACT 

requirements. Lastly, there are no specific rules regarding liquefied petroleum gas 

transfer and dispensing in SCAQMD in the SIP, so the submitted rule strengthens the 

SIP and complies with CAA §110(l) and §193. 
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On May 31, 2010, EPA sent a comment letter asking the District to remove a section 

of the rule protecting confidential business information under State law. It is not 

necessary to include the reference to the State law as Federal law allows sources 

protection from certain kinds of disclosure. The District removed the section from 

their submitted rule; therefore we find the rule is SIP approvable.

RULE DEFICIENCIES – We have identified no deficiencies with Rule 1177 sufficient 

for EPA to propose less than full approval. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – The

following revision is not currently the basis for rule disapproval, but is recommended 

for the next time the rule is amended. 

 Consider adding a definition for “recreational vehicles” to further clarify who 

the exemption (i)(3) applies to.

EPA ACTION -

The submitted Rule 1177 will incorporate provisions on LPG transfer and dispensing

into the SIP. The rule fulfils the relevant CAA §110 and part D requirements. EPA 

staff recommends approval of Rule 1177 pursuant to CAA §110(k)(3).

REFERENCES –

1. SCAQMD Rule 1177, Liquefied Petroleum Gas Transfer and Dispensing, as 

submitted on February 6, 2013.

2. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” 

(a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

3. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.