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 Quali ty Management District, Rule 1177, Liquefied Petroleum Gas Transfer and Dispensing

Prepared by: Nicole Law

August 2013 2

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RULE IDENTIFICATION

-
Agency: South Coast Air Quality Management District ( S C AQMD )

SIP Approved Rule: There are no versions of S C AQMD Rule 1177 which have been SIP approved.

Subject of this TSD: Rule 1177

- Liquefied Petroleum Gas Transfer and Dispensing
A dopted
– June 1, 2012 ; Submitted
– February 6,
2013

BACKGROUND

– S C AQMD 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 . Howe ver, 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 plan t s.

RULE SUMMARY SMAQMD Rule 1177 , Liquefied Petroleum Gas Transfer and Dispensing , is a rule designed to limit fugitive emissions of volatile organic compound s (VOC s ) 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. 3

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2. Equipment is properly connected and maintain ed 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 periodi c 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

owne r/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 specificati ons 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. Own ers/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 s torage 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. 4

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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 fol lowing 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 district s
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. 5

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On May 31, 2010, EPA se nt a comment letter asking the D istrict to remove a section of the rule protecting confidential business information under State law. It is not necessary to include the reference t o the State law as Federal law allows sources protection from cer tain kinds of disclosure. The D istrict removed the section from their submitted rule; therefore we find the rule is SIP approvable.

RULE DEFICIENCIES
– We have identified no deficiencies wi th 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. S C AQMD 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.